While multiple parallel plans are in place, there is no cohesion; not even the basic high tide mapping matches across the coast.
On July 31, the Union environment minister said in parliament that so far only Lakshadweep has submitted its Coastal Zone Management Plan (CZMP), a document that guides coastal development and regulation as prescribed in the Coastal Regulation Zone (CRZ) notification, to his ministry. This was the fifth deadline until when the validity of the ‘antiquated’ CZMPs, prepared in 1996, were extended. Despite the looming deadline, nine coastal states and three union territories were yet to submit their draft plans. Now, observing that the states and union territories needed “some more time,” the ministry has extended the existing CZMP by another year.
The CRZ notification was first issued in 1991 to protect the first 500 m from the high tide line (HTL) of the sea. All coastal states and union territories finalised their CZMPs by 1996. In 2011, the CRZ notification was replaced by a new one with the same name. The 2011 CRZ notification required all coastal states and union territories to prepare fresh CZMPs within two years of its issuance. But the new CZMPs are still in the making. In the absence of new CZMPs, the 1996 versions have been given extensions.
From the experiences of CRZ enforcement along the coastline, there are numerous instances of mismatch between the 2011 CRZ notification and the old CZMP. For instance, parts of Vizhinjam in Kerala are marked as ecologically sensitive in the CZMP because the original CRZ provided for the identification of areas of ‘outstanding beauty’ as ecologically sensitive. But these areas do not qualify for the same status as per 2011 CRZ. Moreover, tidal lines, which form the basis of coastal zoning and planning, tend to shift over time and the existing CZMPs are based on the HTL mapped over 20 years ago. Currently, while appraising projects, most State Coastal Zone Management Authorities (SCZMAs), the state-level bodies responsible for the implementation of the CRZ notification, use their discretion to decide the HTL line for an area (often these HTL maps are provided by the project proponents).
In 2014, after attending to the states’ lamentations about lack of resources to complete the task and observing inconsistencies in tidal demarcation across the country, the environment ministry involved the National Centre for Sustainable Coastal Management (NCSCM). Since most states had already started work on CZMPs, the NCSCM was expected to review these documents and ensure that the tidal line was consistent across the 7500-km coastline.
The NCSCM has nearly completed the mapping of the HTL, but the line seems to have left out ecologically-important tidal-influenced wetlands and mudflats from within its limits in Tamil Nadu. Accurate HTL mapping is crucial because this is the reference point for the demarcation of CRZ – 500 m from the HTL on the coast, 100 m from the tidal-influenced water bodies and areas between the HTL and hazard line. This identified zone is subject to regulations and restrictions related to construction, mining, tourism and the like, to ensure coastal conservation and livelihood protection.
Incorrect HTL mapping may leave vulnerable coastal areas and fishing villages outside of the CRZ and make them available for unhindered tourism, and commercial and real estate projects. But this is not all – there are planning exercises other than the CZMP that rely on accurate HTL mapping that hold great significance but are hardly talked about.
The 2011 CRZ notification talks of three more plans – a comprehensive plan, sewage treatment plans for coastal towns and cities, and integrated management plans for critically-vulnerable coastal areas.
The comprehensive plan is for the narrow strip of coastal land falling within 100-200 m of coastal villages. This plan is to guide the construction of dwelling units for coastal communities. The plans are to be prepared by the state government in consultation with traditional coastal communities. A reading of the minutes of the meeting of the SCZMAs indicates that Karnataka has initiated the process.
The second kind is the sewage treatment plans for coastal cities and towns. These plans were to be completed in the first year of the notification. As per meeting minutes, only the Maharashtra SCZMA has discussed it. In fact, the Maharashtra SCZMA has recently approved a sewage treatment plan near the Malad creek, which is an ecologically-fragile area. This was after the environment ministry issued an amendment to the 2011 CRZ notification allowing sewage treatment plans in ecologically-sensitive areas (in case no alternate site is available).
Integrated management plans are for areas that have high ecological importance and livelihood dependence. The CRZ notification provides an indicative list of 12 such sites. While the NCSCM held consultations in Gujarat and Karnataka to demarcate these areas, none of the areas listed in the CRZ law have been notified as yet.
No common goals
In all, four planning exercises have been suggested for the coastal areas of India. While work has begun individually on all, these planning exercises have not been tied together and there is no prescribed sequence to be followed for carrying these out. All these activities have gone on in silos. Such disconnected planning exercises have real-time implications, for the planning institutions and communities alike.
As per the minutes of the meetings of the SCZMAs, Karnataka and Maharashtra had initiated preparation of a sewage treatment plan and comprehensive plan respectively, only to find out at the near-completion stage that they needed to modify the plans to accommodate fresh tidal demarcations. Replacing the existing tidal lines with fresh demarcation would “not be difficult,” reckons the Karnataka CZMA in one of its meetings. However, change in tidal lines means the area in question changes and with it changes the number of villages and households that fall in the 100-200 m zone that need a comprehensive plan. How the Karnataka CZMA will tackle this administrative nightmare without much ‘difficulty’ is anybody’s guess. In the absence of fresh HTL mapping, the Malad sewage treatment plan in Maharashtra has been given the CRZ nod without an accurate assessment of which ecologically-important areas are being sacrificed for it. Besides, individual projects are being appraised and allowed based on discrete HTL mapping provided by the project proponents and assessed by the CZMAs. Business is going on as usual and it doesn’t really matter if we do not have a contiguous HTL mapped out. A ‘plan’ by definition is a scheme of things towards a desired outcome in the future. In case of coastal areas, there seems to be neither a scheme nor an idea about how far away that future is. In the meanwhile, these planning and management exercises are going on in parallel without any shared outcomes for the coast.
In June 2014, the environment ministry constituted the Shailesh Nayak Committee to review the CRZ notification in light of the issues raised by the states. Neither did the states raise any concerns regarding these discrete plans, nor did the committee go beyond appreciating the involvement of the NCSCM in tidal demarcation and coastal planning. Based on the recommendations of the committee, the ministry has drafted a new Marine Coastal Regulation Zone Notification, 2017, and a draft obtained from the ministry reveals that instead of tying these plans together, the ministry is contemplating the introduction of another planning exercise – tourism plans for the CRZ.
Plans for sewage treatment, construction of houses for traditional communities and promotion of tourism are all hinged on consistent, accurate and real-time tidal demarcation. If these plans are made separately from one another, they will bear the imprint of a confused process lacking priority setting, logical order and coordinated thinking. It seems inevitable that the implementation woes of CRZ will continue despite (or because of) an over-indulgence in planning.
Meenakshi Kapoor is the project manager of the Namati Environmental Justice Program at the Centre for Policy Research, New Delhi.