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From: [EMAIL PROTECTED]

Dear friends,
In response to the call of National Fishworkers Forum(NFF), Kerala
Swathanthra Malsyathozhilaly Federation (KSMTF) is organizing the
protest against SEZs& CMZ (Dr.Swaminathan Committee recommendation) on
5th June 2007 at AG's office, Trivandrum at 2pm. The dharna will be
inaugurated by Smt.Medha Patker, the leader of NBA& NAPM.
We request you to collaborate and support the event.

In solidarity,
T.Peter, KSMTF

Background on CMZ
=================

 MoEF is issued a Draft Notification on Costal Management Zones.
 It will replace the CRZ notification of 1991 and will open a
floodgate of  loot in the coastal zone and the territorial waters and
destroy they coastal communities and environment. I am pasting bellow
some reflections on the proposed notification. The full text of the
Swaminathan Committee Report can be downloaded from the MoEF website
http://envfor.nic.in/mef/crz_report.doc  or
http://envfor.nic.in/mef/crz_report.pdf



Comments on CMZ

(A). V.Vivekanandan

 Though based on the internationally accepted concept of integrated
coastal area management (ICAM), the Swaminathan recommendations will
create problems in India where the state is itself keen on diluting many
of the CRZ provisions. The following are some of our main criticisms of
the MOEF trying to introduce CMZ based on the Swaminathan Committee
report.

1. The Committee report is only a starting point for a debate on how to
manage the coastal zone and cannot be the basis for a new legislation
immediately. In fact the committee itself seems to suggest this.

2. The committee report is based on inputs from many stakeholders, but the
most important stakeholders, the fishermen who live on the coast and who
depend the most on coastal resources, have not been consulted at all. The
Chairman himself had suggested this but the MoEF had not facilitated the
participation of the fishermen leaders in any of the meetings. So, the
process is questionable.

3. There are many points in the report that only give the basic concept or
idea but one is unable to comment without getting more details. One such
point is the development of a vulnerability/hazard line. How this will be
precisely fixed and who will fix it is not very clear. This will decide
the no-development zone as well as the restricted development zone.

4. The inclusion of the territorial waters (upto 12 nautical miles) in the
coastal zone has been done without much explanation and is very confusing.
How this will affect the classification and implementation of the CMZ is
not clear. For instance, if there is a mangrove in on the shore, and the
area is designated CMZ I, will the sea area upto 12 nautical miles be also
subject to CMZ I regulations? If there is a coral reef in the sea, will
the land portion be also designated CMZ I? What will be rules governing
fishing in the CMZ I, II, III and IV? Given that fish resources are
mobile, how can fish resources be managed by a Panchayat or municipality
with a narrow coastline? Our fear is that the sea upto 12 nautical miles
has been included so that the local body will have the powers to give
license for extracting of non living resources like sand and minerals to
private parties.

5. While the logic of decentralisation and local resource management is
good, it seems doubtful that Panchayats and Municipal Corporations can be
straight away given these responsibilities. The experience so far in CRZ
implementation, it is the local bodies that collude with vested interests
and allow the illegal use of coastal resources. It is a high risk to
straight away make this radical change. We suggest that pilot projects be
run in all the states to demonstrate the CMZ concept before it is made
into a national legislation covering the entire 8600 km coast of India.

6.  The introduction of the CMZ is likely to be lead to a condoning of the
past CRZ violations. This is completely unacceptable.

7. Another issue is that of departmental/ministerial jurisdictions. CMZ
requires an interdisciplinary effort and cooperation across ministries and
between the Centre and the State. The MOEF is not the only agency involved
in the coast and is probably not the best agency to take up the
responsibility to manage the coast. MOEF is largely the offshoot of the
Forest Dept and the wildlife protection act. For instance, it is the Water
Resources Ministry that is responsible for coastal protection (sea walls,
etc.). The fisheries department, which is probably the entity that deals
with fishermen, the key stakeholders on the coast, is nowhere in the
picture and has not been consulted at all. At state level the MOEF deals
only with the Forest departments and none of the state fisheries or
revenue departments have given any feedback on the Swaminathan Committee
report.

In view of the above, it is better that CRZ implementation is strengthened
and pilot projects to develop and demonstrate integrated coastal zone
management are taken up. We also suggest that the MoEF bring out a policy
note on the CMZ rather than say that it is bringing out a notification
based on the Swaminathan Committee. Based on the policy note, the MoEF
should conduct consultations across the country with all stakeholders
before taking any decision on the CMZ notification. There is very little
trust in the MoEF which acts arbitrarily and its positions are often
violently contradictory and is subject to pressures from the environmental
groups on one side and corporate sector on the other.





(B) Chandrika Sharma



I have had a quick look through the draft. The same concerns, as for the
earlier draft, apply. There is unlikely that any action on post-1991
violations will be taken.

Though the objective of the new Notification mentions the need to take
into account the sustainable livelihoods of local communities, this is not
reflected in any way in the rest of the Notification.

In CMZ-I, it is likely that there will be severe restrictions on
fishing, now that the 0-12 mile zone will be part of the coastal zone.

CMZ-II is clearly a concession to commercial interests, and with the new
provision that if appropriate coastal protection structures are in place,
development on the seaward side of the setback line will be allowed, there
is all likelihood of SEZs, tourism resorts etc., coming up right on the
coast. No mention of EIAs.

What is very disturbing is that there is no representative of the Ministry
of Agriculture in the proposed National Board for Sustainable Coastal Zone
Management. Very strange, given that now the 0-12 mile zone is also under
the coastal zone. This will have major implications. Also, none of the
experts to be on the board, are from fisheries.

Some concerted action to highlight key concerns is clearly needed.





Dear Medhaji,
I am sending you the draft notification that the MoEF is all set to
notify soon. It will replace the CRZ notification of 1991 and will open
a floodgate of  loot in the coastal zone and the territorial waters and
destroy they coastal communities and environment. I am pasting bellow
some reflections on the proposed notification. The draft and our earlier
protest letter is in attachment. The full text of the Swaminathan
Committee Report can be downloaded from the MoEF website
http://envfor.nic.in/mef/crz_report.doc  or
http://envfor.nic.in/mef/crz_report.pdf

Regards
Harekrishna Debnath


Comments on CMZ

(A). V.Vivekanandan

 Though based on the internationally accepted concept of integrated
coastal area management (ICAM), the Swaminathan recommendations will
create problems in India where the state is itself keen on diluting many
of the CRZ provisions. The following are some of our main criticisms of
the MOEF trying to introduce CMZ based on the Swaminathan Committee report.

1. The Committee report is only a starting point for a debate on how to
manage the coastal zone and cannot be the basis for a new legislation
immediately. In fact the committee itself seems to suggest this.

2. The committee report is based on inputs from many stakeholders, but
the most important stakeholders, the fishermen who live on the coast and
who depend the most on coastal resources, have not been consulted at
all. The Chairman himself had suggested this but the MoEF had not
facilitated the participation of the fishermen leaders in any of the
meetings. So, the process is questionable.

3. There are many points in the report that only give the basic concept
or idea but one is unable to comment without getting more details. One
such point is the development of a vulnerability/hazard line. How this
will be precisely fixed and who will fix it is not very clear. This will
decide the no-development zone as well as the restricted development zone.

4. The inclusion of the territorial waters (upto 12 nautical miles) in
the coastal zone has been done without much explanation and is very
confusing. How this will affect the classification and implementation of
the CMZ is not clear. For instance, if there is a mangrove in on the
shore, and the area is designated CMZ I, will the sea area upto 12
nautical miles be also subject to CMZ I regulations? If there is a coral
reef in the sea, will the land portion be also designated CMZ I? What
will be rules governing fishing in the CMZ I, II, III and IV? Given that
fish resources are mobile, how can fish resources be managed by a
Panchayat or municipality with a narrow coastline? Our fear is that the
sea upto 12 nautical miles has been included so that the local body will
have the powers to give license for extracting of non living resources
like sand and minerals to private parties.

5. While the logic of decentralisation and local resource management is
good, it seems doubtful that Panchayats and Municipal Corporations can
be straight away given these responsibilities. The experience so far in
CRZ implementation, it is the local bodies that collude with vested
interests and allow the illegal use of coastal resources. It is a high
risk to straight away make this radical change. We suggest that pilot
projects be run in all the states to demonstrate the CMZ concept before
it is made into a national legislation covering the entire 8600 km coast
of India.

6.  The introduction of the CMZ is likely to be lead to a condoning of
the past CRZ violations. This is completely unacceptable.

7. Another issue is that of departmental/ministerial jurisdictions. CMZ
requires an interdisciplinary effort and cooperation across ministries
and between the Centre and the State. The MOEF is not the only agency
involved in the coast and is probably not the best agency to take up the
responsibility to manage the coast. MOEF is largely the offshoot of the
Forest Dept and the wildlife protection act. For instance, it is the
Water Resources Ministry that is responsible for coastal protection (sea
walls, etc.). The fisheries department, which is probably the entity
that deals with fishermen, the key stakeholders on the coast, is nowhere
in the picture and has not been consulted at all. At state level the
MOEF deals only with the Forest departments and none of the state
fisheries or revenue departments have given any feedback on the
Swaminathan Committee report.

In view of the above, it is better that CRZ implementation is
strengthened and pilot projects to develop and demonstrate integrated
coastal zone management are taken up. We also suggest that the MoEF
bring out a policy note on the CMZ rather than say that it is bringing
out a notification based on the Swaminathan Committee. Based on the
policy note, the MoEF should conduct consultations across the country
with all stakeholders before taking any decision on the CMZ
notification. There is very little trust in the MoEF which acts
arbitrarily and its positions are often violently contradictory and is
subject to pressures from the environmental groups on one side and
corporate sector on the other.





(B) Chandrika Sharma



I have had a quick look through the draft. The same concerns, as for the
earlier draft, apply. There is unlikely that any action on post-1991
violations will be taken.

Though the objective of the new Notification mentions the need to take
into account the sustainable livelihoods of local communities, this is
not reflected in any way in the rest of the Notification.

In CMZ-I, it is likely that there will be severe restrictions on
fishing, now that the 0-12 mile zone will be part of the coastal zone.

CMZ-II is clearly a concession to commercial interests, and with the new
provision that if appropriate coastal protection structures are in
place, development on the seaward side of the setback line will be
allowed, there is all likelihood of SEZs, tourism resorts etc., coming
up right on the coast. No mention of EIAs.

What is very disturbing is that there is no representative of the
Ministry of Agriculture in the proposed National Board for Sustainable
Coastal Zone Management. Very strange, given that now the 0-12 mile zone
is also under the coastal zone. This will have major implications. Also,
none of the experts to be on the board, are from fisheries.

Some concerted action to highlight key concerns is clearly needed.
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