Rezistans ek Alternativ +230 433 64 31

℅ Mother Courage Centre rezistans@freeitmauritius.org

Bois Cheri Road https://facebook.com/reziste
Moka
Republic of Mauritius
25​th​ of January 2019

Please refer to;

● Permanent Secretary letter reference ENV/DOE/EIA/1804
● Our public comment letter dated 16th of November 2018, titled “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”

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 Construction and Operation of a five-star 233 keys hotel at Les Salines, Petite Rivière Noire, by Stella Di
Mare Mauritius Ltd

Sir,

We refer to our correspondence dated 16th of November 2018 ​“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”​, and to your
acknowledgement letter dated 3rd of December 2018 having reference ​ENV/DOE/EIA/1804

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 ​the presence of intertidal mudflat wetland occurs
on the site​. We hereby invite you to take cognizance of same in the attached Assessment Summary.

Also, we would like to highlight the following:

1. 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 “Unvegetated mudflat and intertidal marshes...” (Ramsar COP 13 Resolution XIII.14)

2. 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

3. 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 intertidal mudflat wetland hydrological cycle
amongst others, we urge the corresponding ministries to take immediate remedial necessary actions
 Rezistans ek Alternativ +230 433 64 31
℅ Mother Courage Centre rezistans@freeitmauritius.org
Bois Cheri Road https://facebook.com/reziste
Moka
Republic of Mauritius
25​th​ of January 2019

4. 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

 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 the occurrence of tidal mudflat wetland at Stella De

Mare

Dear Sir

I have, as requested, visited abovementioned site (Figure 1) to establish the

presence of tidal mudflat wetland.

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”.
Mudflats are internationally recognised for their importance that “are very
significant socio-economically and culturally, providing multiple and important
ecosystem, benefitting not only local dependent communities but a wider
society, in mitigating effects of climate change through sequestration of
carbon, and contributing also to adaptation by protecting against storm surges
and sea level rise, and that their conservation and wise use directly
contributes to multiple Social Development Goals (Draft Ramsar COP13
Doc.18.22)

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
“Unvegetated mudflat and intertidal marshes…” (Ramsar COP 13 Resolution
XIII.14)
Intertidal mud flats can be defined as shallow-sloped shoreline, with expanses
of fine sediment. They are often components of estuaries, and are revealed
when the tide goes out (https://www.crd.bc.ca/education/our-
environment/ecosystems/coastal-marine/intertidal-mud-flats)

Findings
The site (Figure 1) was visited on 2 December 2018 at 15H06 at low tide and
the following features were noted:
1. Extensive mud flats with a high tide mark (indicated by debris on the
shoreline (Figure 0
2. Mangrove trees (Rhizophora mucronata) occurring on the mud flats
(Figure 2).
3. Crabs of the order and family Uca Ocypodidae (Figure 3) were
abundant on site.

Therefore, having considered the abovementioned factors it is concluded that

intertidal mudflat wetland occurs on the site.

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 presence of intertidal mudflats was established as indicated at the Stella Di Mare study area
 Debris indicating the high tide mark

Mudflats – note the gentle character of the landscape The inundated nature of the mudflat
is evident.
Figure 2: Mudflats occurred on the site and debris indicated the high tide level
Figure 3: Mangroves occurred on the mud flats and are indicative of brackish water conditions
(often associated with mudflats and the interaction between freshwater and sea water)
Ocypodoidea crab Crab holes filled with water indicated saturated condition

Figure 4: Ocypodoidea crab frequent mudflats were abundant on the site