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Shree, Vijay Kumar Member Secretary, Karnataka State Coastal Zone

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Shree, Vijay Kumar Member Secretary, Karnataka State Coastal Zone Date: To: Shree, Vijay Kumar Member Secretary, Karnataka State Coastal Zone Management Authority Department of Ecology and Environment, Room No: 710, 7th Floor, IV – Gate MS Buliding, Bangalore – 560001 From: Dr. MahabaleshwarHegde Centre for Policy Research – Namati Environmental Justice Program C/o Snehakunja Trust, Kasarkod, Honavar Uttara Kannada, 581 342 Karnataka Ref: KSCZMA, Notification No: FEE 289 CRZ 2017 dated 07-09-2017 Subject: Submission of comments on Draft CZMP maps and requesting to incorporate the changes suggested. Respected Sir, This is with reference to the Notification issued by the Karnataka State Coastal Zone Management Authority (KSCZMA) on 07-08-2017 regarding the Publication of draft of Karnataka State Coastal Zone Management Plan inviting suggestions objections comment from stake holders and public. We have included below three kinds of suggestions for your consideration. These relate to potential violations of the CRZ notification in the CZMP process; inaccuracies in the CZMPs and the inadequate process of public consultation. We are from Centre for Policy Research working in Environment Justice Program along Uttara Kannada coast. Our program workslegal empowerment of fishermen and coastal communities along the Uttara Kannada coast and we are working towards the implementation of CRZ law for the welfare of coastal communities.. We would like to convey our gratitude for initiating the preparation of CZMP maps. We believe updated version of CZMP maps after 2011 CRZ Notification is very important since HTL and Hazard lines have been changed from last two decades. Further, CZMP maps with ecological sensitive areas are essential for coastal conservation. We have seen all the maps and are well prepared as compare the earlier maps containing most of information as per the CRZ Notification 2011. However, we have noticed that few important clauses of the Notification were not considered in preparing draft CZMPs and also several technical and factual inaccuracies in the draft maps were noticed in the same. In this regard to fulfill the sole purpose of CRZ Notification which is conservation of coastal ecology and livelihood security of coastal communities there are few concerns which we would like to convey to you. A. Process of Community Consultations and Involvement 1. The CRZ Notification, 2011 states that local communities shall be involved in preparation of CZMP (Clause 5. VI :The coastal States and Union Territory will prepare within a period of twenty four months from the date of issue this notification, draft CZMPs in 1:25,000 scale map identifying and classifying the CRZ areas within the respective territories in accordance with the guidelines given in Annexure-I of the notification, which involve public consultation). Comment: We have noticed in the Notification No: FEE 289 CRZ 2017 issued on 07-09- 2017 it is not mentioned about the public consultation and from the 65 villages we work on we got to know that public consultation was not carried out in any of those villages. In view of this we kindly request you to conduct public consultation block level/village level before finalizing the final CZMP. B. Violation of CRZ Notification: 2. The CRZ Notification, 2011, (Clause 1, ii) states that CRZ shall apply to the land area between HTL to 100 mts or width of the creek whichever is less on the landward side along the tidal influenced water bodies that are connected to the sea and the distance upto which development along such tidal influenced water bodies is to be regulated shall be governed by the distance upto which the tidal effects are experienced which shall be determined based on salinity concentration of 5 parts per thousand (ppt) measured during the driest period of the year and distance upto which tidal effects are experienced shall be clearly identified and demarcated accordingly in the Coastal Zone Management Plans (hereinafter referred to as the CZMPs). Comment: We have noticed all the maps and nowhere the 5 ppt line has been marked in the tidal influenced water bodies. It is very important to understand the extent of CRZ areas in the landward side. 3. The CRZ Notification, 2011, Annexture I, D (ii) 5 it states that, the hazard line to be drawn up by MoEF shall be superimposed on the CZM maps in 1:25,000 scale and also on the cadastral scale maps. Comments: The Hazard line was not drawn in any of the draft maps which shall be marked as per the CRZ Notification, 2011. 4. The 12 nautical mile line in sea to demarcate the CRZ- IV is not marked in any of the maps. C. Technical and Factual inaccuracies in the maps: We have also identified several inaccuracies in map related to marking of zonations, survey number, ecological sensitive areas which are listed below according to sheet number. We believe that several of these could have been avoided had the villagers themselves been involved in the CZMP preparation. In Sheet no: NCSCM/D4316/SW which covers Gangavali and Aghanashini estuary, includes villages such as Gokarna, Tadadi, Aghananshini, Kagak. 1. NDZ line is marked in sea which creates confusion in communities live in that area. 2. Large sand dunes present near Tadadi andKagal, is not mentioned in the map. 3. Fish landing centers are not clearly marked in Aghanshini village, where only one is marked, there are two more landing centers in Aghanshini village. 4. Tadadi village the survey number of entire village is missing. 5. Gangavali river NDZ line is marked in the River. 6. Survey numbers in Gokarna, Om Beach and Kudle beach area is completely missing 7. Mangroves present in Middle Gajani, Betkuli, (KIADB land) is completely missing new draft map. It is very important since the Tadadi port is proposed in this area and EIA report says there are more than 600 acres of mangrove forest present, but it is not marked in the map. 8. Mangrove islands beside the Aigalkhurve village is also completely missing. There are 6 mangrove islands with total approximate mangrove cover of 95 acres. 9. Hazard line is not mentioned in the map. 10. Rock cliffs are not notified in the map as it is mandatory to mention in map acceding the CRZ Notification, 2011, Annexture-I. 11. Tadadi fish drying area is not mentioned in the map 12. Salt marsh in Sanikatta village is not mentioned in the map. 13. Boat parking and fish drying area in Birkodi village is not mentioned. 14. Mud plats in Agahanashini estuaries are not marked. 15. Survey numbers near Madanageri village is completely missing. 16. Survey numbers in Gangavali village also completely missing in the map. 17. Sand dunes present in from Gangavali to Bhavikodla village is completely missing 18. Fish landing centers in Gangavali is not marked. 19. Nadumaskeri village is misplaced in Gangekolla village and Gangekolla village is not mentioned 20. Gangavali and Gangekolle villages are completely missing in Map Sheet no: NCSCM/D4316/SE 1. Survey number in Madanageri, Middle Gajani area is completely missing 2. Survey number of entire Nushikote village is not marked 3. Mangroves in Nushikote area is not marked 4. Mangroves in Madanageri in KIABD land is completely missing. 5. Torke and Hosakatta village is not shown in the map and survey numbers of the village Torke and Hosakatta village is also not mentioned. Sheet no: NCSCM/D4317/NW 1. Sand dunes in Hubbanageri, Bada is completely missing, 2. Survey numbers in entire Kagal village are completely missing 3. Fish drying areas and boat parking areas in Hubbanageri village are not marked in the draft CZMP maps. Sheet number – NCSCM/D4317/NE 1. Survey numbers of private land in Hubbanageri village is not marked. 2. 16 acres of Salt pan which is in Hubbanageri village is not marked in map. 3. Fish landing centre in Hubbanageri is not marked. 4. Buffer Zone of 50m for mangrove forest in not marked in Tannir Honda and Aigalakurve village. 5. Sand dune in Holanagadde is not marked 6. Fish drying area in Vannalli village is not marked. 7. Fishing Jetty inVannalli village is also not maked in map. 8. The entire Vannalli village comes under Municipality Jurisdiction but it is mentioned as CRZ-III in map and CRZ II in Vannalli village is not marked clearly. 9. Light house in Vannalli region is not marked. 10. Survey numbers of Hegde and Mirjan villages are completely missing in the map. Sheet number – NCSCM/D4317/SE 1. Sand dunes in the Tonka, Kasarkod village are not mentioned. 2. Fish drying area in Tonka, Kasarkod village are not mentioned. 3. All the survey numbers in Tonka, Mallukurva, Pavinakurva village have been marked in the sea and estuary. The village Mallukurva is eroded by river erosion and in is not updated in Revenue record also, however panchayat records mentioned that Mallukurva village is not in existence. Mention of survey numbers in sea and estuary creates confusion among the villagers live in that area. Further, the land is under dispute between port department and fishermen regarding the common use. 4. River erosion also changes the HTL and LTL in this area but maps shows the previous HTL and LTL only. New HTL and LTL shall be updated before finalization of maps. 5. Survey numbers of Kasarkod Tonka 1 and Tonka 2 village is completely missing. There are more than 1000 households living in these two villages. 6. Entire Maki village is missing in Map, the name of Manki village and survey numbers are not mentioned in the map. 7. Survey Numbers in Entire Haladipur to Karki beach area survey numbers are missing. Other than the above points, we have noticed: • several landmarks, common use of lands, ecological sensitive areas such as mangroves, mudflats, sand dunes are missing in Sheet number – NCSCM/D4311/SE, NCSCM/D4311/SW also.
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