1 All those villages that prepared their own CZMPs and were supported in this by the Environment Minister, are with egg on their faces, since none of those CZMPs taken into account.
2 The casual approach to the khazan problem is manifest. The (government appointed panel led by) Simon D'Souza’s report on Khazan (Management) is physically attached to the CZMP, but its recommendations do not show in the draft CZMP.
3 Similarly with the Simon D'Souza reports on the fishing community and on the mangroves. What was the purpose of setting up those committees if their inputs are not taken into consideration? This is a repeat of what happened with (1) above.
4 The CZMP draft itself is 46 pages. The total report is 299 pages. The bulk of the report is made up of the three reports.
5 Government/GCZMA was to prepare this plan within 24 months of the CRZ notification of 1991. The plans were to be ready by January 2013. They have only been produced right now in a hurry because of some NGT deadline to complete which the Goa government has repeatedly breached. The effort, right now is to push and get it done with. Citizens have to study the following within one month.
a) 16 large maps at a scale of 1:25,000 (entire CRZ carved into 16 panels)
b) 254 panels of maps at a scale of 1:4,000 (entire CRZ carved into 254 maps)
c) The CRZ covers 178 villages and 8 MMCs and 10 talukas.
6Expecting citizens and poorly endowed NGOs to process all this information in a month is bad governance. Worse, several maps not uploaded. Earlier this week, the CZMP site itself was dysfunctional. Mamlatdar of Tiswadi has produced for inspection, files given to him in 2019 (these are the old and non- updated files and are not the present files). All that we are saying is, do not take us for granted, we have legal rights. Get your information correctly uploaded and then fix the date for the public hearing. You have delayed it for ten years, not the public. Now you want the public to decide in one month.
And the plans are full of errors
A Primary problem: Sand dunes are now shown as patches across the beach areas, when they were continuous ridges. NIO plans have not been used for data. Sand dunes in patches do not have any ecological significance. There is no sand dune restoration plan. This is primarily because the Goa government and GCZMA have been routinely approving projects on sand dunes, and NCSCM is located in Chennai and therefore unfamiliar with the Goan sand dune systems and sand dune fields.
BOn Friday, it emerged in Benaulim that fishing wards are shown outside the CRZ. This is ridiculous. Anyway, how come fishing villages are now reduced to fishing wards? The notification requires you to demarcate fishing villages.
CSome constructions in CRZ areas are shown, some not. Either all constructions are shown or none should be shown. How come illegal constructions are showing whereas legal ones are not shown? This means NCSCM was approachable to influential CRZ violators. Someone should file criminal charges.
DThere is neither a mangrove restoration or management plant nor a khazan management and restoration plan. Mangroves, sand dunes and khazans are our primary ecosystem assets in Goa. A plan which does not handle these for the future is a failure. Therefore it can be called an obituary and not a plan.
EThe entire reason why the Goa government went to Delhi to get the High Tide Line (HTL) changed for the khazan areas is now infructuous, as mangroves shown within the khazans are still shown as CRZ1A. The HTL is now marked along the bunds but the khazan mangroves are marked as per the unchanged notification.
FThere is no evidence that the GCZMA has approved these draft plans. They were received in January 2021 and put up for notification on 27.1.2021. Now they want the public to also approve as a matter of formality. But people will have to own responsibility for this plan and all its defects.
(As submitted by Claude Alvares to Karsten Miranda)