Dear Mr. President, 

Minister for Agriculture, Climate Change and Environment,

Minister for Land Use and Habitat, 

CEO Planning Authority, 

Reviewing Project Reefresh, which consists of plans to redevelop the ex-Reef Hotel to construct a large 200 room hotel with conference venues, a large oceanside infinity pool along the coast, as well as two reclaimed islands in the sea for restaurants, villas and extra pools, we, The Ocean Project Seychelles and other concerned citizens, call upon the Seychelles Government and relevant authorities not to grant authorisation for land reclamation under Project Reefresh for the following reasons:

• Reclamation will destroy the largest remaining seagrass meadow adjacent to Mahe and one of the few healthy and easily accessible meadows in the inner islands of Seychelles. By authorising this, the Seychelles Government in breach of its recently submitted national climate commitments to the United Nation Framework Convention on Climate Change to protect 100% of seagrass meadows by 2030;
• In no small part because of the seagrass meadow, the beaches at Au Cap are healthy and relatively free from serious erosion. Reclamation will weaken this natural line of defense and impact coastal stability;  raising serious concern for the integrity of the beaches adjacent to the ex-Reef Hotel and further south along Au Cap; 
• The reclaimed land area is a designated shell reserve under the 1987 Fisheries Regulations where by law no person is to disturb any shell or its natural environment.
• Reclamation will put the livelihoods of artisanal fishers at stake. Deploying fish traps in the seagrass meadow during the South-East Monsoon allows fishermen to continue their subsistence activity despite the bad weather and provide fish to the local communities; 
• The site is of high sociological value to the local population who visit the beaches adjacent to the ex-Reef Hotel for recreation and sporting activities such as picnicking, kayaking, paddle boarding, kitesurfing and surfing; and 
• The developers of Project Reefresh have purchased the land and not any land over and upon the foreshore or the seabed. It should not be Government policy to authorise land reclamations over and upon the foreshore or the seabed that are not necessary, not in the public interest, and for the benefit of private interests. This will set a dangerous precedent; resulting in widespread destruction of our marine environment. 
• The EIA process, intended in part to consult the public and collect public concerns on the development, did not provide clear and accessible information to the general public during the public scoping exercise. This, as a result, prevents the general public from formulating an informed and accurate opinion.

Each point is set out in further detail and referenced below:

1. Reclamation will destroy the largest remaining seagrass meadow adjacent to Mahe and one of the few healthy and easily accessible meadows in the inner islands of Seychelles; putting the Seychelles Government in breach of its own national climate commitments submitted to the United Nation Framework Convention on Climate Change (UNFCCC) to protect 100% of seagrass meadows by 2030

The best remaining seagrass habitat adjacent to Mahe is the patch that remains along the coastline of Au Cap, of which the richest is that immediately adjacent to the ex-Reef Hotel property.[1] This seagrass meadow represents very high seagrass biodiversity hosting at least 6 species of seagrass including the highly endangered Enhalus acoroides (Gomon gran fey).[2] It hosts the full spectrum of seagrass life history traits and, according to scientists, would serve as an important site to study and understand species dynamics in the transition from short-lived to perennial species and test site for restoration science.[3] Other organisms of interest hosted by this seagrass meadow include the very beautiful and delicate coral, Pavona cactus, and species of the Porites genus.[4] Because the meadow is so rich, the SeyCCAT “Coastal Wetlands and Climate Change Project” have used it as the primary site to showcase to scientists, students, and the general public, the beauty and importance of seagrass ecosystems. It is the most accessible seagrass meadow; one would otherwise have to travel St Anne Marine Park, Praslin, La Digue or the outer islands (where the assemblage of seagrass is very different).[5] 

Land reclamation will result in the destruction of this habitat. It is well-known that land reclamation is generally fatal to seagrass meadows.[7] Project Reefresh claims that land reclamation will only impact 1 hectare out of a nationwide inventory of 2 million hectares of seagrass habitat,[8] but this figure, the intention of which appears to be quantification of the total impact of the reclamation, is very misleading. The national seagrass mapping study is still underway, and the anticipated figure is nowhere near 2 million hectares but is probably closer to 140,000 hectares.[9] Either way the final figure is not yet available. The additional claim that reclamation has been positioned over low density seagrass areas does not correlate to the Project Reefresh Bythermy map which shows high density seagrass across the entire site except near the beaches.[10]

More importantly, the figure represents only the footprint of reclaimed islands and not the impact to the surrounding seagrass habitat that will occur as a result of the reclamation. For instance, it does not represent the impact to surrounding seagrass during the pre-construction, construction and post-construction phases of the project e.g., from heavy plumes of sediment that will emanate from the construction site onto adjacent seagrass and coral habitats, the latter being highly sensitive to sedimentation as well as resuspension of sediment[11]; from sand accumulation over seagrass as a result of changes in sea currents around the reclaimed islands; from the destruction of seagrass at the swimming pool site (through excavation) or below the walkways (through shading).

Claims about the potential for recovery of damaged seagrass meadows are over-optimistic. References to seagrass at Anse Etoile being evidence that seagrass resists the effects of reclamation is false - only fragments of what were once thriving healthy seagrass meadows remain at Anse Etoile.[12] In any case, complete recovery of the disturbed seagrass habitat will not have occurred by 2030 which is the deadline for 100% seagrass protection.

The Seychelles Government has a duty to take climate change mitigation and adaptation measures due to the severity of the consequences of climate change. On 30th July 2021, the Seychelles government submitted its Nationally Determined Contributions (NDCs) to the UNFCCC with climate targets and actions for the period 2021-2030. The Government has committed to protect 100% of seagrass meadows by 2030. Seagrass ecosystems play an important role in carbon sequestration to combat climate change. While occupying only 0.1% of the ocean surface, seagrass ecosystems have been estimated to bury 27–44 Tg organic carbon (Corg) year–1 globally, accounting for 10–18% of the total carbon burial in the oceans, and have soil Corg stocks comparable to those of temperate and tropical forests, mangroves, and tidal marshes.[13]

Given the critical role that seagrass ecosystems play in carbon sequestration and climate adaptation, the destruction of any part of this seagrass meadow not only puts the Government in violation of its general duty and NDCs, but because degraded seagrass areas are a source of greenhouse gases (GHGs) to the atmosphere, Seychelles will have to report this source of GHG to the atmosphere in its national greenhouse inventory in the near future.[14]  This is a step in the wrong direction and will severely  impact our country’s international reputation as an ocean champion which could negatively impact our ability to access much-needed climate adaptation funds. Locally, it will send a strong message, especially to the younger generation whose lives will most be impacted by climate change, that the Government is not committed to taking action to protect their future. 

2. Reclamation will weaken the natural line of defense against coastal erosion and impact coastal stability.

Seagrass meadows play a significant role in protecting coastlines from associated flooding, erosion and storm surges.[15] Many studies emphasize the role of above-ground shoots in attenuating waves, enhancing sedimentation and preventing erosion.[16] The beaches of Au Cap are currently healthy and relatively free from serious erosion, attributable in no small part to the seagrass meadows growing adjacent to them. [17] Therefore, the claims that Project Reefresh will prevent erosion of the two small beaches adjacent to the Reef Hotel by rock armouring the site is illogical. Hard armouring is usually only effective in protecting human infrastructure and often negatively impacts the integrity of the natural functioning of the beach and dune systems.[18] Changing the coastal morphology, especially that of a coastal lagoon, is known to directly alter the coastal dynamics and the sedimentary balance of the lagoon. We have already experienced such impacts with past reclamation plans e.g., the construction of Ile Soleil and the runway between Ile Soleil and Mahe. Therefore, on the contrary to what is being presented, reclamation raises serious concerns about the integrity of the two beaches through hard armouring as well as serious concern for the adjacent beaches further south along Au Cap. Hard armouring at this healthy site runs counter to the Coastal Management Plan 2019-2024, the overall goal of which is to help maintain and protect the coastal zone to reduce coastal risk, support healthy ecosystems, and enable sustainable coastal economic development by, amongst others, harnessing the function of coastal ecosystems to reduce coastal risks.

3. The area is a designated shell reserve under the Fisheries Act where by law no person is to disturb any shell or its natural environment.

The reclaimed land under Project Reefresh lies within the Shell Reserve longing South East Island to Pointe au Sel, which consists of “areas lying within 400 metres seaward from the low-water mark between the northeast corner of South East Island and Anse Faure and the area lying between the low-water mark and the edge of the reef between Anse Faure and Pointe au Sel.” (Fisheries Regulations). Under the 1987 Fisheries Regulations, no person is allowed to - (a) collect any shelf from; or (b) disturb any shell or its natural environment on a reef, a rock or the bed of a lagoon within this shell reserve..

4. Reclamation will put the livelihoods of artisanal fishers at stake.

The seagrass meadow contributes to essential socio-economic activities such as artisanal fisheries. Deploying fish traps in the seagrass meadow during the South-East Monsoon allows fishermen to continue their subsistence activity despite the bad weather and provide fish to the local communities. As a result of consulting a group of Anse Aux Pins artisanal fishermen during the month of July, we also raise the concern that this group of important stakeholders do not appear to have been consulted on the Project Reefresh reclamation plans. This group raised their unease on the reclamation plans as well as other aspects of hotel design which is significantly closer to the coastline than the ex-Reef Hotel.

5. The site is of high sociological value to the local population.

This site has recreational importance to the people of Seychelles who visit the beach adjacent to and south of the ex-Reef Hotel, enjoying activities such as picnicking, kayaking, paddle boarding, kitesurfing and surfing. Keeping the seagrass meadow intact will also help keep the beaches intact and nearshore waters clean. 

6. The developers of Project Reefresh have purchased the land and not any land over and upon the foreshore or the seabed. It should not be Government policy to authorise land reclamations over and upon the foreshore or the seabed that are not necessary, not in the public interest, and for the benefit of private interests. This will set a dangerous precedent.

The developers of Project Reefresh purchased the land on which the ex-Reef Hotel stands. This never included any part of the foreshore or the seabed. If the Government were to authorise reclamation in this instance, it would open the floodgates for other landowners to do the same, leading to further destruction of healthy marine and coastal ecosystems. Project Reefresh seeks to differentiate itself from other larger-scale reclamations on Mahe (e.g., Perseverance) by stating that the reclamation will represent only 0.55% of total reclaimed land on Mahe.[19] The size of the reclamation is irrelevant. The real difference between Project Reefresh and past reclamations lies in necessity and public interest. Past reclamations relate to development of critical infrastructure (e.g., national port, international/domestic airport, energy plant, primary roads), housing purposes and other community-based infrastructures. The Project Reefresh reclamation would, in contrast, be purely used for temporary leisure accommodation, accommodating 16 - 30 people on an on-and-off basis. The State has a constitutional duty to take measures to safeguard the right of every person to a clean, healthy and ecologically balanced environment. Authorising reclamation in this instance and others like it runs counter to this constitutional right and other international commitments of the country. The impact to our marine environment will be catastrophic, as will the corresponding impact to our tourism industry which despite attempts at diversification remains one of the pillars of our economy.

7. The EIA process, intended in part to consult the public and collect public concerns on the development, did not provide clear and accessible information to the general public during the public scoping exercise. 

Following the public workshop on the 2nd July 2022, TOP Seychelles and several individuals contacted the Environmental Assessment and Permits Section under the Ministry of Environment, as well as the lead consultants from Eco-Sol Consulting Pty Ltd, to gain access to any EIA documents and/or presentations. Although the Eco-Sol presentation was eventually sent, we felt that there was a lack of transparency in making documents accessible to the general public. It is not possible for the general public to formulate an objective and well-informed opinion on such a large project development with just one (poorly advertised) public scoping meeting and no documents made openly accessible.. We also note that during discussions with Anse Aux Pins fishermen and community members, the majority of individuals consulted were not aware of the scope of the Project Reefresh and that reclamation was part of the development plan.

Yours sincerely,

The Ocean Project Seychelles and Concerned Citizens of Seychelles

REFERENCES:

[1] Mortimer pers. comm.

[2] Harlay & Mortimer pers. comm.; Seagrass and Carbon Mapping Project - PEW Charitable Trust

[3] Harlay & Mortimer pers. comm.

[4] Harlay & Mortimer pers. comm.

[5] Mortimer pers. comm.

[6] Mortimer pers. comm.

[7] Meinesz, A.; Lefevre, J.R.; Astier, J.M.

[8] Project Reefresh ESIA ECO-SOL 07/06/2022

[9] Mortimer pers. comm.

[10] Project Reefresh ESIA ECO-SOL 07/06/2022

[11]https://www.reefresilience.org/pdf/Coral_Reefs_and_Global_Climate_Change.pdf - Land reclamation and construction activities can result in increased sedimentation or resuspension of sediment in the marine environment. Once there has been substantial influx of land-derived sediment to a reef region, the “new” sediment often remains in place and is subject to resuspension, making the substrate where it accumulates less hospitable to corals. Reefs closest to land masses will probably continue to experience the most intense chronic (and locally acute) sediment stress, and the effects will be magnified by climatic change in some areas.

[12] Harlay & Mortimer pers. comm.

[13] Duarte et al., 2005; Fourqurean et al., 2012a

[14] Pendleton et al., 2012

[15] Duarte et al., 2013; Ondiviela et al., 2014; Effrosynidis et al., 2018; Ondiviela et al., 2020

[16] Duarte et al., 2013; Ondiviela et al., 2014; Effrosynidis et al., 2018; Ondiviela et al., 2020

[17] Mortimer pers. comm.

[18] Mortimer pers. comm.

[19] Project Reefresh ESIA ECO-SOL 07/06/2022