Summary

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. At the same time, 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, rising sea levels, and increased flooding.

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, airports, and artificial islands for tourist resorts and guesthouses—are crucial to the nation’s economic development. However, the government’s failure to enforce environmental protection laws has damaged—sometimes irrevocably—livelihoods from fishing, farming, 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, public land, and natural resources such as fruit trees.

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, and in Malé, the capital, and Hulhumale. 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. 

On Kulhudhuffushi, 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, in many cases devastating livelihoods. 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. “Now we have to import bananas. Development to us means imported fruits no one has the money for.”

Although the Maldives has adopted several laws to prevent such harm, there is lax enforcement. Crucially, the Environment Protection and Preservation Act mandates environmental impact assessments (EIAs) for all development proposals, but while the process seems good on paper, many projects are preapproved by the government, rendering any EIA irrelevant. The Environmental Protection Agency, the Maldives’ primary environmental regulatory authority, is not independent but operates under the minister of environment, technology and climate change. 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, saline intrusion, and other effects of climate change. 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, and consult affected island communities. 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.

Methodology

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, 8 and 20 people. The group of 20 was all women. 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, seeking their response to our findings. The responses we received are included in the appendix.

 

I. Maldives: Politics and Geography

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.

Until it gained independence from the United Kingdom in 1965, the Maldives was geopolitically isolated.[1] In the early 1970s, the government sought new revenue through tourism,[2] which expanded quickly under President Maumoon Abdul Gayoom, whose oppressive dictatorial rule[3] lasted from 1978 until 2008. The Gayoom government established a one-resort, one-island policy, leasing only uninhabited islands to be developed as self-contained resorts.[4] After the 2004 Indian Ocean tsunami devastated the Maldives’ economy, the government expanded island leasing.

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.

Leasing and sales of islands for development increased rapidly under President Yameen amid allegations of large-scale corruption by a state-owned corporation that was in charge of leasing and sales of islands.[6] His administration also pursued increased land reclamation to build artificial islands for new resorts. Yameen lost the 2018 election amid corruption allegations and a crackdown on dissent;[7] in 2022 a Maldives criminal court convicted him of money laundering and accepting a bribe in leasing islands and sentenced him to 11 years in prison.[8] President Ibrahim Moahmed Solih took office in 2018 on a platform of promised reforms, including environmental protection.[9]

Tourism continued to expand after 2018, although the Maldives suffered an economic downturn during the Covid-19 pandemic.[10] Tourism accounted for one-third of the national economy by 2023.[11] With this growth, resort owners and government officials have pressed for additional investments in transport infrastructure, including airports and harbors, to service the growing number of island resorts. While tourism has been vital for Maldives’ economic development, unregulated expansion of tourist facilities and infrastructure poses a serious risk to the fragile island ecosystem.[12]

Environmental Governance

Environmental issues fall under the Ministry of Environment, Climate Change and Technology.[13]

The Environmental Protection Agency, a regulatory entity established under the Environment Protection Act in 2008, ostensibly has oversight of development projects, but it lacks independent enforcement authority. Although President Solih pledged in 2019 that his administration would make the EPA an independent entity,[14] it continues to operate under the minister of environment, climate change and technology. In a communication with Human Rights Watch, Ibrahim Naeem, director general of the EPA, stated that according to the government’s strategic action plan, the EPA should have become independent in 2020. He added that he had “no information” as to why the government had not made this happen.[15]

A member of a Malé-based environmental organization told Human Rights Watch:

There is a structural problem in the entire environmental regulatory regime: the Tourism Ministry supersedes all other ministries, particularly when it comes to issues of land. …The EPA does not have a regulatory structure and is housed in the Environment Ministry. There have been talks to make it independent, but no real progress has been made.[16]

An EPA official described the situation as “a conflict of interest,” saying “given that the number one developer is the government, it becomes very difficult for us to regulate the government while being part of the government.”[17] A former EPA official said that even the limited autonomy the EPA once had has been eroded: “A presidential decree requires that the EPA should be governed by a governing board. However, the government has reduced the board to be an administrative board, chaired by a politician nominated by the president.”[18]

A Politicized Environmental Impact Assessment Process

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.

The Maldives Environment Protection and Preservation Act (EPPA) mandates a rigorous screening process for every EIA, subject to two independent reviews, before a project can be approved. However, according to a former EPA official, despite the anticipated social and environmental costs inevitably enumerated in the assessment reports, planning ministry reclamation projects arrive preapproved before any EIA is carried out, in violation of the EPPA and EIA regulations.[21] After the EIA is done, said a former EPA official, the ministry rejects “most of the recommendations made in an EIA.”[22]

In addition, EIA consultancy firms bidding on government projects are in competition to show they can complete their assessments swiftly. “The EPA does not have the teeth to say it cannot be done in less than three or four weeks,” said an EIA consultant.[23] An EIA consultant also criticized the project-by-project manner assessment approach, saying the authorities failed to integrate these into an overarching environmental policy on development and mitigation practices.[24]

Activists said that reclamation is often done without adequate planning for how the land will be used, and thus in some cases “the reclaimed land mostly sits barren and unused for years.”[25] A fisherman in Addu told Human Rights Watch that a project that had promised housing had failed to deliver: “The Feydhoo reclamation project was completed years back. However, till this day there has been no use of it for anyone except for the dead. Recently they have opened a cemetery in part of the reclaimed area of Feydhoo.”[26] The representative of a fishing community in Addu described how island workers were routinely excluded from development decisions that have an impact on their lives and livelihoods. He said it “will take years for it to become normal. We still haven’t recovered from the [last reclamation] project.”

Access to information about planned development projects is limited. The scoping process that determines what the EIA will cover involves only government entities and the selected EIA consultant, not public interest groups.[27] Environmental activists have also noted that while EIAs are required to be made public online, they are published in English with only the summary in Dhivehi, leaving many residents unable to read them.[28] Island residents without internet may have no access to the EIA. Even if they do have access, the island councils publish little on planned projects. Many island residents said they had never seen EIA reports.[29] Although there is a right-to-information law in the Maldives, requests filed with government ministries for information on development projects face delays or denials.[30]

EIAs must include a list of all those consulted, including officials, civil society groups, residents, fishing communities, and others including diving guides and hotel owners whose livelihoods could be affected. However, for the projects that Human Rights Watch investigated, island residents said that the council or the dominant political party either hand-picks attendees or fails to reach out to communities likely to be otherwise excluded—including women.[31]  

One EIA consultant noted that it is crucial to consult women because development projects have a disproportionate impact on their work in the informal sector. “Unless you go and spend time and speak to the women separately, you won’t understand,” the consultant said. Despite this, an EPA official said including women in consultations “varies project to project—if a project requires extensive consultation with women, we will do it.”[32] He did not explain which projects would not need such consultations.

Women who are invited or choose to participate may face reprisals when they speak up. A schoolteacher who was one of only a few women to attend a public consultation on one island, described some of the risks involved in expressing her views. She had raised concerns about a planned development project on the island council’s Facebook page and then faced criticism from her employer and colleagues. “It was awkward for me,” she said. “I have applied to be lead teacher, but I do not think I will get it now as I am seen as critical.”[33] A woman who had joined the public consultations said, “We feel [women] are not heard, not listened to, and no action is taken.”[34]  

 

II. Kulhudhuffushi Airport and Road Project

During the 2013 presidential election campaign, Yameen Abdulla promised to build an airport in Kulhudhuffushi, even though there was already one 17 kilometers away, saying the new airport would be key to development in the region.[35] He also promised additional airports on other islands. After Yameen was elected, Maldivian activists alleged that the Environment Ministry overrode the EPA, which had denied approval for the airport without mitigation measures.[36] The EPA had based its decision on the EIA’s conclusion that destroying the island’s protected mangroves would cause irreparable harm. 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, 2017. Bulldozers buried the island’s mangroves to create the airport.

The loss of the mangroves has had a direct and far-reaching negative impact on already at-risk local communities. Residents have said that flooding has become more frequent and severe because the mangroves that had provided a natural protection had been destroyed.[38] The EIA had warned that the loss of the mangroves could “escalate flooding” because they act “as a natural coastal defense system.”[39] To mitigate the risk, the EIA had proposed altering the airport’s location to spare the mangroves. It had also recommended breakwater structures of at least 1000 kilograms to protect the coast. However, the authorities did not implement the recommendations. In response to questions from Human Rights Watch about the EIA’s mitigation measures, the Kulhudhuffushi City Council said in July 2023 that the airport development authorities initially installed structures that were smaller than the recommended specifications. Subsequently, these structures suffered damage, “resulting in significant erosion of a substantial portion of the island.” In 2023, a new project installed shore protection barriers at a cost of MVR 42.37 million (US$2.76 million).[40]The EIA had noted that destroying the mangroves and adjacent palm forest would hurt livelihoods, particularly of women whose businesses depended on natural resources from the trees, including those involved in the indigenous coir rope industry.[41] At least 400 women and their families had depended on the forest for a living, and the destruction of the trees thus harmed nearly 2,000 people, or about a fifth of the island’s population, with total losses up to USD $565,000 a year.[42] They claimed they had not been compensated for their loss of income, an assertion Kulhudhuffushi council officials confirmed.[43]

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]

The women said they had not been consulted when the project was approved. In response to questions submitted by Human Rights Watch, the Kulhudhuffushi City Council said, “Women’s participation is not ensured in the developmental process.”[46] This is the case even though a disproportionately large number of island households are headed by women, who bear the burden of risks such as flooding and loss of assets.[47]

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 road project has not had an EIA even though it entails the loss of numerous trees in one of the last green areas of the island.[53] One resident said, “We have memories here—we enjoyed the use of this space, so do our children.”[54] Another said, “It’s not just some greenery, it’s a communal area, it’s linked to social cohesion as people gather around to these places.”[55]  

When Human Rights Watch interviewed Kulhudhuffushi City Council members about the road, they said that it was part of the original development plan that had already been approved, and so it needed to be built.[56] In an online meeting with Human Rights Watch, the mayor said that very few trees were destroyed in the construction. Others whom Human Rights Watch interviewed said the damage was significant, with hundreds of trees cut down.[57] According to local activists, the land use plan had not been approved and no EIA had been done. On May 24, 2023, after residents complained to the EPA, the agency ordered a halt to the road construction while it investigated.

While flooding has increased across the Maldives because of stronger sea swells and more extreme weather, the Maldives Red Crescent, which coordinates disaster relief in the islands, said that impact and damages from flooding have become more severe due to poor planning and events like the destruction of the mangroves.[58] The Women’s Development Committee in Kulhudhuffushi told Human Rights Watch that flooding has increased significantly in recent years, due in part to newly developed roads, especially on reclaimed areas, being higher than the natural ground level.[59] The Maldivian Red Crescent agreed that height differences in reclaimed areas had exacerbated flooding. “This highlights the lack of proper public consultation, planning and incorporation of Indigenous knowledge,” an official said.[60]

 

III. Addu Reclamation Project

The Addu City Land Reclamation Project was a 2018 campaign promise by President Ibrahim Moahmed Solih. It is one of the largest land reclamation projects in the Maldives. The EIA for the project says its purpose is to create new land to facilitate “residential, tourism and long-term commercial developments…[and] the allocation of reclaimed islands in the lagoon for 4-star private resorts.”[61] The EIA warned that “long term irreversible negative impacts will be generated from the project,” and concluded that:

It is anticipated that this project will have potential negative impact on the tourism industry and hence the local economy due to irreversible damages to the marine ecosystem… When economic values are examined, we advise community, developers and proponents to weight out these losses against the potential benefits.[62]

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.

In response, Mayor Ali Nizar was reported in the media saying, “Any kind of project would have damage to the environment but what we have to do is take measures to minimize it.”[64] According to a former member of the EPA, when some members of the EPA’s governing board called for a thorough investigation and assessment of the anticipated damage, they were overruled.[65] He said, “The Addu reclamation will cause irreversible damage to a very important ecosystem. It is done without any real planning with the only objective being securing popularity and votes.”[66]

A community liaison officer for the Addu project said that information on the project is updated on their website, but only in English.[67] While some residents interviewed by Human Rights Watch hoped that new resorts would provide employment, others noted that the damage to dive sites and coral reefs would diminish tourist interest, thus undercutting the very purpose of the project. The EIA also noted that the project would harm the Addu fishing community as sedimentation would kill many fish and cause estimated tourism losses of between $17.4 million and $27.4 million annually due to damage to marine life.[68]

In March 2022, Minister of Environment, Climate Change and Technology Aminath Shauna, speaking at the People’s Majlis, Maldives’ parliament, stated that despite concerns raised in the EIA, the government “will not get in the way of Addu’s development.”[69] In a meeting with Human Rights Watch, the mayor of Addu City said he had not read the EIA although he was aware of its contents, but that the decision rested with the planning ministry.[70] Human Rights Watch requested but was unable to get a meeting with the ministry.

The reclamation project’s impact will be greatest on communities whose livelihoods depend on the reef’s marine life. A diver at one of Addu’s resorts said that due to the sedimentation after a previous reclamation project at the nearby island of Feydhoo, the reef had not fully recovered even 10 years later: “My question is if they are continuing with the project for the purpose of tourism, what are they planning on delivering to the tourists after all this damage to the reef?”[71] A fisherman noted the continuing effects of the Feydhoo reclamation saying that “the land was reclaimed and the community has not benefited from this project.”[72] Fishing communities particularly noted the loss of bait fish, which inhabit the reef, and are essential for fishing larger species like tuna.

VI. Lack of Monitoring and Maintenance

Among the most important features in an EIA are the recommendations on monitoring during the construction phase and after a project is completed. However, an expert described post-EIA monitoring as “the main weakness,” since there are no clear guidelines on accountability.[73] Even when monitoring reports are mandated, many are not submitted, he said. “Without monitoring data there is no way regulators will know if a project has gone beyond the threshold” for sedimentation or other concerns.[74] An official with the Maldivian Red Crescent, which handles local responses to flooding emergencies, said “the monitoring bodies do not conduct robust monitoring as expected, leaving the island and its occupants at risk.”[75]

According to an EPA official, reclaimed land is often higher than natural land, which causes flooding and drainage issues, and not including maintenance and monitoring as part of the plan leads to problems after a project is completed.[76]  The EPA has stated that maintenance of mitigation measures is the responsibility of the developer, and the EPA does not have information on whether sufficient funds are earmarked for maintenance on government projects.[77] In a statement to Human Rights Watch, the agency added:

However, we are aware that maintenance of mitigation measures, such as the upkeep of drainage systems, is now mostly being mandated to Island/City councils and utility service providers. As a result, the costs associated with maintaining these measures during the operational phase are not always included in the budget allocated for infrastructure projects proposed by the government.[78]

If the EPA receives updated reports, it can intervene to mandate increased monitoring or other mitigation. In his response to Human Rights Watch, EPA Director General Naeem said that the EPA’s approvals are issued on the condition that the developers “fulfill the mitigation measures and submit environmental monitoring reports as outlined in the EIA.”[79] However, one official told Human Rights Watch, “The EPA does not have the financial resources to monitor projects.”[80] 

There are few avenues for citizens to challenge government decisions on development projects. A court case against the Gulhifalhu reclamation project, which President Yameen authorized to develop a new port in the greater Malé area, is the first of its kind. On September 26, 2021, Humaida Abdul Gafoor, an activist, filed a case in the Maldives Civil Court seeking to stop the project on the grounds that it entailed serious environmental, economic, and cultural losses. Hearings in the case have been subject to many delays. As of July 2023, the court had not granted a temporary work stoppage order, which the plaintiffs had requested, and dredging has continued.[81]

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.

V. Maldives and Climate Finance

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.

The Maldives has sought funding for its largest infrastructure projects through line of credit agreements with India or China, and has also been the recipient of global financing from bilateral and multilateral donors for climate adaptation.[83] The Maldives government has, however, criticized the global system for creating too many hurdles for small states to get funding. In 2022, the high commissioner of the Maldives to the United Kingdom, speaking at an event on the climate crisis, said, “It feels like you need a PhD in climate finance to get hold of any funding.”[84]

Although the obstacles largely stem from lack of institutional capacity to navigate cumbersome application processes, the donors, in theory, require recipient countries to ensure compliance with environmental laws, consult affected communities, and carry out monitoring and evaluation.[85] However, as an activist in the Maldives said, “There is no real push from donors to ask Maldives to be more transparent.”[86]

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.

 

VI. Recommendations

The Maldives government should:

• Require budgets for reclamation and other development projects to include resources for monitoring, mitigation, and maintenance.
• Ensure that before approving any projects, including those proposed by ministries, the EIAs have been thoroughly and independently reviewed, and open for adequate public consultation.
• Make EIA-recommended mitigation measures mandatory. No government entity should be exempt from this requirement.
• Adequately compensate residents who experience loss of income or housing from development projects.
• Develop ways to ensure public consultations at the island council level are inclusive by actively soliciting input or adopting other measures for women and other less represented groups, and ensure that all such consultations take place well before projects are approved, and that their concerns and input are reflected.
• Ensure that EIAs are available in full in Dhivehi. They should be well-publicized and easily available at council offices and other accessible venues.
• Fully implement the Maldives Access to Information Act, simplify request procedures, and reduce the maximum time allowed for institutions to comply with requests.

 

Acknowledgments

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. Saroop Ijaz, counsel for Human Rights Watch’s Asia Division, provided additional research. Three consultants in the Maldives also contributed to the research but have requested to remain anonymous for their own security. Meenakshi Ganguly, Asia deputy director, edited the report. James Ross, legal and policy director, and Joseph Saunders, deputy program director, provided legal and programmatic review, respectively. Specialist review was provided by Erica Bower, researcher, Environment and Human Rights Division, and Juliana Nnoko-Mewanu, senior researcher, Women’s Rights Division.

Production assistance was provided by Robbie Newton, Asia coordinator; Travis Carr, digital publications officer; and Fitzroy Hepkins, administrative manager.

Special thanks to all those individuals and organizations who aided in our research and who generously shared their time, energy, and experiences with Human Rights Watch. 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.