Suggestions/objections/comments on the draft Coastal Zone Management Plan (CZMP) by Mahesh Pandya of Paryavaran Mitra, Ahmedabad, to the member secretary, Gujarat Pollution Control Board (GPCB), Gandhinagar:
This is in reference to the Notification No. S.O. 19(E) dated 6th January 2011 issued by the Ministry of Environment, Forest and Climate Change (MoEF&CC, Government of India in supersession of CRZ Notification 1991, declaring the designated areas as Coastal Regulation Zone (CRZ). As per the provisions of the CRZ Notification, 2011, the Forests & Environment Department, Government of Gujarat, has been entrusted with the responsibility of preparation of the Coastal Zone Management Plans of the coastal areas of the state through agencies authorized by the MoEF&CC.
The work of preparation of draft CZMPs for all the coastal districts of Gujarat was entrusted to the National Centre for Sustainable Coastal Management (NCSCM),Chennai, which is an authorized agency approved by the Government of India, for the said purpose, vide MoEF&CC. Accordingly ,the Coastal Zone Management Plans of districts of Gujarat has been prepared by NCSCM.
Firstly, we would like to seek your attention to poor communication and misleading information about public hearing schedule on THIS link. We encountered following problems:
- Schedule and executive summary of the public hearing on GPCB website are given under the information section. Although we regularly visit the GPCB website for environmental public hearing purpose, we had great difficulty finding in information about CZMP public hearing on the website. Please justify.
- We have gone through the executive summary and noticed that at the end of the English executive summary of each district there was information about public hearing by the Gujarat Ecology Commission (GEC), which mentioned that “The draft CZMP maps and the Executive Summary, CRZ Notification 2011 (in English and Gujarati languages) are kept at the following offices falling within the jurisdiction of Anand district, for public verification/notice.” Here, it only mentions the office of only one district, keeping two others blank (the screenshot of it is given below). Please justify.
- It is also mentioned in the executive summary that “suggestions/ objections/ comments received after the due date and time, either by post or by email (5 pm on 20th August 2018) will not be considered.” The public hearing is scheduled from 3rd of August to 5th of September 2018, then why are the comments restricted to 20th August, giving only 17 days for review to stakeholders for submitting comments? Please justify.
After seeing the above issues we have reason to doubt about GEC and would like to ask about the role of GEC in making of CZMP maps. Also, will you please provide letter which authorizes GEC for its role in CZMP?
We have gone through the executive summary and would like to submit following comments/suggestions:
- There are issues related to the edge matching between two subsequent maps (top and bottom/right and left) because of which there is a loss of information of the area in those regions.
- There is no mention of the villages’ names in the maps because of which it becomes difficult for the villagers or common people to identify their plots in particular maps. Hence, they cannot comply with the deadline provided by NCSCM.
- There are terms in the NCSCM maps, like active mudflats. There is no clarification or definition of mudflats or active mudflats. It is requested to provide the definition of all the terms mentioned in the NCSCM maps in a separate annexure, so that there does not remain any doubt about them. This would also eliminate any possibilities of misusing the terms.
- There are other government agencies, which have already prepared maps of various regions. It has been found that there are differences between the map prepared by these agencies and the NCSCM map. Since they are prepared with detailed field survey and at 1:4000 scale, which is the required format for clearance, would these not be given priority by NCSCM?
- It is also requested to clarify on the procedure that has been followed by NCSCM for preparing the maps, in particular, to the level of field verification done by NCSCM for mapping and identifying HTL and LTL.
- What would be the procedure to resolve the dispute once the deadline of providing the feedback or after any kind of public hearing gets over in cases of discrepancy in maps with respect to the real scenarios found by the locals/ stakeholders in a later stages?
- As per the CRZ Notification 2011, Clause 4.2 “Procedure for clearance of permissible activities” the stakeholder are required to provide the maps at the scale of 1:4000. As per the guidelines for preparation of Coastal Zone Management Plans “Annexure 1”, the maps that are provided by NCSCM are on the scale of 1:25000, which would be useful for macro level planning, especially useful for HTL and LTL demarcation. When would be the maps at 1:10000 and 1:4000 available for micro planning and village level mapping for the use by local and/or local government authorities?
- Will there be public hearing for the maps of 1:4000 scale in case if they are going to be published?
- There is already a draft notification of 2018 for CRZ, which may soon get clearance. Since it has not been published, it may not be possible comment much on it. Kindly inform us whether maps will comply with all the clauses and terminologies of the 2018 Notification. This is important, as the next official update can only be after five years from the first publications as per the current notification. One may note that the term like “Biologically Active Mudflats” has been used in the 2018 draft CRZ notification, while NCSCM has used the term “Mudflats-1A”. There is no official definition published either for Biologically Active Mudflats or for Mudflats-1A.
- Will the stakeholders have to go for a separate CRZ survey from one of the approved CRZ agencies for detailed mapping of their plots at 1:4000 scale as per the requirement of the current notification of 2011 or draft notification of 2018 even after the publication of the NCSCM maps?