Date : 24/05/2018
To,
The Member Secretary
DDCZMA
O/o the Member Secretary
Pollution Control Committee
1st Floor, Udyog Bhawan
Bhenslore
Nani Daman – 396 210
Ref.: CCF/DNH/2017/160/2017-18/202 & 203 dated 10/05/2018
Sub: Submission of Objections/Suggestion on Draft CZMP maps of Daman & Diu
Respected Sir,
With reference to above-referred Notices, I submit my Objections and suggestions as below:
1) Errors in Maps:
a) There are many Rivers shown in the Map of Daman without any trace of water coming in and going out. In fact, these are ponds/tanks shown as Rivers.
b) Kolak River is shown with a length of 1191 metres and is shown and measured upto NH 848B only in the Map. The length above it i.e. the landward side of Jani Vankad is not shown, whereas as per Google map total length of this River comes to 3600 Metres in Daman.
c) Kalai River is also shown with a length of 1802 metres upto the Bamanpuja Bridge only, whereas same is measured as 3813 metres on Google Map in Daman i.e. River towards Thana Pardi is not taken into account.
d) The moot question here is that when Damanganga River can be shown upto the boundary of Daman, why Kolak and Kalai Rivers are curtailed and not shown upto the boundary of Daman?
e) There are no Creeks in Daman, there are only Rivers hence, classification as ‘Rivers and Creeks’ is unjustified. In fact, except three rivers Kolak, Damamganga and Kalai there is no creek or river in Daman. It should be corrected.
f) There is inconsistency between maps prepared presently by the National Centre for Sustainable Coastal Management (NCSCM), Ministry of Environmental & Climate Change, Chennai published with Draft CZMP Map for Daman & Diu and Institute of Remote Sensing, Anna University, Chennai published by UT Administration of Daman & Diu on dated 04/03/2014 with Draft Notification for CZMP.
g) The Institute of Remote Sensing, Anna University, Chennai has depicted the correct position of these two rivers located on the boundary of Daman.
h) Fishing Villages are shown 500 metres away from the sea. Fishing Village Kadaiya is not portrayed as Fishing Village in Nani Daman. Same way in Moti Daman, Villages Dholar, Bariyawad and Jampore are not marked as Fishing Villages. In fact, villages outside 500 metres are shown as local communities’ villages and villages within 500 metres are not demarcated as local communities in villages which is an error and would put a lot of difficulties for them later on. Local Community villages are outside the purview of 500 metres are out of the ambit of CRZ and therefore demarcating such villages as local communities are meaningless and give the impression of malafide.
i) These maps have not considered the public petition to classify all Forts and ancient monuments of Daman & Diu in CRZ – II.
2) Draft Notification of CZMP of Daman & Diu of 2014:
a) This CZMP Map is published as per central Notification of 2011 but there was Draft Notification of Coastal Zone Management of Daman & Diu published on 04/03/2014 by UT Administration of Daman & Diu also. What has happened to that Draft Notification? The Administration of Daman & Diu has not come out clean with any clarification about it.
b) This Draft CZMP Map does not depict any suggestions/objections given by the citizens and given during the public meeting held by the Administration on Draft Notification of CZMP of Daman & Diu of 2014.
3) Designation of Forts as CRZ – II:
a) There was a unanimous demand during a public meeting held for Draft CZMP in 2014 to re-designate Forts and ancient monuments of Moti Daman, Nani Daman and Diu under CRZ – II since these areas are located inside CRZ – II and are densely populated by local native communities including fisherfolk.
b) If these Forts are classified as CRZ – I, there may attract a restriction of No Development Zone upto 500 metres from the outer boundaries of Forts and ancient monuments, which will adversely affect the local communities.
c) All these Forts are located within the Municipality boundaries. There are many people residing in those forts, this classification as CRZ – I will not give them an opportunity to renovate or expand their houses.
d) There are already restrictions applied by the Archaeological Survey of India for these sites. There is no need for any new restrictions.
4) Restrictions and Constraints in Development:
a) Coast Guard Airport has No Development Zone surrounding the Airport.
b) Coast Guard also has height restrictions applicable in funnel area so vertical development is not allowed only horizontal development is possible.
c) There is Forest land which cannot be used for development.
d) The existing National Highway has rendered vast amount of land as unusable, now it is also learned that National Highway passing through Daman is being expanded, which will bring with it, acquisition of land and more roadside margins and hence, more unusable land.
e) Daman & Diu Administration has adopted a policy that all new structures constructed should follow Fire Safety norms and for that, they require 7 metres of clear space all around the structures. This will further restrict land use.
f) Now, CRZ will take away a major chunk of land available on the coastal belt of Daman leaving hardly 2 to 3 Sq. KM. for development.
g) Do this mean that the local community including fishermen living on the coastal belt from last many centuries will have to move out and go to the mountain and do fishing there?
5) Conclusion:
a) Looking at errors in the Map, it is best that this notification is deferred till new and proper map is prepared after correcting all errors.
b) Clarification may be sought from the NCSCM for preparing maps with so many errors.
c) Clarification may be provided on the present status of Draft Notification published by UT Administration of Daman & Diu in 2014.
d) It is perplexing that when the central government has published Draft Notification for CZMP 2018, how prudent is to publish CZMP Map as per 2011, this will only create confusion and panic in people.
e) All Forts be re-designated as CRZ – II keeping in mind dense population and public demand.
f) The whole of Daman coastline be declared CRZ – II since the coastal area of Daman is highly populated from the time of Portuguese era and now due to acute scarcity of land as it is getting more populated.
g) The proper depiction of Fishing Villages on coastline including Kadaiya, Dholar, Bariyawad, Jampore in the published map be ensured.
h) No Fishing Villages could be 500 metres away from the coast.
i) Diu should be declared island and benefits of island shall be given to Diu.
j) There is no provision for tourism in these Maps which is a lifeline of Daman & Diu.
k) It appears that DDCZMA is hell bound to finish tourism industry in Daman & Diu.
l) It appears from the plain reading from the Maps that these Maps are prepared without proper consultation with local communities and with ulterior motives.
Hence, these Maps should be kept on hold till process of consultation with local communities are completed and all errors are corrected and made error free. If these maps are notified without proper correction it will bring devastating effect on people of Daman & Diu.