Annexe 1 -Important Communication to EIA Committee and Ministry of Environment

7th December 2018

Please refer to;

● Letter reference to ENV/DOE/EIA/ 1767
● Our response letter dated 10th of August 2018, titled “Re: Invitation for Technical Committee EIA for Proposed
Resort Hotel at Les Salines, Rivière Noire”, postal registration number RB013245165MU

The Permanent Secretary / The EIA Committee / The Minister of Environment

Ministry of Social Security, National Solidarity and Environment and Sustainable Development
(Environment and Sustainable Development Division)
2nd Floor, Ken Lee Tower
Barracks Street,
Port Louis
Copy to Media
Release to Public

Important Communication to EIA Committee concerning

EIA for Proposed Resort Hotel at Les Salines, Rivière Noire by NMH

Sir,

We refer to your correspondence dated 5th of July 2018 inviting 3 members of Rezistans ek Alternativ (namely Kugan
PARAPEN, David SAUVAGE and Stephan GUA) to appear before a Technical Committee with respect to the EIA for proposed
Hotel Project at Les Salines, Rivière Noire by Beachcomber (New Mauritius Hotels Ltd)
We also refer to our response letter dated 10th of August 2018, titled “Re: Invitation for Technical Committee EIA for
Proposed Resort Hotel at Les Salines, Rivière Noire”, postal registration number RB013245165MU

We urgently wish to bring to the attention of the Minister of Environment, the EIA Committee, and composing Ministries of the
EIA Committee (Agriculture, Fisheries and Marine Resources, Health, Housing and Lands, Industry, Local Government, Public
Infrastructure, Water Resources and Waste Water) the following crucial information:

Following an ​Expertise Assessment on site carried out by an internationally renowned wetlands expert ​Dr.
Piet-Louis GRUNDLING, Research Associate, Centre of Environmental Studies, University of Free State
South Africa on the 2nd of December 2018, it was established that ​the new proposed wetland will not be
able to function as a tidal salt marsh (c.f the existing ESA Wetland #76) and therefore cannot be
considered as a ‘like-for-like’’ offset measure to compensate for the loss of the natural salt marsh that
will be destroyed by the proposed development. We hereby invite you to take cognizance of same in the
attached Assessment Summary.

Also, we would like to highlight the following:

1. Concerning the Technical Committee we have been invited to participate to concerning the EIA for Proposed Resort
Hotel at Les Salines, Rivière Noire by Beachcomber (New Mauritius Hotels Ltd). We are still waiting for a response
concerning our letter (see point 2. above) regarding your invitation, in order to be able to participate to this important
meeting

2. The Ramsar contracting parties, including the Republic of Mauritius, accepted Resolution XIII.14 during COP 13 in
Dubai, U.A.E. 2018 calling for the “Promoting conservation, restoration and sustainable management of coastal blue
carbon ecosystems’’. These include “salt marshes” (Ramsar COP 13 Resolution XIII.14)
 3. Following the UNDP GEF funded project ‘Mainstreaming Biodiversity into the Management of Coastal Zone in the
Republic of Mauritius’, an the Inception Workshop on “Consultancy Services for Review of the ESA study and ICZM
planning” helded on the 29th of November 2018, at Le Labourdonnais Waterfront Hotel, Caudan. The experts from
FCG ANZDEC Ltd, the awarding consultancy services, shared with us that such projects are not compatible with
current UNDP GEF initiative, as well as proper management of Mauritius ESAs

4. Given that the new “Les Salines Rivière-Noire” road initiated by the Ministry of Housing and Lands has been carried out
without any EIA process and also given that this road is a threat to the ESA Wetland #76 hydrological cycle amongst
others, we urge the corresponding ministries to take immediate remedial necessary actions

5. We urge the corresponding ministries to take immediate action concerning the potential violation of the following
International Conventions, to which the Republic of Mauritius is a contracting party of:
● Ramsar Convention
● Convention on Biological Diversity (CBD)
● African-Eurasian Waterbird Agreement (AEWA)

In view of the above, Rezistans ek Alternativ reiterates its stand against granting an EIA License to the proposed project. We
also invite the EIA Committee as well as any other person/entity concerned to give due consideration to these new crucial
informations, and take corresponding actions responsibly.

Thanking you for your cooperation,

Kugan PARAPEN David SAUVAGE Stephan GUA

kugan.parapen@alternativ.mu david.sauvage@alternativ.mu stephan.gua@alternativ.mu
591 553 24 542 818 32 593 768 33

on behalf of Rezistans ek Alternativ

 Annexe 2 - Rapport de l’expert sur les Wetlands #76, Rivière Noire

ASSESSMENT & EXPERT OPINION by

Dr Piet-Louis Grundling

(SACNSP – 400088/06)

Research Associate Centre of Environmental Studies

University of Free State South Africa

3 December 2018

RE: Establishing if the proposed constructed wetland at Les Salines Resort and Spa NMH will function
as a tidal salt marsh

Dear Sir

I have, as requested, visited abovementioned site (Figure 1) to establish if the proposed constructed
wetland at LeSaline Resort and Spa NMH will function as a tidal salt marsh

Introduction

The republic of Mauritius is a signatory to the Ramsar Convention since 1997. Wetlands are defined by
Article 1 of the Ramsar Convention as “areas of marsh, fen, peatland or water, whether natural or
artificial, permanent or temporary, with water that is static or flowing, fresh, brackish or salt, including
areas of marine water the depth of which at low tide does not exceed six metres”. Hence, as defined by
the Convention, wetlands include a wide variety of inland habitats such as marshes, peatlands,
floodplains, rivers and lakes, and coastal areas such as saltmarshes, mangroves, intertidal mudflats and
seagrass beds, and also coral reefs and other marine areas no deeper than six metres at low tide, as well
as human made wetlands such as dams, reservoirs, rice paddies and wastewater treatment ponds and
lagoons”.

“Coastal salt marsh or a tidal marsh, is a coastal ecosystem in the upper coastal intertidal zone between
land and open saltwater or brackish water that is regularly flooded by the tides. It is dominated by dense
stands of salt- tolerant plants such as herbs, grasses, or low shrubs.[1][2] These plants are terrestrial in
origin and are essential to the stability of the salt marsh in trapping and binding sediments. Salt marshes
play a large role in the aquatic food web and the delivery of nutrients to coastal waters. They also
support terrestrial animals and provide coastal protection”

https://en.wikipedia.org/wiki/Salt_marsh
To that cause the Ramsar contracting parties, including the Republic of Mauritius, accepted Resolution
XIII.14 during COP 13 in Dubai, U.A.E. 2018 calling for the “Promoting conservation, restoration and
sustainable management of coastal blue carbon ecosystems’’. These include “salt marshes” (Ramsar COP
13 Resolution XIII.14)

The proposed constructed wetland

The EIA states that

● The constructed wetland will be created to form a ‘cut-off’ channel along the eastern perimeter
of the site which will be designed to intercept all offsite storm water run-off from the upslope
rainfall catchment to the east and ensure that the retention function of the existing wetland is
maintained and managed.

● The constructed area of the wetland will extend around the southern extremity of the site. The
two swells will extend towards the lagoon, stopping approximately 30m short of the high water
mark.

● The proposed new areas of the wetland will be excavated to various depths below mean sea
level to create an optimum wetland environment. Due to the porosity of the coral/ sand subsoil,
the water level in the wetlands will be tidal. The total area of the proposed wetlands at mean sea
level shall be 54, 030m2. The proposed wetland will provide a very extensive retention volume,
so that storm water run-off is generally held within the wetland area, and allowed to percolate
through the sand/coral substrate, thereby reducing impact of silt and sediment on water quality
within the lagoon. The proposed new areas of wetland will also provide an important habitat for
flora and fauna,enhancing the natural and visual value of the site.

● To ensure that there is no risk of flooding of the site during extreme rainfall conditions, the 30m
strip of land from the ends of the two wetland channels to the lagoon will be set at +1.6m AMSL.
This will mean that during extreme conditions, if the wetlands overtop, then the excess storm
water will be able to evacuate to the sea without affecting the proposed hotel buildings.

Findings

The site (Figure 1) was visited on 2 December 2018 and the following features were noted:

1. Extensive salt marshes occur on site (Figure 1)

2. Various salt works occurred in the salt marsh.

3. The salt marsh are connected with a natural channel to the sea and tidal fluctuations were evident
allowing for extensive and shallow tidal inundation of the salt marsh.

Therefore, having considered the abovementioned EIA report and the natural factors of the salt marsh it
is clear that the proposed constructed wetland will be isolated from the sea without any tidal in and out
flow surface connection to the sea. Consequently it will not be able to function as a tidal salt marsh and
therefore cannot be considered as a ‘like-for-like’’ offset measure to compensate for the loss of the
natural salt marsh that will be destroyed by the proposed development.

Any queries could be directed to myself.

Yours sincerely

Dr Piet-Louis Grundling

(SACNSP - 400088/06)

Research Associate

Centre of Environmental Studies

University of Free State

South Africa
Figure 1: The extent of the proposed development and the proposed constructed wetland. The natural
salt marsh occurs within the footprint of the proposed development and proposed constructed
wetland.