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Ministry of Environment and Forests,
Paryavaran Bhawan, CGO Complex 24th May 2010
Lodhi Road, New Delhi – 110003

Sub: Comments and recommendations to pre-draft CRZ Notification 2010

Dear Sir,

Greetings from Pondicherry!

We deeply appreciate the Ministry’s concern for the livelihoods of coastal communities and the coastal
environment of India; letting the CMZ notification 2008 to lapse and holding consultation meetings with all the
coastal communities to amend the existing CRZ Notification 1991 for better coastal management. We also
appreciate that the Ministry has put up on its website the CEE report of the public consultations and the pre-draft
notification and invited comments before 30th May2010.

Considering the following facts:

1. The realisation by MoEF that the amendments to CRZ 1991 have posed continuing difficulties for the
effective implementation for the sustainable development of coastal regions as well as conservation of
coastal resources and the Minister’s statement “the new notification would primarily draw regulations
from the CRZ 1991, it could be termed as ‘Sustainable Coastal Zone Protection Regulation’ Notification,
whose primary aim would be to protect the coastal ecology and rights of the fisher and coastal
2. The recommendation of the Expert Committee, formed under the chairmanship of Prof M.S.
Swaminathan, in its report titled “Final Frontier” on the 16th July 2009 that the CRZ 1991 needs to be
strengthened as the coast is facing unprecedented pressures because of industrial and urban development.
3. The CEE report after the public consultations stating among other concerns
a) Strict enforcement and monitoring is needed as the violations are largely the outcome of ineffective
and weak implementation of CRZ 1991, that stringent punishment needs to be initiated for all the
CRZ violations and that the active participation of coastal communities is important.
b) No permission should be granted for activities related to SEZs, industries, atomic power plants, ports
and other infrastructure projects within 500 meters from HTL and there should be total ban on sand
4. Coastal environment plays a vital role in the nation's economy by virtue of the resources, productive
habitats and rich biodiversity. India’s coastline, inhabited by 30% of its population, has taken a severe
battering for the last 2 decades and needs time to heal. It is in fact already overdeveloped. The cost of
repairing the present damage caused by the private developers, if it is at all taken up, is going to be
enormous and will be spent from public money.

We are of the opinion that since none of the above points have been addressed in the pre-draft CRZ 2010
Notification, it will be totally ineffective in terms of conserving the coastal resources from the unprecedented
pressures of development. It will in fact weaken the CRZ 1991 considering that there are no effective monitoring
mechanisms or system for penalising the violators in place. Our conclusion therefore, as stated in the CEE
report, is that the draft of improved CRZ 2010 notification should be prepared involving experts,
environmentalists and representatives from coastal communities for achieving the desired outcome.
No: 34 Francois Martin Street, Pondicherry – 605001 Ph: +91-413-4210032
Email: Website:
Pondicherry is reeling under the impacts of coastal erosion caused by a small harbor which has been detailed in
“The Last Frontier”. Many top coastal management experts in India and abroad have been consulted for the
problem of erosion. We have organized/attended many public consultations and workshops on the impacts of
ports and harbors on the environment and coastal communities and find that many other coastal communities
across India are facing exactly the same problem. We would therefore like to make some recommendations to
address the issue of coastal erosion based on the following:

1. The proposed CRZ 2010 state under “Classification of Erosion-Prone Areas: The 1991 Notification does
not provide for restrictions on port development and other foreshore developmental activities along the
coasts which are erosion prone. Majority of the erosion being caused is due to anthropogenic activities”.
The MoES, ICMAM and INCOIS among other national and international agencies have also identified
that the major development activities that contribute to anthropogenic shoreline changes are man-made
structures that are built within the CRZs for ports, harbours and coastal defence/protection measures.

2. The premise for the definition of the CRZ is that the shoreline and therefore the High Tide Line (HTL) is
constant and does not change. The coastal structures are causing erosion which is altering the shoreline.
With a changing shoreline, the CRZs as defined in the Notification become meaningless.

3. There are already 200 ports in India working only at 25% capacity. The Times of India reported that
there is a distinct drop in business registered by the ports
4. As per the Environment (Protection) Act (1986) and the Environment Impact Assessment Notification
(2006), the permissible development activities are granted environmental clearance with the condition and
understanding that environmental impacts caused by these activities shall be mitigated. However, the
record of mitigating measures undertaken is very poor. According to ADB report “In India, about 1,500
km or 26% of the mainland coastline faces serious erosion and much of the coastline is actively retreating
and coastal properties and investments remain threatened by erosion”.

5. The littoral drift along the coastline of India is one of the highest in the world. Any
hard structure will trigger erosion (like in the case of Pondicherry) and result in a
devastation of that coastal cell so technically there is no part of the coast which can
be classified as “low erosion or stable coast”.

6. Extract from “The Last Frontier”: (7.4) Introduce regulations to manage the proliferation of
ports along the coasts, with possible impacts on coastline by considering cumulative
impacts of these developments.

The committee noted that currently, the shoreline of the country is undergoing a
major change because of a large number of port and harbour projects. These
projects involve large quantities of dredging, shore protection works, breakwaters,
and reclamation. The problem is that there is little information of the cumulative
impacts of these projects on the coastline.
The Committee was of the view that these developments have all led to serious
threats to the coast, as especially beaches face severe erosion and shorelines are
visibly changing. Given that the Central and state governments propose to construct
several ports and harbours all along the shore in the coming years, these projects
could have irreversible adverse impacts on the coast.
No: 34 Francois Martin Street, Pondicherry – 605001 Ph: +91-413-4210032
Email: Website:
The Committee recommends the following: “The government must immediately
study the cumulative impacts of the individual projects on the coastline, pending
which there should be a moratorium on expansion of existing ports and
initiation of new projects.

Our recommendation is that the MoEF should defer the consideration of all coastal projects particularly
those relating to ports, harbours and jetties until

 A detailed study on the cumulative impacts of ports is conducted

 The existing ports are upgraded to world class standards working at full efficiency and made easily
accessible by building a good network of roads and railway

 Enforcement of all mitigating measures, regulatory mechanisms / policies have been carried out on all
existing projects

 An effective monitoring committee, which should include the coastal communities, is in place to ensure
full protection of the coast

 The punitive provisions are incorporated that includes fines and imprisonment of violators

 The carrying capacity of India's coastline is determined

 The most suitable locations with relation to environmental, social and economic factors for future projects
have been identified and justified by the Centre in conjunction with States and coastal communities

The “1st National Convention for Protection and Restoration of India’s Coastline” proposed by us and agreed
by Shri Jairam Ramesh vide letter D.O. No19-11/2010-1A.III dated January 28, 2010, which would have the
participation of all the concerned Ministries, technical and environment experts, research institutes, coastal
communities, representatives from various development sectors and funding agencies, would provide an excellent
platform for strengthening the CRZ 1991 Notification for future sustainability of the coastline.

We therefore request you to kindly hold in abeyance the pre-draft CRZ Notification 2010 until comprehensive
consultations have been undertaken in a scientific, rational and participatory manner which will address both the
conservation measures that are required for a sustainable development of the coast as well as the needs and
aspirations of the coastal communities.

Best Regards

Probir Banerjee

No: 34 Francois Martin Street, Pondicherry – 605001 Ph: +91-413-4210032
Email: Website: