Rezistans Ek Alternativ Public Comment For EAI Stella Di Mare (Les Salines, Black-River)

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

roposed Construction and Operation of a five-star 233 keys hotel
P
at Les Salines, Petite Rivière Noire,
by Stella Di Mare Mauritius 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
Kugan PARAPEN,
Stephan GUA,
David SAUVAGE,
on behalf of Rezistans ek Alternativ
16th of November 2018,
Re : Proposed Construction and Operation of a five-star 233 keys hotel at Les Salines,
Petite Rivière Noire, by Stella Di Mare Mauritius Ltd
Summary 2
Environmental Issue - Disruption of Tidal Mudflat ESA 3
Environmental Issue - Unknown impact of Tidal Mudflat disruption and Nautical

activities on the Black River Fishing Reserve Marine Protected Area 5
Environmental Issue - Lack of assessment of ”cumulative effects” 6
Social Issue - Water and Energy issue 6
Social Issue - Nature Resort project announced during public consultation but then
converted to a Beach Resort 7
Power Politics Issue - Non compliance to Black River Outline Planning Scheme
Development Management Plan 8
Power Politics Issue - Absence of Lease Agreement terms and conditions 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
Public comment for Proposed Construction and Operation of a five-star 233 keys hotel at Les Salines, Petite
Rivière Noire, by Stella Di Mare Mauritius Ltd
1/13
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 Construction and Operation of a five-star 233 keys hotel at Les
Salines, Petite Rivière Noire, by Stella Di Mare Mauritius 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.
2/13
2. Environmental Issue - Disruption of Tidal

Mudflat ESA
All the coastline area of the proposed project consist of a Tidal Mudflat. Tidal Mudflats are an
important kind of wetland, that form part of our Common Environmentally Sensitive Areas to
be properly restored and preserved.
EIA Annex L, section 1 Introduction, page 8
This Tidal Mudflat 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.
Moreover, the tidal mudflat to be disrupted is to be replaced by an artificial beach. However

the EIA does not specify the corresponding quantity of sand required to reprofile the 29’000
m2 surface, nor the approved quarry site from where the sand would come from.
EIA Annex L, section 4.1 Beach Reprofiling works, page 10

“The total area of beach to be reprofiled is 29,000 m2”
3/13
EIA Annex L, section 1 Introduction, page 8
In such scenic places, it is crucial that projects integrate themself to the existing Nature
instead of disrupting it. These are part of the natural cultural heritage of Mauritius, to be
preserve for future generations.
EIA Annex L, section 3.1 General Features, page 10
4/13
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.
EIA Annex L, section 4.4 Nautical Activities, page 10

“The resort will provide appropriate amenities and nautical activities to ensure that
it serves the worthy of 5-star rating.”
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.”
5/13
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 requires an assessment of
cumulative impacts of undertaking on ESAs. In the Les Salines Peninsula Black River,
where the press has reported no more 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 lacks 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.
6/13
5. Social Issue - Water and Energy issue

It is well known that several regions of Mauritius, including the Black River region, face
important issues regarding water supply each year. The condition for the promoter to only
make provision is not strong enough. It shall be compulsory for the project to be
self-sufficient in water supply.
Concerning electricity resource consumption, as excessive electricity consumption already

identified in the EIA, it shall be compulsory for the project to be self-sufficient in energy
supply from day one.
EIA Chapter 9, section Environment Impact Analysis, page 65
7/13
6. Social Issue - Nature Resort project

announced during public consultation but then
converted to a Beach Resort
During EIA consultation setup by a communication agency for the promoter, following the
question of an inhabitant of the locality, asking whether the project is about a Nature Resort
or a Beach Resort, as no beach is present on the site, but rather a Tidal Mudflat wetland, the
CEO of the promoter group said to the inhabitant that the project is a Nature Resort, thus
implying that the Tidal Mudflat would not be disrupted. However, in the EIA, the promoter
proposes to proceed a complete coastline reprofiling, that is disrupting the Tidal Mudflat ESA
and replacing it by an artificial beach.
EIA - ANNEX C - Outcome of Public Consultations - page 14

Local inhabitant: “What is your vision regarding the lagoon and to the fact that you are in
a muddy area? Will you be constructing a beach? Will your customers be
expecting a beach or are you advertising the hotel as a nature resort rather than a beach
resort?”
George Ayoub : “It’s more a natural resort. It’s difficult to make a beach resort with no
beach and we are not trying to sell it this way to our clients. This is more of a nature resort
than a beach resort, it is about how they can enjoy the hotel itself, the nature, the space
etc…”
This is of major concern given one of the main environmental issue concerning this project
concerns the Tidal Mudflat disruption. The proposed EIA is not inline with the information
given during the EIA public consultation. Thus, we are of the opinion that the EIA public
consultation was grossly misleading and untruthful, and that an EIA should not be awarded
to such a promoter.
8/13
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.
9/13
8. Power Politics Issue - Absence of Lease

Agreement terms and conditions
EIA - Annex F, labeled “Letter of Intent from State of Mauritius” is in fact a copy of the
reservation approval letter from the Ministry of Housing and Land. This reservation approval
letter stipulates in its Section 8 that a proper Letter of Intent would then be issued to the
promoter with the terms and conditions to be satisfied for both the drawing up and the issue
of a Lease Agreement. However, the Letter of Intent referred to in Section 8 of the
reservation approval letter is missing in the proposed EIA.
Consequently, due to the missing Letter of Intent, Citizens of Mauritius are not in the
capacity to assess the Lease Agreement terms and conditions. This could be the result of
the Fast Track Committee’s excessive zeal to speed up the EIA procedures, and is clearly
against the interest of the Citizens of Mauritius. As a consequence, important information
such as the rental fee of the State Land Lease is unknown, as well as the duration of the
State Land Lease.
A standard requirement in the State Land Lease would be that “The Lessee shall not
undertake any such activities which shall cause physical damage directly or indirectly to the
environment;", as this requirement is usually present in coastline State Land Lease.
Having this requirement in the State Land Lease, would imply that the Lessee shall not
disrupt the Tidal Mudflat.
10/13
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 quite 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 a 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.
11/13
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.
12/13
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.
16th of November 2018,

on behalf of Rezistans ek Alternativ
Kugan PARAPEN Stephan GUA David SAUVAGE

kugan.parapen@alternativ.mu stephan.gua@alternativ.mu david.sauvage@alternativ.mu
13/13

Rezistans Ek Alternativ Public Comment For EAI Stella Di Mare (Les Salines, Black-River)

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Rezistans ek Alternativ

Mother Courage Centre, Bois Cherie Rd, Moka

Public comment for

16th of November 2018,

Environmental Issue - Disruption of Tidal Mudflat ESA 3

Environmental Issue - Unknown impact of Tidal Mudflat disruption and Nautical

Environmental Issue - Lack of assessment of ”cumulative effects” 6

Social Issue - Water and Energy issue 6

Power Politics Issue - Absence of Lease Agreement terms and conditions 9

Economic Issue - Saturated Economy 10

2. Environmental Issue - Disruption of Tidal

EIA Annex L, section 1 Introduction, page 8

Moreover, the tidal mudflat to be disrupted is to be replaced by an artificial beach. However

EIA Annex L, section 4.1 Beach Reprofiling works, page 10

EIA Annex L, section 1 Introduction, page 8

EIA Annex L, section 3.1 General Features, page 10

3. Environmental Issue - Unknown impact of

EIA Annex L, section 4.4 Nautical Activities, page 10

4. Environmental Issue - Lack of assessment of

5. Social Issue - Water and Energy issue

Concerning electricity resource consumption, as excessive electricity consumption already

EIA Chapter 9, section Environment Impact Analysis, page 65

6. Social Issue - Nature Resort project

EIA - ANNEX C - Outcome of Public Consultations - page 14

7. Power Politics Issue - Non compliance to

8. Power Politics Issue - Absence of Lease

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

16th of November 2018,

Kugan PARAPEN Stephan GUA David SAUVAGE

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