Nine Goan associations say the draft must be discarded completely and the entire process should be re-started to improve the State’s environment protection
Team Herald
Voluntary Associations of Goa (VAG), Margao – a combination of nine different organizations – has slammed the Draft CRZ Notification saying the changes proposed are regressive and against the public interest, and that this Draft Notification blatantly violates the principles of legislation, logic and science.
In a letter to Director, Ministry of Environment, Forest and Climate Change, New Delhi, the VAG — consisting of Goencho Avaz, Our Rivers Our Rights, Goa Against Coal, Federation of Rainbow Warriors, Goenkarancho Avaaz. Revolutionary Goans Loliem, Citizens Committee, Poinguinkarancho Ekvott and Curtorkarancho Ekvott says this Draft Notification and the procedure followed while preparing the Draft must be rejected completely and the process started afresh, if our National Interests are to be upheld and safeguarded.
“The Draft CRZ Notification 2018 is full of deregulations and diminutions of environmental legislation, without any regard to the Principle of Non-Regression,” it says.
Further the letter reads, “In view of the total failure to adhere to this basic Principle, the Draft Notification has been prepared with changes that are exactly opposite to what is necessary, thus losing the plot completely and placing the entire nation on the path to socio-economic and environmental disaster.”
It is therefore necessary, it continues, that the Draft CRZ Notification 2018 must be discarded completely and the entire process be started again with the sole objective to increase and improve the environmental protection.
VAG says before preparing the Draft CRZ Notification 2018, all of these people should have been consulted regarding the implementation and performance of the CRZ Notification 2011 and the issues faced by the local communities and the coastal environment in order to understand the successes and failures of the past, as well as the needs for the future.
“The concerns raised repeatedly by Civil Society, local fisher folk, environmental groups and concerned citizens in the past have never been addressed,” it says.
Moreover, it says, the Draft Notification should have been preceded by preparation of the CZMPs, collection of data on the status of the coastal environment, detailed descriptions of the issues faced by the Coastal Zone Management Authorities (CZMAs) of various States and MOEF&CC in the implementation of the CRZ Notifications, collection of the experiences of the local communities, scientific studies, including local impact of sea level rise and occurrence of extreme natural events in each locality, assuming the worst-case scenario.
“…the Draft Notification is arbitrarily and blindly catering to a few vested interests, namely the same profit seeking ventures and industries that cause the environmental destruction which the law aims to curb and regulate,” it alleges.
Further, the letter reads, the fact that despite the implementation of CRZ Notification 1991 and 2011 the objectives have not been met and the situation is only getting worse, it is simple common sense that any changes to the CRZ Notification must be to strengthen and increase the regulations and restrictions.
“The CRZ areas of tidal influenced water bodies have been reduced to 50m from the 100m that the 2011 notification prescribes. The CRZ notification 1991 that preceded the 2011 notification mandated a 500m buffer. These changes are against the basic principles of law-making, as explained in previous paragraphs,” VAG says.
It adds, with ever expanding cities and municipal limits, this could be a way to promote get-rich-quick coastal real estate schemes even while home-buyers and other buyers of such developed realty will be harmed by natural disasters.
“The draft CRZ 2018 notification plays into the coastal tourism agenda of the government by permitting the development of year-round tourism facilities in all coastal states. The intent of the government to shift coastal areas from being livelihood spaces of the fishers and safety buffers for the inland to recreational space for the rich is evident and ill-advised,” it says.
It further says, the environmental impact of the draft will be significantly negative, especially since the draft permits encroachment of water areas and intertidal areas along the sea and in estuaries and creek without any understanding of its overall impact on coastal surface water or groundwater hydrologies, biodiversity, fishery habitats and resources or the fisheries economy.
VAG has further demanded that the draft notification should make it absolutely clear that the base line date should remain as February 19, 1991 for the purpose of determining the various categories of CRZ I, II, III & IV.
It further demands that violations of CRZ 1991 and 2011 to be prosecuted and restoration of areas destroyed by violations.
VAG also demanded that no further projects of commercial tourism, industries, ports, roads, highways, railways, etc may be allowed within the CRZ in the future.
“If the Government finds a public interest project to essentially require land within the CRZ, such a project may be allowed only after receiving Free, Prior, Informed Consent from the local communities,” it adds.

