Tuesday 29 October 2019

Response to Ashwin Tombat: Reasons for objecting Nauxim AHOY Marina Public Hearing


The media is the most powerful entity on earth. They have the power o make the innocent guilty and to make the guilty innocent, and that’s power. Because they control the minds of the masses.
                                                                                                                                                                                  Malcolm X

On Sunday 27th October 2019 Ashwin Tombat wrote thought provoking article about Marina at Nauxim in Marathi daily Lokmat. Points he raised are translated into English deserves closer scrutiny. English version of his article is available online here

The First point Tombat communicates is an assumption: Europe has mare than 4000 marinas with 5 lakh berths but still waters there are healthier than Goa waters.

What is the evidence to prove this has not be supplied are even hinted so we need to cross check it this is indeed true. In Goa release of urban waste untreated and treated waste into rivers as well as mining run-offs into rivers has created intense pollution of rivers in Goa. Role of mining industry in polluting Goa’s rivers is recorded in first meeting of the Goa State Pollution Control Board and available online. However comparative study between Europe and Goa waters with regard to Pollution standards needs to be shared by Ashwin Tombat publicly based on which he has made this assumption.

Second point that Tombat communicates is a question: When a small nations like Monaco and Singapore can have so many marinas then what harm will be done if Goa has one Marina?
Goa State Biodiversity Board (GSBB) - decided against Sancoale Marina proposal few years prior in 2013. In a letter dated 30th December 2013 GSBB filed its objections before GSPCB citing several reasons for rejecting proposal to set up marina named ‘Yatch Haven (Goa)’ in Sancoale bay in Zuari river. One of the reason is the EIA ignoring of the existence schedule specie Window Pane Oyster (Placuna Placenta) and diverse other marine organisms such as the pistol shrimp, clams, fiddler crabs, etc at the proposed site for marina. Further GSBB expressed apprehension and concern on the likely impact during constructional and operational phases on the general ecology, hydrodynamics, sedimentology, and livelihood potential that the bay has traditionally offered to the locals for the last several decades. GSBB pointed out the fall outs from dredging of the rivers that will interfere with nutrient flux and bentho – pelagic coupling in the bay. Huge ecological damage was found to be intrinsic to the  marina project proposal. Further project proponent Umaji Chowgule was not able to furnish details on the carrying capacity of Sancoale Bay for Yatch density and berthing facility. During the meeting a the records in the minutes ‘A member of the Board categorically pointed out that NIO who had carried out the impact study on the said proposal at the site was also engaged for a study on the biodiversity of the Chicalim Bay, NIO in its report had highlighted its rich biological endowment and in particular that this bay was not only a habitat but also a breeding site for the Window Pane Oyster a schedule species as per the Wildlife Protection Act 1972.’ After hearing Project Proponent and experts GSBB reached consensus on seven counts before rejecting the Sancoale Marina. It’s worth noting them as they have serious repercussions on coastal fishing communities as follows (a) Far from being ecologically benign, (b) The proposed facility would largely cater to the demands of the elite tourism, (c) The integrity of this habitat would be challenged both during constructional and operational phases, (d) There would be obvious repercussions on the marine biota particularly in the benthic zone and some species with precarious conservation status could be further pressurized and even locally decimated, (e) The traditional livelihood options exercised by the local would cease, displacing the locals culturally, (f) The project will have repercussion of the intertidal and the landward zones, and (g) There is a possibility of inadvertent introduction of invasive species from foreign water.   All the above objections for Sancoale Marina from GSBB are applicable to the Nauxim Marina as well even though GSPCB has not passed on the file of Nauxim Marina to GSBB.

The third point that Tombat communicates is public objection perceived by him: Goa is too small for marina.
It is not the issue is Goa is small or big but the fact stated in EIA that Nauxim marina is basically meant to serve needs of the Luxury tourism. The issue then is should needs of Luxury tourism be allowed to override Goa’s economy destroying all nature based economies? In the present case Draft EIA report on pages 5.9 and 5.10 through Table 5.2 (Coefficient values for impact assessment) and Table 5.3 (Impact quantifications) admits on major permanent long term irreversible negative impact on fisheries of Zuari river with double coefficient of -2. This means fishing in Zuari river will be completely disrupted and fishing communities will be squeezed out of their fishing spaces.

The fourth Point that Tombat makes is danger o fishing by mechanised trawlers: real danger to fishing in Zuari is from mechanised trawlers. It is true and several complains are filed before Goa Fisheries department. However danger from marina is as real as mechanised trawlers and it cannot be ignored as the dangers are confirmed by draft EIA report quoted above at point three response. In addition several complaints are received by Goa fisheries department to cancel the water sports NOC to Aquasail distribution that operate from Hotel Grant Hyatt for disrupting fishing activities near Nauxim where Marina is planned. NOC was revoked for nine months but was restored after political pressure by then Chief Minister Manohar Parrikar.  Tombat  claims that workers on trawlers release human excreta in waters creating pollution. He however is silent as to why Nauxim Marina will support these very trawlers as recorded in Draft EIA on page 3.15 that reads “Development in the fishing activity as there would be development and maintenance of jetty, market would be available at the door step, availability of fuel for the trawlers shall be easy.” When there is not a single trawler in Nauxim then whose trawlers this marina is going to fuel? This indicate that Marina promoters have entered into under the table deals to support very trawlers that Tombat fiercely criticised so that illegal fishing in Zuari as well as pollution pointed out by Tombat increases. Tombat is also silent on construction of special fishing Jetty for trawlers at MPT who has leased out Zuari waters. Performance budget 2010-2019 of the Directorate of Fisheries on page 61, point 61 (Fishing Berth – MPT) records “An outlay of Rs. 1000.00 lakh is provided towards Other capital Expenditure in the State Budget 2018-19 for construction of fishing berth at MPT, Vasco.” Why do MPT creating facility supported by Goa Government for the trawlers that pollute rivers by open defecation in waters as pointed out by Tombat? Why Tombat is silent on this nexus for pollution of marine waters?

Draft EIA report on Nauxim Marina points out real dangers to Zuari and Mandovi at page 4.24 as follows:

Zuari is the longest river with second largest basin and Mandovi is the second largest river with largest basin in the state of Goa. The urbanization and Iron ore transfer activities have polluted both the rivers very badly and the water as such is highly polluted. The sewage disposal ito the rivers from habitations have contaminated the rivers with heavily with microbial contamination.
The bilated barges in the Zuari river is found continuing the manganease contamination in the estuarine complex and a heavy metal threat to the marine environment.
The contamination in the Water Environment of the project location is very alarming with both organic and inorganic contamination which requires cleaning or decontamination to preserve and protect the marine diversity of the estuarine complex of both Zuari and Mandovi.” 

EIA report does not mention anything about pollution of Rivers by trawlers that Ashwin Tombat pointed out. This means Draft EIA report is not genuine in its assessment of Goa’s rivers particularly Zuari and Mandovi, or Ashwin Tombat  is not genuine. One of the two has to be the case.

Tombat must introspect that what is claimed above as real dangers for fishing that includes Trawlers, purse seiners, pollution through urban sewage disposal, mining triggered pollution as well as Marina are in vogue due to non-implementation of SSF Guidelines or VG-SSF (Voluntary Guidelines for securing sustainable small-scale fisheries in the context of food security and poverty eradication) signed by 143 countries including India in July 2014. India through Article 54 of the National Policy on Marine Fisheries 2017 has called for enforcement of SSF Guidelines. There is great expectation and hope that the enforcement of SSF Guidelines will improve conditions of fisheries that includes health of aquatic ecosystems and human rights of small scale fishers. It is here that efforts of Ashwin Tombat are needed: to criticise everyone for non-implementation of SSF Guidelines. 

The fourth point that Tombat makes is an allegation: Trawler owners are misguided traditional fishermen that marina will affect their livelihood.

If trawler owners have misguided traditional fishermen that marina will affect their livelihood then why proposed Marina at Nauxim supports their trawlers by making fuel easily available as pointed above? It is clear that Tombat has not read the Draft EIA and speaking from his hat rather than head. This is not a healthy practice for a Journalist as it results in proliferation of confusion that blurs quest for truth for sometime as all the people cannot be fooled all the time and truth ‘escapes from the cracks in the wall’ as Rousseau wrote in his ‘Confessions’.

The fifth point that Tombat makes is factual status on Marina at Nauxim: Its true that one lakh square meters of water front will be covered by Marina.

The acceptance of this truth simultaneously means one lakh square meters of water front will be denied for fishing activities. This amount of space will be deepened through dredging by blasting of existing rocks as per draft EIA report. And this will decimate marine life as reported in GSBB report quoted above. And it is not one lakh square meters of water front but minimum one lakh square meters of water front as per draft EIA documents.

The sixth point that Tombat makes is assumption: Marina construction will boost Xinanneos and Calvam harvesting. With rocks blasted off through dredging as guaranteed in Draft EIA report where Calva and Shinanneo to grow? Tombat is ignorant of marine environment required for the growth of the two referred. By the way what about rest of over 185 marine species identified by ICAR studies through collaborative research work with fishing communities of Nauxim, Cacara, Siridao, Bambolim and Odxel?

The seventh point Tombat makes is semi-factual: Marina will affect fishing during construction phase but after completion, in the long term it will cover up all the loss caused.
This claim is contrary to the Draft EIA report as reported above that fishing will have long term irreversible negative impact on fishing activities.

The Eight point Tombat is making is an assertion: Marina at Nauxim will have no impact on Cacra, Odxel and Siridao.
Interview with fishing communities of the villages of Cacra, Odxel, and Siridao reveal that Nauxim river front is their a favorite fishing site. Marina at Nauxim will destroy their fishing based livelihoods.

The ninth point is a question: How is that opponents of Marina has not noticed pollution caused by trawlers to river waters?

Bharat Mukti Morcha as an opponent of Nauxim Marina has filed several objections against trawler operation in Zuari river. Tombat can access these complaints from Goa Fisheries department, Panjim. Trawlers not only cause pollution by oil spill but also dig out river bed and Goa’s own marine ecologists Aaron Lobo has been quoted in our letters pointing to the damage that trawler are carrying on to river bed. Oil spill from water sports boats in Zuari river too has been observed and objected to. Tourism department has written to Goa Fisheries department that it has no hesitation if Fisheries department withdraws NOC granted to water sports boats in rivers for disrupting fishing activities. Draft EIA report on Marina has also indicated release of oil, grease and paints into the waters of Zuari river during Marina operations.

Tenth point is out of context of draft EIA report: Marina sewage from Nauxim will be sent to Panjim at Tonca for effluent treatment. This information is not there in draft Marina EIA report that claims EIA treatment plant construction in Nauxim itself and use of treated waste water for Gardening in Nauxim on 50,000 square meters of land will be reclaimed from Zuari river. Have  Panjim Municipal Corporation permitted use of their facility for Marina facility at Nauxim? Or will Nauxim will be merged with Panjim city to facilitate this?

Eleventh point is prescriptive: Local Representatives of People must negotiate with Marina management and get jobs for locals at Nauxim Marina.

Currently Zuari river through fishing activities provides jobs to local at Nauxim and neighboring coastal villages. Public representatives are doing well in opposing Marinas to retain these jobs. Bambolim Panchayat has opposed Marina, their Gram Sabhas too has opposed, MLA of St. Andre Constituency too in a letter to Goa Chief Minister has conveyed his opposition to Marina citing among other terrorist threat that Goa will face from Nauxim Marina. So Public representatives have not degenerated into brokers that Tombat desires.

Twelfth point of Tombat is a promise: Locals employed will be sent abroad to work on Marina for higher salaries. So this confirms that the jobs offered in Marina will paid low or poorly so that they will require to be sent abroad for higher salaries. These fishing communities has refused to move out anywhere else for employment. Even when India’s shipping Minister Nitin Gadkari offered one trawler on loan for every four families to go to high sea for fishing they refused. And Tombat expects them to leave fishing and join Marina and then join Marina abroad.

Thirteenth point that Tombat makes: Marina is an opportunity that has come walking to them.
Local see Nauxim Marina as an aggression against their fishing economy imposed on them by India’s Ministry of Shipping though Mormugao Port Trust (MPT) who has pushed this Marina only to assert their ownership of Zuari river as per MPT Board meeting annexed with draft EIA report with zero safe guard to fishing communities. In fact in lease agreement with Kargwal Constructions pvt ltd not even existence of fishing activities in Zuari river is mentioned.

Then in conclusion Tombat raises two questions. The first one: What is the reason to object Public Hearing fixed for November 02, 2019?

The environmental governance in India is guided by bullying as proved by the Mopa International Airport hearing and the details the contents of the Judgment of 29th March 2019 wherein SCI division bench consisting of Justice Dr. Dhannajaya Y. Chandrachud and Justice Hemant Gupta suspended the EC granted on 28th October 2015 to Mopa Airport by EAC of MoEFCC. Views expressing dissent to Mopa Airport of public in complaints filed and verbal depositions never reached Expert Appraisal Committee (EAC) and Environmental Clearance was granted. Even people from Nauxim, Cacra, Odxel, Bambolim and Siridao had filed objections against Mopa Airport construction. 

It took enormous amount of effort for Rainbow warriors to challenge the malady at various levels and finally after cutting down over 54,000 trees EC got suspended. All this required tremendous amount of efforts and funds as EAC is proved to be grossly deficient in its functioning as an expert body and decides in favour of corporate interests as proved in this judgment referred as Rainbow Warriors versus Union of India. After knowing the way EAC functions and firm on the determination to oppose Marina at Nauxim call has been given to cancel Public Hearing and stop further process at this moment itself.

Tombat’s second question: If locals want to protect their interests, then shouldn’t locals communicate their interests during Public Hearing?
As replied above it has proved that EAC is biased against Environment as well as local people as per evidence contained in the above cited Judgment relating Mopa airport. Environmental Governance has failed as per the Judgment and Supreme Court of India had to intervene to restore. Even then Central Government Minister Piyush Goyal during his Goa visit in mid October 2019 criticized people and NGOs going to Supreme Court and restoring Environmental governance in India. Goyal even called for a mass movement against individuals and NGOs approaching Courts and restoring environmental governance. First of all it is costly affair to approach the Court and then Central Minister instead of awarding Padma Bhusan to those brave individuals and NGOs who approached Supreme Court of India in Mopa Airport case has called for mass movement against them. This is truly the case of governance by bully that is truly worthy of condemnation. Locals in the context of gross corruption, bullying  and their justifications are far sighted in calling for cancellation of Public Hearing and put an end to the process to grant  Environmental Clearance for which Public Hearing is compulsory.  Example of Croatia cannot be replicated in Goa to satisfy the needs of luxury tourism.

One last observation on Ashwin Tombat’s writings: Silence on joint tagging of villagers of Cacra, Nauxim and Odxel as ‘Shudras’ in draft EIA on page 4.78. Silence on Tombat’s part may mean consent if he doesn’t object and broadcast worldwide just the way he has done in his 27th October 2019 article on Marina at Nauxim. 

A week ago he had written another article on Marina and its linked here

Links to the complaints from Bharat Mukti Morcha is here.


Sebastiao Rodrigues
Convener, Bharat Mukti Morcha, Goa State
Member, National Council, National Platform for Small Scale Fish Workers (Inland)
Vice-President, Dialogue, Empathic Engagement and Peacebuilding Network (India)


Thursday 17 October 2019

Problems faced by small scale fishing communities in Goa’s rivers




                                                                                                      Date: 17th October 2019

To,

Rohita R. Naik,
Superintendent of Fisheries,
Panjim, Goa.

Subject : Your letter dated 11/10/2019 with subject Problems faced by small scale fishing communities in Goa’s rivers

Dear Rohita,

Thank you for your above mentioned letter asking for details of documents [Vessel Registration Certificate (VRC), Fishing Vessel Licences, Fishing Net Licence Book] of fishermen facing problems due to water sports activities by Aquasail Distribution in response to our letter to the Fisheries Minister dated 26/08/2019.

All the fishermen in Odxel, Siridao, Cacra and Nauxim using motorized canoes are facing the problem. Now till November 02, 2019 they are busy preparing for Public Hearing on Nauxim AHOY Marina that promises to increase water sports boats in Zuari and disrupting the fishing completely several times more than Aquasail Distribution.

Therefore you are requested to access documents from Fisheries department records as they were issued by your office as it is macro problem affecting all the fishermen and fisher communities.Alternatively you can visit all these villages and hold consultations to know about the matter. If needed, we will facilitate the visits. However make sure that NOC are not issued to Aqua sail this year. You may check the department records when Director Shamila Monteiro had revoked NOC to Aquasail distribution and restored after nine months due to Political pressure from then Chief Minister late Manohar Parrikar.

Sharing important study abstracts for your information on the subject: 10.5 of SSF Guidelines that requires implementation of holistic and inclusive ecosystem approaches in the fisheries sector. Approach in locating Aquasail boats in Zuari river is not holistic, its not inclusive and it is hostile to ecosystem. A.K. Whitfield from South African Institute for Aquatic Biodiversity, South Africa and A. Becker from School of Biological, Earth and Environmental Sciences, University of New South Wales, Sydney, Australia has jointly published their study titled “Impact of recreational motor boats on fishes : A Review” in Marine Pollution Bulletin Vol. 83 pages 24-31 in 2014. Sharing abstract their study to harm Marina boats and water sports boats could cause to biology and ecology of fish: “A considerable amount of research has been conducted on the impacts of recreational boating activities on fishes but little or no synthesis of the information has been undertaken. This review shows that motor boats impact on the biology and ecology of fishes but the effects vary according to the species and even particular size classes. Direct hits on fishes by propellers are an obvious impact but this aspect has been poorly documented. Alterations in the wave climate and water turbidity may also influence fishes and their habitats, especially submerged and emergent plant beds. Sound generated by boat motors can also influence the communication and behaviour of certain species. Pollution arising from fuel spillages, exhaust emissions and antifouling paints all have detrimental effects on fishes. Finally, the use of recreational boats as vectors of aquatic invasive organisms is very real and has created major problems to the ecology of aquatic systems.”

Further Sofia Jain-Schlaepfer, Eric Fakan, Jodie L. Rummer, Mark I. McCormick from ARC Centre of Excellence for Coral Reef Studies, and College of Science and Engineering, James Cook University, Townsville, Queensland 4811, Australia together with Stephen D. Simpson from Biosciences, College of Life and Environmental Sciences, University of Exeter, Geoffrey Pope, Stocker Road, Exeter EX4 4QD, UK has published their joint study titled “Impact of motorboats on fish embryos depends on engine type” in a Journal named Conservation Physiology Volume 6, 2018. Abstract of their study is reproduced and worth noting as to what could be the impact of motorboats that aquasail distribution attracts in Zuari and resultant impact on marine ecology. “Human generated noise is changing the natural underwater soundscapes worldwide. The most pervasive sources of  underwater anthropogenic noise are motorboats, which have been found to negatively affect several aspects of fish biology. However, few studies have examined the effects of noise on early life stages, especially the embryonic stage, despite embryo health being critical to larval survival and recruitment. Here, we used a novel setup to monitor heart rates of embryos from the staghorn damselfish (Amblyglyphidodon curacao) in shallow reef conditions, allowing us to examine the effects of in situ boat noise in context with real-world exposure. We found that the heart rate of embryos increased in the presence of boat noise, which can be associated with the stress response. Additionally, we found 2-stroke outboard-powered boats had more than twice the effect on embryo heart rates than did 4-stroke powered boats, showing an increase in mean individual heart rate of 1.9% and 4.6%, respectively. To our knowledge this is the first evidence suggesting boat noise elicits a stress response in fish embryo and highlights the need to explore the ecological ramifications of boat noise stress during the embryo stage. Also, knowing the response of marine organisms caused by the sound emissions of particular engine types provides an important tool for reef managers to mitigate noise pollution.” In this context water sports installation in Zuari river is a major set back to ecosystem approach advocated for fisheries. Goa Government through Fisheries department has commissioned study in Zuari river to find out impact of water sports boats on marine ecology and on fishing activities but study is delayed by one year due to lack of finance and file is pending in the Goa Finance Ministry for so long. It is safe to conclude from the way state of affairs are that Goa Government is sabotaging prosperity of small scale fishing activities in a planed manner and we strongly condemn this attitude of Goa Government.

Thanking you,

Yours Sincerely,

        Sd/-

Maggie Silveira
President, Goa State

Objections to holding of Public Hearing for setting up AHOY Marina in Zuari River at Nauxim waterfront


Date: 17th October 2019
To,
The Collector (North Goa),
Panjim, Goa

Subject: Objections to holding of Public Hearing for setting up AHOY Marina in Zuari River at Nauxim waterfront.

Dear Madam/Sir,

We had submitted letter to your office on 01/03/2019 objecting proposed public hearing on marinas in Zuari river. In this letter we re-iterate our opposition to fresh notice from Goa State Pollution Control Board declaring Public Hearing for setting up of “AHOY Marina” at Nauxim on 02/11/2019 at 10.30 am at Shyama Prasad Mukherjee indoor Stadium near Goa University as per advertisement from Goa State Pollution Control Board dated 25/09/2019 signed by Member secretary Sanjeev S. Joglekar. As per this advertisement in media District Magistrate or her/his representative is to supervise the entire Public Hearing Process. Hence we address this letter to you.

We object the holding of above mentioned Public hearing on the following grounds:

1.     Coastal Zone Management Plan (CZMP) preparation end only on November 05, 2019 and it is inappropriate to install project of Marina in Nauxim before the completion of CZMP.

2.     Location of the Marina is fish breeding/spawning site as well fishing site for several fishers on Zuari river bank specially in villages of Nauxim, Bambolim, Siridao, Odxel, and Cacra. Location of AHOY Marina is in violation of international law governing fisheries world wide. From July 2014 India is a signatory to Voluntary Guidelines for Securing Sustainable Small-Scale Fisheries in the context of Food Security and Poverty Eradication. These are known as SSF Guidelines and are made enforceable in India via Article 54 of the National Policy on Marine Fisheries, 2017. SSF Guidelines are applicable in scope to both marine as well as inland waters as per its para 2.2. And so they are applicable to Zuari river as well. According to para 1.1.c SSF Guidelines are to function in consistent with Code of Conduct for Responsible Fisheries, 1995 for which India is a signatory too. AHOY Marina location is in violation of this Code. Article 6.8 of this Code of Conduct for Responsible Fisheries states “All critical fisheries habitats in marine and fresh water ecosystems, such as wetlands, mangroves, reefs, lagoons, nursery and spawning areas, should be protected and rehabilitated as far as possible and where necessary. Particular effort should be made to protect such habitats from destruction, degradation, pollution and other significant impacts resulting from human activities that threaten the health and viability of the fishery resources.” Destruction of Nauxim famous fish spawning area itself is site for AHOY Marina that will be subjected to heavy drilling and blasting of the purpose of dredging as per the draft EIA report leading to major long term negative irreversible impact on fisheries in Zuari river. Hence this constitutes violation of Article 6.8 of the Code of Conduct for Responsible Fisheries.

3.     The Jurisdictions of MPT over Zuari waters is disputed as Central government circular of 24th May 2000 was issued without consulting fishing communities of Zuari river as well without consulting Goa Government.

4.     The representative of Goa Government Dr. Modassir (PA to Secretary – Ports) was absent for the 8th September 2010 meeting MPT 24th Board of Trustees when it decided to rent out Zuari river for two marinas at Sancoale and Nauxim. Dr. Modassir had sent note top postpone this matter as it is important as per records in the minutes of this meeting.

5.     Lease deed of 12th October 2010 between MPT and Kargwal constructions does not acknowledge the existence of fishing communities depend upon fishing in Zuari river and need to safeguard their rights.

6.     Port Land Policy -under which Zuari river has been leased out - was never discussed with fishing communities of Zuari river before its formulation nor shared after formulating. So there was complete non-transparency in this matter and leasing our of water fronts at Nauxim admeasuring more than 1,50,000 square meters of river bed amounts to land grab and Blue grab and contrary to claims of Blue-Green enterprise in Chapter III of the Draft EIA.

7.     In-Principle approval dated 29/04/2015 granted by Goa Investment Promotion Board to Kargwal Construction Pvt Ltd to set up Marina near Nauxim village –annexed with draft EIA report - is a fraud in several respects. First there is no ecologist who is a member of Goa Investment Promotion Board. Second there is no fisher community member who is engaged in fishing on Goa Investment Promotion Board. Thirdly, local people from Nauxim were not consulted at all by Investment Promotion Board before granting in-principle approval. Fourthly, after granting in-principle approval for Marina the decision was not communicated to Nauxim people or to Curca-Bambolim Panchayat under whose Jurisdiction Nauxim village comes.  Fifthly, In-principle approval decision was conveyed to the Village Panchayat of Cortalim that has no Jurisdiction over Nauxim village. Chief Minister of Goa who is chairman of this Board should call for immediate meeting and revoke the in-principle approval granted. Sixthly as per draft EIA report (Chapter III) “A marina is a harbour for yachts and other luxury boats and it is becoming a necessity of luxury tourism.” Such large scale projects destroying fishing practices cannot be imposed in a fishing village. According to para 6.8 of SSF Guidelines only community based tourism is allowed.

8.     Draft EIA on AHOY Marina admits significant fishing activity at the site of proposed AHOY Marina. Careful reading of Tables 5.2 (Coefficient values for impact assessment) and 5.3 (Impact quantifications) on pages 5.9 and 5.10 indicate with certainty that Fisheries in Zuari River will have Major permanent long term irreversible negative impact of coefficient of double (-2).

9.     Fisheries are entry 21 in the State List of Schedule 7 under Article 246 of the Constitution of India. Union Government through its Surface Transport Ministry, Shipping Department though MPT has no Jurisdiction to interfere and destroy Fisheries in the State of Goa within 12 nautical miles territorial limits. Any interference amounts to violation of Article 246 of the Constitution of India.

10.                        Draft EIA report on AHOY Marina commits to follow PIANC/IAPH guidelines for construction of Marina facility. Guidelines of World Organization of Dredging Organizations (WODA). At the same time ignores SSF Guidelines on small scale fisheries to which India is a signatory from July 2014 and pledged its enforcement through Article 54 of the National Policy on Marine Fisheries, 2017. According to SSF Guidelines that stands for “Voluntary Guidelines for securing sustainable small-scale fisheries in the context of food security and poverty eradication” has a provision to hold accountable to those who are responsible for destruction of fisheries as AHOY Marina is a disaster for fishing in Zuari river. According to para 9.5 of SSF Guidelines “in case of disasters caused by humans,impacting small-scale fisheries, the responsibleparty should be held accountable.” In the case of Nauxim AHOY Marina it is Union Surface Transport Ministry and its subsidiary MPT together with Kargwal Constructions pvt Ltd is a responsible party that will be held accountable for willful destruction of Zuari river fisheries. It is willful destruction as it is indicated in draft EIA itself.

11.                        According to the draft EIA report (page 4.78)villagers of Nauxim, Odxel and Kakra are primarily Shudra. This word Shudra means slaves. This word does not exists in the Constitution of India but found in Manushmriti that rates Shudra communities to the lowest in the hierarchy of graded inequality without any right to education and social interactions restricted within caste boundaries subjected to untouchability as Shudra is held unworthy even to lift body of a dead brahmin. Only duty of Shudra is to be servants of Brahmins, Kshatriyas and Vyashas. System of graded inequality as well as untouchability is made redundant by Constitution of India though Articles 13, 14, 15, 16, 17, and 21 which are the Fundamental Rights that cannot be suspended. Use of the word Shudra suspends these Fundamental Rights. If classification of section of people as Shudra is allowed in official documents like this draft EIA then every one will have to clarify whether he or she belongs to Shudra Varna or Brahmin Varna or Vyashya Varna or Kshatriya Varna. This is ridiculous practice and can snowball into unpredictable consequences of social disorder.

12.                        Location of AHOY Marina in Nauxi water is direct contradiction of SSF Guidelines para 5.9 which states that “States should ensure that small-scale fishing communities are not arbitrarily evicted and that their legitimate tenure rights are not otherwise extinguished or infringed. States should recognize that competition from other users is increasing within small-scale fisheries areas and that small-scale fishing communities, in particular vulnerable and marginalized groups, are often the weaker party in conflicts with other sectors and may require special support if their livelihoods are threatened by the development and activities of other sectors.” Tenure rights of small scale fishers are going to be extinguished and that’s reason why package is included in the draft EIA report in Chapter II.

13.                        AHOY Marina location is also in violation of para 5.13 of the SSF Guidelines that states States and all those engaged in fisheries management should adoptmeasures for the long-term conservation and sustainable use of fisheries resources and to secure the ecological foundation for food production. They should promote and implement appropriate  Management systems, consistent with their existing obligations under national and international law and voluntary commitments, including the Code, that give due recognition to the requirements and opportunities of small-scale fisheries”. Goa’s Fisheries department has refrained from enforcing SSF Guidelines, the Code of Conduct for Responsible Fisheries, Voluntary Guidelines on Responsible Governance of Tenure of Land, Fisheries and Forests in the Context of National Food Security and other international legal instruments applicable to Fisheries. If these were enforced then Goa Fisheries department would have quickly objected the Marina project at Nauxim at the planning stage itself rather than compel public to enter into the phase of public protests and agitations on this issue. Equitable access to fisheries guaranteed under para 5.13 would have never been allowed to be blocked though plans of installing Marina in Nauxim bay.

14.                        Nauxim AHOY Marina, the way it has planned is in complete violation of para 5.17 of SSF Guidelines that states “All endeavours should be made so that small-scale fisheries are represented in relevant local and national professional associations and fisheries bodies and actively take part in relevant decision-making and fisheries policymaking processes.” All the impact of the AHOY Marina will be directly felt by small scale fisheries in Nauxim, Siridao, Agassaim, Goa Velha, Bambolim, Cacra, Odxel and other villages on the northern bank of Zuari river as well as villages and towns in Southern banks of Zuari river. Yet in none of the decision making bodies connected Nauxim AHOY Marina small scale fisheries were represented at MoEF Expert committee, Board of Trustees at MPT, Goa Investment Promotion Board, Union Ministry of Surface Transport and Goa Fisheries department. Goa Fisheries department is so archaic in functioning that it does not have information as to who is at the receiving end of the water sports in Zuari river after fishermen repeatedly filed complains complaining about water sports boats tearing their fishing nets, creating oil spills and prompting fish migration due to non-stop engine sound in the river near Nauxim-Bambolim. It has taken no steps to form strategy group to enforce SSF guidelines as per requirement under para 13.5 for the Development and application of implementation strategies for the Guidelines.

15.                        Nauxim AHOY Marina is in violation of para 10.5 of SSF Guidelines that requires implementation of holistic and inclusive ecosystem approaches in the fisheries sector. Approach in locating Marina is not holistic, its not inclusive and it is hostile to ecosystem. A.K. Whitfield from South African Institute for Aquatic Biodiversity, South Africa and A. Becker from School of Biological, Earth and Environmental Sciences, University of New South Wales, Sydney, Australia has jointly published their study titled “Impact of recreational motor boats on fishes : A Review” in Marine Pollution Bulletin Vol. 83 pages 24-31 in 2014. Sharing abstract their study to harm Marina boats and water sports boats could cause to biology and ecology of fish: “A considerable amount of research has been conducted on the impacts of recreational boating activities on fishes but little or no synthesis of the information has been undertaken. This review shows that motor boats impact on the biology and ecology of fishes but the effects vary according to the species and even particular size classes. Direct hits on fishes by propellers are an obvious impact but this aspect has been poorly documented. Alterations in the wave climate and water turbidity may also influence fishes and their habitats, especially submerged and emergent plant beds. Sound generated by boat motors can also influence the communication and behaviour of certain species. Pollution arising from fuel spillages, exhaust emissions and antifouling paints all have detrimental effects on fishes. Finally, the use of recreational boats as vectors of aquatic invasive organisms is very real and has created major problems to the ecology of aquatic systems.”Further Sofia Jain-Schlaepfer, Eric Fakan, Jodie L. Rummer, Mark I. McCormick from ARC Centre of Excellence for Coral Reef Studies, and College of Science and Engineering, James Cook University, Townsville, Queensland 4811, Australia together with Stephen D. Simpson from Biosciences, College of Life and Environmental Sciences, University of Exeter, Geoffrey Pope, Stocker Road, Exeter EX4 4QD, UK has published their joint study titled “Impact of motorboats on fish embryos depends on engine type” in a Journal named Conservation Physiology Volume 6, 2018. Abstract of their study is reproduced and worth noting as to what could be the impact of motorboats that Marina likely to attract in Zuari and resultant impact on marine ecology. “Human generated noise is changing the natural underwater soundscapes worldwide. The most pervasive sources of  underwater anthropogenic noise are motorboats, which have been found to negatively affect several aspects of fish biology. However, few studies have examined the effects of noise on early life stages, especially the embryonic stage, despite embryo health being critical to larval survival and recruitment. Here, we used a novel setup to monitor heart rates of embryos from the staghorn damselfish (Amblyglyphidodon curacao) in shallow reef conditions, allowing us to examine the effects of in situ boat noise in context with real-world exposure. We found that the heart rate of embryos increased in the presence of boat noise, which can be associated with the stress response. Additionally, we found 2-stroke outboard-powered boats had more than twice the effect on embryo heart rates than did 4-stroke powered boats, showing an increase in mean individual heart rate of 1.9% and 4.6%, respectively. To our knowledge this is the first evidence suggesting boat noise elicits a stress response in fish embryo and highlights the need to explore the ecological ramifications of boat noise stress during the embryo stage. Also, knowing the response of marine organisms caused by the sound emissions of particular engine types provides an important tool for reef managers to mitigate noise pollution.” In this context Marina installation in Zuari river is going to be major set back to ecosystem approach advocated for fisheries. Goa Government through Fisheries department has commissioned study in Zuari river to find out impact of water sports boats on marine ecology and on fishing activities but study is delayed by one year due to lack of finance and file is pending in the Goa Finance Ministry for so long. It is safe to conclude from the way state of affairs are that Goa Government is sabotaging prosperity of small scale fishing activities in a planed manner and we strongly condemn this attitude of Goa Government.

Bharat Mukti Morcha, Goa Unit strongly condemns this draft EIA report and call for immediate cancellation of Public Hearing.
Thanking you in anticipation,

Yours sincerely,
       Sd/-
Maggie Silveira

President, Goa Unit

Member of National Council, National Platform for Small Scale Fish Worker (Inland)

Copy to:
Director of Fisheries, Panjim, Goa with a request to follow up and object Nauxim AHOY Marina as well as its Public Hearing