CRZ Violations

MAPPING THE EXTENT OF COASTAL
REGULATION ZONE VIOLATIONS

OF THE INDIAN COAST
REPORT
Prepared by
D. Nandakumar & M. Muralikrishna
For
National Fishworkers Forum

Valiathura, Thiruvananthapuram – 695 008
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CONTENTS
Forward
Acknowledgements
List of Tables
List of Figures
Chapter 1 Introduction 1–6
Chapter 2 Coastal Zone Management – The People’s Initiative 7–19
Chapter 3 The Comments of the MoEF of the CZMPs of Each State 19–34
Chapter 4 Analysis of the Violations at State Level 35–50
Chapter 5 Violations of Centrally Governed Mega Projects 51–58
Chapter 6 Field Observations and Comments 59–66
Chapter 7 Summary and Conclusion 67–69
References
Appendix I – CRZ Notification and the Amendments
Appendix II – Checklist
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21-11-1998
FORWARD
The National Fishworkers Forum (NFF) takes pride in looking back at the significant event;
the Kanyakumari March of 1989. It was an environmental march with a slogan “Protect Water/
Protect Life”. For the first time, the NFF raised the issue of the pollution of the water bodies all
over the coasts of India. The various problems caused by Industrial pollution, oil pollution, sew-
age pollution and other destructions due to dredging and reclamations were raised. The organic
link between the sea, the estuaries, the lakes and rivers were highlighted. The CRZ Notification
of 1991 was definitely a positive legal response to this outcry. The thirteen prohibitions in the
pronouncement have been radical enough to stop some of the causes of destructions to begin
with. However, the very judgement of the Supreme Court clearly shows that neither the coastal
states nor the Government of India took any steps to implement the CRZ Notification. Only the
Supreme Court judgement succeeded to force the State apparatus into operation.
This significant judgment emphasizes the customary rights of the coastal communities. Yet,
as the judgement is sometimes interpreted by the local governments, the working fishermen are
prevented from constructing houses in the CRZ. This was used by some political parties, who
actually ventilated the grievances of ‘developers’, industrialists and the tourism lobby, to demand
for an amendment. They did this even before acknowledging that the CRZ Notification was by
and large an important step in the right direction. Because of the non-commitment of some State
Governments to the execution of the Notification, these cries were made excuses for not enact-
ing control. This has resulted in continuation of the violations of the CRZ.
The NFF wanted to know the extent of these violations and decided to launch into this exer-
cise and because the assistance offered by D. Nandakumar and MuraliKrishna of Trivandrum
who generously trained the volunteers and conducted the entire study, this exercise was possi-
ble. Dr. N.D. Chchaya from Gujarat also lend his advice and assistance. We are deeply indebted
to them. We also thank the volunteers who undertook this task.
Harekrishna Debnath R.K. Patil

(Chairperson) (General Secretary)
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ACKNOWLEDGEMENTS
This work, even if incomplete for various reasons, has been possible because of the assist-
ance of numerous people who collaborated unstintingly because of their interest and commit-
ment to this particular issue. We thank each one profusely but do not mention each of them by
name except for RAMESH MASANI, a social worker in Gujarat was one who spontaneously
responded to the call of the mapping exercise. Although he had no idea regarding this issue, he
got intensely involved when he understood how CRZ violations affected the lives and livelihood
of coastal communities. Sadly, he died in a car accident right at the start of the fieldwork. We
cannot help recalling his enthusiasm and devotion to involve himself in people’s problem.
Our special thanks to Nalini Nayak, the National Committee member of NFF, for, without
her excellent co-ordination and relentless effort, this exercise would not have been possible.
And we thank T. Radhakrishnan, GAIA, Trivandrum whose moral and physical support
went all the way throughout the exercise and in bringing out this report with its GIS compo-
nent.
MuraliKrishna. M D. Nandakumar
Gaia Info Systems, Divakaramandiram, Dept. of Geography
Ayurveda College West Lane, University College
Trivandrum-695001. Trivandrum-695034
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LIST OF TABLES
1. Summary of the Physical features of the Indian Coast

2. Details of the survey done in each of the coastal States
3. Details of the CRZ of Karnataka
4. Percentage analysis of CRZ violations mapped across the country
on different categories
5. Percentage analysis across the country different categories in the NDZ
6. Different CRZ violations of Gujarat coast
7. Different CRZ violations of Maharashtra coast
8. Different CRZ violations of Karnataka coast
9. Different CRZ violations of Kerala coast
10. Different CRZ violations of Tamil Nadu coast
11. Different CRZ violations of Andhra Pradesh coast
12. Different CRZ violations of Orissa coast
13. Different CRZ violations of West Bengal coast
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LIST OF FIGURES
1. Coastal States of India with CRZ

2. Location of some major violations in the Okha-Veraval Belt: Gujarat
3. Location of some specific violations in Maharashtra
4. Location of some violations in Karnataka
5. Location of some violations in Kerala
6. Location some specific violations in Tamil Nadu
7. Location of some violations in Nellore and Prakasam districts in Andhra Pradesh
8. Location of some specific violations in Orissa
9. Location of violations in West Bengal
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CHAPTER 1
Introduction
The enactment of the Coastal Regulation Zone (CRZ) Notification of 1991 in India certainly
set the beginning of the State’s Involvement in the conservation of our coasts. The purpose of
enactment of CRZ Notification was to protect and conserve the coast and the sea. This environ-
mental concern drew from the environmental Protection Act, 1986. And the coastal communi-
ties, Peoples’ groups and conservationists welcomed this move. But it did create a furor among
other stakeholders of Industries, Industrial Aquaculturists and Tourism/Hotel Lobbies. Actually
the CRZ Notification violations affect the security and future of millions of traditional fishing
families which are threatened with physical and ecological displacement by industrial and land
developers looking for short term financial gain, rather than long term ecologically sustainable
use. And more often they violated the Notification and the traditional fishing community took
this legal weapon to fight. However, the unprotected vast stretches of our coasts certainly were
vulnerable to so-called ‘development’. Thus arose the need to know about the ‘conditions’ of
our coasts. Though there were reports of violations from here and there, no one knew the extent
of it at a macro scale. So this initiative is an attempt to systematically document the violations of
CRZ Notification, keeping in mind the spirit of the CRZ Notification rather than its legal jargon
(for the law and legality set the right loopholes for the violators!)
In the personal communication to the Additional Secretary, MoE & F, Bittu Sehgal writes that
the “land developers around the country are working overtime with state government officials to
encash literally thousands of crores of rupees worth of public lands. There is a similar move afoot
for forestlands and together the attack on coastal belts and forest belts will alter the survival ecol-
ogy of over 300 million people within the next three to five years. To my mind this represents a
more serious threat than any other development project or anti-people initiatives ever initiated on
the Indian subcontinent in the past 50 years. The net effect of both changes will be the creation of
vast monocultures in both forest and coastal belts: In forests, teak, eucalyptus, acacias, wattle and
poplars will clothe the commons. In coastal areas, salt marshes, wetlands, sand dunes, corals,
mudflats and mangroves – which are the breeding grounds of fish upon which coastal communi-
ties survive will be replaced by prawn farms, five star hotels, thermal plants, chemical and petro-
leum complexes, copper smelters, coastal highways and urban sprawl.” 1
Geography of Indian Coast

The coasts of India comprise a wide variety of diverse habitats and ecosystems – from estuar-
ies, coral reefs, seagrass beds, mangrove swamps, creeks, back waters and lagoons to bays,
1
Billu Sahgal, MEMBER. COASTAL TASK FORCE (1998) correspondence with Mr. Vishwanath Anand.
Additional Secretary, Ministry of Environment and Forests.
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2 Chapter 1
cliffs, sandy and rocky beaches. The linkages between these wide varieties of diverse habitats
and ecosystems are essential for the maintenance of food webs, migration routes and increased
productivity. These functions generate ‘goods’ (e.g. fish, seaweed, oil and gas and minerals) and
‘services’ (e.g. mangroves protecting the coasts against the storms, tidal waves; transport and
recreation). Such ‘goods’ and ‘services’ have an economic value as well.
India has a coastline of 7,500-km spread over 9 coastal states. It has 2.02 million sq. km area
of Exclusive Economic Zone (EEZ). The peninsular coasts of India have the Arabian Sea in the
west, the Bay of Bengal in the east and the Indian Ocean in the south. The influence of tides and
coastal geomorphology of the West Coast of the country is determined by the physical and cli-
matic factors of the central Indian Ocean region. This in turn influences the type and extent of
coastal habitats, dispersion patterns of coastal pollutants, seasonal patterns of erosion/deposi-
tion and beach migration and the effect of long term sea level changes on the coasts.
While the West Coast of the country has a broader continental shelf, the East Coast is char-
acterised by a narrow shelf. The Northern part of the Bay of Bengal is less than 3km deep and
increases along the continental margin of the East Coast southward. A similar bathymetric char-
acter is seen along the western margins because of its broader continental shelf. The average
depth of the India Ocean is about 4–5 km from here rises the Chagos-Maldives-Laccadive ridge
running parallel to the western margin of the country. Similarly the Ninetyeast ridge runs south
from the Andaman Islands to 33°S.
Table no. 1 Summary of the Physical features of Indian Coast
Coastal state Area (km2) Coastline (km) Population

Gujarat 1,96,024 1915.29 4,11,74,060
Daman & Diu 112 1,01,439
Maharashtra 3,07,690 510.31 7,87,06,719
Goa 3,702 113.03 1168622
Karnataka 1,91,791 258.15 44817398
Kerala 38,863 560.0 29011237
TamilNadu 1,30,058 864.73 55638318
AndhraPradesh 2,75,068 1037.0 66304854
Orissa 1,55,707 457.20 31512070
West Bengal 88,752 374.0 67882732
(Total) India 2,973,190 7,500 416317449
The West and East coasts of India are constantly subjected to the vagaries of Monsoonal
climate which is the dominant climatic regime of the northern Indian Ocean and its effects are
felt far into the subtropics of the southern hemisphere. The word ‘monsoon’ is derived from the
Arabic word ‘mausom’ meaning seasonally reversing winds. The northeast monsoon (December
to March) determines the climate of the northern Indian Ocean during Northern Hemisphere
winter. It is characterised by a high pressure over the landmass and a persistent northeasterly

Mapping The Extent of Coastal Regulation Zone Violations of the Indian Coast 3
wind over the coasts. The southwest monsoon determines the climate of the northern Indian
Ocean during the Northern Hemisphere summer (June – September); the low pressure is devel-
oped over northern Arabia and Pakistan; the rain lashes down the entire coasts. Apart from these
monsoonal regimes, the Indian coasts are constantly affected by the cyclonic storms. The
cyclonic storms are strongly concentrated in the Bay of Bengal, the Arabian Sea and the south
West Indian Ocean. The East Coast is subjected to some of the most severe storm surges in the
world. The surges cause an elevation in the sea level adding to the height of the sea level.2 And
when such surges occur during the spring tide they cause devastating effects on low-lying coast-
lines and rivermouths of the East Coast. West Coast experiences comparatively homogenous
wave climate throughout the year, and the current pattern is usually influenced by the shifting
of the intertropical convergence zone. Compared to this, East Coast has a varying climatic
regime. Every year the depression formed in the Bay of Bengal move towards the land and
strike the coast during April – May period. Calamities and hardships caused by this to Andhra
Pradesh, Tamil Nadu and to West Bengal and Bangladesh coasts are immense. Since this is a
meteorological phenomenon than an oceanic process, it needs different management outlook
specific to the East Coast.
The West Coast is fed with rapid, short and swift flowing rivers having hardly any delta
formations. The tidal range here is comparatively low. The only exception being in Gujarat
coast with the tidal amplitude ranging 11m. In contrast to West, East Coast rivers are long with
wide and extensive delta formations. One of the world’s largest delta formation and largest
mangrove ecosystems are found here in the East Coast. The West Coast has a wider continental
shelf compared to the East Coast. These characteristics added with the wave and current pattern
makes the West Coast rich in biotic wealth compared to the East Coast.
The continental shelf off the East Coast with its submerged reef formation causes refraction
of the long shore waves. Therefore, a calm condition prevails more or less throughout the year,
except during the northeast and southwest monsoon seasons. Currents reverse their direction
with the change of the monsoon – water moves from south west to north east during March to
September and opposite during the rest of the year. The sea off the East Coast appears to be
uniform but actually offers a wide range of habitats – both physical and biological. This becomes
apparent when the physical geography of the land itself offering various types of habitats like
the bay formations, creeks, estuaries, reefs, rocky or sandy shores etc., each with its own dis-
tinctive fauna. Of this, the greatest variety of life forms is seen in the pelagic zone. The wind
and current pattern, together with the heavy runoff from the several rivers flowing into the
Arabian Sea, cause a nutrient-replenishing coastal upwelling and account for the productivity
of the coastal waters which is comparatively higher in the west coast. One of such unique phe-
nomena occurring off the Kerala coast is the mud-bank formation (locally called ‘chakara’).
Prevalence of extreme calm conditions indicates the occurrence of ‘chakara’, an area rich in
aggregation of fishes and shrimp.
Sea surface temperatures are a major determinant to the existence and survival of all marine
and brackish flora and fauna. Recent analyses of historical sea temperatures data and sea sur-
face measurements in the Andaman Sea at Phuket, Thailand show a significant increase in the
2
Brown B E. (1997). Intcgrated Coastal Management: South Asia. Department of Marine Sciences and Coastal
Management. University of New Castle, UK. pp2.1-2.22

4 Chapter 1
sea surface temperatures for the eastern Indian Ocean over the last 50 years at 0.126°C per dec-
ade.3 Since the marine life is extremely sensitive to such changes, it can have serious implica-
tions to the future of marine fishery as well.
Ocean currents for both the East and West Coast show seasonal reversal. In the west coast,
the water masses circulate clock wise for about 8–10 months for the year, starting during the
onset of the south west monsoon and reversal occurs with the end of the monsoon season and
the counter clock wise motions is set in for the next 2–4 months. The circulation in the East
Coast is characterised by the clockwise flow during most months but strong counter clockwise
currents occur with the onset of the south-west monsoon.
In the West Coast, evaporation exceeds precipitation and runoff thereby adding to the salin-
ity of the Arabian Sea while in the East Coast, in the Bay of Bengal, due to higher runoff and
precipitation, there prevails low salinity.
CRZ Notification and its relevance to sustainability

As the sea provides the channel for communication to the other parts of the world, the coastal
areas with their natural harbors have grown to be the most densely populated pockets in India.
The impact of human activity in the coastal system is multi-faceted. Over the years, with tech-
nological development this has not only increased but also the increasing competition for the
coastal resources have caused conflicts between the resource users.
India with its 7,500-km coastline in 9 coastal states holds about 49% of the country’s popu-
lation. The coastal state has a population density ranging from more than 2000 person per sq.
km in Kerala to more than 600 person per sq. km against the national average density of 300
person per sq. km. The population load and the multifaceted activity in the region have led to
the deterioration in the quality of coastal life.
Major modifications in this thickly populated and resource rich coastal systems are the
result of the State intervention through coastal engineering structures; whether it is for the pro-
tection of the coast or for the coastal resource exploration and coastal area development.
More recently, the rising global demand for fish and fish products attracted Industrial
Aquaculturists to invest in coastal aquaculture. Traditional, low production type of aquaculture,
that has helped fill the plates of local households for centuries, is then supplanted by modern,
resource intensive, high production systems that cater to international markets. This restructur-
ing has contributed to the degradation of coastal ecosystems. The cultured organisms are raised
in a variety of aquatic milieus ranging from fresh water ponds to brackish water lagoons and the
coastal sea. They are composed of a wide variety of products such as finfish, shellfish, mollusc
and aquatic plants. Since they can be raised at different scales of operation from small home-
stead ponds, cages in flowing fresh water, impounded brackish lagoons and large-scale indus-
trial operations covering several hundred hectares artificially in sea and fresh water, it caught up
in the entire east and west coasts of the country.
The culture practices also cover a wide range of systems. They may vary from those that
depend heavily on natural forces like tidal variation with negligible human-induced inputs to
closely controlled operations in artificially built-up areas with very high externally induced mat-
3
IPCC (1995) Climate change 1995 impacts, adaptations and mitigation of climate change: scientific-technical
analyses. Cambridge University Press. 878pp.

ter and energy inputs. The cultured products may be part of a larger integrated agro-ecosystem
catering to the food needs of the locale or monocultures that cater to the luxury protein demands
of very distant international markets. Marine aquaculture is often profoundly wasteful and
destructive. Unlike the traditional, low productivity systems of fish and crustaceans farming that
have been undertaken by rural households, modern day marine aquaculture is a “big business”
that is both technology and capital intensive. Although aggregate economic and production sta-
tistics may suggest that production from aquaculture is providing handsome benefits to India’s
national economy, they provide little indication of the large-scale social, economic and environ-
mental disruptions that marine aquaculture is generating within coastal communities. The culture
of marine shrimp in India and other developing nations, for example, has had a devastating
impact on the ecology of coastal areas, displaced local inhabitants and their activities, disempow-
ered local actors from the management of common property resources, and fomented social
unrest. There is also growing evidence that the benefits and costs of marine aquaculture are not
evenly distributed within rural communities, as some impacts may hold particular consequences
for women either as participants in the industry or as members of households that are vulnerable
to negative externalities.
The Ministry of Environment and Forests (MoEF), Government of India issued
‘Environmental guidelines for Development of Beaches’ in 1983 to prepare Master plans for
the Development of the coastal stretches for each state. Under the environment (protection)
Act of 1986, MoEF declared coastal stretches as Coastal Regulation Zones (CRZ), regulating
all activities within this area. Coastal States and Union Territories are empowered to enact the
provisions of the CRZ Notification.
In this context, the coast can be defined as the land portion upto which the sea has its influ-
ence, from the low tide line (LTL). Tidal influence, reaches interior of land through rivers,
creeks, lagoons and backwaters. Therefore, according to the CRZ Notification, the coastal zone
encompasses all that land with which the sea has direct contact and also those portions of the
land on which the sea has an influence indirectly through tidal action.
As per the notification, the coastal stretches are categorised into different zones and certain
activities are restricted and regulated within the particular zone. The main objective of this noti-
fication is to conserve the rich and diverse coastal resources and for the better management of
the same.
As per the notification, the Central Government has declared the landward part of the coastal
stretches of open sea, bays, estuaries and any tidal water bodies upto 500 m from high water line
(HTL) and the land (beach) between the HTL and low water line (LTL) as the CRZ. HTL and
LTL as used in the CRZ Notification are synonymous to the High Water Line (HWL) and Low
Water Line (LWL). Certain restrictions are imposed on the setting up of/expansion of, opera-
tions/processes of industries, through this notification, which came into force from 19th Feb.
1991. Later certain amendments were made. The Indian Society for Enviro-legal Action filed a
public interest litigation in the Supreme Court in 1994, seeking the court’s intervention in direct-
ing the States to comply with its provisions. The writ petition also challenged the validity of the
amendments to the main notification of 1991, especially those which sought to provide the
Centre with discretionary powers to permit any construction within the 200 meters ‘No
Development Zone’ (NDZ) along any part of the coastline. This amendment was sought partly
to accommodate the interests of the hotel and tourism industry. As a result, the Supreme Court

6 Chapter 1
intervened and issued an order to all coastal state governments to prepare the management plans
of their coastal areas based on CRZ Notification and take necessary steps to implement this.
Consequently, all the nine coastal states prepared the plan and were approved by the ministry
but with certain conditions and queries to clarify many sections in the plans.
As per the notification, HTL is defined as the line upto which the highest high tide (simply
means the highest reach of sea during the highest high tide period) reaches at spring tide. The
distance from the HTL in any tidal water bodies can be modified on a case by case basis, however
this distance shall not be less than 100 m or the width of the water body which ever is less.
Except in the case of Kerala, all other states followed Survey of India (SOI) topographic
sheets to fix the HTL and recent satellite data is used to update it wherever there are drastic
changes in the shoreline. Kerala has made detailed field measurements to fix the HTL in 1995
at every one-km interval and satellite data is used to interpolate the rest of the values. The
Ministry is yet to approve this method, though it may be more accurate.

CHAPTER 2
Coastal Zone Management – The People’s

Initiative
As stated in the forward, the NFF, which represents the interest of the artisanal fishworkers, had
raised the issue of coastal pollution and damage to the coastal resources during the Kanyakumari
Coastal march. It called both for a management of coastal waters as well as the coastal zone as
fishing communities were threatened not only by depletion of fish but were being indiscrimi-
nately being displaced in favour of the development projects. The CRZ Notification was there-
fore welcomed by the NFF although all the bureaucratic secrecy and ambiguity that shrouded it
did not facilitate the popularisation of the Notification. Nevertheless, when the Supreme Court
directed the State to provide the CZM Plans, the NFF network moved into action trying to see
that the plans were objectively drawn up. Wherever there was some public discussions and
where the plans were accessible the NFF made its constructive contributions. It was only when
the submitted plans began to be contested by the State Governments and when there was a move
to scrap the Notification in the parliament, the NFF felt the need to create wider awareness
in the issue. It decided to map the existing violations of the coastal zone and for this it launched
a laborious exercise of training volunteers to undertake the task.
Training programs
The primary objective of the training programs was to make the coastal community aware of the
Government notification, its importance and the importance of the different coastal resources,
both biotic and abiotic and how important they are for their livelihood. The linkages of these
ecosystems with the different spheres of human life, their needs and the management of these
ecosystems were also dealt with. In addition to the training programs, a rapid survey on the status
of violations along the entire East and West coasts of the country was made with the help of the
volunteers of the locality. The responses from the volunteers were very participatory and they car-
ried out the survey with utmost sincerity and accuracy so that a representative sample for the entire
coast could be compiled and analysed. In addition to this, these trained volunteers would monitor
the future developmental activities in the coast and the violations of the CRZ Notification.
The training programs for the entire Indian coast were conducted in three centres, well dis-
tributed over the 7,500-km long coast of the country. The training centres selected were at Veravel
in Gujarat, Nagercoil in Tamilnadu and Diamond Harbor in West Bengal. The local fish workers
groups chose volunteers and were sent to the nearest training centres. The training was of three
days duration. A handbook was prepared in English and was sent to each state a month in advance
to be translated into the local languages for the volunteers and was distributed during the training
program. The handbook comprehensively explains the CRZ, its different amendments and

8 Chapter 2
explains with diagrams the different terminology used in the notifications. Since all the CZMPs
are basically in the map form, a section of the handbook is about maps: how to read a map, famil-
iarise different mapping techniques and also to identify HTL, LTL and to measure different zone
of CRZ. Simple techniques, which can be easily learned and adapted by any layperson, were
explained in the handbook. The training program included lectures on CRZ, coastal ecosystems
and habitats, map reading and demonstration through charts, maps and slides and field mapping.
In the discussion the volunteers from different parts of the country explained their experiences,
the different activities taking place in their premises. On the last day of the training program, the
volunteers were taken to the field for a real world experience of field mapping. Simple tech-
niques like pacing to measure the linear distances in which the paces of each volunteer were
standardised, is imparted. A trial filling of the Performa by each volunteer during the exercise
was done during the training program by mapping a couple of violations each. This was to equip
them to map independently in their respective designated areas.
In addition to the training in these three centres, local groups of different coastal states
organised a series of similar group meetings in different parts of the coasts. Except Goa, repre-
sentations from the entire coastal states participated in this countrywide exercise. During this
process we also could personally experience the different situations and developmental activi-
ties in different coastal districts of each coastal states which will be reflected in this report.
A checklist prepared along with the handbook is also translated into the local languages.
This has become a very useful tool for understanding and mapping of the CRZ Notification.
Violation mapping
A country’s coastline is a sensitive geographical feature, which not only gives the country its
character but also is an integral component of its economy. Created over centuries of geomor-
phologic changes, it composes numerous features, each with its own importance and richness,
Table no. 2 Details of the questionnaire surveys done in each of the coastal states.
States Total Violations Mapped Pockets Surveyed

Gujarat 10 Porbander, Veraval, Valsad, JamNagar
Maharashtra 44 Ratnagiri, Bombay, Thane, Palghar, Tarapur
Daman & Diu Not done
Goa Not done
Karnataka 35 Entire coast
Kerala 377 Entire coast
Tamil Nadu 18 Kanyakumari District
Andhra Pradesh 48 Nellore, Prakasam
Orissa 23 Ganjam, Baleswar, Gopalpur
West Bengal 177 24 Parganas, Midnapur
Pondicherry Not done

which need to be understood and conserved. With this sensitive ecosystem now being under
threat and with the fishing communities crying halt to interventions, Central Government has
notified coastal stretches of the country as Regulation Zones. This in itself, while being a safe-
guard, is not a comprehensive management tool. Yet enacting this regulation is a Herculean
task, which cannot be left to the Government alone.
The trained volunteers on getting back to their respective villages/municipalities shared
their knowledge acquired during the training to their comrades. They then proceeded with the
violation mapping. Though this cannot give a 100% view of the violation scenario of the coun-
try’s entire coastal stretch, it does indicate the extent and depth of ongoing destruction of our
coasts. This information was collected between June and September 1998. The mapping details
and the coastal stretches covered are given in the table no.2. The summary of findings are given
in the table no. 3 to 4.
The responses from some coastal states were few in number compared to others. However,
the data is quite representative given the enormity of the spatial extent of the Indian coast. The
Performa were compiled and appropriate statistical analyses was done. Those Performa, which
lacked clarity or with unfilled columns, were sent back to the concerned groups for further cor-
rection. The Performa that could not be corrected in this sort of process were eliminated from
the analysis.
The information of each state was then grouped into different categories according to the
nature of the violation. This is based on the CRZ Notification. According to each topic, zone,
and year of the events, tabulation of the questionnaires were done. The explanatory notes on
tabulated results are elaborated in Chapter 4.
Checklisting and surveys

A Checklist is prepared from the CRZ Notification with all the amendments included. This is
to simplify the CRZ Notification indicating prohibited, permitted and regulated activities in dif-
ferent regulation zones. The explanations of the conditions for the regulated activities are given
in the end of the checklist. The Performa were filled checklisting the prohibited and regulated
activities in different zones of the coastal stretches.
Review of CZMP of all Coastal States

All the coastal states have prepared the Coastal Zone Management Plan (CZMP) maps and
were all examined and approved by the Ministry of Environment and Forest and this notifica-
tion is now in force.
The Supreme Court has asked each coastal state to submit CZMPs by June 1996 despite the
fact that the report seems to be a guarded document. The confidentiality nature of the report still
exists even after the Ministry approved the report. Here, a brief review of the reports submitted
by each coastal state is attempted. Since we could not have access to some of the State CZMPs,
they are left out of this review. Tamil Nadu rewrote the report twice and what is reviewed here
may not be of the latest one. However, this review along with the comments from the Ministry
of Environment and Forests would give a clearer picture of what the state has worked out in this
regard. It should be noted here that the MoEF had asked each coastal State to finalise the CZMP

10 Chapter 2
on the basis of the comments send to each State within two months from September 1996, but
so far none has obliged it.
Gujarat plan
Department of Agriculture on behalf of the Department of Forest and Environment, Government
of Gujarat, prepared the Gujarat CZM plan. The plan briefly explains the notification and gen-
eral geography of the area and the different area falling under each CRZ zones of the notifi-
cation. The methodology for the preparation was not explained in it. The Space Application
Centre (SAC) classification of landuse was used for the presentation of the plan in the map
form. The SAC maps are prepared under the national program of coastal. Landuse mapping,
which is prepared using the SPOT satellite data. The national forest, reefs, coastal vegetation,
coastal forest, fish breeding area, historical and heritage area are demarcated in this map and
classified as CRZ-I. The municipal town and corporation has been classified as CRZ-II. Also
the notified industrial complexes with fully developed region, which are marked as black tri-
angles are categorised as CRZ-II which is not in accordance with the notification. As per the
notification only the legally designated urban areas should be categorised as CRZ-II other than
the municipal and corporation areas.
The fixing of HTL is a crucial in the case of Gujarat state for it has a tidal range of 11 m.
The methodology of fixing the HTL is therefore very important for Gujarat but is not mentioned
in the report. Evidently, extensive tidal flats are omitted, as the HTL has not been mapped accu-
rately. The SAC has made use of the information from the topographic maps (mentioned in the
AP report) to fix the tidal limits. The state government has fixed slab systems of 500 m, 350 m
and 100-m different regulation zones for different creek regions (from the discussions with
Deputy Director, Dept of Agriculture, Government of Gujarat) though the Notification advo-
cates demands 500 m (100 m from the width of the creek) from the HTL.
The State of Gujarat has opened up its coast for all sort of developmental activities, from
ship wrecking to aquaculture industry. This necessitate that the management plan should be
carefully prepared to conserve this unique, more so the fragile ecosystem of the Gujarat coast
which is India’s one of the richest fishing grounds.
General infirmities of the CZMP include the following points: – All ports irrespective of
whether or not they are in municipal areas/other legally designated urban areas are categorised
as CRZ-II. This cannot be accepted under any circumstances. Moreover the State Government
has not provided the names of the 10 ports that it intends to develop as part of the CZMP nor
the various jetties that are proposed by the various industries. The CZMP does not integrate the
State Government’s port policy with the jetty requirements of various industries.
Maharashtra CZMP
We couldn’t access the management plan
Goa CZMP
Goa State committee prepared CZMP of Goa for Environment, Town and Country Planning,
Government of Goa in 1996. Goa was one of the first states to respond towards the CRZ and the

coastal environmental management activity. This was initiated with the constitution of a com-
mittee under the Chairmanship of Chief Secretary to prepare a Status report on Environmental
Management Plan for the coastal areas, in 1988. Meanwhile, the Central Government was draft-
ing the Regulation Act. The terms of references of the committee are:
1. Identification of the present status, the landuse with in 500 m of the high tide line in map
form, evaluation of proposal for development, demarcating areas for conservation, preserva-
tion and development.
2. Evaluation of the status of marine/coastal pollution to take appropriate steps for its preven-
tion and abatement.
3. Evaluation of the legal and socioeconomic status of fishing villages along the beaches and
their implication to conservation and preservation of beaches.
4. Assessment of coastal ecosystem with particular reference to endemic species of flora in
contrast to monocultures of coconut palm along the seacoast.
Goa has submitted its plan way back in 1992. This was scrutinised by various Task Forces
of 1993 and 1995 of the Ministry of Environment. The State Government is consistent in its
stand not to include the tidal creeks within Coastal Regulation Zone. The fact that the state has
a unique geography in terms of its wide beaches, the tidal effect reaching far interiors and innu-
merable creeks. The final report was submitted in 1996, which is more of an explanatory note
presented in justifications to the queries of the Supreme Court. The State seems to have attempted
to safeguard its developmental policies rather than that of the true spirit of the notification.
The CZMP contains maps of typical coastal stretches of the state prepared at 1:10,000 scale.
The map depicts the settlement pattern, cultural features and linear features like roads, rivers
and the shoreline. The 200 m and 500 m lines are also marked from HTL. The HTL and LTL
are not labeled separately and the regulations along tidal waters are not mapped. The maps
available are not continuos and are not self-explanatory. They have neither the legend nor the
index map. As per the report, most of the coastal stretches falling within CRZ-III are earmarked
as areas for tourism promotion like resorts and hotels, which is not in accordance with the noti-
fication. At the end of the report village wise CRZ classification tables with explanatory notes
is given. Under the regulation zone, 9.65-km length of riverbank is included.
Daman and Diu CZMP

We couldn’t access the management plan
Karnataka CZMP
Coastline
i. Dakshina Kannada (12° 279 & 13° 589 N and 74° 359 & 75° 409 E)
ii. Utter Kannada (74° 099 & 75° 109 E and 13° 559 & 15° 319 N) length 320 kms. Few dunes –
near Mangalore, Coondapur, Honavar and Kumta.
Dak Kannada:
i. 160 kms, indented coast, 8 main rivers drain into it – Netravati, the Gurpur, the Udiyavara,
the Mulki and Pavange, the Sita and Swarna, the Haladi, the Chakra, Kollur and Baindur.

12 Chapter 2
ii. Two major ports – Mangalore port and Malpe Fishing Harbour and 6 minor ports
iii. Other infrastructures: NH 17 (west coast, road – Mumbai to Kanyakumari) and Konkan
Railway
iv. Industries – heaviest concentration around Mangalore, Kudremukh Iron Ore Project.
Utter Kannada:
i. 160 kms, Taluks – karwar, Ankola, Kumta, Honavar and Batkal. Coastal land is well
developed with a high degree of economic development followed by a high density of
population.
Fisheries: sea and inland, molluscs, oysters and prawns.

Coastal plain – 16 to 48 km stretch wide, depending on the nature of estuaries and the inter-
mediate tableland. Karwar port is situated on the Kali estuary. Laterite occurs extensively. Low
hills and plateaus. South of Aghanashini basin, the coastline is straight, sandy with dunes. Areas
cleared of sand support a poor rice economy. Dumps of cleared sand dune landscapes, and
locally these are known as Chitte lands.
Climate: Generally the two district has more or less similar climate along the coast. – High
humidity, 2,741 mm annual rainfall, about 87% of the total rain from the southwest monsoon
with July heaviest rain. Three meteorological observation in Uttara Kannada nearer to the coastal
strip – Shriali, Honavar and Karvar. Temp. 25 to 32 in coastal part. The only meteorological obs.
of Dakshina Kannada is at Mangalore.
Methodology: Base map SOI 1:50,000 (1967) and 1:25,000 (1981), latest available C.D.P maps
in the case of Karwar, Mangalore, Udupi and Malpe towns. Base line information on landuse
landcover prepared from satellite data information like HTL, LTL, roads, area under reserved
forest, rivers, backwaters, revenue boundaries, major land marks (State, district, Taluk bounda-
ries) other topographical features are directly traced from the SOI maps. The boundaries of
rivers, backwaters, HTL and LTL have been suitably updated using satellite data. Landuse land
cover mapping was carried out by visual interpretation of IRS LISS II and SPOT (FCC). The
maps are spread over 28 plates. The 500 m regulation zone is identified along the coastline and
100 m or width of the creek in tidal water body.
The coastal stretches are classified into 4 zones as per notification with respective survey
numbers and is given in a tabular form. The existing situation under each survey number, village
wise along the coastal stretches is tabulated based on their occupational setting.
Toposheet of 1:25,000 scale is used as the base map to depict the coastal features, HTL, LTL
and different CRZ Zones. Mangroves, mudflats, saline areas, fish breeding centres and protrud-
ing cliffs along the beaches are classified as CRZ-I.
Mangroves in each estuary are rated as good, moderate, very poor, though this categorisa-
tion is not stipulated in the Notification. All the urban areas and planned cities (Municipal areas
and corporation areas) are classified as CRZ-II, rest of the areas as CRZ-III. AONB, mining and
erosional spots, heritage and archeological areas coming under the CRZ are indicated.
In addition to the CZMP maps there is a table showing the revenue survey numbers of the
entire area listed into different CRZ categories. But the methodology how it was done is not
clearly mentioned. In the Karwar beach there are a few small islands, namely Kangi,

Table no. 3 Details of the CRZ of Karnataka (sq. km)
CRZ of Karnataka (sq. km)

Total area between HTL and LTL 30.07
Total area under CRZ-III 172.71
Total area under CRZ-II 15.70
Total area under CRZ-I 54.96
Total area under CRZ-IV 0.60
Total area under CRZ 274.04
Kumargadgudda, Shimirgudda and Anjudip islands that are under the Sea Bird area project,
which should be categorised under the Island category, CRZ-IV.
Kerala CZMP
The Science, Technology and Environment Department of the Government of Kerala was vested
with the responsibility of preparing the CZMP of the state. The Centre for Earth Science Studies
(CESS), an autonomous research institute under the State Government was instrumental in
executing it. CESS prepared a detailed report with original CZMP maps prepared at 1:12,500
scale and point measurements for HTL and LTL are given as an Annexure. The report has some
uniqueness while compared to that of other state reports.
As per the notification, the Chief Hydrographer is the sole responsible authority to demar-
cate the HTL for the entire Indian coast or the state has to demarcate the HTL and get it
approved by the authority. The HTL fixed 30 years back was the only source available. But
the coastal areas have undergone dramatic changes due to its dynamic nature. And the delay
of the chief Hydrographer in mapping the HTL, CESS was prompted to map the present HTL
(1991) and the methodology is well explained in the report. However, this methodology is yet
to be approved by the Chief Hydrographer. The methodology followed by CESS seems quite
logical and accurate than using the map prepared from satellite data prescribed by Government
of India to all coastal states. The other States prepared maps using the satellite data, of the
period 1989. This is done under the national program of “Remote sensing application for
Coastal area Studies” sponsored by Space Application Centre, Government India. The satel-
lite data used is of the resolution 20 m and the tree canopy cover is taken as delimiting line
for this method.
Systematic beach profiling was done at an average distance of 1-km interval and this is
transferred into the base map prepared from the topographic maps. Wherever there is sea wall
the sea ward side of seawall is considered. In the other places the land ward berm, i.e. the berm
that is not affected by the monsoon is considered. In some places vegetation line is taken as the
HTL by making use of the satellite data.
The CZMP of the state consist of 81 plates with 109 sheets. The map is marked with HTL,
LTL. 200 m, 500 m and 50 m regulation lines. Each regulation zone is hatched with different
pattern for easy reading. An index map of the state and the location of the sheet at district level

14 Chapter 2
are given along with the legend in each State. All the corporation and municipal towns are clas-
sified as CRZ-II. Thumba residential area is the only notified legally designated urban area,
which is also mapped as CRZ-II. There are 200 Panchayats, which are all categorised as CRZ-
III. The extend of the historical area and areas of out standing natural beauty are not mapped.
Only the location of each is written on the map and a separate table is given along with the text.
Mangrove forests and fish breeding areas are mapped and are categorised as CRZ-I. Sheet wise
description is given in the text. The proposed roads of the Town and Country Planning authority
were also included in the plan.
The report is well appreciated by the Ministry though there are some criticisms as well. The
areas east of Thannermukkam barrage are excluded in the plan. The Kumarakom, which has got
an extensive stretch of mangroves, is excluded on the grounds that the barrage is closed for
more than 6 months of the year. This Kumarakom mangrove stretch is a well-known bird sanc-
tuary of the State. Kerala Shastra Sahitya Parishad (KSSP) has filed a writ in the division bench
against this omission.
Though the map is prepared at 1:12,500 scale, these maps can be used only for guidance
rather than as a CZM plan. Taking into account of the coastal situation of the State, where plot
units are of small size, it needs field measurements on an individual basis for clearance. With
the changed political scenario of the state with new venture in the decentralized planning,
empowering the Panchayats in decision making process, it would have been more useful had the
plans been prepared at panchayat level.
Tamil Nadu CZMP

The Town and Country planning, Government of Tamil Nadu has vested the responsibility of
preparing the CZMP of the state. The initial plan prepared and submitted was rejected in toto
due to lack of information. Final CZMP could not be accessed.
Andhra Pradesh CZMP

The Andhra Pradesh Shore Area Development Authority of Environment and Forest, Science
and Technology Department, Government of Andhra Pradesh has prepared the CZMP of the
state. This is a voluminous report worked in detail at Cadastral scale, at plot level. The report
consists of 16 volumes, furnishing information of each Taluka in each of the volume. The report
is basically a compilation of the revenue boundaries with demarcation of different regulation
zones in it. The HTL was fixed and identified by Andhra Pradesh State Remote Sensing Centre
using satellite data. This was fixed in the cadastral map and the survey number falling with in
this zone is identified and categorised into different coastal regulation zones. The present lan-
duse of these plots were taken into account to arrive at the categorization of these regions into
different zones. The reports were prepared as separate volumes under the supervision of the
District collectors.
There are separate tables at mandal level to list the number of industries, tourist spots and
fishing villages in the area. The industry also includes the aquaculture activity and the salt pans
in the region. This is the only state plan that dealt information at state level which is quite essen-
tial for implementation and monitoring of the notification.

Of all the CZMPs of the coastal states, Andhra Pradesh’s stand out in its content and
method. The Plans are voluminous and was completed with in the time limit. The ambiguity
may be regarding its reliability. The fixing of HTL in Andhra coastal situation was by using
satellite data. Regarding the regulations in the water bodies upto the tidal effect areas; the state
has followed slab system of 500 m, 350 m and 100 m regulation zones depending on the width
of the water body. The tidal channel runs parallel to the coast well into the interiors which is 1
km away from the HTL and this is the area were intense aqua culture activity is taking place.
Therefore the appropriateness of the slab system to this locality needs reconsideration.
Orissa CZMP
The Coastal Zone Management Plan of Orissa was prepared by Orissa State Remote Sensing
Application Centre and assigned by Dept. of Forests and Environment. In the CZMP, Orissa
coast was divided into 4 areas –
i. Bhauda estuary to Chilka mouth
ii. Chilka mouth to Konark
iii. Konark to Paradeep
iv. Paradeep to Balasore
CZMP were prepared from the high resolution satellite data, SPOT (88–89) and 1993 IRS
1A and 1B was used in some cases for updating the information SOI maps (72–73) were used
as the base maps. The landuse classification based on the nationwide landuse mapping of the
Coastal Landuse conducted by SAC.
The report explicitly states the physical and demographic status of the region and also
information on the landuse. A change scenario of the Marine Fisheries statistics is given in
the form of a table over the period of 83 to 93. The status of aquaculture, the government’s
initiative in this regard, the status of mangroves, sand mining, port and about tourism in this
region are mentioned. The extend of the tidal reach in each rivers and creeks are tabulated
with distance from the estuary and the name of the village nearby is mentioned. This is of
great convenience to check the violation and also for the future management and develop-
ment. But as a whole the report doesn’t convey the entire need of the management plan for a
coastal region.
Lat. 19° 039 – 21° 379 N & Long. 84° 459 – 87° 309 E dominantly sandy with stretches of
mud flats with mangrove swamps. Mahanadi, Brahmani, Baitharani, Devi, Budhabalang,
Subarnarekha, Rushikulya and some other distributaries drain the coastal zone of Orissa. Av.
Spring Tide l–3m Av.Wave ht < 2m.
Rainfall 1100–1500 mm mostly from retreating SW Monsoon. Coast is quite vulnerable to
cyclones, storm surges, and floods. Between 1891–1989, 90 cyclones and severe cyclonic storms
occurred. Coastal hydrography is influenced by 2 major currents – north – easterly (Jan-July)
S westerly (Aug-Dec). The 480-Km long coastline. 6 coastal district, – Balasore, Bhadrakh,
Kendrapara, Jagatsinghpur, Puri and Ganjam & 82 admn.blocks. Prograding and depositional
environment- 6 major estuaries, rich mangrove belts. Asia’s largest brackishwater lagoon –
Chilka. Extensive non-vegetated wetlands, sandy beaches, beach placer rich in heavy miner-
als. Beach at Gahirmatha is the largest known rookery for Olive Ridley turtles, lepiodochelys

16 Chapter 2
olivacea (Dec-Jan & Mar-Apl). 2 rare sp. Of Horseshoe CRZbs occurs in abundance at Chandipur
at Balasore coast (inshore waters, creeks and sand flats) Sp. Tachypleus gigas & carcinoscorpius
rotundicauda. Fisherpopn. 1, 50,000 plus 1,00,000 fishers in Chilka. Supports 36% of total popn.
43% urban popn. Of the state.
Land-use: Cultivated cropland, irrigation canals, salt pans, aqua ponds and settlements, Orissa
sand complex (IRE), Chhatrapur, Chloroalkali plant, Ganjam, Phosphate factory, Paradeep.
40% coastal area is flood prone.
Continental shelf- 24,000 sq. km upto 200 m depth
Aquaculture: Government identified 17677 hect. of brackish water aqua culturable area, for-
mulated landlease policies under different Schemes. 1993 brought 8017 hect brought under the
scheme, mostly extensive type.
Mangroves: 195 sq. km at Bhitarakanika (Status of Forest Report, 1993). 62 sp.
Sand mining 18 km bet. Gopalpur and Rushikulaya estuary mouth, est. 230 mt of heavy miner-
als in 2900 hect of dune sands.
Two port – Paradeep port operational 1966, Gopalpur monor port in 1987 to cater the needs of
IRE.
Tourism – Puri, Konark, Chilka, Chandipur and Gopalpur.
Chilka lake – largest brackish water in Asia, also a Ramsar site.
Extent of tidal effect along the river and creeks.
River/creek Dist. in km Nearest village
1. Chhamu Nadi from Chilka mouth – Mangala Nadi 11.4 Jagannath patna
2. Mangala nadi 7.3 Khariapada
3. Nuanai nadi 6.4 Ura
4. Kushabhadra nadi (Paikpara) 22.0 Netyapur
Archaeological importance: Lord Jagannath temple (1100 AD), Konark temple (1250 AD)
West Bengal CZMP

Coastline 220 km (21° 359 N and 87° 309 89° 109 E) from the mouth of Subarnarekha on the
west to the mouth of the river Harinbhanga on the east covering important beaches like Digha,
Sankarpur, Bakkhali, Frezargaune, places of important like Ganga Sagar Island, Mangrove
forests of Sunderbans, Nijkasba and Khejuri, the wildlife sanctuaries (Sajnakhali, Halliday and
Lothian), one national park (Sunderbans National Park) the Sunderbans Tiger Reserve, the
Sunderbans Biosphere Reserve, Sankarpur Fishing Harbor apart from innumerable jetties and
fish landing centres within Sunderbans Biosphere Reserve. About 4,05,000 ha area exist within
CRZ for brackish water aquaculture.4
The plan states that the document is essentially a preliminary concept as stated in the title.
The document therefore serves a very limited purpose of indicating the first approach.
4
Shambhogue S.L. 1995 An overview of Coastal Fisheries and aquaculture. Workshop on CZMP by British
Council, Calcutta.

The Bengal basin is tilting gradually towards east – resulting in change of Ganga River
course which is now coursing eastwards through river Padma. The erstwhile river Course rep.
the tidal stream Hooghly, where tidal traverse ranges 200 kms upstream to Nawadwip area. On
the east the tidal range reaches Barishat town along river Ichamati. The entire intertidal zone of
Suderbans – demarcated from Kakdwip on west to Barishat on east. Subdivided into 3 principal
zones from east to west.
i. Eastern sector: From mouth of Harinbhanga river to mouth of river Hooghly are essentially
the Suderbans delta along the sea. Intertidal zone covers 9630 sq. km, out of it 2100 sq. km
mangrove; and 4264 sq.km area declared as reserved. Sandy coast – Halliday, Frazergunge,
Bakkhali and Sagar group of tidal shoals with recent dunes and runnels.
ii. Central sector: river Hooghly has a tidal excursion of 200 kms upstream; 30s q. km Nayachar
Island at the mouth of Haldi river. Khejuri and Nijkasba have mangrove patches.
iii. Western sector: essentially a coastal plain with 3 rows of dunes – earliest one continue from
Subernarekha to Junput with beaches of Digha and Shankarpur. From Orissa border Jatranal
is the zone of accretion Digha proper is the zone of erosion, east of Mohana to Chandpur
village end is a zone of accretion which again is followed by a zone of erosion on the east.
From the year 1582 to 1988 there were 16 major cyclones, 6 earthquakes, and 15 floods.
Tidal range – 5.5 m at Sagar and lm at 200 km upstream. Max. HWL is 3.05 m.
Pollution: oil tanker wash at sand head islands and Calcutta Metropolitan sewage drains 397
tons per day to Hooghly. Coast is devoid of sea grass and coral beds.
Mangroves: 34 true sp. and 33 associates. Tiger and Salt water crocodiles (crocodilus poro-
sus) form the apex of aquaterrestrial food chain. Endangered sp. – Fishing cats (felis viverim),
Leopard cat (F.bengalensis), Smooth Coated Otters (Iutra perpesillata), Gangetic Dolphin
(Platinista gangetica), Black finless porpoise (neomeris phocoenoides), Salvator Lizards
(veranus salvator), Bengal monitor (V. bengalensis), Olive Ridley (Lepidochelys olivacea),
Hawksbill turtle (erethmochelys imbricata) Green Turtle (Chelonia myrdus), rare esturine ter-
rapin (batagur baska). Endangered birds include Goliath Heron (Ardea goliath), White-bellied
Sea Eagle, Osprey, Lesser and Greater Adjutant Storks etc. Creek waters harbour the post lar-
val stage of ‘tiger prawn’ (penaeus monodon), edible Crab (scylla serrata), Horseshoe Crabs
(tachepleurus gigus and carcinoscorpius rotundicanda), eels, fish larvae and milkfish.
2/3 of the population within the central and within western sector. Eastern unpopulated
except Sagar, Mahisani, Namkhana, Fraserganj including the inter tidal reclaimed part about
5000 sq. km. Total population is 3.4 million – 50% SC/ST. Series of town ships from Hooghly
to Nawadwip town. Newly developing industrial complex and also a port at Haldia. Fishing
harbour at Shankarpur on the eastern side of Mohana River, also boat/trawler-manufacturing
Centre. In the eastern sector collection of post larval tiger prawns is a family occupation for
40,000 people catching an estimated 540-m post larvae/yr.5
Tourism: Digha attracts 1.5 lakhs people every year. Sagar – proposal for a marine park (800
sq. km) 100 visitors per day and doubles during the winter season. Annual pilgrimage at Ganga
Sagar – 1 lakh pilgrims. 50,000 tourists visit Sunderbans Tiger Reserve.
5
Choudhury AB, Choudhury A 1994, Mangroves of Sunderbans, India, Pub by 1UCN, wetland program

18 Chapter 2
The West Bengal CZMP which covers the 157 kms coastline, plus riverine system should
never be approved without a site visit to doubtful areas such as Digha and Sand Heads where it
is common knowledge that oil tanker wash is affecting the fragile CRZ-I Sunderbans mangrove
ecology. The state government has not clarified its position regarding the proposed Sagar Marine
Sanctuary and nor has the MoEF clarified to the State Government that its position about the
CRZ Rules being stopped above the Kulbi Point along the Hoogly River is bad in law as the
tidal effect goes past the city of Calcutta itself.

CHAPTER 3
The Comments of the MoEF of the CZMPs

of Each State
The Deputy Secretary of the Government of India has sent detailed comments on each of
the CZMP of the Coastal State on behalf of Ministry of Environment and Forest (MoEF),
Government of India, dated 27th Sept 1996. This is the approval letter of the ministry with
conditions specified to each state separately under the title “Special conditions /modifications /
classifications”. The general conditions stated in all the review letters of the state are the same
and are given below. Since the “Special conditions/modifications/ classifications” section of
each coastal state differs it is dealt with separately.
General conditions
i. All the relevant provisions of the Coastal Regulation Zone (CRZ) notification, 1991 as
amended in 1994 (after incorporating directions given by Honorable Supreme Court vide
its judgement dated 18.4.1996) shall be strictly incorporated in the CZMP.
ii. No activity that has been declared as prohibited, under Section 2 of CRZ Notification,
1991 shall be carried out within the Coastal Regulation Zone.
iii. The permissible activities shall be regulated in accordance with section 3 and follow the
norms for regulation as indicated in Section 6(2) of CRZ Notification, 1991 as amended
in 1994.
iv. The classification of Coastal Regulation Zone shall be in accordance with Annexure I,
Section 6(1). For development of Beach Resorts/Hotels in the designated areas of CRZ-
III, the guidelines indicated under Annexure-II shall be followed.
v. In addition to the information already available with Government of _______ (each
state is specified separately), all ecologically important and sensitive areas shall be
demarcated on the basis of the following sources of information and be classified as
CRZ-I.
(a) National Parks, sanctuaries and Marine Parks – information published, made avail-
able by Ministry of Environment and Forest (MoEF).
(b) All reserves and protected Forests as marked in the Forest Atlas updated through
Biennial Forest Report Status published by Forest Survey of India (Scale
1:50,000).
(c) Mangroves, Mudflats, Corals reefs/Corals – Maps prepared on the basis of Satellite
Imagery in the scale of 1:25,000 by Space Application Centre, Ahmedabad and the
information as published by MoEF.
(d) Breeding grounds for turtles, horse shoe Crabs – wildlife Institute, Dehradun.

20 Chapter 3
(e) Historical and Heritage sites – As listed with Archaeological Survey of India, State
Departments of Archaeology, Culture and Tourism in addition to the sites, if any,
mentioned under specific conditions of this letter.
(f) Areas rich in genetic diversity – Information published/furnished by MoEF.
(g) Areas of outstanding natural beauty – State Government (specifically each State
government) to decide keeping in view the generally recognized perception regard-
ing such areas.
(h) Sea level rises due to global warming – National Institute of Oceanography, Goa. In
case requisite information is not available from the sources mentioned above, infor-
mation obtained from other sources may be used after approval of MoEF.
vi. On the basis of further studies or in the event of any additional such information brought
to the notice of State/Central Government, all areas that are ecologically sensitive and
important (as per CRZ Notification) shall be classified as CRZ-I by the each State
Government (specifically given each State) with the prior approval of MoEF.
vii. The State Governments, which have prepared maps on 1:25,000 scale through satel-
lite imagery for the purpose of delineating the HTL, should submit these maps to the
Chief Hydrographer, Government of India for the purpose of demarcation. Those State
Governments that were not in a position to prepare the maps in this manner should sub-
mit them to the Chief Hydrographer, Government of India for the purpose of demarca-
tion. It is advisable that whenever there is any doubt, any development activity should
not be permitted after ground measurements from the HTL taking into consideration
marks left by water, presence of mangroves, mudflats and beach.
viii. State Government (specifically to each state government) shall delineate LTL, HTL,
200 m, 500 m, lines and other relevant lines in respect of creeks, backwaters and rivers
affected by tidal action so that distances can be measured, whenever required.
ix. All uninhabited islands would be classified as CRZ-I (subject to continuation of existing
traditional rights, special rights and customary uses) except those islands, which have
been approved by MoEF as CRZ-IV. In case of uninhabited islands classified as CRZ-I,
in exceptional cases should a carrying capacity study establish conclusively that the
proposed development will not have adverse ecological impacts, those particular islands
could be reclassified as CRZ-IV, subject to prior approval of Ministry of Environment
and Forest.
x. Each State Government (specifically to each state) shall ensure that all development
and activities in CRZ areas take place within the framework of the approved Coastal
Zone Management Plan. Violation shall be subject to the provisions of Environmental
(Protection) Act, 1986 and other relevant laws.
xi. State Government (specifically to each state) or any authority so designated shall be
responsible for the monitoring and enforcement of provisions of CRZ Notifications and
CZMP.
xii. Approval of this CZMP would not imply approval of any proposed project such as roads,
airports, jetties, ports and harbors, building etc; indicated in the plan/map.
xiii. All mangroves with an area of 1000 square meters or more would be classified as CRZ-I
with a buffer zone of at least 50 meters.
xiv. Dredged materials will not be disposed within the CRZ area.

xv. Sand dunes are classified as CRZ-I.

xvi. Parks, play grounds, regional parks, green zones and other non-buildable areas falling
within CRZ-II areas are categorised as CRZ-III.
xvii. State Government (specific to each state) shall not make any changes in the approved
categorization of CRZ areas without prior approval of Ministry of Environment and
Forests, Government of India.
xviii. State Government (specific to each state) will give wide publicity to CZMP and indicate
the list of places where it is available/can be inspected.
Special condition prescribed for each coastal state by Ministry is given below separately.
Special condition/modification/classification Gujarat

i. For rivers, creeks and back waters a slab system of CRZ as follows is approved:
(a) 100 m or width of the creek, river, backwater, which ever is less, if the width of the
creek, river, backwater is upto 100 m.
(b) 100 m if the width of the river, creek, backwater is between 100 m and 300 m.
(c) 150 m if the width of the river, creek, backwater is more than 300 m.
(d) 150 m if the width of the river, creek, backwater is more than 300 m.
ii. The categorisation of Dharangthar and Kavathar areas are kept pending till the decision
regarding status of this area has been given by Hon’ble Gujarat High Court in the Case
No. 2870 of 1996.
iii. The CRZ areas in the five municipalities, namely Chhaya, Chorwad, Jafrabad and Salaya
are categorised as CRZ-III.
iv. Only the substantially built-up portion of CRZ area shown in the maps submitted by
Government of Gujarat in the municipalities of Bilimora, Jamnagar (Survey no. 63),
Mandavi, Mangrol, Porbander and Valsadare are categorised as CRZ-III.
v. The CRZ area within Bhavnagar municipal limits, if any, and in Navsari municipality are
categorised as CRZ-III.
vi. Details requested for the determining various areas proposed for CRZ-II categorisa-
tion, namely Patan and Surat; all the 17 industrial complexes and all the 43 ports and
ship breaking areas mentioned in the CZMP have not been completely furnished by the
State Government. In view of this, it is decided that a committee may be set up under the
Chairmanship of the Chief Secretary with at least two NGOs as members to identify and
demarcate CRZ-II areas within the proposed CRZ-III areas. 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 % or more, such areas (built-up and buildable) are
classified as CRZ-II provided the same conforms to the criteria of CRZ-II as per the CRZ
Notification. The remaining areas will be classified as CRZ-I or III as applicable. A copy
of the final categorisation of CRZ-II so made will be sent to this Ministry for record.
vii. Inhabited islands as mentioned in the CZMP are classified as CRZ-IV. Government of
Gujarat is to submit to MoEF, details on size of the islands for a decision on the setback
limit for no development for these islands. Till such time the set back limit for these
islands is decided by Ministry of Environment & Forests, Government of India, no con-
struction in these islands shall be permitted upto 200 m of High Tide Line.

22 Chapter 3
viii. Government of Gujarat shall submit to MoEF 1:25,000 scale Maps prepared on the basis
of Satellite Imagery by SAC, Ahmedabad within two months of obtaining from SAC,
Ahmedabad after incorporating the conditions/modifications/ stated in the approval letter.
The plans submitted by Government of Gujarat vide letter No. ENV-1090-GOI-165-P dated
19.6.96 is not in conformity with the conditions indicated above. These modifications may be
made and the modified plan and the maps should be sent to this Ministry, within a period of two
months, for records.
Special condition/modification/classification for Daman and Diu

i. Along the rivers (Kolak, Daman Ganga and Kalai), creeks and backwaters, the CRZ areas
having mangroves and mudflats are classified as CRZ-I and in these areas, the extent of
CRZ will be 100 m or upto the width of the mangroves and mudflats, whichever is higher.
If there are no mangroves/mudflats, the extent of CRZ will be 100 m or width of river,
creek or backwater whichever is less.
ii. The sea-shore where Kolak river meets the sea is classified as CRZ-I.
iii. From the area marked in map as CRZ-I, upto Daman distillery in Nani Daman, the area is
classified as CRZ-III.
iv. Area south of Daman distillery upto Daman Ganga river in Nani Daman, is classified as
CRZ-II.
v. In Moti Daman, area from South of Daman Ganga river upto the Moti Daman police sta-
tion, is classified as CRZ-II.
vi. The area from Moti Daman police station to the Southern Municipal limits, is classified as
CRZ-III, from the High Tide Line eastward upto the main road is classified as CRZ-II.
vii. Both Moti Daman, Nani Daman forts are classified as CRZ-I, with a No Development
Zone of 200 m.
viii. With respect to Jammpore Bay, developments and activities will be undertaken only after
demarcation of HTL by Chief Hydrographer.
The plan submitted by UT Administration of Daman and Diu vide letter No. DOF/DMN/200/96-
97/432 dated 20.8.96 are not in conformity with the conditions indicated above. These modifi-
cations may be made and the modified plan and the maps should be sent to this Ministry, within
a period of two months, for records.
Special condition/modification/classification Maharashtra

i. Island forts and forts along the coast are classified as CRZ-I.
ii. The entire Malvan Marine Sanctuary in Sindhudurg district is classified as CRZ-I.
iii. The sand dunes south of Malvan town (in Sindhudurg district) upto the creek at Devbag are
classified as CRZ-I with a buffer zone of 50metres. Other sand dunes are also classified as
CRZ-I with a buffer zone of 50 meters.
iv. The nursery within /outside Ratnagiri town up to CRZ limits is classified as CRZ-III.
v. The alignment of coastal bund in New Bombay will be so aligned that it is on the land-
ward side of the mangroves.

vi. The mudflats and mangroves to the west of the coastal bund in New Bombay would not
be reclaimed. To maintain the mudflats, water ingress should be ensured through cul-
verts or any other form of water channel that may be expedient to maintain the nature of
the mudflats.
vii. For any proposed coastal road project in New Bombay, a separate proposal may be sub-
mitted to MoEF, which would be examined on its merit.
viii. All areas marked in the Development Plan of New Bombay as Regional parks are classi-
fied as CRZ-III. These include Nerul and Nhava, the areas mentioned in the environmen-
tal clearance issued by this Ministry vide letter No. j-11013/21/88-I A. dated 16.9.1988
for Nhava Sheva Port project, viz., the green area of 500 meters all along the periphery
of the port; 800 ha of afforestation, along with mud flats and mangroves on the shore line
around Nhava. are classified as CRZ-I.
ix. The inner part of the loop (the Island around which Selapur CBD in New Bombay is situ-
ated, is classified as CRZ-I as agreed to by the State Government, subject to infrastructure
development in the form of road and rail projects. The island of Vagivali is classified as
CRZ-I and the restriction of CRZ-I would apply only to the island.
x. It shall be ensured that the fresh map of Kalyan Municipal area to be submitted is con-
sistent with the document.
xi. The area of mudflats at Sewri is classified as CRZ-I.
xii. The area with mangroves in the Mithi river estuary is classified as CRZ-I.
xiii. The non-municipal areas of Murud-Janjira in district Raigad are classified as CRZ-III.
Within the municipal limits those areas which have been classified as No Development
Zone (NDZ)/ Green Zone are classified as CRZ-III.
xiv. The area of Bordi, which is outside the municipal limits of Dahanu town, is classified as
CRZ-III,
xv. As already agreed to by the State Government, the golf course in Colaba will be included
as a Green Zone in the Development Plan of Great Bombay with FSI less than normally
permitted for Green zone areas. No change in this classification will be made without the
prior permission of MoEF.
xvi. Elephanta Island is classified as CRZ-I except for the village, which is classified as CRZ-
III upto its boundary.
xvii. The following areas in Thane district (Bhawar, Tarapore, Mangalpada, Dhanapada, Bordi
and Cchinchwar) are classified as CRZ-III except for those areas in Dddahanu taluka,
which are classified as CRZ-I.
xviii. The Coastal Regulation Zone in respect of the creeks, rivers and backwaters is as fol-
lows:
a. 100 metres or less where the width of the rivers, creeks or backwaters is upto lOOme-
tres or less.
b 100 meters where the width of the river, creek, or backwater is in the range of 100-
350 meters.
c. 150 meters where the width of the river, creek or backwater is more than 350
meters.
xix. All those areas in Greater Bombay along the western coast falling in No Development
Zone as per the Development Plan for Greater Bombay are classified as CRZ-III.

24 Chapter 3
xx. Details requested for determining whether various areas proposed for CRZ-II catego-
rization such as Gaothans Madh, Erangal, Manori, Aksai, Gorai and other residential
zones in Greater Bombay and New Bombay have not been furnished by the Government
of Maharashtra. In view of this, it is decided that a committee may be set up under the
Chairmanship of Chief Secretary with at least two NGOs as member to identify and
demarcate CRZ-II areas within the proposed CRZ-II areas. For the purpose of determin-
ing 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 50per cent or more, such areas (built up
and buildable) are to the criteria of CRZ-II as per the CRZ Notification. The remaining
areas will be classified as CRZ-I or III as applicable. A copy of the final categorization
of CRZ-II so made will be sent to this Ministry for record.
xxi. The write-up submitted in the CZMP is not fully in conformity with the provisions of
the CRZ Notification. This will stand approved only to the extend that it conforms to the
general and specific conditions contained in this letter.
The revised plan as per the conditions/ modifications mentioned above shall be sub-
mitted to this ministry within two months for record.
Special condition/modification/classification Goa

a) CRZ along sea coast
Pernem taluka
i. Tiracol Fort area is classified as CRZ-I and settlement area is classified as CRZ-III.
ii. The whole stretch of Querim is classified as CRZ-I because of outstanding natural
beauty and sand area except settlement area, which is classified as CRZ-III.
iii. The whole stretch falling in Palien village is classified as CRZ-III.
iv. Sand dune and mangrove areas falling in Arambol village is classified as CRZ-I expect
settlement area, which is classified as CRZ-III.
v. Settlement area falling in Mandrem village is classified as CRZ-III. Sand dunes, man-
groves and turtle nesting sites are classified as CRZ-I.
vi. Sand dunes, mangrove and turtle nesting site falling in Morjim village are classified as
CRZ-I and settlement area is classified as CRZ-I.
Bardez Taluka
i. In Anjuna village, chapora Fort is classified as CRZ-I and rest of the area is classified as
CRZ-III.
ii. Calengute area is classified as CRZ-III except sand dunes, which is classified as CRZ-I.
iii. Candolim is classified as CRZ-III except sand dunes and forts, which are classified as
CRZ-I.
Tiswadi Taluka
i. Dona Paula is classified as CRZ-I being a fort area.
Murmugoa Taluka
i. Substantially built up area of Vasco having approach roads, drainage and other infra-
structure facilities is classified as CRZ-II, rest is classified as CRZ-III.

ii. Dabolia, Chicalim, Chicolna, Issorcam and Sarcola areas are classified as CRZ-III.
iii. Pale and Velasso areas are classified as CRZ-III. Cansaulim and Arossim are classified
as CRZ-III except sand dunes, which are classified as CRZ-I.
Salcete Taluka
i. The entire villages falling in Salcete Taluka namely, Utorda, Majorda, Consua,
Betalbatim, Ccolva Sernabatim. Benaulim, Varca and Cavellossim are classified as
CRZ-III except sand dunes, which are classified as CRZ-I.
Guepem Taluka
i. The villages of quitol and Naquerim are classified as CRZ-III.
Cancanona Taluka
i. The whole of Cola stretch is classified as CRZ-I except settlement area, which is classi-
fied as CRZ-III.
ii. In Agonda the entire Agonda village is classified as CRZ-I except built up areas which
are classified as CRZ-III.
iii. N agarcem area is classified as CRZ-I except settlement and built up areas, which are
iv. Area falling in Paiguinium village is classified as CRZ-III.
v. In Loliem, the entire stretch is classified as CRZ-I except settlement and built up areas,
which are classified as CRZ-III.
Along banks of rivers, backwaters and creeks
i. Along the rivers namely Tiracol, Chapora, Mandovi, Zuari, Sal, Talpona, creeks and
backwaters in Goa influenced by tidal action, the extent of CRZ will be either 100
meters or width of the river or creek or backwater which is less.
ii. Along Tiracol River, tidal influence is felt up to Patradevi. All areas up to Patradevi
within the CRZ having mangroves including mouth of Kerim bay, near Paliem, Densua
Konad, Naibag and Torxem are classified as CRZ-I and rest as CRZ-III.
iii. According to NIO, in Chapora River, tidal influence is felt up to Ibrampur in Tillari
River whereas in Osalna river it is felt up to Eelpur.
iv. All along Chapora river areas with mangroves including areas of river mouth, Siolim,
Chopdem, Oxel, Tuenbank, Colval, Revora, Pirna are classified as CRZ-I and other
areas classified as CRZ-III.
v. According to NIO in the various tributaries of Mandovi river i.e., in Madei tidal influ-
ence is up to Gauiem in Khandepar river up to Odi Karvada in Singquerim up to Verem
and in the three feeders of other tributary, the Maousa river tidal influence is up to
Mapusa, Tivim and Mulgao.
Special Conditions/Modifications/Classifications for Karnataka

i. Details requested for determining various areas proposed for CRZ-II categorization,
namely Karwar, Kumta. Honavar, Bhatkal, Baindur, Gangolli, Coondapur, Surathkal
and Mangalore have not been furnished by the State Government. In view of this, it is

26 Chapter 3
decided that a Committee may be set up under the Chairmanship of Chief Secretary with
at least two NGOs as members to identify and demarcate CRZ-II areas within the pro-
posed CRZ-II areas. 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% or more, such areas (built up and buildable) are to be classified as CRZ-II provided
the same conforms to the criteria of CRZ-II as per the CRZ-I or CRZ-II so made will be
sent to this Ministry for record.
ii. The survey number furnished in the CZMP (Annexure-I) will be cross-checked with the
map and the running note to remove discrepancies, if any.
iii. In sheet No. 1 uninhabited islands, forest areas, mudflats and sand dunes are classified
as CRZ-I and rest as CRZ-III.
iv. In sheet No. 2 Anjadip Island is classified as CRZ-III, reserve forest areas as CRZ-I and
the rest as CRZ-III.
v. In sheet No. 3 all the mudflats are classified as CRZ-I and remaining area as CRZ-III.
vi. In sheet No. 4 casurina plantations, areas of outstanding natural beauty, reserved forests,
mudflats, marshy lands are classified as CRZ-I. Rest of the area is classified as CRZ-
III. The CRZ-II area of Karwar will be decided by the Committee headed by the Chief
Secretary.
vii. In sheet No. 5 uninhabited islands, reserved forest, sand dunes and areas of outstanding
natural beauty, mudflats are classified as CRZ-I and rest of the area as CRZ-III.
viii In sheet No. 6 uninhabited islands, casurina plantations, forests lands, mangroves are
classified as CRZ-I and rest of the area as CRZ-III.
ix. In sheet No. 7 historical areas, areas of outstanding natural beauty, mudflats and man-
grove areas are classified as CRZ-I and rest of the area as CRZ-III.
x. In sheet No. 8 mangroves, mudflats marshy areas are classified as CRZ-I and rest of the
areas as CRZ-III.
xi. In sheet No. 9&10 mangroves, mudflats and uninhabited islands are classified as CRZ-I.
Inhabited islands, rural and agricultural areas are classified as CRZ-III. Regarding
Kumta town the CRZ-II categorization will be decided by the committee headed by
Chief Secretary.
xii. In sheet No. 11 uninhabited islands, mudflats and mangroves are classified as CRZ-I.
Rest of the area is classified as CRZ-III.
xiii. In sheet No. 12 the casurina plantations, mudflats and mangroves are classified as CRZ-I.
Rest is classified as CRZ-III.
xiv In sheet No. 13 Heritage area and the cliff area are classified as CRZ-I and rest of the
area as CRZ-III.
xv. In sheet No. 14 area classified as CRZ-III, except reserve forests, which are classified as
CRZ-I
xvi. The area in sheet No. 15 is to be classified as CRZ-III, except reserve forests, which are
classified as CRZ-I.
xvii. In sheet No. 16 the settlement areas are classified as CRZ-III, except mangroves and
mudflats which are classified as CRZ-I.
xviii. In sheet No. 17 the reserve forests and mudflats are classified as CRZ-I. With respect to
CRZ-II categorization of Bhatkal TMC, decision will be taken by the Committee headed
by Chief Secretary. Rest of the area is classified as CRZ-III.

xix. In sheet No. 18 mudflats and reserve forests are classified as CRZ-I. Rest of the area is
xx. In sheet No. 19 mangrove areas are classified as CRZ-I and undeveloped areas as CRZ-II
categorization of Baindur will be taken by the committee under the Chairmanship of
Chief Secretary.
xxi. In sheet No. 20 CRZ-II categorization of Gangooli town and Coondapur town will be
decided by committee headed by Chief Secretary. Marvantha coast, mangroves and mud-
flats are classified as CRZ-I and rural areas as CRZ-III.
xxii. In sheet No. 21 CRZ-II categorization of Coondapur will be decided by Committee
headed by Chief Secretary. Sand dunes and mangroves areas are classified as CRZ-I and
rest of the area as CRZ-III.
xxiii. In sheet No. 22 mudflats, mangroves and areas of outstanding natural beauty and unin-
habited islands are classified as CRZ-I and undeveloped areas as CRZ-III. Decision on
CRZ-II will be taken by a committee headed by Chief Secretary.
xxiv In sheet No. 23 mudflats, mangroves, forests and areas of outstanding natural beauty are
classified as CRZ-I and rest of the area as CRZ-III.
xxv. Areas in sheet Nos. 24&25 are classified as CRZ-III.
xxvi. In sheet No. 26 mangroves, uninhabited islands and mudflats are classified as CRZ-I.
Regarding Surathkal town the decision will be taken by the committee headed by Chief
Secretary. Rest of the area is classified as CRZ-III.
xxvii. In sheet No. 27 areas of outstanding natural beauty, casurina plantation, mudflats and
mangroves are classified as CRZ-I. Regarding proposed CRZ-II areas, decision will be
taken by committee headed by Chief Secretary.
xxviii. In sheet No. 28 area from Ullal to Someshwara is classified as CRZ-I. Someshwara
Cliff, spit, mangroves and mudflats are classified as CRZ-I. Categorization of proposed
CRZ-II areas will be decided by committee headed by Chief Secretary. Rest of the area
is categorised as CRZ-III.
xxix. Areas in sheet No. 29 are classified as CRZ-III. Barring mudflats, mangroves and forest
areas, which are classified as CRZ-I.
xxx. The CRZ for creeks, rivers and backwaters will be 100 m where width of the creek, river
or backwater is less than 350 m and will be 150 m where the width of the river, creek or
backwater is 350 m or more.
xxxi. All fish breeding area and protruding cliffs along the beaches are classified as CRZ-I.
The revised plan submitted by Government of Karnataka vide their letter dated 6.9.96 is not
in conformity with the conditions indicated above. These modifications may be made and the
modified maps should be sent to this Ministry within a period of two months for record.
Special Conditions/Modifications/Classifications for Kerala

i. Details requested for determining various areas proposed for CRZ-II categorization, namely
Kasaragod, Kanhangad, Payyannur, Kannur, Tellicherry, Badagara, Kozhikode, Tirur,
Ponnani, Chavakkad, Kodungallur, Cochin, Parur, Tripunithura, Alapuzha, Kayamkulam,
Cherthala, Kollam, Paravur, Varkala, Thiruvananthapuram, Vaikkam have not been fur-
nished by the Government of Kerala. In view of this, it is decided that a Committee may
be set up under the Chairmanship of Chief Secretary with at least two NGOs as members

28 Chapter 3
to identify and demarcate CRZ-II areas within the proposed CRZ areas. 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% or more, such areas (built up
and buildable) are to be classified as CRZ-II as per CRZ Notification. The remaining
areas will be classified as CRZ-I or III as applicable. A copy of the final categorization of
CRZ-II as made will be sent to this Ministry for record.
ii. All areas of outstanding natural beauty/historical/heritage area mentioned in the plan
namely Puvar south, Pulinkudi-Kovalam, Sankumugham, Veli, Papanasam-Varkala,
Edava, Kappil, Pozhikkara, Mundakkal (Jonnapuram), Thirumullavaram, Palliyamturuth,
Alapuzha, Fort Kochi, Cherai, Bekal, Kottikulam, Vettukad, Papanasam, Pozhikkara-
Paravur, Neendakara, Arthungal, Kottukal, Anjengo Fort, Thangaserri, Karunagapally,
Ambalapuzha, Vaikom, Mattancheri, Chennamangalam, Parur, Chemanchery-Quilandy,
Bekal will be marked as CRZ-I after identifying spatial extend of these areas, even if these
areas are surrounded by CRZ-II or CRZ-III areas.
iii. The distance from the High Tide Line to which the CRZ regulations will apply in case of
rivers, creeks and backwaters shall be kept as 100 m (not 50 m as proposed) or width of
the rivers, creeks or backwaters whichever is less.
iv. The existing discrepancies in the plan i.e., between the running notes, the tables and the
map will be rectified.
The plan submitted by Government of Kerala vide Chief Secretary’s D.O. letter No. 221/
B1/94/STED dated 29th January 1996 is not in conformity with the conditions indicated above.
These modifications may be made and the modified plan and maps should be sent to this
Ministry, within a period of two months, for record.
Special Conditions/Modifications/Classifications for Tamilnadu

i. The monumental zones of Mamallapuram, Poomphuhar, Nagore, Rameshwaram,
Thiruchendur and Kanyakumari upto 500 m are classified as CRZ -1.
ii. The islets and “theevus” near Keelakaral are classified as CRZ -1.
iii Along the rivers creeks and back waters which are influenced by tidal action, the CRZ will
be extend upto 500 m. However, the CRZ will extend only upto 100 m along rivers. creeks
and backwaters within areas which are categorised as CRZ-11.
iv. With respect to Pallikarainai swamp, the Tamilnadu Government will re-examine to ascer-
tain whether the area falls within CRZ, it will be classified as CRZ - I.
v. With respect to Coovum river, Ennore creek and Buckingham canal, the State Government
will get a study conducted to ascertain the extend upto which tidal action is experienced
and classify the area as CRZ.
vi With respect to Sadras and Tranquebar, the areas are classified as CRZ-I except settle-
ment areas, which are classified as CRZ-III.
vii In Sheet No.! & 2, the entire stretch is classified as CRZ-I except settlement areas, which
are classified as CRZ-III
viii. In sheet No. 5 the entire belt is classified as CRZ-III except the southern portion of estuary
which is classified as CRZ-I.

ix. In sheet No. 6 & 7 the settlement areas are classified as CRZ-III and rest of the area as
CRZ-I
x In sheet No. 8 the stretches classified as CRZ-I except settlements, which are classified
as CRZ-III.
xi. In sheet No 9 the stretch is classified as CRZ-III
xii In sheet No. 10 Rural habitation areas are classified as CRZ-III and Cuddalore town
areas are classified as CRZ-I. South of Gadilam river is classified as CRZ-II.
xiii. In sheet No. 11 area northern portion is classified as CRZ-III and area South of Vellar
River as CRZ-I. Porthova is classified as CRZ-III.
xiv. In sheet No. 12 northern portion is classified as CRZ-I and other coastal belt devoid of
ecologically sensitive areas classified as CRZ-III.
xv. In sheet No. 13 the stretch is classified as CRZ-III except the heritage town which is
xvi. In sheet No. 14 built up area is classified as CRZ-II, rural settlements as CRZ-III and
heritage areas as CRZ-I.
xvii. In sheet No. 15 reserve forests, are classified as CRZ-I. except settlement area, which
is classified as CRZ-III.
xviii. In sheet No. 16 the stretch is classified as CRZ-I, except the settlement area which is
xix. In sheet No. 17 Vedaranyam swamp is classified as CRZ-I and Adhiramapattinam as
CRZ-III.
xx. In sheet No. 18, the stretch is classified as CRZ-I, except settlement area, which is clas-
sified as CRZ-III.
xxi. In sheet Nos. 19&20 the stretch is classified as CRZ-I, except settlement area which is
xxii. In sheet No. 22 the whole stretch is classified as CRZ-I, except settlement area which
is classified as CRZ-III and Mandapam as CRZ-II.
xxiii. In sheet No. 23 built up area of Rameswaram is classified as CRZ-II Pamban area as
CRZ-III and rest of the area as CRZ-I.
xxiv. In sheet Nos. 24&25 the stretch is classified as CRZ-I except settlement areas which
are classified as CRZ-III.
xxv. In sheet No. 26 Saltpan is categorised as CRZ-I, settlement area as CRZ-III and built
up municipal area as CRZ-II.
xxvi. In sheet No. 27 Rural belts are classified as CRZ-III, Tiruchendur town as CRZ-II and
lagoon area as CRZ-I.
xxvii. In sheet No. 29, the stretch is classified as CRZ-III except for river mouth, which is
xxviii. In sheet No. 30 built up area of Kanyakumari town is classified as CRZ-II, other areas
as CRZ-III and area close to Manakkudi Kayal is classified as CRZ-I.
xxix. In sheet No. 31 built up area of Kanyakumari town is classified as CRZ-II and rest of
the area as CRZ-III.
xxx. In map Nos. 1&2 the stretch of Madras Metropolitan area is classified as CRZ-II and
areas in Map Nos. 3, 4&5 are classified as CRZ-III.

30 Chapter 3
The revised plan submitted by Government of Tamil Nadu vide letter No. 16342/EC-III/91-65
dated 23.8.96 is not in conformity with all the conditions indicated above. These modifications
may be made and the modified maps should be sent to this Ministry within a period of two
months, for record.
Special condition/modification/classification Andhra Pradesh

i. Heritage areas of Bhimunipatham as per Annexure are categorised as CRZ-I.
ii. In the Guntur District reserve forest area in the Repelle, Nizamopatnam & Pittavalanipanem
mandal to the extent falling in CRZ area as categorised as CRZ-I
iii. In the East Godavari District, the accretions 1, 2&3 in the Pilanka Village in Tallrevu man-
dal are categorised as CRZ-I subjecting to existing uses only.
iv. In the West Godavari District, since Koller lake is a fresh water lake (already notified of
CRZ Notification. All reserve forests are classified as CRZ-I.
v. In the Nellore District, the following modification are made:
a. Village Channayapalan in Kavali mandal is categorised as CRZ-III.
b. Wet lands in Kavali mandal are categorised as CRZ-I.
c. In the Chittmur mandal, the entire reserve forest area and swamp in village
Aruru is categorised as CRZ-I
d. In Kalagurthipadu village, the entire Survey No. 306, of salt swamp is categorised as
CRZ-I.
e. The SHAR area has not been categorised into any category of CRZ-I, II or III until
further orders from Ministry of Environment and forests, Government of India.
f. All islands in Pulicat Lake are categorised as CRZ-I. The portions of these islands
where there is habitation/agriculture use are classified as CRZ-III.
vi. In Krishna district, the areas proposed as CRZ-I in Koduru, Machilpatnam (expect the
areas within the municipal limits itself) Mandavalli, Kaikallur are classified as CRZ-
III. In Nagaya mandal all uninhabited islands in Rivers/Sea are categorised as CRZ-I
subject to provisions of general condition A (ix) above. In the villages of Tallapallem
and Manginakudi, all unsurveyed portions is categorised as CRZ-I, subjected to exist-
ing land use, if any. In the Gudur mandal, the 200 m to 500 m areas from HTL shall
also be shown in the map. Kolleru Lake is not categorised as CRZ. In Kaikalur mandal
the survey No. 75 in village Koliada is categorised as CRZ-III and not as CRZ-II. In
Kruthivennu mandal the villages of interu and Nidamaru the swamp land in Survey No.
94 is categorised as CRZ-I and not CRZ-III. The CRZ-I zone shall be shown in the map
along Chinagothapalam village.
vii. In the 1:25000 scale maps, changes shall be made in classification and categorization as
stated against each map no. as follows. Map No. 63L/I SE the areas marked as 3.5, 3.101
are CRZ-I. Map No. 62/L SE all areas like 3.6, 3.10 and adjacent to BOB are CRZ-I and
areas beyond this are CRZ-III. Map No. 65 L/3 NW, all areas of category 2.1, 3.6, 3.10
are CRZ-I and beyond that it shall be categorised as CRZ-III. In the following Map Nos.
areas demarcated as 3.6, 3.10 are CRZ-I: 65 H/11 NE, 65 K/8 SW, 65 L/5 NW, 65 L/3 NE,
65 L/l NE, 65 L/2 SW, 65 H/15 NW, 65 H/11 NE, and 65 H/7 NE. Map No. 65 H/11 SW
the entire blue area shown is categorised as CRZ-I Map No. 65 H/11 NW the entire area

shown as blue in Upputeru River, bounded in North, upto embankment is categorised as

CRZ-I.
In Krishna District, all areas as 3.6, 3.10 in the following maps are categorised as CRZ-I:
65 H/11 NW, 65 H/7 SW, 66 A/13 SE, and 66A/13 NE. In map 66 E/I NW, all areas shown
in blue colour and all areas marked as 3.6 in the pink area are CRZ-I. In Map No. 65 H/3
SE. In the Lazzabanda drain, all areas marked as 3.6 are categorised as CRZ-I. Map No.
65 H/7 SE all areas west of Padu village is in blue colour, except West of 81 129300 is cat-
egorised as CRZ-I. Bandar fort to the extend falling in the CRZ is categorised as CRZ-I.
In Map No. 65 H/4 NW, the entire blue area shown is categorised as CRZ-I. The yellow
area shown with category of 5.1 is also categorised as CRZ-I (or III if portion of 5.2 lie in
the pink shaded zone). Map No. 65 H/4 SW, all blue areas, North and East of embankment
(approx. 81 59), except agricultural land is classified as CRZ-I.
In the Guntur District, all areas marked as 3.6, 3.10 in the Map Nos. 66 A/9 NE, 66
A/9 NW, are categorised as CRZ-I. In Map No. 66A/13 NW, the entire blue area, in
Nizampatham mandal is CRZ-I. In Map 66 A/9 SW the entire blue area, expect North of
3.12 area of Nagarajukoiva be categorised as CRZ-I. In Map No. 66 A/13 SW, the entire
area is categorised as CRZ-I.
In Prakasham District all areas marked as 3.6, 3.10 are categorised as CRZ-I. Map No.
66 A/2 NW all blue areas shown are categorised as CRZ-I Map No. 66 A/2 SE all blue
area shown, except gundlakamma river proper is categorised as CRZ-I. Map No.64 B/4
NW, the entire blue/pink area shown bounded by 3.6 and areas, as the case may be, in the
main river channel is categorised as CRZ-I.
In the Nellore District, the entire yellow areas shown in Map Nos.66 O/2 NE and 66
O/1 SE shall not be categorised into any category pending further orders from MoEF.
Map Nos. 66 B/2 SE, all areas shown south of Yeradipalli is categorised as CRZ-I. In Map
No.57 N/16 NE and 66 E/3 SW the entire blue area shown is categorised as CRZ-I. In
Map No. 66 B/2 NW, the areas shown as 3.10 are classified as CRZ-I.
viii. In the areas approved as CRZ-III the No Development Zone as defined in the CRZ notifi-
cation shall be 200 m from HLT.
ix. For rivers, creeks and backwaters, a uniform 500 m of Coastal Regulation Zone is
approved.
x. All the wards mentioned in the Government of Andhra Pradash letter in respect of
Vishakapatnam Municipal area the Muvvalavanipalem Ward/Locality which has been
categorised as CRZ-III. All wards/locality mentioned in Government of Andhra Pradesh
letter in the municipality, except bandarkota are categorised as CRZ-II. For Kakinada port
areas the categorisation of wards proposed as CRZ-I is to be decided by the committee
headed by Chief Secretary.
xi. Details of CRZ-I areas mentioned in Guntur district are to be shown in the plan clearly.
xii. Details requested for determining various areas proposed for CRZ-II categorisation,
namely Kakinada Municipal area, Vishakhapatnam Port and Kakinada Port areas have
not been completely furnished by the State Government. In view of this, it is decided that
a committee may be set up under the Chairmanship of Chief Secretary with at least two
NGOs as members to identify and demarcate CRZ-II areas within the proposed CRZ-II
areas for the purpose of determining whether an area is substantially built-up, the ratio

32 Chapter 3
of built-up plots to that of total plots is to be ascertained. Where this ratio is 50% or more
such areas (built-up and buildable) are to be classified as CRZ-II provided the same con-
forms to the criteria of CRZ-II as per the CRZ Notification. The remaining areas will be
classified as CRZ-I or III as applicable. A copy of the final categorisation of CRZ-II so
made will be sent to this Ministry for record.
The plan submitted by Government of Andhra Pradesh vides letter No. 10003/SADA/95
dated 1.2.96 is not in conformity with the conditions indicated above. These modifications may
be made and the modified plan and the maps should be sent to this Ministry, within a period of
two months, for record.
Special conditions/modifications/classifications for Orissa

The categorisation of areas into CRZ-I/II/III/IV, as mentioned vide Government of Orissa letter
No. 20750/E&F/EE-11/96 dated 10.9.96 are not approved. With reference to CZMPs submitted
earlier, the following modifications/classifications are made:
i. All mangrove vegetation in the Paradip urban region, including the mangroves in Musadiha
and Boitarakuda is classified as CRZ-I.
ii. In the Paradip-Balasore stretch, the following two areas are also classified as CRZ-I.
(a) The Chandipur protected forest.
(b) Waterbodies. Waterlogged land adjacent to mudflats in the area of the confluence of
Kansbans river upto Jamka Nadi and then upto confluence of Paga Nadi.
iii. Satpada Island of Chilka is classified as CRZ-III.
iv. In the Bahuda-Chilka lake zone, the following modifications are made in the categorisa-
tion of CRZ area:
(a) Sand dunes in the region around Markundi, Nuagolabanda and Baksipalli are classi-
fied as CRZ-I.
(b) Mudflats around the creeks of ambagnai are classified as CRZ-I.
(c) Orissa sand complex near Matiknalo village is classified as CRZ-III.
(d) The industrial area of Chlorg-Alkali plant near Rushikulya estuary is categorised as
CRZ-III.
v. A slab system for demarcating Coastal Regulation Zone along the banks of rivers, creeks
and deltas and Bhitarkanika area where the CRZ shall be 500 m. shall be as follows:
(a) 150 m in case the width of the river, creek, backwater is more than 350 m.
(b) 100 m in case the width of the river/creek/backwaters is less than 100 m.
vi. A 200-m line from HTL shall also be demarcated on the maps for the areas, which have
been categorised as CRZ-III.
vii. Islands which are inhabited or where some developmental activities have already taken
place are classified as CRZ-III, subject to categorisation of CRZ-I areas, if required, as
per notification for portions of such islands.
viii. Mahanadi-Brahmani-Vaitrani Deltas are classified as CRZ-I, except the settlement areas,
which are classified as CRZ-III.
ix. All reserve/protected forest areas between Konark and Puri in the CRZ are classified as
CRZ-I, other CRZ areas in this stretch are classified as CRZ-III.

x. Turtle migratory routes, as ascertained form Wildlife Institute, Dehradun, will be classi-
fied as CRZ-I.
xi. Dhamra fishing jetty is classified as CRZ-III.
xii. Urban areas of Konark and Balasore (Chandipur) are classified as CRZ-III.
xiii. In urban area of Gopalpur wards No. 1 to 11 are classified as CRZ-II.
xiv. The entire Chilka Lake CRZ area is categorised as CRZ-I, except the portions of CRZ
where there are habitations/agriculture, which are categorised as CRZ-III.
xv. The portions of Chilka cuter channel which are ecologically important and sensitive as
per the requirements of the CRZ Notification are categorised as CRZ-I. Other areas of
channel where there are habitations/agriculture are categorised as CRZ-III.
xvi. Mukitola islands is categorised as CRZ-I.
xvii. All fishing harbors not falling within municipal limits are categorised as CRZ-III.
xviii. Chandipur defense area and wheeler Island defense area is not categorised into any cat-
egory, pending further from MoEF, Government of India.
xix. Within Paradip Municipal area, 4 wards are classified as CRZ-II. Other areas within
Paradip Municipal area, except Paradip Port area are categorised as CRZ-III.
xx. Details requested for determining various areas proposed for CRZ-II categorisation,
namely Puri Municipal area, Ealugaon and Rambha NAC areas and Gopalpur and
Paradip Port areas have not been furnished by the State Government. In view of this, it
is decided that a Committee may be set up under the Chairmanship of Chief Secretary
with at least two NGOs as member to identity and demarcates CRZ-II areas within the
proposed CRZ-II areas. 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% or more, such areas build-up and buildable are to be classified as CRZ-II
provided the same conforms to the criteria of CRZ-II as per the CRZ-I or III as appli-
cable. A copy of the final categorization of CRZ-II so made will be sent to this ministry
for record.
xxi. Classification in 1:25000 maps shall be in accordance with CZMP submitted earlier, sub-
ject to conditions/modifications indicated in this approval letter.
The plan submitted by Government Orissa vide letter No. 16498/F&E/EE-26/95 dated
16.8.95, 22245/F&D/EE26/95 dated 31.10.95 and 14658/F&D dated 27.6.95, is not in
conformity with the conditions indicated above. These modifications may be made and
the modified plan and the maps should be sent to this ministry, within a period of two
months, for record.
Special conditions/modifications/ classifications for West Bengal

i. For Digha Development Area, sectors A-l, B-5, F-1, H-1 and N are categorised as CRZ-
III. The sectors B-l, B-3, B-4, B-4, B-7, C-5 E & E-3 are categorised as CRZ-II.
ii. In case of Haldia Development Area, the area proposed by the State Government, which
includes the Haldia Port Complex Area only is categorised as CRZ-II. The CRZ for Haldia
shall be 100 m from the HTL.
iii. In case of river Hooghly, CRZ regulations will be applicable upto Southern Municipality
limit of Diamond Harbor Municipality and not upstream of this limit.

34 Chapter 3
iv. A CRZ of 500 m throughout will be applicable for Hooghly river, except for the portion
of Haldia area as shown in the approved map, where it will be reduced to 100 m.
v. In case of Haldia river, the CRZ will be applicable upto the confluence of river Haldia
with Roop Narian Canal. The Coastal Regulation Zone will be 500 m from HTL in the
river Haldia, except for the portion of Haldia Development area for which the CRZ will
be reduced to 100 m, as shown in the approved map.
vi. The Dunes/Runnels in CRZ areas are classified as CRZ-I.
vii. Fraserganj is classified as CRZ-I.
viii. For Digha/Shankarpur area, the portion upto sand dunes shall be classified as CRZ-I and
area beyond dunes, if any, upto 500 m from HTL shall be CRZ-III or II as stated in condi-
tion No. B (I) above.
ix. The following clarification/changes are to be made in the 1:25000 scale maps:
(a) All areas in the following maps are categorised as CRZ-I: 79 C/9 NE; 79 C/9 SE; 79
F/4 SW; 79 G/l SW & NW; 79 C/10 NW, NE, SE, SW; 79 C/13 SE, SW, NW, NE; 79
C/14 SE, NW, SW, NE.
(b) Areas outside Dampier Hodges line are not shown as CRZ.
(c) Gangasagar Island is categorised as CRZ-I subject to continuation of existing tradi-
tional rights, special rights and customary uses.
The plans submitted by Government of West Bengal vide letter No. EN/437/IE-46/87 (Pt.
II) dated 10. 4. 96 is not in conformity with the conditions indicated above. These modifications
may be made and the modified plan and the maps should be sent to this Ministry, within a
period of two months, for record.

CHAPTER 4
Analysis of the Violations at State Level
The performa collected were tabulated and analysed in computer using appropriate statistical
packages. The performa, which were incomplete and incorrect, were sent back to the concerned
group to verify and make necessary corrections. In the final tabulation, some of the performa
were scrutinized further due to the ambiguity of the information in it. Thus screened performa
were categorised into different themes and zones. The percentage analysis at state wise on dif-
ferent categories gives a clear picture of this, given in tables 4 and 5. The violation in the NDZ
has been separately tabulated and is given in table 5. Though the survey was attempted for the
entire coast of the country the sample collected can be only representative of that particular area
and varies from the neighbouring village or city So in the section below the details of the coastal
stretch covered in each of the state is mentioned along with other details
Tabulation of performa were done for different themes in both the NDZ and between the
200–500 m zones separately and also for CRZ-I, II and III. The themes selected were on the
nature of the activities and with reference to the CRZ Notification into tourism, industry, infra-
structure, reclamation, aquaculture and mining. All these themes have been referred to sepa-
rately in the notification as each of these activities has a different impact in the coastal system.
An overview of the CRZ Violation is depicted in the map of India. (see fig. no. 1).
Though the attempt was made on the above-mentioned themes, all activities need not be
relevant to many parts of the country. For instance, mining was reported only in the coast of
Kerala state though this is taking place else where in the coast. The mining in the Kerala coast
reported is basically sand mining from beach dunes and from riverbeds.
All the themes are sub divided into “new” and “expansion” of the existing structures. The
“new” means any new construction of that particular theme. Expansion of the old includes
expansion of the exiting structure, extraction of ground water and pollution due to the related
activity. Reclamation means reclamation of tidal water bodies, mangroves, marsh and even
agricultural wetlands Aquaculture theme is categorised into two: hatchery and aqua ponds.
Though most of the hatcheries are only for namesake, they are operating as aquaculture ponds.
Mining is categorised for seaside and riverside. And this category is for the extensive sand min-
ing in the beaches and riverbeds of the Kerala coast.
State wise analysis of violations

Gujarat
Only a rapid survey was conducted and ten violations were reported from Gujarat. It covers
some areas in Porbander, Jamnagar, Bhavnagar, Kutchh, Bharuch, Daman and Valsad. Though

36 Chapter 4
COASTAL STATES AND CRZ

INDIA
Gujarat West Bengal
Orissa
Maharashtra
ARABIAN Andhra Pradesh BAY

SEA Goa OF
Karnataka BENGAL
Tamil Nadu
CRZ
Kerala
GAIA/GIS
Figure 1.
Table no. 4 Percentage analysis of CRZ violation mapped across the country on different
categories
Total
surveyed Tourism Industry Infrastructure Reclamation Aqua culture Mining
West Bengal 177 4.39 1.12 – – 94.35 –
Gujarat 10 – 50 50 – - –
Tamil Nadu 18 77.78 5.56 16.67 – - –
Karnataka 30 82.76 13.77 – – 3.45 –
Andhra Pradesh 48 – – – – 100 –
Kerala 377 28.12 39.52 5.77 11.67 10.34 477
Orissa 24 4.17 – – – 95.83 –
Maharashtra 44 2.27 28.81 – 69.45 13.64 –

1 AREA SURVEYED IN CRZ
OKHA
Q023-DRAFT-Chapter_01 to 04.indd 37
Gulf
of
Kuchch
2
3
2 3
PORT PORBANDAR
CRZ VIOLATIONS - GUJARAT
1. Infrastructure and Tourism
VERAVAL 2. Ports and Harbours

Mapping The Extent of Coastal Regulation Zone Violations of the Indian Coast
3. Industries and Infrastructure

Arabian Sea Arabian Sea
CRZ
GAIA / GIS
37
Figure 2.
8/29/2009 2:40:51 PM
38 Chapter 4
Table no. 5 Percentage analysis across the country on different categories in the NDZ
Aqua
Total Tourism Industry Infrastructure Reclamation culture Mining
West Bengal 177 3.39 0.56 90.39
Gujarat 10 50 50
Tamilnadu 18 44.44 5.56 1.11
Karnataka 30 82.76 13.77 3.45
Andhra Pradesh 48 100
Kerala 377 26.25 38.73 5.77 11.67 10.34 4.77
Orissa 24 4.17 37.5
Maharashtra 44 2.27 28.81 69.45 13.64
* The total of which does not include the 200 to 500 m CRZ
the region is experiencing drastic growth in the industrial and infrastructure development,
especially the coastal areas of the state, only ten violations were reported. With the liberalisa-
tion policy and abundant availability of raw materials, the country’s best fishing grounds are
being encroached into by polluting industries like the ship wreck industry and cement indus-
tries. The development of these polluting industries has adverse effect on the fishery resource
of the state. Out of the 10 violations 50% are contributed by industries and rest of 50% by
infrastructure development like construction of jetties and ports. The summary of violations is
given in table no. 6. Location of some major violation sites between Okha and Veraval belt is
depicted in the map No. 2. All the ten violations recorded are within the NDZ and of this five
are in the CRZ-I.
Table no. 6 Different CRZ violation of Porbander, Jamnagar, Bhavnagar,

Kutchh, Bharuch, Daman and Valsad of Gujarat
Number of violations in
NDZ 200–500 m
Industry 5 None recorded
Infrastructure 5 None recorded
Maharashtra
Raigad, Mumbai, Sindhudurg, Thane and Ratnagiri districts of Maharashtra were surveyed for
the violations and 44 violations were recorded Reclamation and construction related activities
together constitute to 69.45% of the total violations. There are extensive reclamation activities
taking place in the suburbs of the Mumbai Metropolitan City and in the Thane creek, both the
areas are tidal marshes with mangroves. Industrial area contributes to 28.81% of the violation.
The pollution of Tarapur Industrial estate is visible not only for its obnoxious smell but the
extent to which it has spread out into the sea. It is as if the whole sea has turned red and not far

LOCATION OF SOME VIOLATIONS IN MAHARASHTRA
Madhya Pradesh
Gujarat
1 Dahanu
2 Tarapur
3 Palghar
4 Thane
5 Bombay
CRZ VIOLATIONS - MAHARASHTRA

1. Industrial Pollution
2. Shrimp farms & Industries
Ratnagiri 3. Reclamation & Constructions

6
Arabian 4. Reclamation & Constructions
Sea Andhra Pradesh 5. Tourism
Karnataka
0 100 200 300 Km
Goa
GAIA / GIS
Figure 3.
39
8/29/2009 2:40:52 PM
40 Chapter 4
from this location the Tarapur Atomic Power Station impose the horizon with its huge dome on
the horizon sowing invisible death. Aquaculture and related activities contribute to 13.64% and
tourism contributes to 2.27% of the total violation. The summary of the violation in the state is
given in the table no. 7. Location of some specific violations in Maharashtra is depicted in the
map No.3.
Table no. 7 Different CRZ violation of Raigad, Mumbai, Sindhudurg,
Thane and Ratnagiri districts of Maharashtra
NDZ 200–500 m
Tourism 1 None recorded
Reclamation 30 None recorded
Aquaculture 6 None recorded
Of all the 13 industrial violations recorded three are in the CRZ-I and ten in CRZ-III. Within
the CRZ-III itself 9 violations are either in ‘new’ or ‘polluting’ category. Of the 30 reclamation
violations, twenty are either reclamation of tidal marsh or destruction of mangroves for urban
development.
Karnataka
As for the Karnataka coast, the north Kanara and South Kanara districts are surveyed for the viola-
tion mapping and 30 violations were recorded Of the 30 violations, 82.76% are tourism related,
clustered around Uduppi, Mavalli and neighbouring areas Industrial activity contributes to 13.77%
and aquaculture 3.45%. All the violations recorded are in the NDZ, of this 21 violations recorded
are in the tourism sector and all are in CRZ-III. Location of some specific violations in Karnataka
coast is given in map No. 4.
Table no. 8 Different CRZ violation for Uduppi and North Kanara
of Karnataka
NDZ 200-500m
Kerala
Kerala is the only state for which violation mapping was carried out throughout the coasts.
Though Kerala has a well-prepared CZM Plan, the State’s interest is to relax the notification
so as to accommodate the ‘development’ in the state. Different committees were constituted
to dilute the present accepted plan, but to no avail. Thanks to the resistance put up by peoples
groups. The plan enforces all that is mentioned in the original notification. The survey was

LOCATION OF SOME VIOLATIONS IN KARNATAKA
Maharashtra
Goa Andhra
Pradesh
1 Karwar
Arabian 2Bhatkal CRZ VIOLATIONS - KARNATAKA

Sea 1. Industries
3Udupi 2. Tourism
3. Industries, Tourism, Housing
4Mangalore Bangalore 4. Tourism & Industries
0 100 200 300 Km

Tamil
Kerala Nadu
GAIA / GIS
41
Figure 4.
8/29/2009 2:40:52 PM
42
LOCATION OF SOME VIOLATIONS IN KERALA
Karnataka
1 Bekal
Kannur
2
3 Kozhikode
Tamil
Nadu
Arabian 4 Kodungallor
CRZ VIOLATIONS - KERALA
Sea 5 Kochi
1. Tourism
2. Destruction of Mangroves and Shrimp farms
3. Industries and Tourism
4. Shrimp farms
5. Reclamation and Industries
6. Tourism
Trivandrum 0 150 300 450 Km
6 Kovalam
GAIA / GIS
Figure 5.
Chapter 4
8/29/2009 2:40:52 PM
conducted only in the coastal stretches and not on the back water systems which has significant
tidal effects.
Of the 377 violation recorded, major chunk, 39.59% contributes to industrial related activi-
ties. Tourism constitutes to about 28.12% of the total, which concentrates on certain pockets
like Kovalam, Bekal, Cheri, etc. Of this, 26% is in the NDZ which is representative to what is
happeing to the coastal Kerala. Within this category, out of 106 violations, 73 are ‘new’ con-
structions. Industrial activity includes large projects like the Naptha based power projects at
Kannur and Vypeen to small scale units, both ‘new’ and ‘polluting’ ones. 11.67% of reclama-
tion is reported which are taking place along the back water systems, from the water bodies or
in the mangrove marshes Mining is an additional theme included only for Kerala state which
come to 4.77% Infrastructure contributes to 5.77% and all are within the NDZ. The 21 infras-
trcture violations mapped all are in ‘new’ category and of this three are in CRZ-I. This takes
place in the beaches and in the river beds in the coastal stretch. Summary of the violations is
given in table no. 9. Location of some violations in Kerala coast is given in map No.5.
Table no. 9 Different CRZ violation recorded in Kerala
NDZ 200–500 m
Tourism 99 7
Industry 146 3
Infrastructure 21 None recorded
Reclamation 44 None recorded
Aqua culture 39 None recorded
Mining 18 None recorded
Tamilnadu
It was only in Kanyakumari district of Tamilnadu State in south India where CRZ violations
were recorded in detail. The most notable of them are tourism and infrastructural develop-
ment related and also part of the East Coast Highway. A total of 18 violations were recorded.
The survey has covered the Kanyakumari town and the villages of the district. The violations
recorded are all in the tourist centre of Kanyakumari, which is one of the most important
tourist/pilgrim locations of south India and 77.78 % of the violations recorded, are tourism
related. The constructions of the resorts are close to the seacoast with the coastal road right on
the HTL leading to haphazard growth of hotels in this area. In the survey it was recorded that
the waste dumping, both solid and liquid waste of the hotels and resorts drains directly into the
sea without any sewage treatment. This leads to the conflict between the resort owners and the
fishing communities living here. Though the entire village’s water is of poor quality (saline),
most of the houses within the NDZ are using motorised pumps for extraction of ground water
both for domestic and agricultural purposes. Infrastructure contributes 16.67% and the rest 5.56%
towards industrial activity. Of the 14 violations recorded 8 are in the NDZ, clustering around
the tourist centre in Kanyakumari. Location of some specific violations in Tamil Nadu coast is
given in map No.6.

LOCATION OF SOME VIOLATIONS IN TAMILNADU 44
Andhra
Pradesh
Karnataka Madras 1
Mamallapuram 2
Pondicherry 3
Nagapattinam 4
CRZ VIOLATIONS - TAMIL NADU
1. Port and Reclamation
2. Tourism
Kerala Bay 3. Tourism
of
4. Shrimp farms
Bengal
5. Port and Infrastructure
Tuticorin 5
6. Tourism & Waste Disposal
0 150 300 450 Km

6 Kanyakumari
GAIA / GIS
Figure 6.
Chapter 4
8/29/2009 2:40:53 PM
Table no. 10 Different CRZ violation recorded in Kanyakumari

district of Tamilnadu
NDZ 200–500 m
Tourism 8 6
Infrastructure 2 1
Andhra Pradesh
Districts of Prakasam and Nellore of Andhra Pradesh were surveyed for the violation mapping.
The survey was restricted to the aquaculture violations and related activities alone. Still for the
two districts alone, 48 violations were recorded. The aquaculture activity in this region is con-
centrated on the banks of the creeks and the Buckingham canal, which though located in the
interior has the influence of the tidal waters. It is in Andhra Pradesh that the adverse effects of
intensive aquaculture activity severely felt. And this lead to the Supreme Court order banning
all modern aquaculture activities in the entire coastal stretch of the country. Out of the 48 viola-
tion recorded, all are either in or near the creeks or on the banks of the canal about 400 meters
away from the seacoast. And the average size of each of these plots comes to 100 hectares. The
violations recorded in the state are given in the table no. 11. Locations of some violations in
Nellore and Prakasam districts are shown in Map No. 7.
Table no. 11 Different CRZ violation recorded in Prakasam

and Nellore district of Andhra Pradesh
Activity NDZ 200–500 m
Orissa
Ganjam, Balewar, Puri, Bhadrak, and Kasaphale districts of Orissa were surveyed and a total
of 24 violations were recorded. Out of the five districts, Puri comes under the CRZ-II, which
is an urban area. This area has experienced rapid development in the tourism sector 4.17% of
the surveyed violations are reported under this category. This is only a representation to overall
tourism development in the coasts of Orissa. Puri town is one of the known tourist areas of the
country. Therefore, this choice. Recently one of the holiday resorts companies has constructed
a road close to the HTL, north of Puri Township, at Baliapada. This is done to develop the land-
ward part of the road taking the advantage that the area is in CRZ-II.
Though the rest of the violations are reported as aquaculture which contributes to 95.83 %,
our field visit revealed a much intensive coastal activity. The violations recorded in the state is
given in the table no. 12.

LOCATION OF SOME VIOLATIONS IN NELLORE & PRAKASAM Dist. – AP
46
Maharashtra Orissa
Madhya
Pradesh
Hyderabad
CRZ VIOLATIONS - ANDHRA PRADESH

1. Shrimp Farms
Alluru Kottapatnam 2. Shrimp Farms
1
3. Shrimp Farms
2 Singarayakonda
4. Shrimp Farms
3 Kavalli 5. Shrimp Farms
4 Muthukur
Gudur 5
0 200 400 600 Km
Bay of Bengal
Karnataka
Tamil Nadu
GAIA / GIS
Chapter 4
Figure 7.
8/29/2009 2:40:53 PM
LOCATION OF SOME SPECIFIC VIOLATIONS IN ORRISSA
West
Bihar
Bengal
Baleswar 1
Madhya
Pradesh
Bhubaneshwar
Konark 2 CRZ VIOLATIONS - ORISSA

Puri 3
1. Intensive Shrimp Farms
Ganjam 4 Chilika Lake
Gopalpur 5 2. Tourism
3. Tourism
4. Hatchery, Hotels
Bay 5. Hatchery
of
Bengal
Andhra
0 150 300 450 Km
Pradesh
GAIA / GIS
47
Figure 8.
8/29/2009 2:40:53 PM
48 Chapter 4
Table no. 12 Different CRZ violation recorded in Ganjam, Baleswar,

Puri, Bhadrak and Kasaphale district of Orissa
Activity NDZ 200-500 m
Aquaculture 14 9
Orissa is probably the only state in the country where aquaculture ponds were demolished
as per the court order. Across the village Sahana and the river Devu, there is extensive areas of
modern shrimp farms, owned by the son-in-law of the Orissa Chief Minister. The land is acquired
from 6 villages – Sahana, Nuagad, Nanapur, Balisali and Dudhia. Extensive mangrove clearing
has taken place. The Supreme Court Order stopping all aquafarm activities were carried out
only at Boripada Gram Panchayat of Gopalpur district. About 12 shrimp farms, i.e. about 340
acres have been stopped and demolished by the administration here. Another farm, 40 km south of
Diega extends right out to the inter-tidal zone, which is active even now. A total of 95.83% of
the violation are reported as aquaculture related. This is only a representative district, which
cannot be generalised for the entire state. The visit to Puri, Baliapada and Chandrabaga revealed
the extent to which the Orissa coast has been subjected to tourism, urbanisation and other devel-
opmental activities. Location of some violations in Orissa are shown in map no. 8.
West Bengal
A sample of 177 Performa were collected from Midnapur and 24 Parganas districts both comes
within the CRZ-III. The villages selected are in the flood plains of River Ganga where tradi-
tional aquaculture was practiced. But the last decades have witnessed drastic conversion of
these traditional aquaculture fields and other agricultural fields into intensive and semi intensive
farms. This is no way different from other parts of the country. The 94% of the performa are
on violation related to aquaculture, like new one or expansion of the exiting one and pollution
caused by these ponds. The violations recorded in the state is given in the table no. 13.
Table no. 13 Different CRZ violation recorded in Midnapur

and 24 Parganas of West Bengal
Activity NDZ 200–500 m
Aquaculture 120 7
Out of the 177 Performa 90.13% are related to the aqua cultural activity of which almost all
are extending into the NDZ area. Out of the 164 aquaculture violations mapped, 157 are new
constructions, ie, taken place after 1991. Of the rest 4.39% contributes to the tourism activity
and the rest industrial activities. Since the survey was done in an industrially backward area, the

LOCATION OF SOME VIOLATIONS IN WESTBENGAL
Nepal Bhutan
Assam
Bihar
Bangladesh
CRZ VIOLATIONS - WEST BENGAL
1. Tourism and Shrimp farms
2. Shrimp farms
Calcutta
Diamond Harbour 3. Shrimp farms
2
Digha 3 Kakdwip
Orissa 1 0 100 200 300 Km
Bay of Bengal
GAIA / GIS
49
Figure 9.
8/29/2009 2:40:53 PM
50 Chapter 4
number of violations recorded is well reflected in this. Though the tidal influence is reaching
upto Calcutta in real situation, the CRZ area was delimited further south about 100 km down
the river which other wise would hamper the developmental and constructional activities of the
Calcutta Metropolitan City. Since the survey in this area restricts only to two districts, only the
real picture of that particular district can be analysed. Location of some violations in West
Bengal is shown in map no. 9.

CHAPTER 5
Violation of Centrally Governed Mega Projects
West Mangrove Reserve Forests: Gujarat

Ever since the Government of India liberalized its economic policies to compete with the western
model of development, the country’s poor and their livelihoods are under threat. The worst hit
in this regard is the coastal environment and coastal communities. In order to facilitate the sud-
den spurt of investment in the industrial sector, the State is going to the extent of de-regularising
the already notified areas of forest reserves. Even the protected areas like the sanctuaries are
in the process of de-regularising - the most recent being the de reservation of West Mangrove
Reserve Forest of Gujarat. The West Mangrove Reserve Forest (WMRF) is located in the Kutchh
district of Gujarat State - this 52951.71 hectare of contiguous, luxuriant mangrove extending
to the India-Pakistan border which supports a diverse marine ecosystem and in turn supporting
the entire fishery of the North West coast of India. The move to de-reserve this area came after
the recent de-reservation of a large part of the Narayana Sarovar Chinkara Sanctuary in order
to facilitate the Cement industries. One of the reasons that Cement and Soda Ash factories
congregate here is because of the rich deposits of limestone. There are 22 companies pushing
for clearance to lease for mining limestone here - 6 of them have already been granted licenses
for mining and erecting their plants. One of them ‘Sanghi Cements’ has already completed
building its main plant. Now the WMRF has come under threat of de-reservation by these com-
panies in order to construct their private jetties. These industries would soon start their dredg-
ing operations, install their power plants, desalination plants, clinker crushing plants etc. with
their effluents released into the WMRF. This will result in great pollution. Sanghi Cements has
already applied for de-reservation and at least three other companies have applied as well.
The physical and biological diversity of the WMRF is unique and together it incorporates
70% of the mangroves that remains in the state of Gujarat It supports hundreds of fisher folks for
their livelihood. Over 60% of marine life depends/and thrive in these rich mangrove shelters.
One of the fishery Harbors, Jakkau accounts for the 6th highest catch in the country. The inter-tidal
zone extending to about 200km would have been vulnerable to erosion and ingress of saline
intrusion to the interiors, had it not been for the presence of these rich mangroves. This is all the
more important, for the district of Kutchh is one of the most drought-affected districts of Gujarat.
People and their cattle depend on the sweet water sources of deep wells along this coastal tract.
Apart from providing the protection, the mangroves of WMRF provide fodder for cattle and
firewood for the village people.
Sanghi Cements and Destruction of Mangroves: The Sanghi Cement company had already
started building their Jetty project inside the WMRF. They blatantly lied to the judiciary when
Q023-DRAFT-Chapter_05.indd 51 8/29/2009 2:52:22 PM

52 Chapter 5
World Wide Fund for Nature, India (WWF) and Forum for Planned Industrialization, Gujarat
and other concerned groups appealed to the judiciary to intervene. The Forum, in one of their
appeals, says, “After three years of court battle, the High Court declared that the Sanghi Cements
have trespassed into forest land and that the land falls under the CRZ-I category of the Coastal
Regulation Zone Management Plan which is ecologically highly sensitive.”
The company now turns its tactics through pressuring the Ministry of Environment and
forests to de- notify the reserve forest in order to bypass the judicial hurdles. Surprisingly the
State Forest Department has recommended to the Ministry for de-notification! If the project
takes off, the creek would be dredged heavily and 9500cmt/day of highly saline water of TDS
5000–7000 PPM higher than sea water will be discharged into the estuary. This is definite to
trigger off chain reactions creating disturbances in the delicate balance of the estuarine ecology.
Apart from such indirect effects, construction activities such the approach road, captive power
plant etc would necessitate clearing of extensive mangroves.
More than all these, this would set a precedence paving the path for a number of private
entrepreneurs to demand for de-reservation. That would be the last of the WMRF and thereby
the rich coastal diversity of that coast.
Modern Shrimp Farms

Modern shrimp farms require high capital investment, most of it for the initial preparations
like lining and bunding, for stocking the seed, for the feed input, and for overheads. Since the
whole venture has a substantial labour requirement only at the initial stage, it is not a labour
intensive sector- in fact, it displaces labour from the labour-intensive ‘poccalli’, the traditional
saline resistant paddy cultivation. Apart from the introduction of the foreign species, the heavy
use of chemicals for sterilizing and disease prevention along with the deoxidization pollutes
the common water body. A large number of shrimp produces large amounts of feces and urea.
These combined with the nitrates and phosphates, released through the breakdown of uneaten
food, are a source of nutrients for microorganisms and algae, which multiply rapidly as a result.
The uncontrolled growth of microbes and algae depletes the oxygen available at the mud/water
interface creating anoxia. If sustained, these anoxic conditions lead to alterations in the chemical
composition of the mud, releasing toxic compounds into the pond. This is a particular problem
in the acid sulphate soils, which are a common feature in mangrove areas. In small concentra-
tions these compounds may cause stress and increase the shrimp vulnerability to disease. In
higher concentrations these chemicals are themselves lethal.6
The fact that without ecosystem support aquaculture cannot take place is well established
through ecological footprint analysis.7 In his paper on the ecological costs of Industrial
Aquaculture, Kurien provides a framework for obtaining a schematic view of the ecological
costs of depletion, degradation and pollution engendered by intensive coastal shrimp aquaculture
being practiced along the East Coast of India.8
6
Nayak N, 1996, ‘Chemmeen Krishi engottu’, (in Malayalam), Soochimukhi, SEEK, Kerala, 16(6),pp 12-16
7
Kautsky et al. 1997. Ecological Footprint for assessment of resource use and development limitations in shrimp
and tilapia aquaculture. Aquaculture research, pp 2-4
8
Kurien. J. 1997, The ecological costs of Industrial Aquaculture An attempt at I Schematisation, RFST&E, New
Delhi, pp 1-4.

Loss of bio-diversity is but one of the consequences of modern shrimp farms, for the social
cost of such development has far reaching consequences. In the recent past, paddy cultivation
has become uneconomic; an inevitable situation when the shift from subsistence to the com-
mercial system takes place. Hence extensive paddy wetlands are left fallow which is ideal for
shrimp investors to buy up: escalating land value attracts even the poor farmers tempting to sell
off their smaller patches of land.
Almost anything that earns foreign exchange is developed and encouraged by the state in all
developing countries. According to Barraclough,9 80% of world cultured shrimp comes from
Asia, of which Taiwan stood first till 1988. By 1990, China became the highest producer but fell
to 4th place with Thailand taking the lead with an output of 32%, followed by Indonesia with
17% and India with 13%. In 1992-93, shrimp exports accounted for 67% of the value of all
foreign exchange earnings from seafood. Bangladesh earned more foreign exchange through
shrimp export than any other agricultural produce after rice. However this trend did not continue
for long because of the outbreak of disease due to ‘environmental backlash’ (the depolluting
ability of the coastal waters decreased rapidly as the saturation level went up beyond a threshold).
In spite of all these setbacks the global market remained lucrative. Short-term profits remained
high. Auxiliary industries of shrimp culture development reaped more benefits- like the profits
from hatcheries, feed pesticides, antibiotics, construction, equipment and a host of other
infrastructure facilities. The situation of Aquaculture in the east coast of India, especially in
Andhra Pradesh and Tamilnadu should be seen in this light.
The last decade has witnessed tremendous growth in this industry both in the west and east
coast in India. Compared to West Coast, east has experienced the intense pressure. The spatial
extent of this activity dominates the rest of all other developmental activities. In contrast to this
the West Coast to some extent had traditional aquafarming. The Kannur coast in Kerala, for
example, had brackishwater extent of 8334 ha which includes the extensive mudflats and man-
groves. The coast is replenished constantly with the fresh water from the Karingote, Kavvai,
Valapattanam and Anjarakandi rivers and the salt water through tidal water from the Lakshadweep
Sea. Not less than 200,000 people depend entirely on these wetland fishery resources for their
livelihood. The ‘pokkali’ cultivation alternating with traditional shrimp farming had a rhythmic
harmony not only between the communities and with nature but also with the natural cycles of
tidal flow and monsoon floods. The process of brackishwater- saline- environment- paddy cul-
tivation locally called ‘pokkali’ or ‘Kaipad’ is a unique system in which the sowing of locally
specific and indigenous, salt-tolerant species like ‘Kudir’, ‘Oorkuzhama’, Anakodan’ etc., are
sown with the onset of the SW monsoon during the middle of June and harvested by September/
October months. This system does not demand any additional input like fertilizers and pesticides.
It rather helps fertilize the feed for shrimp juveniles, which come in along with the tidal inflow.
As soon as the pokkali harvesting is over, the shrimp farmers take over, sealing the outlets and
allowing the shrimp juveniles in captivity to mature within the next 4 months. This method of
alternation with one another is symbiotic. Within a specific unit area, two systems alternate with
each other. Employment generated per unit area is high and is consistent throughout the year.
Meanwhile this study revealed that the employment generation of modern shrimp farms is
9
“Barraclough. s and Andrea. F. 1995. Draft Report Some ecoological and Social Implications of Commercial
Shrimp farming in Asia. UNRISD

54 Chapter 5
initially high but drops down to just a few workers depending on the size of the farm. On an
average labour displacement takes place at 1:5 ratio, i.e., a modem shrimp farm employs one
person whereas traditional systems would have 5 workers (Fact finding team, Society for
Environmental Education in Kerala, Kannur 1996). In a State like Kerala, where the population
is high and more so in poverty ridden primary sector, this labour displacement has far reaching
consequences. This labour displacement weighed against mere foreign earnings for a few, the
social costs created, exerts an imbalance, accentuating social inequality.
The largest support system for aquaculture is the mangrove nursery for shrimp post-larvae.
It extends far beyond the physical location of the shrimp farms and is a vulnerable link in the
farming operations. The mangrove support system supplying post-larvae for Colombian shrimp
farming was between 874 sq. km and 2,300 sq. km for a pond surface area of 29-sq. km. in
1990. If 10% of the post larvae are caught wild and seed are more abundant (one/sq. km), then
the mangrove nursery need be no longer than 10 times the size of the pond area.10 Given this
study, if we estimate the total pond area of all modern shrimp farms of Kannur, it would total
3.52 sq. km whereas the mangroves extend to only 7.6 sq. km. At this rate of destruction even
the traditional shrimp farms will find it hard to sustain.
The rapid growth of extensive and semi-intensive aquafarms all over the country affecting
the social, economic and ecological aspects of the coasts lead to peoples protests and culmi-
nated in the Supreme Court order banning such activity.
Bekal Tourism Project: Kerala

Bekal Tourism Project comes under the Special Tourism Area Program. Originally when this
project was initiated the project design was vested with the architect Mr. N.M Salim & associ-
ates. He has given a detailed plan for the development of the Bekal International Tourist vil-
lage, which encompasses an area of about 2400 acres. In the plan it envisages an integrated
resort complex which includes hotels, recreational facilities such as golf courses, aqua sports,
tennis, casino and other entertainment facilities. The project design cost an amount of Rs. 64
lakhs and the Ms. Christine Vadasz from Australia and Mr. Ludwig G. Rieder from Manila
who are renowned in the field of tourism resort construction has taken up the development of
this project. The work was proposed to start in 1994 and to be completed by 2002. But this
project has not taken into consideration the CRZ Notification and the public protests, forcing
the authorities to make modifications in the original project. Bakel fort and its surrounding vil-
lages of Ajannur, Uduma, Chemmanad and Pallikkara in Kasargod district has been declared
as the Special Tourism Area (STA) by the National Action Council for Tourism Development.
Government of Kerala constituted Bakel Resort Development Corporation Ltd. (BRDC) to carry
out this project. The main objective of the STA is to promote intensive tourism projects to make
up for the loss incurring with the small-scale tourism projects and also to attract international
tourists. In this project, the Government itself would acquire 640 acres of land, develop the
basic infrastructure and resell it to the private hoteliers and other tourism promoters. A Bekal
Tourism Corporation was formed to look after the development of the activities of Bekal with
Dr.Venu the former tourism Secretary as the Chairman. Later the Corporation revamped the
10
Troell, Max 1997, Searching for Footprints, Samudra Report, No.17,ICSF. Madras

entire project plan taking into account of the CRZ Notification and a new project proposal was
submitted to the Ministry for clearance. Though the present status of the project is not known
to the public there is a lot of construction activities taking place here. In the violation mapping
process the volunteers have reported more than a dozen CRZ violations in connection with this
tourism project in this region, including infrastructure development. Violations reported include
road construction, construction of compound walls, construction of resorts and many of them
are even within the NDZ.
The Violation:
1. According to the CRZ Notification Annexure–I CRZ III (ii), Development of vacant plots
between 200 and 500 meters of High Tide Line (HTL) in designated areas of CRZ-III with
prior approval of MEF permitted for construction of hotels/beach resorts for temporary
occupation of tourists/visitors subject to the conditions as stipulated in the guidelines at
Annexure-II. Though this clause in the notification clearly stipulates “development of vacant
plots...” the present project would displace many from the coastal villages of Chettukundu,
Kappil, Kanneel and Chembarikka. Notice for evacuation is already issued to the villagers.
This is an outright violation of the CRZ Notification.
2. Bakel fort is a protected monument under the department of Archeology. BRDC constructed
a facility complex, ‘thanal’, 20 meters north of the boundary wall of the Fort. They started
constructing it in 1996 and finished construction by 1997. Thanal’s boundary wall is only 150
meters from the HTL. There are 4 buildings functional within this campus – Tourism Information
Centre, Toilets, Cafe and Handicrafts sales depot – with a floor space of 1500 sq. ft.
3. This area falls within the NDZ of CRZ III, there for according to the CRZ Notification
‘project proponent shall not undertake any construction (including temporary constructions
and fencing for such other barriers) within 200 meters (in the landward side from the HTL
and within area between LTL and HTL). But the Thanal facility complex comes within
200 meters and is therefore a violation of the CRZ Notification. The Bakel Tourism Virudha
Samithi has filed a case at the High Court against this. It was made known to us by the
Pallikkara Grama panchayat official that the Panchayat has given a letter to BRDC to demol-
ish this building.
4 BRDC has constructed a boundary wall around the 2-acre plot near the Pallikkara Ice Plant,
half a kilometer south east of Bakel fort. This was done in 1998 and it is 150 meters from the
HTL. This area has been classified as CRZ III.
5 On the southern side of the boundary wall parallel to the sea, and half a kilometer in length
and 8 meters in breadth, a road has been built. This is in an inundated green patch of land
where soil from far is brought down for reclaiming. This road leads to the beach and side-
walls are being constructed on both sides of it. This road is 120 to 150 meters from HTL and
falls within CRZ III. A board has been installed there “Road Improvement with financial
Assistance by BRDC” BRDC is financing this project and Pallikkara Panchayat is carrying
out the construction.
Bekal fort is one of the oldest forts located in the promontory of Kasargod district. This
ancient fort was constructed as a watchtower on the coastline. The location has a high pano-
ramic view and the design of the fort is quite unique and the construction still retains its
elegance.

56 Chapter 5
In the coastal stretch here, the traditional fishing communities still enjoy their customary
rights and practices. The coastal stretch has another uniqueness – that being the only area in
Kerala where Tobacco cultivation is practiced. Tobacco cultivation is seasonal and is done only
once every year in the beach area of the coast.
By the coming up of this tourism project the landscape and the life style of the local inhab-
itants will be under threat. According to the CRZ Notification, protection of Gothans assumes
special emphasis.
Goshree Island Development Project: Kerala

The Goshree Island Development Project proposes a series of bridges connecting these islands
to the mainland by reclaiming parts of Vembanad Kayal, the biggest backwater system of the
state. The project envisages medical, educational, communication and recreational facilities for
the island dwellers. A regulatory control of the landuse system of the island and to control the
illegal reclamation of the Kayal land is also envisaged. The authority plans to raise money to
construct the bridges through selling the reclaimed Kayal lands. The project proposes to trans-
form this area into a commercial and trading hub.
Tamilnadu East Coast Road

The East Coast Road (ECR) as conceived by the Tamilnadu State Highways Department is
to link Madras with Kanyakumari, a distance of 700 kms. The first phase of it sanctioned is
from Madras to Cuddalore (about 170 km). The second phase is a stretch of 375 kms between
Cuddalore and Tuticorin. The ECR is expected to eventually extend upto Calcutta thereby link-
ing the entire East Coast.
During the first phase of it there was never an attempt to conduct any proper EIA or to get
the clearance from the MoEF. The Planners claimed that the project is merely widening the
existing road and therefore does not need the clearance or any EIA. Major portions of this road
falls within the 500 meter CRZ.
Near Marakkanam and Pudupet, within 100 meters of the ECR, the remnant coastal ever-
green forest patch is under threat of destruction due to this road construction. Thalanayar
Reserve Forest will be affected. So does the Kaliveli tank. Point Calimere is another important
sanctuary, which will be affected.
Enron Thermal Power plant – Irinavu (Kannur District)

The Irinavu area is situated on the north bank of the Valapattanam River and 1 km east of
Azheekal estuary. The plot 2-km in length and 1 km in width lies parallel to the river. In a letter
that Kinfra M.D gave to Kannur District Collector on 10.7.1997, it was stated that 176.5 acres of
land King as a one plot in Kalliasseri Panchayat and Pappinisserri Panchayat has to be acquired
for the Thermal Power plant. This single plot has 131.5 acres in Kalliasseri and 45 acres in
Pappinisserri. The 500 MW combined cycled Naphtha based power plant, is proposed.
The project proponant K.P.P.Nambiar in collaboration with Enron, an American company
with its 74 % share, is floating Rs. 1,759 Crores for this project.

The major area in the plot is marshy. According to the Environmental Protection Section
(1986), this should not be reclaimed. This area has shrimp ponds, acanthus and mangroves in it.
Mangroves cover more than 1000 sq. m area. In a letter that Environment Ministry gave to
Kerala Government (27.9.1996) approving CZMP, it was suggested that as per A(ix) an area
with more than 1000 sq. km mangrove and adjoining 50 meters should be protected as CRZ-I.
The major area of the plot is covered by brackish water and experiences the tidal influences.
The northern end if the plot, which is inundated by salt water, has to be considered as HTL area
and any activity here would be a violation under CRZ Notification.
According to the stipulation in the NOC given by Kerala Pollution Control Board to KPPL,
“A detailed report on the extent of existing mangroves in the proposed site, impact of the project
on these mangroves and steps proposed for restoration of the mangroves that are likely to be
affected by the project shall be prepared and submitted to the Board and got approved before
starting construction works of the Power Plant” From this it is clear that this area has mangroves
which should be protected. This area falls within the flood plain zone of the 200 m wide
Valapattanam river. The Environment Ministry gave KPPL an approval with 5 conditions: In
this it states that, “As the project is close to Valapattanam river which is under tidal influence,
a set back distance of 100 m from HTL should be kept free from any construction or other
activities”.
Had there been a proper E1A done and report submitted highlighting the marshy brackish
nature of the area with high biodiversity mangrove ecosystem, an approval would not have been
given by the MoEF, for this area would have been CRZ-I.
Seasin Project
Seasin, a Malaysian Power company has proposed a Naphtha based power plant in the Vypin
island region of Ernakulam District of Kerala State. The project got clearance from the Ministry
of Environment and Forests. The area is north of Kochi port and Kochi Metropolitan Corporation.
The proposed project is in the accreted land of New Vypin, a stretch of land formed after the
construction of the port. This uninhabited land has innumerable rill and runnels formations. The
runnels have thick mangrove vegetation mostly dominated by avicennia species. The land was
acquired from Kerala Agricultural University which has rich mangrove vegetation. Agricultural
university has got hatcheries and aquaculture ponds in this region.
Seasin has proposed for a Naphtha based power unit similar to that proposed by KPP group
and ten to fifteen years later to be converted to gas based unit. Surprisingly, the unit has got
clearance even in the uncertain scenario of the naphtha availability in the state. The clearance of
vast expanse of mangrove is inevitable to make this project operational. This is an outright vio-
lation of the CRZ Notification.
International Port at Dahanu, Vadhuvan Maharashtra

P & O Australia is proposing to build an all-weather 8-berth international port with capacity to
expand to 30 berths on demand, which would make it one of the largest ports in the world. This
mega project is supposed to handle 250 million tons of cargo. Besides cargo like coal, oil and
cement, it will include a passenger terminal too. This project if implemented will have devastat-
ing impact on fishing, ecology and culture of Dahanu.

58 Chapter 5
The Dahanu Taluka Notification of 191 designated the area as ‘ecologically fragile’ under
the Environment Protection Act (1986). The federal Notification of June 1991 also declares
Dahanu taluka’s 250,000 acres to be ecologically fragile. This Notification also mandates that
there be no change of land-use in the region. The Regional Plan for Dahanu is valid till 2015
and the Supreme Court over a series of eight hearings has upheld this Notification and has
ordered implementation of it, subject to further restrictions on the Plan.
The draft of the P & O’s own socio-economic survey has stated that this construction will
displace thousands of traditional fishers and will cause loss of thousands of jobs in the small-
scale sustainable fishing industry. P & O under the guise of Vaduvan Ports Pvt. Ltd. (VPPL)
operate in the country with the blessings of the self-styled ShivSena leader, Bal Thackeray.
Dahanu Taluka Environmental Welfare Association (DTEWA) informed P & O Australia of
the illegality of the proposal and also writes to Mr.Naillie of P & 0 Australia of arrests in
Dahanu of non-violent demonstrators protesting the breaking of the law by P & O and the State.
Inspite of all the public protests, the State is planning to go ahead with the project.

CHAPTER 6
Field Observations and Comments
While undertaking the mapping exercise, the CRZ documents presumably would be our basic
working documents. Unfortunately, while it was very difficult to procure such documents in
states like Maharashtra, Tamilnadu, Daman & Diu and West Bengal. We also noticed that vast
discrepancy between the document and the reality.
Gujarat: In Gujarat, the maps submitted in April 1996 have correctly listed some mangrove
forests in Kutchh as CRZ-I, but, presumably to suit the Sanghi Cement Company which wants
to build a jetty in the fish breeding area, the State Government has now indicated to the project
authorities that they are !willing! to mark the jetty site as CRZ-III. Obviously no one has this
discretion without inviting censure from the Supreme Court whose ruling is firm and unam-
biguous where fragile ecological zones are concerned. Further, on the basis of the field visits
made, the following are some of our observations and suggestions:
The Kharo Creek is the site of serious CRZ violations and the state government has even
altered maps between April and June to suit the convenience of Sanghi Industries Ltd. There is
evidence of large scale cutting of mangroves at the jetty site and this is reflected in the site visit
report signed by all members of the Task Force Team. As of now, the MoEF itself has no author-
ity to either regularise past violations, or clear the project outside the strict confines of the
Supreme Court order. In addition, there is evidence of land reclamation within CRZ-I areas.
This assumes particularly serious connotations since the CRZ status of the area in question had
not yet been finalised. In effect, while the MoEF is awaiting further information from the Gujarat
Government the project proponent is physically altering the geography of the coast and creek.
Apart from the Kharo Creek, the MoEF has given clearance to the Adani Chemical Port
project though the site chosen is an uninhabited island and should therefore be granted CRZ-I
status as per the MoEF’s own standards.
Here we propose that jetty sites must also be examined from the CRZ angle and all past
clearances given be put on hold till the MoEF has been able to assess the position and satisfy
itself that the letter and spirit of the Supreme Court order has been followed faithfully.
Gujarat’s industrial planning is most haphazard and several CRZ violations are already taking
place in places such as Jakhau, the Sothri-Bada belt, Mandvi, Mundra, Kandala, Maliya (the Lesser
and Greater Rann of Kutchh must be incorporated as CRZ-I as it comes under tidal influence)
The coastal belt from Jodiya to Sika is also under virtual assault and the project being pro-
posed for the Reliance Refinery near Pirotan island is a violation of CRZ Rules insofar as petro-
leum pipelines cannot be allowed to pass through a National Park.
From Sika to Okha the coastal area must be categorised as CRZ-I. The Mithapur region too
must be categorised as CRZ-I and no industrial expansion should be allowed there.

60 Chapter 6
Dwarka is a heritage site and is obviously CRZ-I.

The belt from Porbandar through Veraval to Mahuva represents one of the world’s richest
fish breeding areas. Species come inland to breed and the coastal belt in this stretch must be
categorised as CRZ-I.
The Gulf of Cambay is the exit point of the Sabarmati. Mahi. Dhadhar, Narmada and Tapi
rivers Millions of fisherfolk even much further south are dependent on the productivity of these
estuaries for their survival. However, the Gujarat Government has revealed that industries, not
fisheries are their priority. The ship-breaking industry is extremely polluting and must not be
allowed in either CRZ-I or III areas. In CRZ-II such activity can only be allowed if international
standards of environmental safety and protection are adhered to Chemical industries must be
held responsible for the toxic material they discharge and under no circumstances can these be
allowed in CRZ-I areas. If necessary pipelines will have to be constructed to carry effluents
away from CRZ-I areas, even by existing industries. In particular the Dahej, Ankleshwar. Surat
and Vapi areas must be declared as frozen zones with no expansion of industrial activity for at
least 10 years until the Centre and State governments are able to work together to restore the
ecological health of the coast. The coastal Gujarat is endowed with rich deposits of calcareous
materials and during our field observations we noted that there are industries which thrive from
mining this raw materials - often violating CRZ.
About 20 kms from Veraval, the village Sutrapada has some unique features Sweet water
aquifer running a few yards from the shoreline. The villages are located within 100 sq.ft have
installed over a 100 handpumps drawing out water for all their needs, right on the beach.
However, not far from this wonderful phenomenon is the gigantic Gujarat Heavy Chemicals
Limited (GHCL), producing Soda Ash, is using motorised pumps extracting ground water. The
effluents from the Industry are freely flowing out into the sea! The coastal stretch has a bleached
appearance and the effluents on examination found to be extremely hot too, raising the tem-
perature of the waters close to the shore.
At the point where Devuka River (originating at the Gir forest area) joins the sea, the village
people complained of the effluent discharge from the Indian Rayons Factory located close to the
estuary. Thousands of fish die here and can be seen often floating. They showed us the keel of
their boats, which is corroding due to the effluents.
This part of Gujarat seems to be a retrograded coast with rich deposits of limestone forma-
tions. At Porbander, Birlas Rayons belch out thick black smoke and pollutes the coastal waters
with their hot effluents, though they claim it to be treated before the discharge. There are few
municipal garbage dumpyards close to the shore, which pollutes the coastal waters too.
Maharashtra: In Maharashtra, vast stretches of mangrove forests have been completely left
out of the maps submitted. Therefore, large CRZ-I areas are categorised as CRZ-II or III When
this question was raised the MoEF responded, “About erroneous categorization of mangrove
areas in Maharashtra as CRZ-II and III instead of CRZ-I, it has been emphasised several times
in the Task Force meetings that mangrove forests are to be classified as CRZ-I or as agreed to
with reference to a minimum area.” The area from Dahanu to Bassein is ecologically sensitive
and must be categorised as CRZ-I. In particular, the violations of the CRZ Rules by the BSES
thermal plant at Dahanu must not be regularised; rather the project must be penalized for con-
spiring to alter the geography of the Dahanu coast to escape the provisions of the CRZ Rules.

Estuaries require very strict protection as these are breeding grounds and the Ulhas river estuary
therefore must be accorded CRZ-I status.
All mudflats and sand dunes from Uttan southwards, including Manori, Marve and Versova
must be categorised as CRZ-I, except for specific municipal urban areas which are substantially
built up which may be excluded on specific basis. CRZ-I areas within municipal areas/other
legally designated urban areas contemplate a no development zone (NDZ) of only 50 meters.
This is against the specifications of the CRZ Notification and must be reexamined for man-
groves and sand dune areas.
The Bombay and Greater Bombay region area has a high density of mangroves particularly
along the creeks. No reclamation of this area can be allowed and strict curb on salt pans and
prawn farms north of Mumbai must be imposed. Mangrove cutting and reclamation in the CRZ
I areas is proceeding apace with the Bombay Sewerage Project taking the view that since the
MoEF has not informed the state of the Supreme Court order regarding CRZ issues, it is not
obliged to take note of any reports either in the press or through other channels.
Several ecologically sensitive areas such as Nhava Island, Uran mudflats and the Sewri
mudflats should be included as CRZ-I. So should the beachfronts of extraordinary beauty
stretching from Alibagh and Mandva, south to Murud-Janjira. Beaches along the stretch south
of Bombay which are renowned for their clean sands and seas, such as Kihim, Revadanda,
Dighi, Srivardhan, Devgarh, Anjarla and Harnai must be included as CRZ-I, as should
Ganpatipule. Sand dunes, sea forts, the coral belts (such as the outcrops near Malvan), must be
categorised as CRZ-I.
The CRZ Rules in the Dabhol regions-must be strictly implemented, particularly in light of
the changes, which have been made in the Enron Project design since the MoEF last accorded
clearance. In particular, the jetty site has undergone a change but no Environment Impact
Analysis of the new site has been conducted. As this is a crucial fish-breeding zone the MoEF
must insist on this analysis being conducted before any construction within the CRZ is allowed.
A pro-active stance on this project is necessary at this stage itself to prevent a fait accompli from
being presented to the nation when construction on the project is recommenced. In any event,
the estuarine habitat of the Vashishti River and the coastal belt both north and south of it must
be categorised as CRZ-I.
The entire stretch down to Vengurla must be categorised as CRZ-I, save for the actual area
falling within municipal limits which are substantially built up.
There must be a categorical refusal to permit any reclamation or dumping in CRZ areas and,
in particular, the Jawaharlal Nehru Port Trust must be informed in writing that their proposal to
reclaim 200 hectares of the Uran mudflats for a chemical terminal would be violative of the
CRZ Rules and would, in fact, invite contempt proceedings from the Supreme Court.
The sewage treatment plants at Tarapur Industrial Area and the effluents let out at Navpur vil-
lage, which seems to be polluting the entire sea here is of such magnitude that it is as if the whole
ocean has turned red and has such obnoxious smell! Between Satpati and Karakuran villages the
entire surface and Ground water seems to have been polluted by this These villages were once
famous for its rich Oyster catches. And Karakuran as the name suggests had been traditionally a
salt producing area but the new trend is for conversion to semi-intensive aquafarms.
The entire stretch from Sindhudurga to Ratnagiri has the threat of Tourism development
while Thane, Tarapur and Dahanu are polluted with the industrial development. Increasing

62 Chapter 6
urbanization threat the coastal stretches from Bombay, Thane to Raigarh (Ali Bagh) The threat
of aquafarms are mainly at Karakuran and Davidare taluks of Palghar districts in
Maharashtra.
Goa: Goa is in the grip of construction fever and the CRZ is the prime focus of attack. The
areas of Calangute, Chicalim-Bogmalo, Candolim, Chauri and Benaulim must be categorised
as CRZ-III and not II. The villages of Cola, Agonda and Loliem must be designated as CRZ-I
and not CRZ-III. The Goa government’s attempt to reduce the overall length of CRZ-I areas
from 20 to 10 kms is a blatant exercise in dilution and this cannot be permitted under any cir-
cumstances. Other than parts of Panaji, Calangute, Candolim and Benaulim CRZ-III status is
not applicable to any stretches in Goa. Tourism is a serious threat to the ecology of the Goa
coast and it should therefore be made clear to the state government that CRZ-III categoriza-
tion does not automatically suggest suitability for resorts. In this connection, the MoEF should
demand that the town-planning department submit a detailed development and land use plan on
the basis of which its request for CRZ categorization can be considered.
The absence of roads on the maps leaves the CRZ regulations open to abuse in future as
implications for future construction are linked to the issue of existing seaward constructions. If
no roads are shown in the state maps, these cannot later be built or else the claim may be made
for construction rights for buildings as well.
The State Government’s interpretations of the CRZ Rules insofar as a river is concerned are
unacceptable. Tidal rivers are valuable breeding grounds for marine species and this is also
where most mangroves are located. The 100-meter setback rule must be enforced strictly here.
Estuarine areas must be strictly protected and where Mangrove are present CRZ-I status must
be automatic. The National Institute of Oceanography must be made the nodal agency for the
MoEF in monitoring the Goa CZMP. The Regional Plan of the State Government must be com-
pared with the CZMP and contradictions clarified.
In any event, this and other CZMP must only be cleared with conditionalities as the ten-
dency in Goa is to interpret all laws through a tourism filter with environmental considerations
invariably given the go by.
Karnataka: In Karnataka CZMP, many villages have been left out.
Kamataka is currently facing a series of public protests on account of the conversion of
ecologically fragile areas in coastal Dakshin Kannada from traditional to chemical and indus-
trial use. Major tourism projects proposed, for example the Tannirbavi project on 124 acres of
land which is to be handed over by the Karnataka Industrial Area Development Board (KIADB)
to the state tourism department is not mentioned in the CZMP. Though the CZMP states that
encroachment of beaches is a major problem, the MoEF has not asked for details.
It should be noted that the fish catch all along the Karnataka coast if falling and one very
good way to reverse this trend would be to implement the CRZ Rules strictly so that breeding
grounds of marine organisms are protected and siltation and pollution into estuarine breeding
grounds is reduced
The estuary of the Kalinadi river should be accorded CRZ-I status on account of its impor-
tance as a breeding ground for fish. This would serve the additional purpose of reducing the
siltation rate of the Karwar coastal region and thus benefit shipping.
All inlets and islands in the Gokam-Kumta stretch should be categorised as CRZ-I

The estuarine belt leading up the Swarna Nadi towards Jog Falls must be accorded CRZ-I
status to the point where tidal impact is felt.
The stretch between Honavar and Coondapoor, particularly the islands in the Gangoli region
must be categorised as CRZ-I.
The coastal belts from Coondapoor to Kalyanpur and Malpe should be categorised as CRZ-I,
particular care should be taken to include the islands as CRZ-I.
As already mentioned, Dakshin Kannada is threatened by a series of developments away
from the coast which will cause major chemical contamination of the coast over the next few
years. None of these developments can be allowed to come up within the CRZ region, and nor
must they release any toxic material in or through CRZ-I areas.
Kerala: While the state is clamoring for special considerations and exemptions from the CRZ
Rules, the fact is that Kerala’s fishing community is up in arms against government policies
designed to compromise the interests of the traditional fisherfolk who must be recognised as the
true beneficiaries of the coastal environment. As a result of their initiatives they have already
negotiated the cancellation of fishing licenses for foreign trawler fleets. The National Fishworkers!
Federation through its Chairman Fr. Tom Kocherry has communicated that the NFF will take a
strong position against any polluting industry and any plan, which involves reclamation or usur-
pation of fishing villages or breeding grounds of fish.
Reclamation areas mentioned by the CZMP include Kuttanad, Kayamkulam Kayal, Goshree
Island Development Scheme, Kattampally, Kole land and some portions of the backwaters of
Alappuzha District. All these are against the CRZ Notification.
It may also be noted that heritage areas and their extents have not been identified for decla-
rations as CRZ-I areas and that though the CZMP acknowledges that areas of outstanding natu-
ral beauty have been identified, their spatial extent has not been established so as to classify
them as CRZ-I.
The riverine and estuarine habitats along the Beypore, Kattipuram, Edappal, Periyar, and
Astamudi Lake areas should be categorised CRZ-I.
The virgin beaches, and many heritage sites along the Kerala coast must be categorised as
CRZ-I.
Tamilnadu: Tamilnadu government has converted the coastal town of Tiruchendur into
Tiruchengode, which is actually situated near Salem, far from the coast. Tamilnadu’s 938 kms.
long coast is already reeling under the adverse effects of the East Coast Road construction,
which is going ahead despite irreparable damage to watersheds, drainage and wetlands and
coastal ecosystems. The issue of CRZ of creeks and rivers upto which tidal effect is felt has not
been classified. Nor has the MoEF paid any heed to the vital issue of coastal erosion, pollution
and haphazard and uncontrolled exploitation due to pressures of tourism which was so forth-
rightly covered in the CZMP.
One of the most serious errors of omission on the part of the MoEF is the fact that the
destruction of Vedaranyam Swamp (Point Calimere).
The Pitchavaram Mangrove Ecosystem should not be used for aquaculture.
The banks of the Ennore creek required to be categorised as CRZ-I and that mangrove
stretches between Tuticorin and Kerala have actually been excluded from the Tamilnadu CZMP
maps. This would be the best way for any state to avert the rule of law. Referring to map no.

64 Chapter 6
27 pertaining to Kayalpattinam, should have been shown as CRZ-I as it has mangroves.

Similarly, the Tuticorin islands require to be categorised as CRZ-I.
The mouths of the Valliyur, Manapaddu and Karaveli rivers should be categorised as CRZ-I.
Protection of the Pulicat Lake should be ensured. Other than the actual fishing settlements, the
entire area must be declared CRZ-I.
Kodikkarai is a nationally recognized habitat for migratory birds attracted by its salt marshes.
Therefore, Kodikkarai and its surroundings must be classified as CRZ-I.
The CZMP makes no reference to Pamban though this is one of Tamilnadu’s most biodiversity-
rich areas and in the nearby Palk Straits and outlying island coral reefs are present.
Three settlement areas, namely Sippikulam, Vembar and another unidentified area have
been classified as CRZ-III. To prevent any usurpation of the commons by industry, except for
the fishing community settlements, landing sites and commons all other areas in between should
be classified as CRZ-I.
The area surrounding Buckingham Canal should be categorised as CRZ-I and not CRZ-III
as suggested by the state government. This area is rich in salt marshes.
The heritage sites of Mamallapuram and Poompuhar are seriously threatened by erosion
and they require extra protection. These must be CRZ-I and not CRZ-III.
The area around Buckingham Canal up to Chetpet Bridge has been left out of the plan. The
state government should be advised to re-examine its plan to construct a new Harbor at Ennore
in the light of the CZMP and the ruling of the Supreme Court. All the uninhabited islands and
the salt marshes along the coastal belt between Tuticorin and Devipatinam must be categorised
as CRZ-I.
Andhra Pradesh: The total mangrove area in the State is around 582 sq. km, largely in the
Krishna and Godavari River estuaries. There are two sanctuaries here namely the Coringa
Sanctuary in East Godavari and the Krishna Sanctuary. All these regions should be categorised
as CRZ-I.
The worst coastal state in terms of pollution is Vishakapatnam where 31 large and small
industries are concentrated. The organic pollutants from sugar mills and food processing indus-
tries threaten to destroy the self-sufficiency of coastal people. In Srikakulam district, an alkali-
based plant is seriously damaging the ecology of the area. A paper plant, which had been set up
in 1983, is similarly causing havoc by the release of organochlorines, which are virtually killing
off marine organisms and life forms.
The Pulicat Lake requires to be categorised as CRZ-I and this protection should extend all
the way to the Kandeleru river mouth.
The mouth of the Penner River near Utukuru requires to be protected with CRZ-I status.
The Bay area between Govundlapalem and Rayapeta must be categorised as CRZ-I.
The coastal stretches which include sandy beaches and mudflats between Tummalapenta
and Nizampatanam to the north should be categorised as CRZ-I. The mouths of the estuaries of
the Krishna and Godavari upward to the points where the tidal impact can be felt and the non-
municipal areas falling in between should be categorised as CRZ-I. This will greatly extend the
life of vital ports such as Masulipatnam, Narasapatnam, and Kakinada
Thermal pollution of the coastal region as a result of a natural gas project, coming up on the
east Godavari shoreline must be prevented at all costs.

Heavy metal contamination, as well as BHC contamination is assuming alarming propor-

tions. Lead run-off from a government run zinc factory in the Guntur district has accumulated
to alarming levels in the marine and shore environment. No new factories should be allowed to
come up here.
Orissa: The coastal district of Orissa is more influenced by aquaculture industry and on certain
pockets tourism industry. At Balgaon, the Chilka Lake is dotted with innumerable penculture
cages raising crabs. However the villagers complained of the siltation problem which is slowly
choking up the lake
Puri coast is taken over by the tourism industries. And the property developers are develop-
ing the stretch from Puri to Baliapada. A number of flats and other residential buildings are
being built at present. They have even constructed a road, unauthorized, along the beach thereby
stepping over the hurdles of CRZ Notification. On inquiring we found out that the Sterling
Developers are building the road. Right next to this violation, we saw more than 100 artisanal
fishers pulling in their catamarans.
At Chandrabaga, a pipeline runs right through the temporary settlement of the migrant fish-
erfolks, drawing in salt water from the sea for the Government run shrimp hatchery. This
Hatchery was set up after 1994 and is within the 200 meters NDZ.
The village Sahana in Astrang has an extensive aquafarm owned by the son-in-law of the
Chief Minister of Orissa. This farm is still functional inspite of the Supreme Court order and is
sprawled out among six villages - Sahana, Nuagad, Nanapur, Balisahi and Dudhia.
The stretch between Balasore to Gopalpur is the site of the semi-intensive shrimp farms now
deserted after the demolition order from the Supreme Court. At Maharudrapur village, there
were 12 aquafarms, which has spoiled the entire area with its salinity that the villagers told us
that their agricultural fields are useless now. Forty meters south of Diega, the shrimp farm
extends right out to the inter-tidal zone. Visit to Gokharakuda village in Ganjam district also
revealed the same sight where the administration has demolished 100s of aquafarms.
West Bengal: The West Bengal CZMP which covers the 157 kms coastline, plus riverine sys-
tem should never be approved without a site visit to doubtful areas such as Digha and Sand
Heads where it is common knowledge that oil tanker wash is affecting the fragile CRZ-I
Sunderbans mangrove ecology. The state government has not clarified its position regarding the
proposed Sagar Marine Sanctuary and nor has the MoEF clarified to the State Government that
its position about the CRZ Rules being stopped above the Kulbi Point along the Hoogly River
is bad in law as the tidal effect goes past the city of Calcutta itself
The Task Force Members are not aware of the MoEF’s position regarding the categorisation
of the belt from Digha through Haldia and Diamond Harbour to Fraserganj East of this point, of
course the Surdarbans Tiger Reserve makes it imperative for CRZ-I categorisation.
The lack of consultation in the process of assessing the CZMPs is bound to have a very
adverse reaction from the very strong fisherfolks organisations and even among trade unions in
West Bengal which are politically active and alert to the issues concerning unorganised fisherfolk.
By opting to listen only to the land-development oriented opinions the MoEF has lost a good
opportunity to take advantage of people’s participation in the CRZ process in West Bengal.
The total mangrove area in West Bengal is calculated at 6,740 sq. kms and this entire belt must
be categorised as CRZ-I. Of this 4,264 sq kms. is in the Sundarbans region. Major pollutants are

66 Chapter 6
being discharged into the Hoogly estuary in violation of CRZ Rules and this is already showing
up in terms of heavy metal concentrations in fish. Zinc in fish kidneys has, for instance, been
measured to a level of 300 ppm and levels of copper, chromium, cadmium, lead and mercury is
also very high. In the Navdwip Island there are 96 factories which are currently discharging
almost 500 million litres of untreated wastes into a vital habitat which is the life-support system
for over one million people. This makes the Hoogly estuary one of the world’s most polluted
areas. The MoEF must accept its responsibility to use the power vested in it through the CRZ
Rules and other legislation to reverse this trend.

CHAPTER 7
Summary and Conclusion
The intent of the CRZ Rules that pervade the MoEF seems to have been based on the belief
that they are drafted to facilitate industrial development, and not to protect the fragile coastal
ecology from such development and force projects to site their plants away from the coast. It
looks as if the desire to protect the coast was not the upper-most on its list of priorities. On
the contrary, loopholes in the notification are intended and sought so as to oblige various state
governments and project proponents. Therefore, the following points should be taken into con-
sideration while finalising the CZMP:
i) No effluents from industrial or municipal outfalls or pipes should be released into CRZ I
areas.
ii) Even within port limits, CRZ I status should be accorded to areas which have ecological
value.
iii) All uninhabited should be categorised as CRZ I.
iv) No-development zones and green belts already declared by states should be set aside as
CRZ I or III as the case may be.
v) Mudflats, wetlands, reefs, mangroves, sand dunes and shoals should be categorised as
ecologically sensitive CRZ I areas.
vi) No reclamation or construction of properties after 1991 should be regularised. This has
particular relevance where industrial clearances are sought from the MoEF.
vii) No dumping of dredged materials be permitted in the CRZ area and if done, such resultant
land formations should be strictly categorised as CRZ I with no commercial use made of
the land whatsoever.
viii) All heritage sites and reserved forests should be categorised as CRZ I.
ix) No sand excavation, mining or shell/shale/stone extraction be allowed from CRZ areas.
x) Common effluent treatment plants, power plants, storage facilities etc. should not be built
in the CRZ area, these must be sited away from the coast.
xi) The National Institute of Oceanography’s report on the impact of sea level rise must be
taken into account when categorising CRZ I areas in all states as per the CRZ Notification.
If they have not conducted studies in all states they should be asked to do so without fur-
ther delay as scientific evidence is pouring in each day to suggest that this could become
the number one concern for coastal states in the near future.
xii) Tidal impacts along estuarine areas must be plotted on a map supported by satellite infor-
mation, not merely be given in terms of distance, but by mentioning the town or village up
to which the tidal impact can be felt.

68 Chapter 7
Conclusion
The CRZ Notifications of 1991 is only a beginning for the protection and conservation of the
seacoasts, the sea and the biodiversity of the resources and the fishing community. The seaward
component is not included. Nor does it takes into account of the diversity of the long coast and
the coastal livelihoods, rather it standardises the entire coast with one single rule of protection.
It needs site specific regulation and management strategies taking into account of the local
needs and issues for a sustainable development.
In order to have a sustainable environment, fish-wealth and the fishing community - the
campaign initiated by the World Forum of Fishworkers and Fishharvesters (WFF) should
become a reality. The sea, waterbodies, rivers, lakes and their wealth should be owned by the
fishing community. The fishing families who are solely depended on fishing for livelihoods
should own the fishing implements. The fishing co-operatives having fishing families as mem-
bers should manage the fish catch and its distribution. They should have major role in managing
the coastal zone and the water bodies. Following are some of the suggestions for the improve-
ment of the CZMP and thereby the coastal environment.
1. Regulation and Enforcement: In order to ensure long-term conservation of the coastal habitats
and the sustainable use of the coastal resources, it is pertinent to regulate the developmental
activities in the coastal zone. As the coasts offer wide variety of opportunities for various
interest groups – from tourism and resort developers to industrial and land developers – there
is every chance for the traditional and artisanal communities to be side tracked and marginal-
ised. Since the real stakeholders are identified in the CRZ Notification to be the fishing com-
munities, the regulation as such should be made applicable to all other interest groups.
2. Research: It is important that academics and researchers are involved not only to take stock
of the present situation of our coasts, but also to investigate the pros and cons of every single
human intervention and the consequent impact to the natural systems. Even the physical
and human geography of our coasts is understood poorly and the informations available are
so fragmented. Moreover, coastal problems and phenomena are inadequately understood.
Therefore, it is desirable to develop an in-depth Coastal Information System.
3. Co-ordination: A proper CZM requires co-ordination of various state agencies and NGOs. It
should be only through co-ordinated efforts that activities on our coasts could be regulated.
Often responsibilities of various agencies overlap, resulting in actual or potential conflicts
among them, or in some cases, it is not clear which agency is responsible for the management
of some activities that result in adverse impacts on coastal resources. Therefore, due to these
jurisdictional gaps or overlaps there should be co-ordinated efforts especially among Urban
Development Authorities, Municipal Corporations, Public Works Departments, Industrial
Financiers and Development Corporations, Tourism Development Corporations, fisheries
Departments and departments dealing with Ports and Harbours. Fisheries Co-operatives,
MPEDA etc.
4. Education: Educating the coastal communities is an important component for a sound Coastal
Zone Management. So far the state initiatives were only in raising the literacy. But being
literate alone is not enough. To improve their living conditions and to be equipped to face
external threats from Developers, it is imperative to be educated. Moreover, the benefits of

any management initiatives would be successful when education programs mobilize public
support.
5. Plan and Policy Development: CZM bears fruit only when planning eftorts focus on develop-
ing objectives and implementing actions for the coastal problems. Area-specific Management
Plans referring to existing legislation etc. should be the priority. Unless plans are formulated
as consequence to the coastal conservation policy, the validity of such activities and their
legitimacy will be questioned.
6. Role of Local Bodies: The 72nd and 73rd Amendments to the Indian Constitution consider
the issues of larger involvement of Panchayati Raj Institutions in management of natural
resources. The decentralization so far meant only political decentralization and not the
issues of natural resource management by Panchayati Raj Institutions. Making use of the
11th schedule to the constitution (73rd Amendment) Act 1992, coast conservation should be
vested and management options should be worked out with local governing bodies.
7. The need to appoint a Coastal Zone Management Authority in each Coastal State to guide
and direct the CRZ Management Plan and implement the CRZ Notification.
8. The traditional fishing community having traditional and customary rights should be accom-
modated in the CRZ-II and III as far as their residences and work places are concerned. The
CRZ Notification should be amended to this effect.

APPENDIX I
CRZ Notification and the Amendments
MINISTRY OF ENVIRONMENT & FORESTS

(Department of Environment, Forests and Wildlife)
NOTIFICATION UNDER SECTION 3(1) AND SECTION 3(2)(v) OF

THE ENVIRONMENT (PROTECTION) ACT, 1986 AND RULE 5(3)(d)
OF THE ENVIRONMENT (PROTECTION) RULES, 1986
DECLARING COASTAL STRETCHES AS COASTAL REGULATION
ZONE (CRZ) AND REGULATING ACTIVITIES IN THE CRZ.
New Delhi, the 19th February, 1991

(as amended up to 3rd October 2001)
S.O.114 (E). - Whereas a Notification under Section 3(1) and

Section 3(2)(v) of the Environment (Protection) Act, 1986, inviting
objections against the declaration of Coastal Stretches as Coastal
Regulation Zone (CRZ) and imposing restrictions on industries, operations
and processes in the CRZ was published vide S.O. No.944 (E) dated 15th
December, 1990.
And whereas all objections received have been duly considered by

the Central Government;
Now, therefore, in exercise of the powers conferred by Clause (d)

of sub-rule (3) of Rule 5 of the Environment (Protection) Rules, 1986, and
all other powers vesting in its behalf, the Central Government hereby
declares the coastal stretches of seas, bays, estuaries, creeks, rivers and
backwaters which are influenced by tidal action (in the landward side)
upto 500 metres from the High Tide Line (HTL) and the land between the
Low Tide Line (LTL) and the HTL as Coastal Regulation Zone; and
imposes with effect from the date of this Notification, the following
restrictions on the setting up and expansion of industries, operations or
processes, etc. in the said Coastal Re gulation Zone (CRZ). For the
purposes of this notification, the High Tide Line means the line on the
land upto which the highest water line reaches during the spring tide.
The High Tide Line shall be demarcated uniformly in all parts of the
country by the demarcating authority or authorities so authorised by
the Central Government, in accordance with the general guidelines
issued in this regard. 1,6.
Note: -The distance from the High Tide Line shall1 apply to both
1
sides in the case of rivers, creeks and back waters and may be modified
on a case by case basis for reasons to be recorded while preparing the
Coastal Zone Management Plans. However, this distance shall not be less
than 50* (*This provision has been struck down by the Supreme Court )
100 metres or the width of the creek, river or backwater whichever is less.
Q023-DRAFT-Appendix-I.indd 70 8/29/2009 2:53:53 PM

The distance upto which development along rivers, creeks and back-
waters is to be regulated shall be governed by the distance upto which
the tidal effect of sea is experienced in rivers, cre eks or back-waters,
as the case may be, and should be clearly identified in the Coastal
Zone Management Plans.1
2. Prohibited Activities:
The following activities are declared as prohibited within the
Coastal Regulation Zone, namely:
(i) setting up of new indus tries and expansion of existing industries, except
(a)10 those directly related to water front or directly needing foreshore
facilities and (b) Projects of Department of Atomic Energy;10
(ii) manufacture or handling or storage or disposal of
hazardous substances as specified in the
Notifications of the Government of India in the
Ministry of Environment and Forests No. S.O.
594(E) dated 28th July 1989, S.O. 966(E) dated 27th
November, 1989 and GSR 1037(E) dated 5th
December, 1989; except transfer of hazardous
substances from ships to ports, terminals and
refineries and vice versa in the port areas:3
Provided that, facilities for receipt and storage of petroleum

products and Liquefied Natural Gas as specified in Annexure -
III appended to this notification and facilities for regasification
of Liquefied Natural Gas, may be permitted within the said
Zone in areas not classified as CRZ-I (i), subject to
implementation of safety regulations including guidelines
issued by the Oil Industry Safety Directorate in the
Government of India, Ministry of Petroleum and Natural Gas
and guidelines issued by the Ministry of Environment and
Forests and subject to such further terms and conditions for
implementation of ameliorative and restorative measures in
relation to the environment as may be stipulated by the
Government of India in the Ministry of Environment and
Forests
(iii) Setting up and expansion of fish processing units

including warehousing (excluding hatchery and
natural fish drying in permitted areas);
Provided that existing fish processing units for

modernisation purposes may utilise twenty five per cent
additional plinth area required for additional equipment and
pollution control measures only subject to existing Floor Space
index/ Floor Area Ratio norms and subject to the condition

72 Appendix I
that the additional plinth area shall not be towards seaward

side of existing unit and also subject to the approval of State
Pollution Control Board or Pollution Control Committee.
(iv) setting up and expansion of units/mechanism for

disposal of waste and effluents, except facilities
required for discharging treated effluents into the
water course with approval under the Water
(Prevention and Control of Pollution) Act, 1974;
and except for storm water drains;
(v) discharge of untreated wastes and effluents from
industries, cities or towns and other human
settlements. Schemes shall be implemented by the
concerned authorities for phasing out the existing
practices, if any, within a reasonable time period not
exceeding three years from the date of this
notification;
(vi) dumping of city or town waste for the purposes of
landfilling or otherwise; the existing practice, if
any, shall be phased out within a reasonable time
not exceeding three years from the date of this
Notification;
(vii) dumping of ash or any wastes from thermal power
stations;
(viii) Land reclamation, bunding or disturbing the natural
course of sea water except those required for
construction or modernisation or expansion of
ports, harbours, jetties, wharves, quays, slipways,
bridges and sea-links and for other facilities that are
essential for activities permissible under the
notification or for control of coastal erosion and
maintenance or clearing of water ways, channels
and ports or for prevention of sandbars or for tidal
regulators, storm water drains or for structures for
prevention of salinity ingress and sweet water
recharge:
provided that reclamation for commercial
purposes such as shopping and housing
complexes, hotels and entertainment activities
shall not be permissible;
(ix) Mining of sands, rocks and other substrata
materials, except (a) those rare minerals not
available outside the CRZ areas and (b)
exploration and extraction of Oil and Natural
Gas

Provided that in the Union Territory of the Andaman

and Nicobar islands, mining of sands may be permitted
by the Committee which shall be constituted by the
Lieutenant Governor of the Andaman and Nicobar
Islands consisting of Chief Secretary; Secretary,
Department of Environment; Secretary, Department of
Water Resources; and Secretary, Public Works
Department. The said Committee may permit mining of
sand from non-degraded areas for construction
purposes from selected sites, in a regulated manner on a
case to case basis, for a period upto the 30th day of
September, 2002. The quantity of sand mined shall not
exceed the essential requirements for completion of
construction works including dwelling units, shops in
respect of half yearly requirements of 2001-2002 and
2002-2003 annual plans. The permission for mining of
sand may be given on the basis of a mining plan from
such sites and in such quantity which shall not have
adverse impacts on the environment.
(x) harvesting or drawal of ground water and

construction of mechanisms therefor within 200 m
of HTL; in the 200m to 500m zone it shall be
permitted only when done manually through
ordinary wells for drinking, horticulture, agriculture
and fisheries;
Provided that drawal of ground water is permitted,

where no other source of water is available and when
done manually through ordinary wells or hand pumps,
for drinking and domestic purposes, in the zone
between 50 to 200 m from High Tide Line in case of
seas, bays and estuaries and within 200 m or the CRZ,
whichever is less, from High Tide Line in case of rivers,
creeks and backwaters subject to such restrictions as
may be deemed necessary, in areas affected by sea
water intrusion, that may be imposed by an authority
designated by State Government/Union Territory
Administration.
(xi) construction activities in CRZ -I except as specified

in Annexure -I of this notification;
(xii) any construction activity between the Low Tide
Line and High Tide Line except facilities for
carrying treated effluents and waste water
discharges into the sea, facilities for carrying sea

74 Appendix I
water for cooling purposes, oil, gas and similar

pipelines and facilities essential for activities
permitted under this Notification; and
(xiii) dressing or altering of sand dunes, hills, natural
features including landscape changes for
beautification, recreational and other such purpose,
except as permissible under this Notification.
3. Regulation of Permissible Activities:

All other activities, except those prohibited in para 2 above, will be
regulated as under:
(1) Clearance shall be given for any activity within the

Coastal Regulation Zone only if it requires water
front and foreshore facilities.
(2) The following activities will require environmental

clearance from the Ministry of Environment and
Forests, Government of India, namely:
(i) Construction activities related to projects of

Department of Atomic Energy or Defence
requirements for which foreshore facilities
are essential such as. slipways, jetties,
wharves, quays; except for classified
operational component of defence projects
for which a separate procedure shall be
followed. (Residential buildings, office
buildings, hospital complexes, workshops
shall not come within the definition of
operational requirements except in very
special cases and hence shall not normally
be permitted in the CRZ;
(ii) Operational constructions for ports and
harbours and light houses and constructions
for activities such as jetties, wharves, quays
and slipways, pipelines, conveying systems
including transmission lines;
(ii) a Exploration and extraction of oil and

natural gas and all associated activities
and facilities thereto;
(iii) Thermal Power Plants (only foreshore
facilities for transport of raw materials
facilities for intake of cooling water and

outfall for discharge of treated waste

water/cooling water); and
(iv) All other activities with investment

exceeding rupees five crores except those
activities which are to be regulated by the
concerned authorities at the State/Union
Territory level in accordance with the
provisions of paragraph 6, sub-paragraph
(2) of Annexure 1 of the notification.
(3) (i) The Coastal States and Union Territory

Administrations shall prepare, within a period of
one year from the date of this Notification, Coastal
Zone Management Plans identifying and classifying
the CRZ areas within their respective territories in
accordance with the guidelines given in Annexures
I and II of the Notification and obtain approval
(with or without modifications) of the Central
Government in the Ministry of Environment &
Forests;
(ii) Within the framework of such approved plans, all

development and activities within the CRZ other
than those covered in para 2 and para 3(2) above
shall be regulated by the State Government, Union
Territory Administration or the local authority as
the case may be in accordance with the guidelines
given in Annexure-I and II of the Notification; and
(iii) In the interim period till the Coastal Zone

management Plans mentioned in para 3(3) (i) above
are prepared and approved, all developments and
activities within the CRZ shall not violate the
provisions of this Notification. State Governments
and Union Territory Administrations shall ensure
adherence to these regulations and violations, if
any, shall be subject to the provisions of the
Environment (Protection) Act, 1986.
4. Procedure for monitoring and enforcement:
The Ministry of Environment & Forests and the Government of

State or Union Territory and such other authorities at the State or
Union Territory levels, as may be designated for this purpose, shall

76 Appendix I
be responsible for monitoring and enforcement of the provisions of

this notification within their respective jurisdictions.
ANNEXURE - I
COASTAL AREA CLASSIFICATION AND DEVELOPMENT

REGULATIONS
Classification of Coastal Regulation Zone:
6(1) For regulating development activities, the coastal stretches

within 500 metres of High Tide Line on the landward side are classified
into four categories, namely:
Category I (CRZ-I):
(i) Areas that are ecologically sensitive and important, such as

national parks/marine parks, sanctuaries, reserve forests,
wildlife habitats, mangroves, corals/coral reefs, areas close
to breeding and spawning grounds of fish and other marine
life, areas of outstanding natural
beauty/historically/heritage areas, areas rich in genetic
diversity, areas likely to be inundated due to rise in sea
level consequent upon global warming and such other areas
as may be declared by the Central Government or the
concerned authorities at the State/Union Territory level
from time to time.
(ii) Area between Low Tide Line and the high Tide Line.
Category-II (CRZ-II):
The areas that have already been developed upto or close to the
shoreline. For this purpose, “developed area” is referred to as that area
within the municipal limits or in other legally designated urban areas
which is already substantially built up and which has been provided with
drainage and approach roads and other infrastructural facilities, such as
water supply and sewerage mains.

Category-III (CRZ-III):
Areas that are relatively undisturbed and those which do not

belong to either Category-I or II. These will include coastal zone in the
rural areas (developed and undeveloped) and also areas within Municipal
limits or in other legally designated urban areas which are not
substantially built up.
Category-IV (CRZ-IV):
Coastal stretches in the Andaman & Nicobar, Lakshadweep and

small islands, except those designated as CRZ-I, CRZ-II or CRZ-III.
Norms for Regulation of Activities.
6(2) The development or construction activities in different

categories of CRZ area shall be regulated by the concerned authorities at
the State/Union Territory level, in accordance with the following norms:
CRZ-I
No new construction shall be permitted in CRZ- I except (a)

Projects relating to Department of Atomic Energy and (b) Pipelines,
conveying systems including transmission lines and (c) facilities that
are essential for activities permissible under CRZ-I. Between the
LTL and the HTL, activities as specified under paragraph 2 (xii) may
be permitted. In addition, between LTL and HTL in areas which are
not ecologically sensitive and important, the following may be
permitted: (a) Exploration and extraction of Oil and Natural Gas, (b)
activities as specified under proviso of sub-paragraph (ii) of
paragraph 2, and (c) Construction of dispensaries, schools, public rain
shelters, community toilets, bridges, roads, jetties, water supply,
drainage, sewerage which are required for traditional inhabitants of
the Sunderbans Bio-sphere reserve area, West Bengal, on a case to
case basis, by the West Bengal State Coastal Zone Management
Authority
CRZ-II
(i) Buildings shall be permitted only on the landward side of

the existing road (or roads approved in the Coastal
Zone Management Plan of the area) or on the landward
side of existing authorised structures. Buildings
permitted on the landward side of the existing and proposed
roads/existing authorised structures shall be subject to the
existing local Town and Country Planning Regulations

78 Appendix I
including the existing norms of Floor Space Index/Floor

Area Ratio:
Provided that no permission for construction of

buildings shall be given on landward side of any new
roads (except roads approved in the Coastal Zone
Management Plan) which are constructed on the
seaward side of an existing road.
(ii) Reconstruction of the authorised buildings to be permitted

subject to the existing FSI/FAR norms and without change
in the existing use.
(iii) The design and construction of buildings shall be consistent

with the surrounding landscape and local architectural
style.
CRZ-III
(i) The area upto 200 metres from the High Tide Line is to be
earmarked as ‘No Development Zone’. No construction
shall be permitted within this zone except for repairs of
existing authorised structures not exceeding existing FSI,
existing plinth area and existing density, and for
permissible activities under the notification including
facilities essential for such activities. An authority
designated by the State Government/Union Territory
Administration may permit construction of facilities for
water supply, drainage and sewerage for requirements
of local inhabitants. However, the following uses may be
permissible in this zone – agriculture, horticulture, gardens,
pastures, parks, play fields, forestry and salt manufacture
from sea water.
(ii) Development of vacant plots between 200 and 500 metres
of High Tide Line in designated areas of CRZ-III with prior
approval of Ministry of Environment and Forests (MEF)
permitted for construction of hotels/beach resorts for
temporary occupation of tourists/visitors subject to the
conditions as stipulated in the guidelines at Annexure-II.
(iii) Construction/reconstruction of dwelling units between 200
and 500 metres of the High TideLine permitted so long it is
within the ambit of traditional rights and customary uses
such as existing fishing villages and gaothans. Building
permission for such construction/reconstruction will be
subject to the conditions that the total number of dwelling
units shall not be more than twice the number of existing

units; total covered area on all floors shall not exceed 33

percent of the plot size; the overall height of construction
shall not exceed 9 metres and construction shall not be
more than 2 floors ground floor plus one floor.
Construction is allowed for permissible activities under
the notification including facilities essential for such
activities. An authority designated by State
Government/Union Territory Administration may
permit construction of public rain shelters, community
toilets, water supply, drainage, sewerage, roads and
bridges. The said authority may also permit
construction of schools and dispensaries, for local
inhabitants of the area, for those panchayats the major
part of which falls within CRZ if no other area is
available for construction of such facilities.
(iv) Reconstruction/alterations of an existing authorised
building permitted subject to (i) to (iii) above.
CRZ-IV
Andaman & Nicobar Islands:

(i) No new construction of buildings shall be permitted
within 200 metres of the HTL;
(ii) The buildings between 200 and 500 metres from the
High Tide Line shall not have more than 2 floors
(ground floor and first floor),the total covered area
on all floors shall not be more than 50 per cent of
the plot size and the total height of construction
shall not exceed 9 metres;
(iii) The design and construction of buildings shall be
consistent with the surrounding landscape and local
architectural style.
(iv) (a) Corals from the beaches and coastal waters shall
not be used for construction and other purposes.
(b) sand may be used from the beaches and coastal
waters, only for construction purpose upto the
30th day of September 2002 and thereafter it
shall not be used for construction and other
purposes.
(iv) Dredging and underwater blasting in and around

coral formations shall not be permitted; and
10

80 Appendix I
(v) However, in some of the islands, coastal stretches

may also be classified into categories CRZ-I or II or
III with the prior approval of Ministry of
Environment and Forests and in such designated
stretches, the appropriate regulations given for
respective Categories shall apply.
Lakshadweep and small Islands:
(i) For permitting construction of buildings, the

distance from the High Tide Line shall be decided
depending on the size of the islands. This shall be
laid down for each island, in consultation with the
experts and with approval of the Ministry of
Environment & Forests, keeping in view the land
use requirements for specific purposes vis-à-vis
local conditions including hydrological aspects
erosion and ecological sensitivity;
(ii) The buildings within 500 metres from the HTL shall
not have more than 2 floors (ground floor and 1st
floor), the total covered area on all floors shall not
be more than 50 per cent of the plot size and the
total height of construction shall not exceed 9
metres;
(iii) The design and construction of buildings shall be
consistent with the surrounding landscape and local
architectural style;
(iv) Corals and sand from the beaches and coastal
waters shall not be used for construction and other
purposes;
(v) Dredging and underwater blasting in and around
coral formations shall not be permitted; and
(vi) However, in some of the islands, coastal stretches
may also be classified into categories CRZ-I or II or
III, with the prior approval of Ministry of
Environment & Forests and in such designated
stretches, the appropriate regulations given for
respective Categories shall apply.
Annexure – II
GUIDELINES FOR DEVELOPMENT OF BEACH RESORTS/HOTELS

IN THE DESIGNAED AREAS OF CRZ-III FOR TEMPORARY
OCCUPATION OF TOURIST/VISITORS, WITH PRIOR APPROVAL
OF THE MINISTRY OF ENVIRONMENT & FORESTS.
11

7(1) Construction of beach resorts/hotels with prior approval of

MEF in the designated areas of CRZ-III for temporary occupation
of tourists/visitors shall be subject to the following conditions:
(i) The project proponents shall not undertake any

construction (including temporary constructions and
fencing or such other barriers) within 200 metres (in
the landward wide) from the High Tide Line and
within the area between the Low Tide and High
Tide Line;
(ia) live fencing and barbed wire fencing with

vegetative cover may be allowed around private
properties subject to the condition that such
fencing shall in no way hamper public access to
the beach;
(ib) no flattening of sand dunes shall be carried out;
(ic) no permanent structures for sports facilities shall
be permitted except construction of goal posts,
net posts and lamp posts.
(id) construction of basements may be allowed
subject to the condition that no objection
certificate is obtained from the State Ground
Water Authority to the effect that such
construction will not adversely affect free flow of
ground water in that area. The State Ground
Water Authority shall take into consideration
the guidelines issued by the Central Government
before granting such no objection certificate.
Explanation:
Though no construction is allowed in the no development zone for the

purposes of calculation of FSI, the area of entire plot including 50% of
the portion which falls within the no development zone shall be taken
into account.
(ii) The total plot size shall not be less than 0.4 hectares
and the total covered area on all floors shall not
exceed 33 per cent of the plot size i.e. the FSI shall
not exceed 0.33. The open area shall be suitably
landscaped with appropriate vegetal cover;
(iii) The construction shall be consistent with the
surrounding landscape and local architectural style;
(iv) The overall height of construction upto highest
ridge of the roof, shall not exceed 9 metres and the
12

82 Appendix I
construction shall not be more than 2 floors (ground

floor plus one upper floor);
(v) Ground water shall not be tapped within 200m of
the HTL; within the 200 metre – 500 metre zo ne, it
can be tapped only with the concurrence of the
Central/State Ground Water Board;
(vi) Extraction of sand, levelling or digging of sandy
stretches except for structural foundation of
building, swimming pool shall not be permitted
within 500 metres of the High Tide Line;
(vii) The quality of treated effluents, solid wastes,
emissions and noise levels, etc. from the project
area must conform to the standards laid down by the
competent authorities including the Central/State
Pollution Control Board and under the Environment
(Protection) Act, 1986;
(viii) Necessary arrangements for the treatment of the
effluents and solid wastes must be made. It must be
ensured that the untreated effluents and solid wastes
are not discharged into the water or on the beach;
and no effluent/solid waste shall be discharged on
the beach;
(ix) To allow public access to the beach, at least a gap of
20 metres width shall be provided between any two
hotels/beach resorts; and in no case shall gaps be
less than 500 metres apart; and
(x) If the project involves diversion of forest land for
non- forest purposes, clearance as required under the
Forest (Conservation) Act, 1980 shall be obtained.
The requirements of other Central and State laws as
applicable to the project shall be met with.
(xi) Approval of the State/Union Territory Tourism
Department shall be obtained.
7(2) In ecologically sensitive areas (such as marine parks,

mangroves, coral reefs, breeding and spawning grounds of fish,
wildlife habitats and such other areas as may notified by the
Central/State Government/Union Territories) construction of beach
resorts/hotels shall not be permitted.
Annexure - III
[See paragraph 2, sub-paragraph (ii)]
13

List of Petroleum Products Permitted for Storage in Coastal

Regulation Zone except CRZ I- (i)
(i) Crude Oil;

(ii) Liquefied Petroleum Gas;
(iii) Motor Spirit;
(iv) Kerosene;
(v) Aviation Fuel;
(vi) High Speed Diesel;
(vii) Lubricating Oil;
(viii) Butane;
(ix) Propane;
(x) Compressed Natural Gas;
(xi) Naphtha;
(xii) Furnace Oil;
(xiii) Low Sulphur Heavy Stock.
(xiv) Liquefied Natural Gas (LNG)
.
Environmental clearances accorded by the Ministry of Surface Transport from 9th
July 1997 till the publication of this notification are valid. All proposals for
environment clearance pending with the Ministry of Surface Transport stand
transferred to Ministry of Environment and forests from the date of publication of
this notification.
The principal notification was published in the Gazette of India vide number S.O. 114(E),
dated, the 19th February, 1991 (Corrigendum number S.O 190(E) dated 18th March 1991)
and subsequently amended vide: -
(i) S.O. 595 (E) dated 18th August, 1994(Corrigendum S.O.690 (E) dated 19th
September 1994.
(ii) S.O. 73 (E) dated 31st January 1997.
(iii) S.O. 494 (E) dated 9th July 1997.(Corrigendum S.O.735(E) dated 21st
October 1997.)
(iv) S.O. 334 (E) dated 20th April 1998.
(v) S.O. 873 (E) dated 30th September 1998.
(vi) S.O. 1122 (E) dated 29th December 1998.
(vii) S.O.998 (E) dated 29th September 1999.
(viii) S.O.730 (E) dated 4th August 2000
(ix) S.O. 900(E) dated 29th September 2000
(x) S.O. 329 (E) dated 12th April 2001
(xi) S.O. 988 (E) dated 3rd October 2001.
******
14

APPENDIX II
Checklist
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Check List for Mapping Violations in CRZ (See at the end of the checklist: details given on conditions permitting activities in CRZ)
Q023-DRAFT-Appendix-II.indd 85
CRZ-I CRZ-II CRZ - III
HTL- Approved
Approved structure HTL- 200 m
Sl. No. ACTIVITIES HTL - 500 M HTL-LTL Structure -500 m (NDZ) 200–500 m
1 New Construction, Building 7 7 7 5 7 5
Facilities for carrying treated effluents and waste water
2
discharge into the sea
3 3 3 3 3 3
Facilities for carrying sea water for cooling purposes, oil, gas
3
and similar pipelines
7 7 3 3 3 3
4 Reconstruction of the authorised buildings 7 7 5 5 5 5

Activities like agriculture, horticulture, garden, pastures,
5 parks, playfields, forestry and salt manufacturing from sea 7 7 7 3 3 3
water
Construction of hotels and beach resorts for temporary
6
occupation of tourists and visitors
7 7 7 5 7 5
7 Construction of basements for hotels and beach resorts 7 7 7 7 7 5

8 Withdrawal of ground water for hotels & beach resorts 7 7 7 5 7 5
Extraction of sand, levelling or digging of sand stretches
9 only for structural foundation of buildings, swimming 7 7 7 5 7 5
pool for hotels and beach resorts

10 Flattening of sand dunes for hotels and beach resorts 7 7 7 7 7 7
Permanent structures for sports facilities except goal
11 post, net post and lamp post in the case of hotels and 7 7 7 7 7 7
85
beach resorts
8/29/2009 2:54:19 PM
86
HTL- Approved
Sl. No. ACTIVITIES HTL - 500 M HTL-LTL Structure - 500 m (NDZ) 200–500 m
Discharge of untreated effluents and solid waste,
12 emissions and noise levels from hotels and beach 7 7 7 7 7 7
resorts
13 New industries and expansion of existing industries 7 7 7 7 7 7
14 Industries which needs water front or foreshore facilities 7 5 5 5 5 5
Manufacturing, handling, storage, disposal of hazardous
15
substances
7 7 7 7 7 7
Transfer of Hazardous substances from ships to port,

16
torminal, refineries and vice versa
7 7 5 5 5 5
17 Setting up of fish processing units including warehouses 7 7 7 7 7 7

Expansion of fish processing units including ware
18
houses
7 7 5 5 5 5
19 Natural fish drying and hatcheries* 7 7 3 3 3* 3

Setting up and expansion of units/mechanism for
20
disposal of waste and effluents
7 7 7 7 7 7
Setting up and expansion of facilities required for

21
discharging treated effluents into the water course
7 7 7 5 5 5
22 Construction of storm water drains 3 3 3 3 3 3

Discharge of untreated waste and effluents from
23
industries, cities/towns, human settlements
7 7 7 7 7 7
Appendix II
8/29/2009 2:54:19 PM
24 Dumping of city waste for land filling or otherwise 7 7 7 7 7 7
Dumping of ash and other waste from thermal power
25
stations
7 7 7 7 7 7
Land reclamation, bunding or any disturbance to the

26
course of sea water
7 7 7 7 7 7
Bunding/disturbance of natural course of sea water for

construction of port, harbour, wharf, quay, slipway,
27 bridge & sealinks & for coastal protection structure, 7 7 3 3 3 3
maintenance and cleaning of water way, structures for
preventing salinity ingress & sweetwater recharge
28 Mining of sand, rock and other substrata materials 7 7 7 7 7 7
29 Mining of rare minerals not available outside CRZ 3 3 3 3 3 3
Withdrawal of ground water manually where no other
30
source of water available
7 7 5 3 5 3
Dressing or altering of sand dunes, hills, natural

31
features, land scape
7 7 7 7 7 7
Construction activity related to defence which requires

32.a
foreshore facilities
3 3 3 3 3 3
Residential, office, hospital complexes, workshops in

32.b
connection to defence
7 7 7 7 7 7
Expansion or modernisation of existing fishing harbour,

33 operational construction of ports, harbours, jetties, 7 5 5 5 5 5

lighthouse, wharves, slipways, quays etc.
Reclamation for commercial purposes such as shopping
34 and housing complexes, hotels and entertainment 7 7 7 7 7 7
activities
87
8/29/2009 2:54:20 PM
88
HTL- Approved
Sl. No. ACTIVITIES HTL - 500 M HTL-LTL Structure - 500 m (NDZ) 200–500 m
Facilities for transport of raw materials to thermal power
35 stations; intake of cooling and outfall for discharge of 7 5 5 5 5 5
treated waste water, cooling water
All other activities with investment exceeding Rs.5
36
crores
7 7 5 5 5 5
7 - Prohibited 3 - Permitted 5 - Permitted under condition * net applicable for hatcheries.
Details of conditions for permitting activities in CRZ:

Sl. No. 1. For CRZ II, it shall be subject to existing local Town and Country Planning Regulation including FSI/FAR.
For CRZ III, should be within the ambit of traditional rights and customary uses such as existing fishing villages and goathans.
Total number of dwelling units shall not be more than twice the number of existing units since 1991. 33% of the floor space can only be
used for construction. Height of the building shall not exceed 9 meters and it should have only two floors (ground floor + first floor).
Sl. No. 4. For CRZ II, it shall be subject to existing local Town and Country Planning Regulation including FSI/FAR.
For CRZ III, should not exceed FSI, existing plinth area, existing density. However, designated authority can permit construction of public
rain shelters, dispensary, community toilet, water supply, drainage, sewerage, bridges, schools only where no other area is available
outside the CRZ.
Sl.No. 6. Both for CRZ II & III, prior approval of the Ministry of Environment and Forest (MEF); total plot size should be more than
0.4 hectares and total covered area on all floors shall not exceed 33% of the plot size. The construction should be consistent with the
surrounding landscape and local architectural style. Height of the building should not exceed 9 meters and should have only two floors
(ground + first floor).
Sl. No. 7. No objection certificate from State Ground Water Authority.
Sl. No. 8. For CRZ III, prior permission from Central/State Ground Water Board.
Sl. No. 9. For both CRZ II & III, prior permission should be obtained from MEF.
Appendix II
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Sl. No. 14. For CRZ I, II & III, prior permission should be obtained from MEF.
Sl. No. 16. For CRZ I, II & III, clearance should be obtained from Govt. of India, (Ministry of Surface Transport), Oil Safety Directorate of
Ministry of Petroleum and Natural Gas.
Sl. No. 18. For CRZ II & III; expansion can be upto an additional 25% of the plinth area only for additional equipment and pollution control
measures, subject to existing FSI/FAR and the additional plinth area shall not be towards the seaward side of the existing unit. Needs approval
from State Pollution Control Board or Committee.
Sl. No. 21. For CRZ II & III, prior approval from State Pollution Control Board. For local inhabitants in NDZ such construction of facilities for
water supply, drainage and sewerage needs prior permission from the designated authority.
Sl. No. 30. Withdrawal of Ground Water can be done manually or by hand pump for drinking and domestic purposes, in the zone between
50 to 200 meters in the case of seas, bays and estuaries. In area affected by sea water intrusion, prior permission from State Government/Union
Territory Administration needed.
Sl. No. 33. Requires environmental clearance from MEF on the basis of EIA from Govt. of India. Storage of the following petroleum products.
crude oil, liquefied petroleum gas, motor spirit, kerosene, aviation fuel, high speed diesel, lubricating oil, butane, propane, compressed natural
gas, naphtha, furnace oil, low sulphur heavy stock are permitted within the port area except in CRZ I
Sl. No. 35. Requires environmental clearance from MEF.
Sl. No. 36. Requires environmental clearance from MEF.
Note: In the case of West Bengal, construction of public rain shelters, dispensary, community toilet, water supply, drainage, sewerage bridges,
schools and jetties which are required for the traditional inhabitants of Sunderban Biosphere reserve area may be permitted on case to case basis
by an authority designated by the State Government.
89
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CRZ Violations

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CRZ Violations

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MAPPING THE EXTENT OF COASTAL

REGULATION ZONE VIOLATIONS

D. Nandakumar & M. Muralikrishna

National Fishworkers Forum

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Chapter 1 Introduction 1–6

Chapter 2 Coastal Zone Management – The People’s Initiative 7–19

Chapter 4 Analysis of the Violations at State Level 35–50

Chapter 5 Violations of Centrally Governed Mega Projects 51–58

Chapter 6 Field Observations and Comments 59–66

Chapter 7 Summary and Conclusion 67–69

Appendix I – CRZ Notification and the Amendments

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Harekrishna Debnath R.K. Patil

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1. Summary of the Physical features of the Indian Coast

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1. Coastal States of India with CRZ

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Geography of Indian Coast

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Table no. 1 Summary of the Physical features of Indian Coast

Coastal state Area (km2) Coastline (km) Population

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CRZ Notification and its relevance to sustainability

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Coastal Zone Management – The People’s

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States Total Violations Mapped Pockets Surveyed

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Checklisting and surveys

Review of CZMP of all Coastal States

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Daman and Diu CZMP

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Fisheries: sea and inland, molluscs, oysters and prawns.

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Table no. 3 Details of the CRZ of Karnataka (sq. km)

CRZ of Karnataka (sq. km)

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Tamil Nadu CZMP

Andhra Pradesh CZMP

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River/creek Dist. in km Nearest village

West Bengal CZMP

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The Comments of the MoEF of the CZMPs

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xv. Sand dunes are classified as CRZ-I.

Special condition/modification/classification Gujarat

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Special condition/modification/classification for Daman and Diu

Special condition/modification/classification Maharashtra

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