Opinion of the Federation issued as part of the public inquiry

A project with a significant environmental impact marred by major shortcomings in terms of commercial urban planning requirements and socio-economic impact assessment.

Summary

As part of the public environmental inquiry into the Carrefour shopping center project in Maharepa, the Tahei auti ia Moorea federation issued a critical opinion based on an in-depth analysis of the environmental impact study and the documents in the file. This opinion highlights major shortcomings in environmental, socio-economic, and urban planning terms.

The project involves the construction of a very large shopping center—more than 8,000 m² of covered space—including a large supermarket, a shopping mall, and a large-capacity parking lot, in the heart of a modest-sized urban center. By way of comparison, the existing Champion shopping center in Vaiare, which belongs to the same group, is less than half this size. Such a disproportionate scale immediately raises the question of whether the project is appropriate for the territory of Moorea and its fragile balance.

Insufficiently assessed environmental impacts

The impact study identifies certain technical issues (drinking water, rainwater, traffic, nuisances), but in a largely incomplete manner. Key points are either underestimated or poorly documented, particularly with regard to massive soil sealing, pollution risks associated with the construction site and parking lot, nuisances for local residents, and fears of increased impact from hurricane-force waves on neighboring land.

These shortcomings have already been noted by the administrative judge, who deemed the study insufficient and requested additional information, particularly on the overall impact on the landscape and the risk of marine submersion linked to the filling of the land. Despite these additions, the analysis remains incomplete and does not allow for a clear assessment of the real effects of the project on its immediate environment.

A major blind spot: socio-economic impacts

One of the most worrying points is the almost total absence of analysis of the socio-economic and commercial impacts. The impact study does not provide any serious assessment of the consequences of the project on local businesses, local independent employment, or the balance of the urban center of Maharepa.

However, the public inquiry received more than 1,000 unfavorable contributions, an unprecedented number, clearly expressing fears of a crowding-out effect on small businesses and excessive concentration of commercial activity. These concerns, although widely

A clear unfavorable opinion from the Competition Authority

In this regard, the unfavorable opinion issued by the Polynesian Competition Authority is a key factor. The Authority considers that the project would not create new economic value, but would mainly capture existing demand, with a shift in jobs to the detriment of the local commercial fabric. The Authority also highlights the structural dominance of the group behind the project and warns of the risks of excessive market concentration, which is incompatible with a balanced island economy.

Urban inconsistency and a lasting risk for Maharepa

Finally, the opinion notes that the project is designed as an isolated operation, without any consideration of consistency with the existing shopping center or with the overall urban organization of Maharepa. This strictly piecemeal approach is contrary to the principles of controlled development and poses a lasting risk of imbalance to the vitality of the urban center, commercial diversity, and the attractiveness of the site.

Serious breaches of environmental requirements

Field observations also show that, from the construction phase onwards, environmental requirements that were explicitly imposed, particularly with regard to green waste management, have not been complied with. This breach reinforces doubts about the project owner’s ability to comply with the commitments made in the impact study in the future.

In conclusion

As it stands, the impact study does not allow either the public or the competent authorities to fully assess the environmental, social, economic, and urban consequences of the project. These substantial shortcomings call into question the legality of the permits issued and raise serious doubts about the relevance of this project for the future of Moorea. The federation is also calling for all such major projects to be presented directly to the population so that they can question the developer directly and thus be involved in the development of the island.

‘Ia vai he’euri noa ‘o Mo’orea!

In a ruling dated November 4, 2025, the Administrative Court of French Polynesia issued a stay of proceedings to allow for the regularization of the building permit for the Maharepa shopping center project by producing a supplementary impact study addressing two specific shortcomings: the analysis of the project’s impact on the landscapes seen from the lagoon and the consideration of the risk of sea water flooding neighboring land.

The public inquiry organized in this context aims to enable the public and the competent authority to assess the quality, sincerity, and adequacy of the additional studies produced. Although the regularization ordered by the judge is legally limited to these two points, their examination cannot be dissociated from the overall economy of the project and its cumulative impacts on the environment, the living environment, and the urban organization of the site.

The shortcomings identified by the court relate to structural issues of the project that are directly linked to its location, its volume, and the development choices made. Their assessment necessarily requires consideration of all the foreseeable effects of the project, as resulting from the initial impact study, the supplementary information provided, and the comments made during successive public inquiries.

In this context, this opinion provides a general analysis intended to place the supplementary impact assessments in their overall context and assess their actual ability to meet the requirements for public information and prevention of environmental damage. This analysis is supplemented by a detailed technical opinion, attached in Appendix 2, specifically devoted to the two points subject to the judge’s order for regularization.

Opinion of the Tahei auti i’a Moorea Federation on the CARREFOUR shopping center project located in Maharepa (municipality of Paopao, MOOREA)

The Maharepa shopping center project, the fourth for the CARREFOUR group in French Polynesia, involves the construction of a single building with a covered area of more than 8,000 m², equivalent to the one in the municipality of ARUE, comprising a large supermarket, a shopping mall, and a large-capacity parking lot, within a modest-sized urban center, characteristic of the fragile balance specific to island territories.

Compared to the TOA shopping center already established in Moorea in Vaiare, under the CHAMPION brand, belonging to the same CARREFOUR group, with a surface area of 3,500 m², , the Maharepa project will occupy more than twice this area.

1. Technical environmental impacts

The environmental impact study, which was subject to public inquiry, highlighted numerous environmental and technical issues, particularly with regard to:

• drinking water supply, in an area that regularly experiences shortages;
• rainwater management, due to the massive impermeability of the soil;
• pollution risks linked to earthworks, waste disposal, and the operation of the parking lot;
• impacts on traffic in an already busy area;
• and nuisances for local residents during the construction and operation phases.

The administrative court ruled that the study was insufficient and suspended its final decision on the legality of the permit pending additional information on the overall landscape impact and the project’s impact on the risk of marine submersion of neighboring land following the 2-meter-high embankment.

A comprehensive technical opinion is provided in Appendix 1, summarizing the points raised during the first public inquiry, and a specific technical opinion on the points covered by the supplementary impact study is attached in Appendix 2.

2. Impacts on the existing commercial fabric

Beyond these environmental aspects, the project raises a major commercial urban planning issue that has not been addressed, despite opposition from a large number of Moorea residents, who have expressed their views at a level never before seen in this type of public inquiry, with more than 1,000 objections filed.

While the environmental impact study mainly addressed the effects of the project from a technical and environmental perspective, it clearly falls short in its analysis of the project’s significant socio-economic and commercial impacts.

For example, the impact study does not include any structured assessment of the project’s consequences on local businesses, local independent employment, or the economic balance of the urban center of Maharepa. However, the establishment of a commercial facility of this size in a limited urban area will inevitably have a commercial displacement effect, by capturing consumer flows, concentrating supply, and dominating competition.

The numerous complaints gathered during the public inquiry explicitly warned of the risk of small businesses disappearing, unable to compete with a supermarket and shopping mall of this size. By merely mentioning these concerns without analyzing them, objectifying them, or responding to them with measures to avoid, reduce, or compensate for them, the dossier reveals a substantial deficiency.

The unfavorable opinion of the Polynesian Competition Authority (APC)

Furthermore, it is important to note the unfavorable opinion issued by the Polynesian Competition Authority, summarized below. It considers that this project would not create new economic value for the territory, but would mainly lead to a capture of existing demand, to the detriment of existing local businesses.

The Authority emphasizes that the jobs announced do not correspond to net creation, but to a displacement of jobs, with a high risk of closures or lasting weakening of local economic players. It also highlights the structural dominance of the group behind the project, reinforced by its control of imports, logistics, and distribution, and believes that the operation would exacerbate excessive market concentration.

Consequently, the Authority warns of the negative effects of the project in terms of competition, local employment, and economic diversity, and considers that the proposed commitments do not compensate for these adverse effects. This unfavorable opinion sends a clear signal to public decision-makers about the economic and social risks associated with this project.

3. A strictly piecemeal approach, contrary to the logic of urban coherence

The project is approached as an isolated operation, without consideration for Maharepa’s existing commercial organization, even though a shopping center is already located in the immediate vicinity. No thought has been given to the functional and urban relationship between these facilities, nor to the possibility of a coherent, gradual, and harmonious extension of the existing hub.

This lack of an overall vision leads to a break in urban continuity, in terms of both pathways and uses, as well as the commercial hierarchy. Instead of strengthening the urban center with an integrated project, the choice made favors a logic of massive juxtaposition, creating an oversized hub that is disconnected from its immediate environment and destroys the pre-existing balance.

4. A structural imbalance incompatible with the principles of controlled development

In commercial urban planning, the issue is not only one of formal regulatory compliance, but also one of proportionality and the suitability of the project for the host territory. In this case, the lack of a hierarchy of centralities, analysis of the local market’s absorption capacity, and consideration of the cumulative effects in the medium and long term leads to a clear structural imbalance.

This imbalance is all the more worrying given that Maharepa is an urban center at the municipal level, whose vitality depends precisely on the diversity of its shops, their proximity, and the local roots of its activities. The project, as it is currently designed, carries a high risk of commercial commoditization that is unattractive to both the population and tourists, increased dependence on large retailers, and a lasting weakening of the local economic fabric for a very long period of time.

The impact on the urban quality of the Maharepa urban center will be major and virtually irreversible.

5. Inadequacy of the impact study in relation to its objectives

Ultimately, by failing to address the major socio-economic impacts of the project in a serious and thorough manner, and by refraining from ensuring urban and commercial consistency with the existing center, the impact study does not allow either the public or the competent authorities to fully appreciate the real consequences of the project on the urban and commercial organization of Maharepa.

This shortcoming affects the overall quality of the assessment, even though these issues have been clearly brought to the public debate.

It calls into question the project’s ability to meet the principles of balanced urban development, respectful of the specific characteristics of the island and the local public interest, even though it would be entirely possible to imagine another type of commercial development on this plot.

6. Failure to comply with requirements relating to green waste management during the construction phase

Field observations show that the project owner did not comply with the explicit requirements set out in the final impact assessment report attached to the initial permit, which stipulated the full implementation of the measures recommended in that report, namely the on-site shredding of green waste in order to limit its volume, transport and environmental impact.

Contrary to these requirements, the waste resulting from the clearing was not shredded on the project site, but transported and stored on another piece of land belonging to the developer, where it was deposited in an unauthorized landfill, outside of any regulatory framework.

This failure constitutes a clear violation of the prescribed environmental measures, even though these were a condition for the acceptability of the project during the construction phase. It reveals a clear discrepancy between the commitments formally made by the project owner in the impact study file and the practices actually implemented on the ground. Such a situation is likely to raise serious doubts about the sincerity of the project owner’s statements and commitments, as well as its actual ability to comply with all the requirements attached to the authorizations obtained.

Beyond the direct damage to the environment, this non-compliance weakens the overall reliability of the impact prevention and reduction measures presented in the impact study and undermines the confidence that the administration and the public can legitimately place in the project owner with regard to future compliance with the project’s operating conditions. This shortcoming is likely to be a determining factor in assessing the legality of the authorizations issued and may justify increased monitoring or even administrative or legal action.

Conclusions

It is important to note in conclusion that, based on the information submitted for public review, the project appears to be significantly lacking in its consideration of socio-economic and commercial impacts, which are nevertheless crucial given the scale of the proposed facility and its location within a modest-sized urban center.

The lack of a serious analysis of the project’s effects on local businesses, local employment, and the commercial balance of Maharepa, combined with the absence of any consideration of urban coherence with the existing shopping center, does not allow either the public or the competent authority to fully appreciate the real consequences of this operation on the organization and vitality of the urban center.

Such a shortcoming is likely to characterize an insufficient impact study, which could undermine the legality of the building permit issued.

The President,
Rahiti Buchin