Rezistans Ek Alternativ

Rezistans ek Alternativ
Mother Courage Centre, Bois Cherie Rd, Moka
Public comment for

Proposed Hotel Development Project under the Invest Hotel Scheme (IHS)
comprising of 69 residential units for Phase 1
over a plot of land of an extent of 5 Arpents at Les Salines Koenig
by Anse des Salines Ltd
EIA Committee
Ministry of Social Security, National Solidarity,
and Environment and Sustainable Development
Ken Lee Tower, Cnr Barracks & Georges Streets,
Port-Louis
Copy to media
By
Kashmira BANEE,
Kugan PARAPEN,
David SAUVAGE,
on behalf of Rezistans ek Alternativ
7th of June 2019,
Re : Proposed Hotel Development Project under the Invest Hotel Scheme (IHS)
comprising of 69 residential units for Phase 1 over a plot of land of an extent of 5
Arpents at Les Salines Koenig by Anse des Salines Ltd
Public comment for Proposed Hotel Development Project under the Invest Hotel Scheme (IHS) comprising of 69
residential units for Phase 1 over a plot of land of an extent of 5 Arpents at Les Salines Koenig by Anse des
Salines Ltd
1/12
Summary 3
Environmental Issue - Disruption of Tidal Mudflat Wetland 4

Beach reprofiling 4
The nonsensical conclusion of the ecological survey report 4
Incomplete marine report 5
Disruption of Scenic places 5
Environmental Issue - Unknown impact of Tidal Mudflat disruption and Nautical

activities on the Black River Fishing Reserve Marine Protected Area 6
Environmental Issue - Lack of assessment of ”cumulative effects” 7
Social Issue - Absence of public consultations 7
Environmental Issue - Potentially harmful impacts of Phase 2 on Seagrasses and tidal

mudflat 8
Power Politics Issue - Non compliance to Black River Outline Planning Scheme
Development Management Plan 9
Power Politics Issue - No ESA Clearance upfront of development process 9
Economic Issue - Saturated Economy 10

Loss of livelihood for the existing population of Black River and high risk of being
gentrified 10
Need for a national consultation on coastline development 11
Need for Sustainable State Land Policies 11
Salines Ltd
2/12
1. Summary
This document, crafted by Rezistans ek Alternativ is dedicated to the public comment
consultation initiated by the Ministry of Environment concerning the Environmental Impact
Assessment of Proposed Hotel Development Project under the Invest Hotel Scheme (IHS)
comprising of 69 residential units for Phase 1 over a plot of land of an extent of 5 Arpents at
Les Salines Koenig by Anse des Salines Ltd.
It summarizes a non exhaustive list of environmental, societal, power politic and economic
issues, that are amongst the reasons why we state that this project should be rethought
inline with a national vision regarding our coastline development.
EIA Annex E page 9
Salines Ltd
3/12
2. Environmental Issue - Disruption of Tidal

Mudflat Wetland
All the coastline area of the proposed project consist of a tidal mudflat wetland, as identified
in the ESA Study 2009, South West Central ESA Map. Tidal mudflats are an important kind
of wetland, that form part of our Common Environmentally Sensitive Areas to be properly
restored and preserved.
This tidal mudflat wetland is an Environmentally Sensitive Area. Although it has not been
listed as a classified ESA in the ESA Study 2009, it is important to understand that ESAs
management is a continuous process that shall be updated on a periodic basis, as stated by
the experts in the ESA Study 2009.
2.1. Beach reprofiling

While the EIA gives a mere estimation of the beach reprofiling area of 3000 m2, the precise
area of the proposed beach reprofiling is not present in the EIA, thus potentially harmful for
the tidal mudflat wetland ., Moreover,It is unclear whether the beach reprofiling project will go
beyond the 30m setback to HWM or not.
2.2. The nonsensical conclusion of the ecological survey

report
We quote extract of the conclusion:
“one can safely conclude that there was no inland wetland hence no environmentally
sensitive areas”.
EIA Annex C, section 8, page 6
The EIA report itself quotes the presence of mangroves in a tidal mudflat system. These two
ecosystems are defined as environmentally sensitive areas in the ESA Classification study
2009, prepared by NWFS Consultancy for the MoE. This study report has been referenced
in the Black River Outline Scheme (BROS).
Moreover, given the site topology and geomorphology, no assessment has been carried out
to assess the presence of a Dune system on the proposed project.
Salines Ltd
4/12
2.3. Incomplete marine report
The annexed Marine report should have included a biota survey especially when the project
site would face a mangrove forest nested in a tidal mudflat system. Mangroves are known to
be the breeding ground of fish. A negative impact of the mangrove system, especially when
possibilities of relocation of the plant exist, would have a direct consequence of the natural
habitat of the marine aquatic life it sustains. How would we assess the impacts on the
marine environment, when no baseline information on the marine biota is available? In the
same field, post EIA monitoring would be inaccurate in the absence of such information.
In the region of Les Salines and Riviere Noire, mangroves play a significant role in the
livelihood of the local people, many of whom are fishermen.
Moreover EIA Annex E is presented as a “Marine Report”, but the consultant does not
include such in the report scope and objective
“1.3 Scope and objective

Under the above project, ANSE DES SALINES LTD requested Lanka Hydraulic Institute
(LHI) to carry out the following tasks:
● Carry out a desktop study of the site
● Propose a concept for beach reprofiling”
EIA Annex E, section 1.3, page 7
As listed in the ESA Study 2009 South West Central ESA Map, the lagoon facing the
proposed project contains Seagrasses, which are a very important kind of Environmentally
Sensitive Area.
2.4. Disruption of Scenic places
In such scenic places, it is crucial that projects integrate themselves to the existing Nature
instead of disrupting it. These are part of the natural cultural heritage of Mauritius, to be
preserved for future generations.
Salines Ltd
5/12
3. Environmental Issue - Unknown impact of

Tidal Mudflat disruption and Nautical activities
on the Black River Fishing Reserve Marine
Protected Area
In reference to Proclamation No. 24 of 2000, the Black River Fishing Reserve has been
proclaimed by section 7(l) of the Fisheries and Marine Resources Act 1998 as a Marine
Protected Area since the 20th of June 2000.
The EIA does not assess potential impacts (including Tidal Mudflat disruption, mud
excavation, and Tidal Mudflat disruption impacts on the lagoon) of the project towards the
Black River Fishing Reserve.
Moreover, the promoter plans to provide nautical activities, without any assessments of the
corresponding impacts on the Black River Fishing Reserve in the EIA.
These omissions do not comply with the Outline Planning Scheme for Black River
District Council Area, section 4.9.1 clause EP4
Outline Planning Scheme for Black River District Council Area 2006 amended 2011,
section 4.9.1 Environmentally Sensitive Areas (ESAs), clause EP4 Marine Protected
Areas, page 67
“In addition to the requirements under the Environment Protection Act 2002 and the
Fisheries and Marine Resources Act 1998, the aims and objectives of Black River Fishing
Reserve and as shown on the Development Management Map should be acknowledged
in the assessment of any development which may affect the operations and environmental
functions of such Fishing Reserves.”
Salines Ltd
6/12
4. Environmental Issue - Lack of assessment of

”cumulative effects”
As stated in the ESA Study 2009 Legal Final Report, section 5.1.2 Regulations to
Improve EIA, page 62, it is crucial that the EIA provisions require an assessment of
cumulative impacts of undertaking on ESAs. In the Les Salines Peninsula Black River,
where the press has reported no less than 6 to 8 real-estates projects, it is of utmost
importance to assess the cumulative impacts of all the real-estates projects, and not only the
assessment of the impact of each project on a standalone basis.
As stated in the ESA Study 2009 Legal Final Report, section 5.1.2 Regulations to
Improve EIA, part 4 Include Cumulative Effects, page 64
“Cumulative effects can result from individually minor but collectively significant
undertakings over a period of time.”
Knowing these existing shortcomings in the Environment Protection Act since 2009, the EIA
Committee should freeze all the projects in the Les Salines Peninsula Black River, and wait
for the Cumulative effects provisions to be correctively introduced in the Environment
Protection Act as proposed by the ESA Study 2009.
5. Social Issue - Absence of public consultations

Public consultation plays is a mandatory step in the process of an EIA. However, no mention
of any public consultations and corresponding report are present in the EIA.
Salines Ltd
7/12
6. Environmental Issue - Potentially harmful

impacts of Phase 2 on Seagrasses and tidal
mudflat
As illustrated in the ESA Study 2009, South West Central ESA map, the presence of
Seagrasses (in green) and Mudfalt wetland (in sandy brown) are present in the South of Les
Salines Peninsula. The proposed project Phase 2 can be potentially harmful to these very
important Environmentally Sensitive Areas.
ESA Study 2009 - Extract of South West Central ESA Map
Salines Ltd
8/12
7. Power Politics Issue - Non compliance to

Black River Outline Planning Scheme
Development Management Plan
The proposed development falls under the Scenic Landscape Area in a Tidal Mudflat
wetland area, and is not compliant with the Black River Outline Planning Scheme
Development Management Plan.
8. Power Politics Issue - No ESA Clearance

upfront of development process
Following best practice enumerated in the ESA Study 2009;
● Before parcelling any State Land, the Ministry of Housing and Land should have
requested an ESA Clearance to the Ministry of Environment
● Before issuing any reservation letter on any State Land, the Ministry of Housing and
Land should have requested an ESA Clearance to the Ministry of Environment
● Before approving any application, the Economic Development Board (EDB) should
have requested an ESA Clearance to the Ministry of Environment.
Salines Ltd
9/12
9. Economic Issue - Saturated Economy

9.1. Loss of livelihood for the existing population of Black
River and high risk of being gentrified
The “Les Salines Peninsula” in Rivière Noire is about to undergo a radical and dramatic
change. No less than 8 real estate projects have been earmarked over coming years in a
region that has long been known for its quiet and peaceful environment. The combined
effects of these planned developments will have far reaching consequences on the local
population and their way of life. The likely degradation of the marine environment in the
immediate vicinity of the planned projects, including damage to the Black River Fishing
Reserve Marine Protected Area, spells trouble for the many fishermen living in the area. The
local population dependent on fishing activities will see themselves deprived of their
traditional livelihood and would, in all probability, become a highly vulnerable group. This is a
major concern, the more so since this particular region has been one that has become the
most emblematic of the gentrification phenomenon that is hitting Mauritius over recent years.
The current extremely loose fiscal regime that has been put in place over the recent years is
attracting an alarming number of rich foreigners who are busy acquiring important property in
this part of the island. This is taking place at the expense of locals who are more and more
alienated from their own country and region and who are more and more enclaved in ghettos
with no possibility of expanding their living places. The very example of the village of the
Grande Rivière-Noire next to la Balise Marina is a clear example of that. An overpopulated
and strangled village where people are living in much promiscuity next to another ghetto
where lives the privileged multimillionaire foreigners, thus, exposing the clear contrast of a
country of widening gap between rich and poor.
On both moral and ethic grounds, “development” projects cannot be carried out at the
expense of the local population that has inhabited this particular region for generations. A
proper cost benefit analysis ought to be carried out to assess whether the combined benefits
of such massive invasive projects outweigh the huge costs associated with these projects,
not only from an imperative ecological standpoint but also from an economic one.
There are viable alternatives to such projects which would provide more inclusivity to the
local population and these include a ‘Ridge to Reef’ concept which would not only be
ecologically conscious but which would also provide the local inhabitants with good paying
jobs while keeping their social environment unharmed, as opposed to the limited low-paid
jobs which would be on offer in the proposed hotel developments for the local population.
Salines Ltd
10/12
9.2. Need for a national consultation on coastline

development
The crucial economic question to be addressed is about the country’s strategy to develop
itself in a sustainable way. State Land allocations is a tool that should help the government
to push forward the development where needed, through the state land lease allocation
process, such that the selected projects are inline with both regional and national interests.
But one thing is certain, coastal land should no more be leased for property and hotel
development. The Vision 2020 document of 1997 already put forward the arguments for no
more hotel constructions and the need to safeguard remaining coastal line free from
construction. In the advent of rising temperatures Mauritius should make use of its natural
spaces like lagoon, coastline, forest and rivers to being more resilient to the adverse effects
of such phenomenon. Having more concrete on our coastline will only add to the already
damaging exerted pressure on our lagoons and their dying corals. Moreover, recent events
like the popular uprising of the Mauritian citizens at Pomponette are clearly showing that
Mauritians are fed-up with hotel construction on the coastline that are limiting their access to
beaches and coastlines. Instead of cutting the Mauritian population and especially the
coastal population off the coastline and having more concrete on our coastline, there
urgently needs to be a moratory on hotel construction and the setting up of a national
consultation on coastal management to ensure that no irreversible further damage is done to
our coastlines and related ecosystems.
9.3. Need for Sustainable State Land Policies
The State Lands of the Republic of Mauritius have long been eyed by the private sector
(both local and international) as being destined to be privatised and consequently be
developed for the benefit of the private developer. Such exclusive pecuniary benefits are
often skilfully hidden behind other benefits (themselves being mere indirect benefits of the
development) such as employment, foreign direct investment (FDI) to sway public opinion in
favour of those projects. It also need to be added that the allocation of the State Lands are
mostly done on an Ad-hoc basis and as such, do not necessarily fit in a national/regional
master plan/vision. The inability to have and implement a coherent vision of development,
while benign in the short term, is more often than not a major hindrance to social welfare in
the medium to long term. With respect to development itself, sustainability is key and there
are reasons to believe that the Republic of Mauritius has reached a saturation point with
respect to what is commonly termed as ‘développement sauvage’, that is projects which do
not take into consideration all relevant aspects of sustainable development.
Is the current trend of development, especially that of our coastal zones in line with a
sustainable vision of Mauritius for the future? In recent years, multiple mega-construction
projects have emerged (including Hotel projects and Smart Cities) and if completed, these
projects will permanently alter the state of our coastal zones and its ecosystem.
Salines Ltd
11/12
Dramatically, the implications of such developments over the long term will be dire and
irreversible. Is the economic and social future of Mauritius compatible with such projects? Is
this sort of development the only known method of development? Successful governance
entails farsightedness and thus the ability to have an alternative vision of society based on
innovation, sustainability and social welfare maximisation. The Republic of Mauritius needs
to undergo a paradigm shift in terms of development activities to be able to achieve the
aforementioned objectives.
From an ecological perspective, it is essential that we preserve our environmentally sensitive

areas as they play an essential role in our ecosystem. The vulnerability of the Republic of
Mauritius to natural weather occurrences has been exposed multiple times in recent years
and preservation and strengthening of our ecosystem is of paramount importance at this
moment in time if we are to develop a sustainable economy. We need to imagine and
implement an economy whose heartbeat is in synchronicity with the heartbeat of the
environment in which it resides. Any other approach can only result in catastrophic outcomes
over the long term including an existential threat to mankind itself.
In line with the above observations, and the numerous constestations taking place all other
Mauritius regarding coastline, lost of public spaces, environmental issues due to new
ecological crisis, we can no more envisage development in the same way that we have been
used to in the past decades.
Any project on the coastline of Mauritius might it be in any remote area, shall be envisioned
globally, considering our fragile interconnected ecosystem. This is why, from our humble
perspective, no EIA License should be granted for this proposed project based on the
non-exhaustive list of issues and limitations highlighted in this document. We reiterate the
urgent need for a moratorium on coastline development pending the findings of a National
Public Coastline Audit Commission.
7th of June 2019,

on behalf of Rezistans ek Alternativ
Kugan PARAPEN Kashmira BANEE David SAUVAGE

kugan.parapen@alternativ.mu kashmira.banee@alternativ.mu david.sauvage@alternativ.mu
Salines Ltd
12/12

Rezistans Ek Alternativ - Public Comment - EAI Anse Des Salines

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Mother Courage Centre, Bois Cherie Rd, Moka

Public comment for

7th of June 2019,

Environmental Issue - Disruption of Tidal Mudflat Wetland 4

Environmental Issue - Unknown impact of Tidal Mudflat disruption and Nautical

Environmental Issue - Lack of assessment of ”cumulative effects” 7

Social Issue - Absence of public consultations 7

Environmental Issue - Potentially harmful impacts of Phase 2 on Seagrasses and tidal

Power Politics Issue - No ESA Clearance upfront of development process 9

Economic Issue - Saturated Economy 10

EIA Annex E page 9

2. Environmental Issue - Disruption of Tidal

2.1. Beach reprofiling

2.2. The nonsensical conclusion of the ecological survey

We quote extract of the conclusion:

2.3. Incomplete marine report

“1.3 Scope and objective

2.4. Disruption of Scenic places

3. Environmental Issue - Unknown impact of

4. Environmental Issue - Lack of assessment of

5. Social Issue -​ ​Absence of public consultations

6. Environmental Issue - Potentially harmful

ESA Study 2009 - Extract of South West Central ESA Map

7. Power Politics Issue - Non compliance to

8. Power Politics Issue - No ESA Clearance

9. Economic Issue - Saturated Economy

9.2. Need for a national consultation on coastline

9.3. Need for Sustainable State Land Policies

From an ecological perspective, it is essential that we preserve our environmentally sensitive

7th of June 2019,

Kugan PARAPEN Kashmira BANEE David SAUVAGE

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5. Social Issue - Absence of public consultations