Rezistans ek Alternativ

Mother Courage Centre, Bois Cherie Rd, Moka

Public comment for

​proposed 5-Star Hotel and World Class Conference and Seminar Centre on a plot of
State Land of an extent of about 43 arpents at Les Salines Koenig, Riviere Noire by
Atalian Global Services 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
Stephan GUA,
Kugan PARAPEN,
David SAUVAGE,
on behalf of Rezistans ek Alternativ

7​th​ of August 2019,

Re : Proposed 5-Star Hotel and World Class Conference and Seminar Centre on a plot
of State Land of an extent of about 43 arpents at Les Salines Koenig, Riviere Noire by
Atalian Global Services Ltd​​

Public comment for Proposed 5-Star Hotel and World Class Conference and Seminar Centre on a plot of State
Land of an extent of about 43 arpents at Les Salines Koenig, Riviere Noire by Atalian Global Services Ltd​​

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Mother Courage Centre, Bois Cherie Rd, Moka

Summary 3

Social Issue - Unsustainable relation of Corporates with Nature 4

Environmental Issue - Unknown impact of the proposed project on the Black River
Fishing Reserve Marine Protected Area 6

Environmental Issue - Unknown impact of the proposed project on the Category 1

ESA Wetland 76 7

Environmental Issue - Lack of assessment of ”cumulative effects” 8

Social Issue - Absence of public consultations 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

Proposed alternative - A Ramsar site of international importance with inland Eco

villages integrated in a Ridge to Reef project 13

Public comment for Proposed 5-Star Hotel and World Class Conference and Seminar Centre on a plot of State
Land of an extent of about 43 arpents at Les Salines Koenig, Riviere Noire by Atalian Global Services Ltd​​

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Mother Courage Centre, Bois Cherie Rd, Moka

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 5-Star Hotel and World Class Conference and Seminar Centre on
a plot of State Land of an extent of about 43 arpents at Les Salines Koenig, Riviere Noire by
Atalian Global Services Ltd”​​.

It summarizes a non exhaustive list of environmental, societal, power politics 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.

Extensive State Land parcellation of Les Salines Rivière Noire Coastline

Public comment for Proposed 5-Star Hotel and World Class Conference and Seminar Centre on a plot of State
Land of an extent of about 43 arpents at Les Salines Koenig, Riviere Noire by Atalian Global Services Ltd​​

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2. Social Issue - Unsustainable relation of

Corporates with Nature
This part of Les Salines Peninsula is anything but a suitable place to develop a Beach
Resort.

EIA Atalian, chapter 4, section 4.9.6, page 46

The number of environmentally risky undertakings, as well as their respective threat levels
for the environment is simply insane (non exhaustive list);
1. Dredging works for navigation channel
2. Artificial beaches
3. 76’600 m3 of dredging/excavation and addition of 27’160 m3 of sand to create an
artificial lagoon
4. 6’900 m3 of dredging/excavation and addition of 2’250 m3 of sand for creation of
artificial pool
5. Continuous pump pipeline system of 400m from hermione channel to artificial lagoon
and artificial pool using a 200mm diameter polyethylene (PE) plastic pipe
6. Floating pontoons
7. Brine disposal system

Being near the Category 1 ESA Wetland 76 tidal connection to the lagoon, all the South area
of Les Salines Peninsula should be properly restored in order to achieve ecological
reconquest for public interest, instead of being yet again under the threat of disruption for the
sake of yet another Beach Resort (private interest).

Public comment for Proposed 5-Star Hotel and World Class Conference and Seminar Centre on a plot of State
Land of an extent of about 43 arpents at Les Salines Koenig, Riviere Noire by Atalian Global Services Ltd​​

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Mother Courage Centre, Bois Cherie Rd, Moka

Public comment for Proposed 5-Star Hotel and World Class Conference and Seminar Centre on a plot of State
Land of an extent of about 43 arpents at Les Salines Koenig, Riviere Noire by Atalian Global Services Ltd​​

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Mother Courage Centre, Bois Cherie Rd, Moka

3. Environmental Issue - Unknown impact of the

proposed project 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 of the project towards the Black River Fishing
Reserve; notably;
● Brine disposal
● Continuous sea water pumping
● Dredging and excavations
● Nautical activities
● Water channels

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.”

Public comment for Proposed 5-Star Hotel and World Class Conference and Seminar Centre on a plot of State
Land of an extent of about 43 arpents at Les Salines Koenig, Riviere Noire by Atalian Global Services Ltd​​

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4. Environmental Issue - Unknown impact of the

proposed project on the Category 1 ESA
Wetland 76
The EIA does not assess potential impacts of the project towards the Category 1 ESA
wetland 76;
● Brine disposal
● Continuous sea water pumping
● Dredging and excavations
● Nautical activities
● Water channels
● Impact of artificial lagoons on Category 1 ESA Wetland 76 tidal connexion

These omissions do not comply with the ​Outline Planning Scheme for Black River
District Council Area, clause EC1

Outline Planning Scheme for Black River District Council Area 2006 amended 2011,
clause EC1, page 68
“Each ESA type has been categorized on their sensitivity in maintaining environmental
functions and provides sufficient flexibility in proposed land uses to strike a balance
between environmental protection and sustainable development needs”

“Development adjoining ESAs should obtain the prior approval of the Ministry responsible
for Environment and should be in accordance with the policies defined in the Study of
Environmentally Sensitive Areas (ESAs) ...”

ESA Study 2009, Report on the Status of Laws and Institutions to protect
Environmentally Sensitive Areas in Mauritius, page ix
“Category 1 ESAs
- All development in or on an ESA is prohibited. (...)
- Development outside an ESA that will adversely affect the ESA is Prohibited; (...)”

Public comment for Proposed 5-Star Hotel and World Class Conference and Seminar Centre on a plot of State
Land of an extent of about 43 arpents at Les Salines Koenig, Riviere Noire by Atalian Global Services Ltd​​

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Mother Courage Centre, Bois Cherie Rd, Moka

5. 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.

Public comment for Proposed 5-Star Hotel and World Class Conference and Seminar Centre on a plot of State
Land of an extent of about 43 arpents at Les Salines Koenig, Riviere Noire by Atalian Global Services Ltd​​

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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 correctly introduced in the Environment Protection
Act as proposed by the ESA Study 2009.

The lack of assessment of cumulative effects in the case of Les Salines Peninsula Rivière
Noire is a tremendous threat to the Environment and is completely unbalanced, as the
authorities do not plan any assessment of the cumulative effects of all Les Salines Peninsula
proposed projects. Such cumulative effects (brine disposal, wetlands backfilling,
excavations, sea water pumping) are not assessed concerning;
● Sea turtles and seagrass beds
● Migratory Waterbirds
● Wetlands
● Mangrove
● Coastline biodiversity fauna and flora
● Black River Fishing Reserve Marine Protected Area
● Public access to the coastline

6. Social Issue -​ ​Absence of public consultations

Public consultation is a mandatory step in the process of an EIA. However, there is no report
of any public consultation meetings in the EIA, although mention is made that issues exist
with people of the locality.

Public comment for Proposed 5-Star Hotel and World Class Conference and Seminar Centre on a plot of State
Land of an extent of about 43 arpents at Les Salines Koenig, Riviere Noire by Atalian Global Services Ltd​​

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Mother Courage Centre, Bois Cherie Rd, Moka

7. Economic Issue - Saturated Economy

7.1. 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 ethical 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.

Public comment for Proposed 5-Star Hotel and World Class Conference and Seminar Centre on a plot of State
Land of an extent of about 43 arpents at Les Salines Koenig, Riviere Noire by Atalian Global Services Ltd​​

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Mother Courage Centre, Bois Cherie Rd, Moka

7.2. 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.

7.3. 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.

Public comment for Proposed 5-Star Hotel and World Class Conference and Seminar Centre on a plot of State
Land of an extent of about 43 arpents at Les Salines Koenig, Riviere Noire by Atalian Global Services Ltd​​

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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 longer 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.

Public comment for Proposed 5-Star Hotel and World Class Conference and Seminar Centre on a plot of State
Land of an extent of about 43 arpents at Les Salines Koenig, Riviere Noire by Atalian Global Services Ltd​​

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Mother Courage Centre, Bois Cherie Rd, Moka

8. Proposed alternative - A Ramsar site of

international importance with inland Eco
villages integrated in a Ridge to Reef project
We invite both the relevant Public Authorities and the Promoters to reorient the development
strategy of Les Salines Peninsula, Rivière Noire towards a Ramsar site of international
importance, having inland eco-villages (which could be privately financed) fully integrated in
a Ridge to Reef concept ( ​http://r2r.alternativ.mu​ ).
Given the national urgency facing Climate Change and Biodiversity loss the Minister of
Environment have all the necessary legal tools to proceed with this strategic reorientation,
for the public interest.

Proposed alternative to Les Salines Peninsula Rivière Noire ​to a Ramsar site of
international importance, having inland Eco-villages fully integrated in a Ridge to Reef
concept

Public comment for Proposed 5-Star Hotel and World Class Conference and Seminar Centre on a plot of State
Land of an extent of about 43 arpents at Les Salines Koenig, Riviere Noire by Atalian Global Services Ltd​​

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The underlying economic potential of such a project are tremendous while being correctly
balanced with the unique ecosystem present in this region, and involves;
● Eco-guide operators
● Ocean related activities (high sea fisherman cooperatives)
● Scientific research
● Ecological reconquest
● Renewable energy
● Cultural Heritage
● Inclusive Eco-Tourism
● Short food and organic production
● Climate Jobs
● Artistic activities
● Nature related activities

It is only such a public interest oriented project that is compatible with the tremendous
Natural and Cultural Heritage present on this site. To name a few;
● Les Salines Black River Tour Martello Cultural heritage
● La Batterie de l’Harmonie Cultural heritage
● Natural heritage ESAs;
○ Category 1 ESA Wetland 1
○ Tidal Mudflats wetlands
○ Black River pass natural heritage
○ Seagrass beds
● Black River Fishing Reserve Marine Protected Area

Such a project could be further elaborated in the National Public Coastline Audit
Commission, that could go inline with the adoption of an ESA Bill ( ​http://esabillnow.org​ ).

7​th​ of August 2019,

on behalf of Rezistans ek Alternativ

Kugan PARAPEN Stephan GUA David SAUVAGE

kugan.parapen@alternativ.mu stephan.gua@alternativ.mu david.sauvage@alternativ.mu

Public comment for Proposed 5-Star Hotel and World Class Conference and Seminar Centre on a plot of State
Land of an extent of about 43 arpents at Les Salines Koenig, Riviere Noire by Atalian Global Services Ltd​​

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