Draft CRZ 2018: a suicidal proposal

Since 1991, human activity along Indian coasts is/has been under the tutelage of Coastal Regulation Zone (CRZ) laws, enacted specifically “to ensure livelihood security to the fisher communities and other local communities, living in the coastal areas, to conserve and protect coastal stretches, its unique environment and its marine area and to promote development through sustainable manner based on scientific principles taking into account the dangers of natural hazards in the coastal areas, sea level rise due to global warming….”. A revised notification issued in 2011 forms the prevailing laws that govern human activities along the seafront. Although with minor deficiencies, the guidelines of 1991 and 2011 largely guaranteed the ecological health of Indian coasts. By ignoring the essence and scientific value of CRZ instrument, the environment authorities have chosen to issue yet another draft which, if adopted, will definitely prove suicidal to our coasts.
We have reiterated time and again and also published research findings about the geological significance of frontal beach-dune systems that face the mighty ocean. Well preserved pioneer dunes with associated vegetation performed exceedingly well in the wake of the tsunami of 2004. In comparison, built-up coasts of Tamil Nadu suffered severe damage. Sandy systems are most vulnerable to any interference as the impacts can be dramatic. Hence we keep insisting that considering the natural buffer capacity of coastal ecosystems, these geomorphic features need to be left untouched, and restored wherever landscape damage is identified.
The draft CRZ 2018 has indeed listed ecologically sensitive areas (ESAs); sadly, sand dunes are placed third. The draft CRZ also has a separate section on conservation, protection and management frame work for ESAs described in the annexure I but not discussed in the main text. Mangroves which colonize any available substrate and thus proliferate easily are given excessive importance in Part 1.1, whereas, the fragile sand dunes are featured at Part 1.9 as geomorphologically important (and not ecologically sensitive) zones. Part 1.9 (i) stipulates that “sand dunes identified shall be conserved and protected”; Part 1.9(b) notes that “no developmental activities be permissible except for providing eco-friendly temporary tourism facilities on stilts such as walkways, tents and the like”; but strangely, Part 1.9(d) warns that “no activities on the sand dunes shall be taken up that would lead to erosion/destruction of sand dunes”. Further, Section 4(ix) of the draft “prohibits dressing or altering active sand dunes”. In contrast, Section 5.3(g) dealing with regulation of activities in NDZ states that “temporary tourism facilities shall be permissible in the NDZ of CRZ-III. 
Can shacks, tents, toilets or change rooms placed on unconsolidated sand not lead to (dune trampling, flattening and) its destruction? How can fragile dunes survive under such pressures? These discrepancies are some of the many glaringly contradictory statements of the proposed scheme.
The scientific role and functions of stable coasts are established globally. Our research has demonstrated what can be expected if habitations are located in vulnerable zones, dangerously close to the shoreline. Virulent waves of the tsunami that pounded the Indian east coast in December 2004 and the recurring storm surges that ravage Indian coasts, have taught us grave lessons. But shockingly, the CRZ III has been subdivided. Densely populated CRZ-III areas, where the population density is more than 2161 per sq. km as per 2011 census, is sought to be designated as CRZ IIIA. Here, the area up to 50 metres from the HTL on the landward side is proposed as the No Development Zone (NDZ). In areas with population density of less than 2161 per sq. km, designated as CRZ IIIB, the NDZ will retain the setback of 200 metres from HTL. If applied in Goa, several coastal segments, and probably the entire strip from Baga to Sinquerim will qualify for a 50 m setback. How will the boundaries of a populated area be demarcated? Who will mark such a zigzag line? What will be the repercussions of multiple CRZ zoning? In a crowded area, should the number of habitations increase or decrease? As such, adopting a population density of 2161 has no justification and the proposal to reduce NDZ from 200m to 50m is arbitrary and lacks scientific backing.
A detailed analysis of the draft 2018 notification is beyond the scope of this article. The existing deficiencies in CRZ 2011 such as guaranteeing the health and biodiversity of coastal vegetation in the form of coastal shelter belts are not addressed. The setback of 50 metres for rivers is bound to convert river banks into urbanised areas. Goa no longer enjoys the special CRZ category status. Instead of strengthening the existing instrument, the guidelines are sought to be diluted. 
In summary, the draft CRZ 2018 completely overrides coastal ecological principles in favour of commercial activities. The proposal invokes sand dunes only 11 times, whereas mangroves are noted 28 times, indicating that stress is laid on a system that is expanding and not under threat as compared to frontal vulnerable sand dunes which are being eliminated rapidly. But surprisingly, although conservation appears 17 times, the term restoration is not found. The utility of coastal forests along with the need for soft remedial measures of beach management is evaded. It is obvious that the ecological rejuvenation of degraded systems, in particular the sandy coasts under assault as is the case in Goa, is given zero priority. It would be worthwhile if this commercially-oriented document is withdrawn; if this draft becomes a reality, the coast of Goa in particular, is bound to come under harm’s way.
(Dr Antonio Mascarenhas is a former scientist, NIO, Goa; ex-member, GCZMA)

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