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Gujarat Pollution Contro! Board Regional Office Sardar Patel Commercial Complex, Rameshwarnagar, Bedi Bandar Road, -361 008. Website : www.gpcb.gov.in

PUBLIC HEARING PROCEEDINGS

As per provisions of CRZ Notification 2011, every coastal State Government/SCZMIA has to prepare the State Coastal Zone Management Plan for their respective State in accordance with the guidelines and procedures laid down there under. The State Government in Forest and Environment Department has entrusted the work for preparation of coastal Zone lvlanagement Plan for through Gujarat Ecology Commission. Now the National Center for Sustainable Coastal Management (NCSCM), has prepared and submitted draft plan for Devbhumi District. As per the provisions of CRZ Notification, 20'l 1, the draft CZMPs should be submitted by the State Government for approval of the MOEFCC, GOI should also include appropriate consultations, in accordance with procedure(s) laid down in the E(P) Act, 1986. Accordingly, the Gujarat Pollution Control Board has been requested to conduct public consultation for Draft Coastal Zone Management Plan (CZMP), for Villages of Costal area of Kalyanpur, Khambhaliya. and okhamandal ralukas of Dev Bhumi Dwarka District. The public Hearing is being held on 3rd August 2018 at 1 1 :00 hrs, at Heerbai Mepabha Manek Memorial community hall Vrajdham Society, near Microstation, Dwarka, Ta: Dwarka, Dist. Devbhumi Dwarka. The list of participants present during the public hearing; as mentioned in their request appllcation received.

A copy of the Draft Environment Impact Assessment Report and the Summary of Environment Impact Assessment Report were sent to the following authorities and offices to make available the draft EIA Report for the inspection 1o the public during normal office hours, till the Public Hearing is over:

1. The District Collector Office, Devbhumi Dwarka. 2. District Development Office, Devbhumi Dwarka. 3. District Industry Centre, Devbhumi Dwarka. 4. Taluka Development Offices, Ta. : Kalyanpur/Khambhaliya /Okha ma nda l( Dwa rka ), Dist. Devbhumi Dwarka 5. The Chief Conservator of Forests, Ministry of Environment, Forests & Climate Change, GOI, Regional Office (West Zone), Kendriya Paryavaran Bhavan, E-5, Arera Colony, Link Road-3, Ravisankar Colony, Bhopal-462016. 6. Regional Office, Gujarat Pollution Control Board, Sardar patel Commercial Complex, Rameshwarnagar, Kasturba Gandhi Vikas Gruh Marg, Bedi Bandar Road, Jamnagar-368008. Talati cum Mantri/Sarpanch offices of following Villages. 7. (a) Village :- Gaga, Gurgadh, , Asota mota, pindara, Virpur - Ta. Kalyanpur Dist. Devbhumi Dwarka (b) Village :- Ajad Tapu, Beh, Bharana, Charabara, Chudeshvar, Goinj, Kalawad Simani. Kalubhar Tapu, Mota Ambla, Mota Mandha, Nana Ambla,Nana Ashota, Nana Mandha, Parodiya, Salaya (M), , Zakasiya - Ta. Khambhaliya Dist. Devbhumi Dwarka (c) Village :- (CT), Baradia, Beyt, Bhimrana, Dwarka (M), Gorinja, Hamusar, Khatumba, Kuranga, Mojap, Okhamadhi, Nani Dhrevad, Padli, Positra, Shamlasar, Shivrajpur, Vachhu, Varvala, Adatra Ta.- Okhamandal Dlst. Devbhumi Dwarka tle

Other concerned persons having plausible stake in the environmental aspects were requested to send their response in writing to the concerned regulatory authorities. They were requested to send their comments to the regulatory a uthorities as above.

The Public Hearing is being held on 03th August 2018 at 11:00 hrs, at Heerbai Mepabha Manek Memorial community hall Vrajdham Society, near Microstatlon, Dwarka, Ta: Dwarka, Dist: Devbhumi Dwarka.

An advertisement in Gujarati was published in "Gujarat Samachar" dtd. 28.06.2018 and in English was published in the "The n Express" dtd. 28.06.2018.

Shri J.R.Dodiya, IAS, District Collecter & District Magistrate, Devbhumi Dwarka, supervised and presided over the entire public hearing process.

A statement showing participants present during the Public Hearing is enclosed as Annexure A.

A statement showing salient points highlighting issues raised by the participants and responded by the representative of the applicant during the Public Hearing in English and Gujarati Languages is enclosed herewith as Annexure B and 81 respectively, along with the proceedings of the hearing.

The Copy of response received in writing from other person having plausible stake in environmental aspects is enclosed herewith as Annexure C, The said representations sent to GEC for reply on same day and as per discussion with the officer of GEC, above representations received will be sent to NCSCNl Chennai for necessary verification and incorporation based on the scientific and technical scrutinity. On the outcome of the study, necessary reply will be given to the concerned applicants.

Place: Dwarka . S utrej a J,R.Dodiya, IAS Dist,: Devbhumi Dwarka Regiona! Officer, Collector Date: O3l08/201a GPCB Jamnagar & as Representative of the District Magistrate Member Secretary, GPCB Devbhumi Dwarka

Encl.: l.Annexure A, B, 81, and C as above. 2. Video CD of Public Hearing - 2 CDs 5ttr

ANNEXURE - B (Enq|ish)

As per provisions of CRZ Notification 2011, every coastal State GovernmenUSCZMA has to prepare the State Coastal Zone Management Plan for their respective State in accordance with the guidelines and procedures laid down there under. The State Government in Forest and Envlronment Department has entrusted the work for preparation of coastal Zone Management Plan for Gujarat through Gujarat Ecology Commission. Now the National Center for Sustainable Coastal Management (NCSCM), Chennai has prepared Draft Map and submitted draft plan for Dev Bhumi Dwarka District. As per the provisions of CRZ NotiFication-2011, the draft CZMPs should be submitted by the State Government for approval of the MOEF& Climate Change, GOI should also include appropriate consultations, in accordance with procedure(s) laid down in the E(P) Act. 1986. Accordingly, the Gujarat Pollution Control Board has been requested to conduct public consultation for Draft Coastal Zone Management Plan (CZMP). For Villages of Coastal area of Kalyanpur, Khambhaliya. and Okhamandal Talukas of Dev Bhumi Dwarka District. The Public Hearing is being held on 3rd August 2018 at 11:00 hrs, at Heerbai Mepabha Manek Memorial community hall, Vrajdham Society, near Microstation, Dwarka, Ta: Dwarka, Dist: Dev Bhuml Dwarka under the Chairmanship of Shri J.R. Dodiya, Collector and District Magistrate.

Shri B. G. Sutreja, Regional officer, Gujarat Pollution control Board (GPCB), Jamnagar and representative of Gujarat Pollution Control Board, welcomed all present at the public hearing. He outlined the various provisions of the Notification dated 14.09.2006 and briefed the procedural details for conducting this Public Hearing including actions taken by Gujarat Pollution Control Board for wide publicity of this public hearing and also about the advertisement given earlier in the local Gujarati newspaper "Gujarat Samachar" dated 28th June 2018 and English newspaper "The Indian Express" dated 28th June 2018. He informed that the Executive summary of said project is distributed to the 43 villages situated Kalyanpur/Khambhaliya /Okhamandal Talukas of Devbhumi Dwarka. In Addition, he informed that one written representation was received from Dr. Shweta Bhatt, Conservation Action Trust, prior to the Public Hearing, which is enclosed as Annexure C-1 along with its reply submitted by the Gujarat Ecology Commission as Annexure D- 1.

Shri B. G. Sutreja, Regional officer, Gujarat Pollution control Board, Jamnagar and representative of Gujarat Pollution Control Board with due permission of Collector and District Magistrate, Invited the Project Proponent to deliver the presentation of their project in vernacular language i.e. in .

Then after, Shri Nischal Joshi, Technical Advisor & Representative of Gujarat Ecology Commission, on behalf of project proponent presented power point presentation in Gujarati language covering detail description of the Coastal Zone Management Plan with details and Survey regarding CRZ I, II, III & IV. t/c

After the completion of power point presentation, Shri B. G. Sutreja, Regional Officer Gujarat Pollution Control Board Jamnagar and representative of Gujarat Pollution Control Board declared the forum open for representations/suggestions/issues from the local public with due permission of Collector and District Magistrate.

The statement showing representation s/suggestions/issues raised by the participants and responded by the representatives of the applicant during the public hearing are as under:

Sr. Name and Point Represented Replies given by Project No. Address Proponent/ Com petent Officer 1 Shri J.R. Dodiya If any Survey No. falls under both If it is not Ecological Collector & CRZ-IA and CRZ-IB then which sensitive Area then CRZ-IB District one to be consider first? is to be consider and also I\4agistrate in that case approval is Dist. Devbhumi given to only permissible Dwarka activity, If any Authorized structure is esta blished before 2017, then the project can be started after getting necessary permission towards the land area of structu re. 2 Shri Usman Gani Applicant introd uced himself Regional Officer informed Husenbhai before starting his views. that as per EIA Notification Serasiya 2006, those who are not (National affected due to this project Fishworkers can submit their objections Fourm) in writing only. But the Village: Kankot presenter informed that he Ta. Wakaner is representing the Dist: fishermen of Dwarka District hence, with due permission of collector objections are permitted.

1. If we talk technically, 28 parts 1. Maps are uploaded in of map have been done which 28 parts. According to people of the village cannot the CRZ notification, understand it hence; explain this map is prepared in this map to people of village. scale of 1:25000 but And also upload the same on after getting approval the web site as taluka wise. the said map will be uploaded in the scale of 1:4000. lle

Sr. Name and Point Represented Replies given by Project No. Address Proponent/ Competent Officer 2. This map are Pre-draft maP, 2. A pre-draft map can be Draft Map are not uploaded on considered as a draft the Web site? map because this draft map has been prepa red by the Authorized agency NCSCM, Chennai.

3. Whichever marking is done 3. Your request will be that cannot be understood by considered by NCSCM

any one as a Fisherman. The while preparing the fina I columns displayed in the map map. are in English, English learned people are very less, give it in Gujarati so it is easily understandable and also Map can be submitted with Boat parking.

4. Boat parking in nearbY area of 4. Concerned matter will Okha Ports is not shown in the be put in notice to Map. NCSCM. Shri Ketan As per description in the second There is no any perfect Thakkar, slide of presentation, there is no measurement for I nter Manager any perfect measurement for Tidal area. Some where it (M/s. Bharat Inter tidal area between HTL and may be 10 Meter, 50 Meter Oman Refinery) LTL line and also kindly clarify or 100 meter. All the Village: Vadinar regarding CRZ-IA and CRZ-IB so details of CRZ-I to CRZ-IV Dist: Devbhumi we can think for the expansion of are described in CRZ Dwarka project in future. Notification 2011. In addition, all the cla rifications will be obtained from the Coastal Zone Management Authority. 4 Shri Janardhan Kindly consider our GMB Pindara Consideration of the project Bhatt, Manager Jetty Project of Bombay Minerals is not covered under our (Bombay Limited situated at Survey No. purview. Minerals Limited) lt7lP of Village Virpur. Village: In concerned matter, Khambhalia Applicants shall have to Dist: Devbhumi apply at the MoEF&CC and Dwarka get permission from them. Once the Map will be prepared in the scale of 1: 3960, the map will be lr L

Sr, Name and Poant Represented R.eplies given by Proiect No, Address Proponent/Com petent Officer

c lea r. 5 Shri Yasinbhai 1. The advertisement of this (l/213) Those Ecological Gajjan Public Hearings was not in sensitive area are presently village- appropriate manner and if it not covered in this map can Chairman not in a language of which the be included if you submit in Workers affected people could writing. This map is Committee, understand, then there is no prepared with the help of Devbhu mi meaning of this Public Satellite map. If mangroves Dwarka Hearing. You are requested to area is less than 1000 come again and consider the square meters, then it will suggestions of Fishermen, not be included in once the final draft is Ecological Sensitive Zone prepared. Maximum fishing as per CRZ Notification. activity in Gujarat is carried out in this district. 2. At some places of this District, there is Ecological Sensitive area like mangroves, coral, and turtle. It is not included in this map. 3. Inform to the fishing club, fisherman and the members of the Fishermen Forum, once the final draft is prepared, The Member Secretary of Gujarat Ecology Commission said that executive summary (in gujarati) as well as Copy of advertisement for public hearing in Gujarati and English News Papers was conveyed to Sarpanch / Ialati / Mantri of 42 Villages located near sea coast of one month ago and their signature have been taken as acknowledgement. All the information is given to them in Gujarati language. During Public Hearing, if any suggestion given by you and if it is appropriate then it will be edited in the map. The Collector of Devbhumi Dwarka informed that if any other information of turtle or mangroves area is made available with you and which are not included in this map can be included if such proposal can be present during this day. 6 Shri Sachin Shah The details of our existing Jetty This Map is prepared on the Representative, and Sea Water Intake are not basis of Aerial photography Nayara Energy mentioned in the map Reference in the year of 2011. If your Limited 42-11 (NE). Jetty existed before 2 011, Village: Vadinar then it will be displayed in Dist: Devbhuml appropriate scale of map. Dwarka Moreover, Collector has informed that any authorized structure or Jetty whlch are already established before the year of 2011 is already included in this map. And if any approved or non approved project which are established after 2011, for that the proposal shall be reviewed in the district level committee and the said committee can send the proposal to competent authority. IJ cz

Sr. Name and Point Represented Replies given by Project No. Address Proponent/Com petent officer 7 Shri Aamad 1. Whether the fishermen 1. As per CRZ Notification Harun Bhaya are included in District Every district has to form Village: Salaya Level CRZ Committee? In CRZ committee and in Dist: Devbhumi Gujarat there is a coastal which three fishermen are Dwarka area of 1600 km, so required to be nominated as concerned matter is a member. The CRZ affected to the fishermen. committee of Devbhu mi 2. Any industry which are Dwarka d istrict is already established near sea coast formed but the names of 3 is constructed their jetty fishermen are to be and hence su rrou nd ing nominated. area is declared as non 2/3 It will be informed to fishing zone. NCSCM for displaying of 3. If you are displaying Non Fishing Zone in Coasta I Fishing zone in Map then Zone Management Plan. It is required to display Fishing zone also. Applicant has raised question related to entire Gujarat state, hence the Regional Officer has instructed that since this hearing is only for Devbhumi Dwarka district, you can raise the queries related to Devbhumi Dwarka dlstrict only.

Shri D.M. Joshl, DCF of Devbhumi Dwarka district informed that we have not been informed about the CZMP Public hearing. From now onwards, klndly inform us whenever any Public hearing scheduled related to our department.

District Collector has informed that from now onwards information related to Public Hearing pertaining to your department will be conveyed.

Regional officer, Gujarat Pollution control Board and representative of, Gujarat Pollution Control Board informed to the people those are present in this public hearing about the written representations received during public hearing from (1) Dr. Shweta Bhatt, Conservation Action Trust, Mumbai (2) Shri Usman Gani Husenbhai Serasiya (National Fishworkers Fourm)Village: Kankota. WakanerDist: Morbi (3) Shri P.R. Dixit, Vice president, Nyra Energy Limited (4) Shri P,R. Dhruve, Secretary of The Indian salt Manufacturers Association , (5) shri B.B. Kathapliya, vice president Manufacturing, Tata chemicals, Mithapur (6) Shri Atul sharma, Gujarat Maritime Board, Deputy General Manager (Environment). He also informed that the same is incorporated in the minutes aS Annexure-C1 to Annexure-C6. The said representations sent to GEC for reply on same day and as per discussion with the officer of GEC, above representations received will be sent to NCSCM Chennai for necessary verification and incorporation based on the scientific and technical scrutinity. On the outcome of the study, necessary reply will be given to the concerned applicants' ttlC.

After completion of above representations, Regional officer, Gujarat Pollution control Board and representative of Gujarat Pollution Control Board, again and again requested all participant to give their representation /suggestion, if any' As none of the participant raised any representation in the form of written or verbal, with due permission of the Collector and District Magistrate, the public hearing was concluded with the vote of thanks to the dignitaries and villagers.

Placer Dwarka, Sutreja J.R, Dodiya, IAS Tal: Dwarka Regional Officer, GPCB, Collector and Dist: Devbhumi Dwarka Ja mnaga r District Magistrate Date: O3l08/2018 as representative of the Devbhumi Dwarka GPCB, t7l

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Annexure-A

A statement showing participants present during the puBLrc HEARTNG

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Conservation ACTION TRUST

5, Sahakar Bhavan, lst Floo( LBS Road Narayan Nagar, Ghatkopar (W) Mumbai - 400 086 Phone : (91-22) 2512 2422 I Sfalel?D< : (91'22\ 2512 2a23 2"d August 2018 emell : [email protected]]g.in w€bsit€ : wwwcat-org.in

collector, Dwarka District District Seva Sadan, 1st Floor, Lalpur Bypasi Road, Dharampur, Khambhalia, Gujarat - 361305

Dear 5irs,

Comments on the draft CZMPs of Dwarka district, Gujarat

Please find below the comments and questions pertaining to the draft CZMP maps for Dwarka District. we request you to kindly forward our letter to the Gujarat coastal zone ManaSement Authority and other concerned authorities as per the provisions of the CRZ Notification,20ll and ensure that the queries raised are addressed appropriately

1. The notice for the public hearing has not been uploaded on the GczMA or on the GPCB website or on the Collector's website. 2. The draft czMPs have been uploaded on the GCZMA website without any date of publication or the date of submijsion being mentioned. This is a8ainst the public spirit and defeats the purpose of inviting commehts and suggestions from the public. 3. The draft czMPs for the area of , , Devbhumi Dwarka, Gir somnath, Amreli, , Ahmedabad and Anand districts were also uploaded without any dates being mentioned. Despite repeated calls to the GczMA and our telephonic discussion with Mr. Ashok Chauhan, we were not given the dates for the submission of draft CZMPs of these areas. Finally, during our call on 26s JUne 2018, we were informed that the maps for these areas were uploaded on 6th May 2o18. This lack of clarity and transparency is rather inexplicable and needs to be looked into. The authority should also provide an explanation for such misconduct. 4. The dates and time of the satellite data used for preparing these maps have not been mentioned. It is not known whether the satellite data is during high tide, low tide, or intermediate tide. lt is also not known whether the entire dislricts have been mapped using satellite images of the same day and same time. The mapping agency/authorities may kindly clarify this. 5. Geomorphologica I features Iike beaches, sand dunes, spits, etc. have not been marked in most of the maps. 6. lnmostof the M udflats ICRZ 1A] has bee n erroneously dema rcated as lntertida I Zone CRZ ,.8. ltis important to rectify this. 7. Ma nv of the creeks have not been marked. At places, entire length/extent of the creeks have not been mapped. High Tide tine (HTL). This is erroneous and 8. .E m ba n kments/bu nds/roads have been demarcated.as needs to be rectified, particularly if these have been constructed without valid permissions, or within the inter-tidal zones. ln case the sea wall has been (i.e in the intertidal zone), the land between the seawall a cRz L ln,r'- lsss: Page 1of 10 f);.- s kltx v Si3n Y 9 71-

9. Similarly, it needs to be verified if all the salt pans and aquaculture ponds have been built with valid permissions. Lo. Many of the salt pans have been demarcated as CRZ ll, CRZ lll and Survey Plots, whlch is again a 'huge mistake. This needs to be rectified. 11. Embankments/bunds of saltpans have been wrongly marked as HTL. L2- AII the areas that have Seen reclaimed illegally or without valid permissions should be restored to their original state. 13. Mapping has not been done on the scale of 1:4000 but instead has been worked on 1:25000 14, Turtle nestinB grounds have not been marked. 15. The authorities may kindly furnish details for'all the approved projects along the coastal area of Dwarka district. 16. The authorities may kindly furnish details for all the proposals/projects in violation to the CRZ Notification and the action taken thereof. 17. lt is not clear how has been marked instead of Guiarat.

SPECIFIC COMMENTS FO R THE DRAFT CZMPS WARKA DISTRICT

F42J15lNW t . The mudflats ICRZ 1Al have been wrongly demarcated as lntertidal Zone CRZ 18. This needs to be 'rectified- 2. The saltpans have not been marked. lnstead survey plots have been shown. This needs to be rectified. AIso, it needs to be verified ifthe saltpans have valid permission. 3. The embankments/bunds made for the saltpans/illegal reclamation have been wrongly marked as HTL. This needs to be rectified. 4. The boundary of Marine National Park and Sanctuary has not been demarcated on the draft czMPs, This needs to be rectified. t42tttlNE

5. The mudflats ICRZ 14] have been wrongly demarcated as lntertidal Zone CRZ 18. This needs to be rectified. 6. The saltpans have not been marked. lnstead survey plots have been shown. This needs to be rectifled AIso, it needs to be verified if the saltpans have valid permission. 7. The embankmentd/bunds made for the saltpans/illegal reclamation have been wrongly marked as HTL. This needs to be rectified. 8. The jetty has not been demarcated separately. Thisreeds to be rectified. 9. The boundary of Marine National Park and Sanctuary has not been demarcated on the draft czMPs. This needs to be rectified. F42tttlsE

10. The mudflats [cRZ 1A] have been wrongly demarcated as lntertidal zone cRz 18. This needs to be rectified. l-1. The saltpans have not been marked. lnstead survey plots have been shown. This needs to be rectified. Also, it needs to be verified ifthe saltpans have valld permission. 12. The embankments/bunds made for the saltpans/illegal reclamation have been wrongly marked as HTL. This needs to be rectified. 13. The boundary of Marine National Park and sanctuary has not been demarcated on the draft CZMPs. This needs to be rectified F42J11lNW be 14. The mudflats [CRZ 1A] have been wrongly demarcated as lntertidal Zone CRZ 18. This needs to .rectified. w Page 2 of l0 /.,1 fc

draft 15. The boundary of Marine National Park and Sanctuari has not been demarcated on the CZMPS. This needs to be rectified. F42J11lSW cRz 18. This needs to be 16. The mudflats [cRz 1A] have been wrongly demarcated as lntertidal zone rectified. needs be 17. The saltpans have not been marked. lnstead survey plots have been shown. This to rectified. Also, it needs to be verified if the saltpans have valid permission marked as 18. The emba nkments/bunds made for the saltpans/illegal reclamation have been wrongly HTL. This needs to be reaified. 19. The boundary of Marine National Park and Sanctuary has not been demarcated on the draft czMPs. This needs to be rectified.

F42t7 ISE zone cRz 1B. This needs to be 20, The mudflats [cRz 1A] have been wrongly demarcated as lntertidal rectified. draft 21. The boundary of Marine National Park and sanctuary has not been demarcated on the czMPs. This needs to be rectified.

F 42t7 ISW cRZ 18. This needs to be 22. The mudflats [cRz 14] have been wrongly demarcated as lntertidal zone rectified. 23. The boundary of Marine Nationat Park and sanctuary has not been demarcated on the draft CZMPs. This needs to be rectified. F42t6lSE 18. This needs to be 24. The mudflats [cRz 1A] have been wronSly demarcated as lntertidal zone cRz rectified. 25. Entire extent of sea grass west of Chank island has not been demarcated' 26. The boundary of Marine National Park and sanctuary has not been demarcated on the draft CzMPs. This needs to be rectified. t42t6lSW CRZ 18. This needs to be 27. The mudflats [CRZ 14] have been wrongly demarcated as lntertidalZone rectified. 28. The sand dunes present on the northern side of Noru island have not been marked. 29. The boundary of Marine National Park and sanctuary has not been demarcated on the draft CZMPs. This needs to be rectified t42!7lNE CRZ 18. This needs to be 30. The mudflats [CRZ 1A] have been wrongly demarcated as lntertidal Zone rectified. 31. The creeks of Gandhiyo kado island have not been marked' 32. The boundary of Marine National Park and sanctuary has not been demarcated on the draft CZMPs. This needs to be rectified. t42r7lNW Zone CRZ 18. This needs to be 33. The mudflats ICRZ 14] have been wrongly demarcated as lntertidal rectifred. 34. The sand dunes present on the western side of Bhaidar island have not been marked' W Page 3 of 10 431(-

35. All the creeks have not been marked. 36. Entire extent of sea grass south of Bhaidar island has not been demarcated. 37- The boundary of Marine National Park and Sanctuary has not been demarcated on the draft czMPs. This needs to be rectified. t42t4lNE

38. The mudflats [cRz 1A] have been wrongly demarcated as lntertidal zone cRz 18. This needs to be rectified. 39. The saltpans have not been marked. lnstead survey plots have been shown. This needs to be rectified. Also, it needs to be verified if the saltpans have valid permission F42t3l5E

40. The mudflats ICRZ 14] have been wrongly demarcated as lntertidal Zone CRZ 18. This needs to be rectified. 41. The saltpans have not been marked. Instead survey plots have been shown. This needs to be rectifie.d. Also, it needs to be verified if the saltpans have valid permission. 42. The embankments/bunds made forthe saltpans/illegal reclamation have been wrongly marked as HTL. This needs to be rectified. 43. The boundary of Marine National Park and Sanctuary has not been demarcated on the draft CZMPs. This needs to be rectified. F42J3lNE

44. The mudflats [CRZ 14] have been wrongly demarcated as lntertidal Zone CRZ 18. This needs to be rectified. 45. The sand dunes have not been marked.

46. The boundary of Marine National Park and sanctuary has not been demarcated on the draft i CzMPs. This needs to be rectified, 42i3lNw

47. The mudflats [CRZ 14] have been wrongly demarcated as lntertidal Zone CRZ 18. This needs to be rectified. 48. The saltpans have not been marked. tnstead survey plots have been shown. This needs to be rectified. Also, it needs to be verified if the saltpans have valid permission. 49. The embankments/bunds made for the saltpans/illegal reclamation have been wrongly marked as HTL. This needs to be rectified. 50. The authorities may kindly furnish with details of action taken against discharge from Mithapur to the mangroves and the gulf of Kachchh area. 51. The turtle nesting sites west of Okha/Dwarka have not been demarcated. The mapping agency/authoritieq may kindly explain this lapse in mapping F42J1slNE

I 52. The sand dunes and the beach ofthis area have not been demarcated. 53. The turtle nesting sites west of okha/Dwarka have not been demarcated. The mapping 'agency/authorities may kindly explain this lapse in mapping

t 42t t5 lsE

54. The mudflats [CRZ 1A] have been wrongly demarcated as lntertidal Zone CRZ 18. This needs to be rectified. 55. The sand dunes and the beach ofthis area have not been demarcated,

P Page 4 of 10 4)/L

55. The turtle nesting sites west of okha/Dwarka have not been demarcated. The mapping age ncy/a uthorities may kindly explain this lapse in mapping

F42J 16/NE

57. The mudflats [cRz 14] have been wrongly demarcated as lntenidal zone cRz 18. This needs to be rectified. 58. The sand dunes and the beach of this area have not been demarcated' 59. The turtle nesting sites west of Okha/Dwarka have not been demarcated. The mapping agency/authorities may kindly explain this lapse in mapping F42J4lNW

60. The entire extent of sand dunes has not been demarcated. t42PtlNE

61. The entire extent of sand dunes has not been demarcated. F42PSlNW

62. The entire extent of sand dunes has not been demarcated. 63. tt is not if allthe turtle nesting grounds have been mapped. Details regarding turtle nesting in this area may please be furnished' F42PslSW

64. The entire extent of sand dunes has not been demarcated. F42P5lSE

65. The entire extent of sand dunes has not been demarcated'

GENERAI COMMENTS AND SUGGESTIONS ON DRAFT CZMPs OF GUJARAT

1 As per the CRZ Notification, a Coastal Zone Management Plan is a compilation of

a) Existing land usP map b) Proposed land use map c) Management Report that elaborates/stipulates rules and regulations for the area covered in the proposed land use maP. However, no draft management rePort document is provided with the draft CZMP maps. This needs to be provided. Also, no existing land use and proposed land use maps are provided with the draft CZMP maps. These need to be Provided.

2. As per the CRZ Notification 2011, "While preparing the CZMP5 under CRZ notification, 2011, the cZMPs that have been approved under the CRZ Notification, 1991 shall be compared A justification shall be provided by the concerned cZMA in case the czMPs prepared under cRz notifrcation, 2oll varies with respect to the approved cZMP prepared under cRZ notification, 1991."

No such comparison or lustification has been provided by the GczMA. PIease ensure that the same is provided before the Public Hearing.

3. The baseline has to be taken as 19u February 1991, which is the date when the CRZ notification was gazetted.

W Page 5 of 10 h'tlc

4. secondly, the approved CZMPS need to be made available on the websites of the respective CZMA5, PCBS and the MoEF. lf there are no approved CZMPS, the submitted CZMP5 should be PUt uP.

5. The CZMP maps should be prepared on 1:4000 scale.

6. What is the data set used (topographic sheets, hydrographic charts and satellite images) for mapping the draft CZMPs? Kindly furnish the date details (time, date, month, year) for each of the data sets used. Kindly furnish the spatial resolution details of each dataset, scale, etc. details as well. This is required to ensure that the satellite imagery has been consistently taken at the same stage of the tide, and preferably at low tide.

7. As per CRZ 2011, there is a requirement for the hazard line to be demarcated on CZMP based on the several parameters given by MoEF. No such line has been shown in the map. This needs to be inserted. The methodology followed for demarcating the Hazard Line should also be exp la ined.

8. Please note that the following information should be shown on the maps, and the Management Report should also cover all these issues -

a) All eco logica lly impo rta nt and sensitive areas shall be demarcated and be classified as CRZ-

I

Mangroves - in case mangrove area is more than 1000 sq mts, a buffer of 50 meters along the mangroves shall be provided; Corals and coral reefs and associated biodiversity; Sand Dunes; Mudflats which are biologically active; National Parks, marine parks, santtuaries, reserve forests, wiidlife habitats and other protected areas under the provisions of Wild Life (Protection) Acl., 7972 153 ot 79721, the Forest (Conservation) Act, 1980 (69 of 1980) or Environment (Protection) Act, 1986 (29 of 1986); includinB Biosphere Reserves; vi. salt Marshes; vii. Turtle nestinB grounds; viii. Horse shoe crabs' habitats; ix. 5ea grass beds; x. Nesting grounds of birds; xi Areas or structures of archaeological importance and heritage sites; xI. The area between Low Tide Line and High Tlde Line;

b) Atl areas that are ecologically sensitive and important (as per CRZ Notification) shall be classified as CRZ-I by the State Government.

c) the LTL, HTL & Hazard Lines.

d) LfL, HTL, 2OO M,5OO Metre lines and bther relevant lines in respect of creeks, backwaters and rivers affected by tidal action so that distances can be measured, whenever required.

e) Approval of this CZMP would not imply approval of any proposed project such as roads, airports, jetties, ports and harbours, buildings etc. indicated in the plan/map.

f) Dredged material will not be disposed within the CRZ area.

g) All fishing villages along the coast will be cateSorized as CRZ-lll.

Page 5 of 10 w h? /"

h) Fishermen gaothans/koliwadas, extension ofthe gaothans/koliwadas, boat parking areas, fish drying areas, are not marked in the draft CZMP Maps'

i) Land used by fishing community for ancillary activities like fish dryin&/storin8, boat parking, etc, should also be demarcated. As has been mentioned in the CRZ Notification 2O!7 "common properties ol the fishermen communities, fishing ietties, ice plonts, fish drying plotlorms or oteds infrostructure Iocilities oflishing ond locol'communities such os dispensories, roods, schools, ond the like, sholl be indicoted on the codosttol scole mops. statesshollprePorcdetoiledplons|orlongtermhousingneedsofcoostalfishel communities in view of exponsion ond other needs, provisions of bosic ser|/ices including sonitotion, salety, ond disdster preparednes!'. Such demarcation is missing in the draft CZMPS,

j) parks, play Grounds, Regional parks, Green zones and other non-buildable areas falling within CRZ-ll areas are cateSorized as CRZ-lll.

k) state Government will not make any chanSes in the approved cateBorization of cRz areas without prior approval of Minlstry of Environment & Forests, Government of lndia'

list of places where r) state Governments will give wide publicity to czMP and indicate the it is available/can be inspected, and will also put them up on the websites of CZMAS, PCBs, and Environment DePartment.

m) lsland forts and forts along the coast are classified as cRz-|.

n) All areas marked inthe Development Plan as Regional ParksareclassifiedascRz-lll.

o) The coastal Regulation zone in respect of creeks, rlvers and backwaters isasfollows:

i. 1OO meters or less where the width ofthe river, creek or backwater is upto 100 meters or less. ii. 1oo meters where the width of the river, creek or backwater is in the range of 100 - 350 meters. iii. 150 meters where the width of the river, creek or backwater is more than 350 meters.

p) All those areas falling in No Development zone as perthe Development Planare classified as CRZ-lll

q) For the purpose of determining whether an area is substantially built-up, the ratio of built- up plots to that of total plots is to be ascertained. where this ratio is 50 per cent or more, such areas (built up and buildable) are to be classified as cRz-ll provided the same conforms to the criteria of cRz-ll as per the cRz Notification. The remaining areas will be classified as CRZ{ or lll as applicable.

r) The write up submitted in the czMP should be fully in conformity with the provisions of the CRZ Notification.

9 Gujarat Government had apparently submitted czMPs to the MoEF for approval sometime around 1995. The MoEF, however, had asked the Gujarat Government to revise these plans and resubmit the CZMPS on 27th September 1996. It is not Clear if the Gujarat Government had resubmitted the czMPs. lt is therefore not clear how these draft czMPs have been prepared - are they based on the draft czMP submitted circa 1995 or on the revised czMP submitted after 27th September 1996? A copy of the draft CZM P of 1995 and the resubmitted V Page 7 of 10 5tI C

version should also be made available to the public for scrutiny, as well as the CZMPs actually approved by the MoEF.

10. several CRZ violations, reclamations, enc[oachments and instances of mangrove destruction have taken place in the Gularat, in spite of mangroves being declared as forests. How has the draft CzMP taken into account those cases and areas where such violations have occurred?

11. All the areas where mangroves have been illegally destroyed or reclaimed should be marked as a separate category. Measures to rehabilitate the area to its original state should be taken. No development or construction should be allowed in these areas.

12. Demarcation of LTL should be done using the satellite lmagery taken during the lowest tide of the month/year.

,13. while demarcatinB HTVLTL on the draft czMP map, it should be made clear if bunds and roads, wherever they have been constructed, have been Permitted by MoEF or have been constructed illegally. lfthere are illegal bunds or roads, these should be removed and the HTL demarcated accordingly.

14. lf the bunds are used to demarcate the HTL that would obviously change the original HTL. Suitable changes need to be made to redefine the HTL as per the original ground situation, as existed prior to construction of the illegal bunds.

15. There are several cases of saltpans having been converted into agricultural land. These violations should be shown clearly on the map and such illegally reclaimed saltpans should be reverted back to their original state at the earliest.

16. By mere visual observation it can be inferred that many of the survey numbers will fall under the 2OOm and the 500 m CRz line. Kindly furnlsh clearances for all the construction/development that has been undertaken on such survey numbers.

.17. The shoreline ihanges of Gujarat coast are not provided in the draft CZMP maps. These need to be provided.

18. High erosion coastlines also need to be demarcated. Projects and reclamation activities that are causing the erosion need to be marked on the C2MPS.

19. Contour map for the coastal areas with the hilly regions should be provided.

20. As observed, allthe coral areas have not been demarcrted on the draft CZMP maps. lt should be ensured that all the coral areas are marked'

21. At many locations the creeks have not been marked properly.

22. sand dunes should be marked wherever present. lt has been observed that sand dunes areas are simply marked as inter tidal areas at many places.

23. At many locations natural vegetation has been marked as salt pans. This needs to be corrected,

24. lt should be ensured that all the turtle nesting grounds and nesting grounds of birds are marked.

25. Have any complaints been received for the violations of the cRz Notifications of 1991 and 2011? lf yes, kindly furnish details and the action taken thereof. These violations need to be marked on the CZMPS.

Page 8 of 10 W ilf-

26. Has the mappini team taken these violations into consideration whilst demarcatin8 the LTL and the HTL?

27. How much area has been encroached or/and reclaimed in between 1991 to date? Kindly furnish details for each cRz category - cRz l, cRz ll, cRz lll and cRz lV'

28. Have clearances been obtained for any of the reclamations? lf yes, copies should be made available. Government 29. Has the respective Municipal Authorities orthe Revenue Authorities or any other agency taken any action against the illeBally encroached or/and reclaimed cRz areas?

30. Do the various Municipal/Revenue Authorities have plans to restore the encroached or/and reclaimed CRZ areas? proposed 31. Has a change detection analysis been undertaken for the approved cZMP and the draft CZMP? Change detection maps should also be made available'

32. What are the changes observed in the land cover and land use category in the approved and the proposed draft CZMP? Kindly furnish details for each category'

33. What are the changes observed in the land cover and land use category for the cRz I category, in the approved and the proposed draft CZMP? Kindly furnish details' while drafting this 34. Have the proposed projects in the cRz areas been taken into consideration czMP?KindlyfurnishwiththedetailsoftheprojectalongwiththecRzareabeingimpacted due to the proPosals.

35. Marine National Parks and sanctuaries and their ESZ area should be marked as cRz lA.

36. please find below a list of the special conditions contained in the MoEF tetter dated 27th september 1995 to the chief secretary of Government of Gu,iarat. All these special conditions should be incorporated in the draft CZMP maps and draft management report document'

" s oecidl Co n d iti o ns lMo di ficoti ons/ Cl ossificotion s

(i) For rivers, creeks ond bockwate9 o slob system of CRZ os follows is opproved: (o)l00norwidthofthecreek,river,bockwoter,whicheverisless,ifthewidthofthe creek, river, backwotet is upto 7(nm. (b) 100m if the width ol the river, creek, bockwoter is between 700m ond 300m' k) 150; if the width of the river, creek, bdckwoter is morc thon 300m'

(ii)ThecotegolisotionolDhorangthorondKovothororeosorekeptpendingtithe decisionrcgdrdingstotusofthisdrcohosbeengivenbyHon,bleGujoratHighCounin the Cose No.2870 of 7996.

(iii) The cRZ dreos in the five municipdlities, nomely Chhoyo, Chonttod, Dworka, Jolrobod ond Soloyo ore cotegorised os CR2-lll-

(iv) Onty the substontiolty built-up portion ol CRZ oreo shown in the maps submitted by Govt. of Gujorot in the municipolities of Bilimoro, lomnogor (survey No'6j), Mondovi, Mongrol, Porbondor ond Volsodore ore categorised os CRz-ll The bolance cRZ oreo in these municipolities is cotegorised os CRZ-lll. v Page 9 of 10 te/.

(v) the CRz orea within Bhovnogor municipol limits, if any, ond in Novsori municipolity ore cotegorised as CRZ-lll-

(vi) Detoils requested for determining vorious oreos Proposed for CRZ-Ilcotego(isotion, nomely municipolities/municipol corporotions ol Bhotuch, Verovol-Poton ond Sutot; otlthe 77 industriol complexes ond allthe 43 ports and ship breoking oreas mentioned in the CZMP hove not been completely Iumished by the Stote Government ln view of this, it is decided thot d Committee moy to set up under the choirmonship ol chiel secretory with ot leost two NGO| os Members to identify dnd demdrcate CRZJI oreds within the proposed CRZ/7 orcos. For the puryose oJ determining whether on ored is substontiolly built-up, the rotio ol built-up plots to thot oJ totol plots is to be ascertoined. Where this rotio is 50% or more, such oreos (built-up ond buildoble) ore to be clossified as cRz-tt provided the some conforms to the iterio of cRzll os per the CRZ Notiftcotion. The remoining oreos wi be clossified os CRZ-| or lll os opplicable A copy of the finol cotegorisotion ol CRZ-ll so mode will be sent to this Ministry for record,

(vii) lnhobited islonds os mentioned in the CZMP ore clossified ds CRz-lV. Govt. ol Gujorot is to submit to MOEF, detoils on size of the islonds, ploce of hobitotion, etc., olong with the maps of these islonds for o decision on the set-bock limit fot no development lor these islonds. Till such time the set bock limit lor these isldnds is decided by Ministry ol Environment & Forests, Govt. of lndio, no construction in these islonds sholl be permitted upto 200m ol High Tide Line.

(viii) Govt. of Gujorot shdll submit to MOEF 7:25,000 Scole Maps prepored on the bosis of Sotellite lmogery by sAc, Ahmedobod within tv/o months oI obtoining from sAC, Ahmedobod ofter incorporoting the conditions/modiflcotions stoted in the oPprovol letter."

The plon submitted by Govt. ol Guiordt vide lefter No.ENV-1090-GOI-165-P doted 19-6-96 is not in conformity with the conditions indicoted obove. These modilicotions moy be mode and the modified plon ond the mops should be sent t:o this Ministry, within o period of two months' lor record."

We request you to kindly give us a hearing to further elaborate on our comments'

Yours fa llv,

D eta Bhatt Conservation officer

Page 10 of 10 , C'Z- 'ty) AxHrxu(f 5l.

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To Hon'ble Collector Shri, Dist: Devbhumi Dwarka, JAM-KHAMBHALIA

:Su estion / O rds draft Costal R tl President: Notification. 201 8 -reo. Aqenda : Public arino to be held at Owarka Dist: Devbhoomi Dwarka Mr. B. C. Raval On 03-08-2018. Ph : (0 ) 0288-2s55403 (n 10288-255s853 We kutch Salt Manufacturers Association and lndian Salt Cell r98252 32329 Manufacturers Assocration on behalf of our below members situated at Disl -a-{arl : raval5 mail com bharat Devbhoomi dwarka . bh6rat raval@solanschemtech com 1. Saurashtra Salt lndustries, Chudeshwar Vice-President: 2. Nawanagar salt works, parodia Mr. Viiay Thorat Ph. r (0.) 02897 - 223483 3. O V salt works, salaya (R ) 0289i 222464 Cell : 98 795 23484 4 Tata Chemicals ltd, mithapur Mail : thorat.ccsp eco ln We are submitling herewith our objections / suggetions raised with minrstry of Environment, Forest & Climate change, Govt of india against draft Hon. Secretary: notification published public Notice F.No 19-1 12201 3 -lA-lll , Dt:18 04 201 8 tUr. J. T. Talsania & subsequent public hearing to be held at Dwarka, Ta Owarka Dist per paper Ph : (0 ) 0288 - 2553448 / 2557396 DevBhoomi Dwarka on 03-08-201 8 as your news advertisement Cell :93277 58188 IJari sa ukemsaltworks@bsnl rn We are submitting our objections / suggestions against the proposed CRZMP draft notificahon as raised by ISMA with Govt Ol lndia, Ministry of Environment. Forest & Climate change Hon. Treas u rer ,Mr. O. P. Sharma Thanking you h rl0 )0288 - 2611181 I82 Cell i 93 755 26735 Yours faithfully KU H SALT l\,,1a rl censalt@sify com THE SAURASHTRA MAN CTURERS'v ASSOCIATION : IA ECRETARY

Encl : Copy of The Indian Salt Manufacturers' Assooation, Managing Committee Ahmedabad ietter No lsMtuzo'l8-19/O'1 'l Date 16'h June,2o18

Mr. P. R. Dhruve coDv to : 01. Regional officer GPCB - Jamnagar Mr. N. H. Kotecha 02. Gujarat Costal Zone Management Authority - Gandhinagar 03 The i rest an+clrnate change 04 The n, Ahmedqbad. Mr. L J. Panchmatia Os.Sau I'j'' Nawanagar salt works, parodia 06. t^ 07. D V salt works, salaya gt, />S-f6 s/r/tr

ON THE KUTCH SAURASHTRA SALT MANUFACTURERS' ASSOCIATI llrl] i f tx i] rLlt1tnNfl[t1l1r lfltflUfltflfl itl illr lilltlilil ll lltilll iilriirifllllflrllllrlfllrrir ' tqf' gB 9.7 W,ISI, lln\r un $ult frlsnuf u ctur erg' I o ci nti o n Premier Association of lndian Salt Manufacturers' D-202, Titanium Square, S G Highway, Thaltej, Ahmedabad - 380 054 rere-Fax: o7s-2s7o2o12. .fr,:i office@indiansartisma com ilT[:::X1P,:#::om:

rsMA/2O1E-19,/011 Date: 16th June, 2018

C ha irman To,

Ashrsn K Desar The Director Cell +91 98253 20090 Ministry of Environment, Forest and Climate Change (14-lll Division) President J-515, Jal Block, lndira Paryavaran Bhawan, Jor Bagh Road, C Raval New Delhi 110003. Cell. +91 98252 32329 - presidenl@ rndiansallisma com sub: Suggestions/Objections towards Draft Coastal Regulation zone Notification, 2018 - reg.

Ref: Public Notice F.No.19 -1L2l2}r3-lA-lll, Dt.18/04/2018' ShamJrbhai Kangad Cell +91 98252 25711 Respected Sir,

Itrranim {Sultan) Patel Cellr +91 90990 53200 Warm Greetings from ISMA!

Hon. Sec_retary We, The lndian Salt Manufacturerd Association (ISMA) is the registered Association, Established since 1945, is the oldest of all the Salt Manufacturers' P R Dhruve lndia. an All-lndia character in its membership, ISMA'S Cell: +91 98790 1'1494 Associations in With ecretary@ Associate Members include the Regional Associations of Salt Manufacturers indiansaltisma com from a number of States. ISMA has done an yeomen service to the Salt promotin8 Jt. Hon. Secretarv industry in its over seven decades of existence, by actively salt exports and representing the problems of the Salt industry in several forums, Akash Patel including the State and Central Governments, Railway Board and the Ministry Cell: +91 97237 00056 of Shipping. Functioning as a democratic institution, ISMA allows free expression of views and suggestions by its Members so as to arrive at a consensus on issues related to the Salt lndustry. Hon._lfqas!'leI

ShamJi Tela Ahtr Considering the longest Coast, Gujarat has a vast opportunity for lndustrial Cell: +9'1 94268 19548 and lnfrastructural development along the cost in empowering the costal industries such has Ports, Salt & Salt By-product, Tourism, Logistic Parks, and many others related industries. The benefit of the coastal development is well experienced by the state economy during past many years with the lndia's Biggest Port (Minor & Major both) having the world class facilities which make Gujarat an lnternational trade leader and lndia's gateway to the World's economy. Gujarat again is the leader in Salt Production & export with more than 80% of the countr/s total production and exports more than 95% of the total country's sa lt export.

Regd. Office: 51 -A, Minal Chambers,5" Floor. Nanman Point, Mumbai 400 021 Vt IC g o.7 U,W nn\i sn $al t fr[snuf s ctur erB' E[g o ci erti o n Premier Association of Indian salt Manufacturers'

Further looking in the Costal Regulation Zone (CRZ) Notification by Ministry of Environment & Forest (MoEF) dated 16tn Jan 2011and latest updates with the Draft Notification released on 18th Apr 2018 which also applies to the Gujarat coast. Considering the current understanding and past studies by the lnstitutes / ngencies appointed by MoEF the major coast is Mud flat and agencies consider these mud flat area under CRZ classification CRZ 1A.

The coastal area classified under CRZ 14 classification by the agencies considering Biologically Active Mudflats and this will results in no any further development on the entire coast line of Gujarat. Further looking on the Biologically Active Mudflat condition, there is no such definition / parameters available in the Notification or anywhere; but the same was left on to the understanding and submission made by NCSCM, the appointed agency.

Considering our understanding and discussion done with multiple agencies, stakeholders & experts we suggest that the Biological Active Mudflat should only be considered up to 10 meters from the creak and or in case if Mangroves area is more than 1000 Sq. mts a buffer of 50 mts along the mangroves and or on density of mudskipper.

Considering the above facts and condition we request your good office before finalizing & amendment in CRZ Notification, kindly provide us an opportunity to representation so that, the interest towards the Coastal development should not get hampered. Even ground fact of Salt production & distribution within Nation is concern, our 4-5 States are producing salt & against which balance states are consuming salt for edible as well as industrial purpose. Since last one decade the supply & demand are almost same, hence any adversity in production of salt may create scarcity is the biggest threat.

Thanking you,

Yours faithfully, For,frL The lndian Salt Manufacturers' Association P. R. Dhruve Hon. Secretary

PaF,e 2 of 2 A^utE XLt4f- C- 5 7). I TI'.-\ ^lwcl323/2018 TNTN 02.08.2018 To The Member Secretary Gujarat Pollution Control Board Gandhinagar

Sub: Public Hearin8 for Draft CoastalZone Mana8ement PIan (CZMP) on 03.08.2018 at Dwarka Ref: Coastal Regulation Zone Notification, 2011

Respected Sir,

Tata Chemicals Limited (TCL) was founded in 1939 and has operated manufacturing facilities and salt works activities in Taluka Dwarka and Kalyanpur of District Devbhumi Dwarka, Gujarat State since 1943. Captive steam power plant and desalination plants supply all utilities like water, power and steam to the complex. lt relies on captive salt works for its principal raw material - solar salt and coastal facilities for sea water intake system and treated waste water disposal system.

We hereby submit following details for consideration as an existing land use in Coastal Zone Management Plan (CZMP):

1. Map showing TCL's existing facilities in coastal area- including Sea water intake system, treated waste water disposal system, salt works and brine conveying systems, electricity supply system etc. is enclosed as Annexure-l. 2. TCL proposal for upgradation of treated waste water disposal system- cRZ clearance issued by Ministry of Environment, Forest and Climate Chan8e vide letter no F.No. 17'3412016 lA- lI dated 10.07.2018. 3. TCL has been conducting mangrove plantations as a part of environment conservatron programs. Mangroves plantations near existing industrial activities should be exempted from the rules (cRz-1A area). such an exemption would encourage industries to develop more mangroves areas near their operations

It is requested that the above points may be favourably considered

For Tata Chem ica ls Lim ited ///.,4-1 / - Ka pa lia BB th ,t,a. l5s:r Vice President- Man ufacturing I (Authorised Signatory) 5 Blr Pr Enclosed: Annexu re-l (Map T-7a646) 9

TATA CHEMICALS UM]TED Mlthapur 16l 345 District Devbhoomi Dwarka Guiarat Tel +9l (02892) 665991 /2/3l4Fat+91 \02892) 223361 www.tatachemicals com Registered Office Bombay House 24 Homi Mody Street Fort M'rmbai400 001 CIN : L24239MHl 939P1C002893 Al\r\E rtJ Rf - C- e r5/. 0 GulaRar Manrtrue BoaRo () SAGAR BHAVAN I Sector- I 0/A I Chh Road I opp Arr Force Station Gandhinagar-382010 I GuJ.rat (lNDlA) Phone : +91-79-23238346-47-18-51 I Fax : +91-79-2323470/. E-mart info@gmbports in

Importent GMB/ENV/CZMP lr 16L66 02l08l2or8

To ember Secretary Gujarat Coastal Zone Management Authority Block No. 14, 8th Floor Gandhinagar.

Sub: GMB's Comments on Draft CZMP Map prepared by NCSCM for Devbhumi Dwarka District. (Sheet no: NCSCM/F42J3lNW)

Sir,

With reference to pubhc hearing organized on 03/08/2018, we hereby attach draft CZMP Map of Devbhumi Dwarka showing necessary correction made over it. Note may be taken that area marked as A-B-C-D and E-F-G-H be considered as CRZ (IB) area instead of CRZ (lA) as there are no cora-l & coral reefs present in this particular region. Accordingly our representation may be considered in frna.l CZMP.

Regards, .ef ' ,5sJF 5 lo/,r / I (Atul Sharma) [g Pr i Dy.General Manager (Env.) i Copy Subnlttcd to: r Member Secretary, Gujarat Ecologr Commission, Udhyog Bhavan, Gandhinagar

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