In October 2020, PML was invited to a thematic workshop on a couple of specific questions relating to the review of the NDS (2003). Following this, PML sent its preliminary comments to the Ministry of Housing and Land Use Management. These are published below.
Main shortcomings:
- Climate change not mainstreamed in its institutional policies;
- resilience is not embodied in the policies and strategies;
- absence of strategic environmental assessment;
- the flexible approach adopted as opposed to a prescriptive one; and
- the absence of the economic valuation of natural capital.
The last three in the single and narrow pursuit of GDP growth as opposed to sustainable development.
If the new NDS is to contribute to achieving sustainable development that is inclusive and green, and to meeting commitments to international agreements and conventions, the tenets and institutional policies of the new NDS should be formulated in that direction.
1. The vision and overarching policy framework as per the Terms of Reference
It cannot be the case and imperative that the “main objective of sustainable development {which} is to facilitate economic growth that respects the island’s natural resources”. Besides, the third bullet point in the PowerPoint Presentation of the Terms of Reference (ToRs) actually contradicts the second and includes the dimension of culture and society. Economic growth and economic development are not the same, and the latter cannot be reduced to the former.
It seems from the presentation made on 1st October 2020 that the vision and the overarching policy framework are the National Strategic Plan. We wish to note that the key challenges are spelt out in confusing, overlapping or contradictory ways. It is of concern that climate change is framed in terms of “embracing climate change opportunities” and not as an ongoing, intensifying challenge. Is it then framed in the light of its economic opportunities? There is not a clear sense of how the interacting dimensions of sustainable development can be reconciled and whether in fact economic growth – irrespective of the sources – is the driving and overriding consideration. One of the main messages of the Assises de l’Environnement is that one of the key problematic factors is precisely this single focus. PML’s views on the matter were expressed in its submission to the Assises (see attached document and link[i]) and it was found during technical working sessions to be shared by various stakeholders.
It seems that the original ToRs of the NDS Review have not been amended to take into account the ensuing context of COVID, then the Wakashio disaster and their cumulative fall out on Mauritius, and in particular the spatial implications of an overarching policy framework.
The main sources of income growth so far are seriously at risk with COVID, in particular contact-intensive services, such as tourism and recreation, located near the coast and the health impacts. We do not think this is just about a recession, but about systemic changes, in particular looking towards 2040. The parameters are very short term.
The section on 2020 development directions (Covid 19) impacts do not address how COVID 19 is a game changer, looking to 2040. The 2020 Land Development Principles also seem to be more about urban design land use than general spatial planning. What is not highlighted sufficiently or at all are
- the context of COVID 19 and climate change impacts on a small, remote island development state,
- how a blue/ocean economy, a major plank of sustainable economic development, starts at the coastal zone,
- how an overall disaster risk reduction and management approach is needed to build coastal zone resilience and what the land use issues are,
- how the coastal zone can also be impacted by threats from maritime security (an early lesson that led to the institution of the Pas Géometriques), whose continued relevance need to be addressed, as the Wakashio disaster illustrates.
2. Climate Change and SDGs
Will the NDS be reviewed completely with regards to climate change and the Sustainable Development Goals (SDG)? Climate change presents the single biggest threat to sustainable development everywhere and its widespread, unprecedented impacts disproportionately burden the poorest and most vulnerable. Urgent action to halt climate change and deal with its impacts is integral to successfully achieving all Sustainable Development Goals (SDGs). How will the forthcoming Climate Change bill interface with/harmonise with the NDS 2040?
- Although the 2003 NDS mentions that Mauritius is a party to the UN Framework Convention on Climate Change 1992 and the Kyoto Protocol 1999, it had not integrated/mainstreamed climate change in its Strategic Policies. Currently, Mauritius is a signatory of both the Paris Agreement and the 2030 Agenda, as well as several other international agreements and environmental conventions.
- The new NDS should demonstrate how climate change adaptation and disaster risk reduction underpins it. There is a need for sound planning to build the island’s resilience to the impacts of climate change; there is a need for food security, water security, energy security and environmental security.Integrating climate change means that climate concerns and adaptation responses are integrated into relevant development policies, plans, programs, and projects at national, sub-national, and local scales.
How will the new NDS take into account climate change in strategic policies? How are the institutional policies climate change proofed? - The consultants have the benefit of several studies and frameworks to formulate strategies and policies.
- The National Climate Change Adaptation Policy Framework for the Republic of Mauritius 2012. This framework aims at integrating climate change into core development policies, strategies and plans. The main objectives of this Framework are to enhance the resilience of key economic sectors, mitigate risks and damages to human settlements, infrastructure and avoid the loss of lives due to extreme climatic events. It assessed that “Spatial planning and land management play an important role in risk prevention, by limiting the development in flood prone areas, and by encouraging flood risk-sensitive land use and management practices. High proportion of areas identified for future development are placed in areas prone to very high and high risk (3.2.5 Integrating disaster risk reduction in climate change adaptation).
- Integrating Climate Change into coastal planning & Management in the Republic of Mauritius 2013 which noted that “the effects of rising sea levels that will effectively shift the coastal zone in a landward direction. Thus it is clear that a consideration of climate change is paramount in a comprehensive and inclusive system for coastal planning and management.”
- Sendai Framework for disaster risk reduction aims at substantially reducing disaster damage to critical infrastructure and disruption of basic services, including through developing their resilience by 2030.
- The policy regarding our coast should therefore be the following:
- Unbuilt sites are to be rehabilitated with green infrastructure (ecological restoration) to build the resilience of the coast and provide a buffer in case of storm surges and coastal inundation;
- New NDS should have clear policies on management of coastal built areas with respect to effects of sea level rise. For example, managed retreat in the case of built sites in coastal flooding/storm surge (chronic coastal hazards) prone areas. In this regard, several studies have already identified these areas (eg. JICA, Landell Mills, Deltares). These studies, if not public should be made public. There is a need for open space once retreat occurs as a buffer against future storms and coastal erosion because natural disasters will continue to impact coastlines.
3. The flexible approach
Figures for real GPD growth do not demonstrate that the 1994 NPDP with its “prescriptive” approach stunted economic growth and conversely that the 2003 NDS with its flexible approach has meant accelerated GDP growth. The flexibility allowed by the 2003 NDS as regards to siting of economic activity, human settlement, infrastructure has led to an increase in the vulnerability of the island to the impacts of climate change. For example, development has been allowed near reservoirs, in woods and in flood-prone zones. The new reviewed NDS should be prescriptive so as to define zones where development is permissible and zones where it is not. This must be stated as a policy. Likewise, buffering limits have to be explicit.
4. Strategic Environmental Assessment (SEA)
SEA is a useful tool in decision-making to assess options/alternatives and impacts when formulating policies and plans as well as cumulative impacts in a given area. Carrying out an SEA that is fully integrated in the formulation of the land use plan would ensure that environmental issues are considered alongside economic and engineering considerations, meaning that final land use plans are fully “integrated”. Conducting a SEA requires consultations to be carried out at the early stages of the process.
- With regard to NDS and outline schemes, the absence of strategic environmental assessments raises concerns as to whether the recommended development plans and strategies for the country would be environmentally and socially coherent. Indeed, several new developments such as Ebene Cyber City and major commercial centres (such as Bagatelle, La Croisette etc.) had not been options considered in the existing NDS. The implementation of these projects has had far reaching environmental and/or planning-related impacts that only a strategic environmental assessment could have predicted. It is significant to note that several of these major projects have been implemented without an Environmental Impact Assessment (EIA).
- Lack of SEA in the development of tourism zones such as the South West, Les Salines peninsula, Balaclava etc. The development of these zones has been left to promoters to demonstrate the ecological sensitivity of these zones whereas this should have been established at SEA level. The regional environmental impacts cannot be addressed at project level. In the case of Les Salines for example, the west coast is a haven for dolphins and threatened sea turtles and the impacts of proposed coastal and sea works (dredging) by the various hotel projects have been completely disregarded in their evaluation.
5. Tourism
Is the review considering a Business as Usual (BaU) scenario regarding the future of the industry? Is the current tourism plan still valid in the wake of the global economic crisis structurally affecting international tourism? Can cruise terminals still be an infrastructural development option?
6. Institutional policies
- Ridge-to-reef in policy formulation.
- What happens upstream has an impact on the coastal zone. So, it is not possible to speak only in terms of the 1km of inland coastal area from the HWM and outward to the reef. The concept of Ridge-to-Reef has to be integrated in the new NDS. It follows then that the review of the NDS has to consider, among other influences,
- the integration of the land drainage network to minimize drains discharging stormwater laden with pollutants directly into the lagoon.
- the integration of wastewater management to stop untreated or inadequately treated sewage from coastal urbanization getting into the lagoon. We are very far from the target of 80% of the population connected to the national sewer network by 2030.
- the integration of river reserves rehabilitation to reduce the sediment load in the lagoon.
- the integration of wetland conservation and restoration to protect beaches and the lagoon.
- a national policy to integrate stormwater management and ESA conservation and restoration.
7. Economic valuation of natural capital/ecosystem services
Business facilitation in the single pursuit of GDP growth has increased our vulnerability as the loss of natural capital and of ecosystem services are not included in the national accounts as a deficit whereas the cost of mitigating the negative impacts of the loss are included as an investment.
8. Heritage value
Integrating the value of cultural and natural heritage in formulating strategic policies is critical. Invaluable natural assets should be preserved and protected from visually intrusive construction.
Platform Moris Lanvironnman (PML)
21 October 2020
[i] Platform Moris Lanvironnman Assises de l’Environnement – December 2019. Additional Views and Comments. https://www.dropbox.com/home/Public%20PML?preview=PML+Assises+Add+Views+and+Comments+FINAL+15+Jan+2020.pdf
Coastal Zone: A Survival Kit 