Friday, 23 March 2018

Call to immediately revoke NOC for water sports in River Zuari


Date: 15th March 2018

To,
The Minister of Fisheries,
Government of Goa,
Secretariat, Porvorim, Goa

To,
The Secretary (Fisheries)
Secretariat, Porvorim, Goa

To,
The Director,
Directorate of Fisheries,
Panjim, Goa

To,
Captain of Ports,
Government of Goa,
Panjim, Goa


Subject: Call to immediately revoke NOC for water sports in River Zuari

Sir,
Please find the bullet points as desired by Secretary (Fisheries) Govind Jaiswal IAS during the meetings held in Director of Fisheries cabin on 05/03/2018 and 09/03/2018 as under:
1.    Reduced Fish Catch
Ø  After commissioning of water sports fish drastically reduced
2.    Noise disturbances
Ø  There is sound in water from water sports boats
Ø  Fish moves far away due to this sound of boats
Ø  The emergency boats of Aquasail Distribution Co. Pvt. Ltd have gone commercial and used entire day especially on every Saturday and Sunday.
Ø  Three safety boats with outboard machine (Rigid Inflatable) listed as serial nos. 37,38,39 of attachment of N.O.C operate entire day commercially specially on Saturday and Sunday.
Ø  This is violation of N.O.C. dated 13/10/2017 of Director of Fisheries No. ENF/WS/AQUA-SAIL/2017-18/4240 condition no.6 and as per condition no.9 of the same N.O.C. it is liable to be revoked with immediate effect.
3.    Oil leakages
Ø  Water sports emergency boats causes leakage of oil from their engines
Ø  Their oil dips into water and reaches river bed.
Ø  Fish then does not get oxygen to breath
Ø  Fish food spaces get damaged
Ø  Fish then moves to some other location
Ø  Some fish dies with oil leakage, with oil odors, we have seen fish dying in river due to this reason
Ø  Fish when gets affected with oil, it rotates around itself
Ø  Fish stays in Siridona, Bambolim, Nauxim coasts, it is breeding ground for fish
Ø  With oil leakages fish eggs and fish larvae are destroyed easily
Ø  There used to be lots of Tisreo available in Bambolim; no trace of them now
Ø  Mendio used to be available, now not traceable
Ø  This causes very dangerous situation
Ø  This is a direct violation of condition no.1 of the above cited N.O.C.
4.    Fishing net traps
Ø  Fishing nets gets trap to water sports boats
Ø  Fishermen in Zuari put out Gill nets in the morning and pull back in the evening
Ø  These nets gets entangle with under water fans of water sports boats and gets cut off
Ø  If cut pieces of gill nets are not tied immediately then two pieces of nets drifts away in water, when this happens net gets destroyed
Ø  If some other fishermen goes in river unaware of torn nets then that fishing boat too gets entangle and engine goes off
Ø  Machine shaft suffer damage with its ropes
Ø  Water sports boats has more powerful machinery and the floating nets gets cut off
Ø  Very often these torn fishing nets gets entangle with other fishing boats when on search for nets
Ø  These cuts nets when gets abundant in river increases risk of ghost fishing in Zuari and Arabian Sea.
Ø  This is a direct violation of condition no.1 of the above cited N.O.C.
5.    Timings fallacy
Ø  The moment fishermen see fish they go into river anytime
Ø  It is not that we will be going for fishing only in the night time
Ø  If need be we go fishing in day time too
Ø  This is a direct violation of condition no.1 of the above cited N.O.C.
Due to above reasons we call upon you the following:
ü  Immediately revoke Director of Fisheries N.O.C for water sports issued by Director of fisheries Govind Jaiswal, I.A.S vide letter no.ENF/WS/AQUA-SAIL/2017-18/4240 dated 13/10/2017.
Only after cancellation you are requested to carry on the necessary scientific studies. In fact there already study on Zuari River carried on by team from ICAR Old Goa that has conclusively proved that Zuari river has abundant of fish (if required we will furnish the copy of this published study to you) and Fisheries department has issued licenses to fishermen to carry on fishing in Zuari river. We will email you this study. However we wish to place on record certain wrong practices currently followed by Department of Fisheries:
v  No fishermen fishing in River Zuari were consulted before allowing water sports in Zuari and yet included first condition in N.O.C under reference “The sports activities shall not cause any hindrance to any fishing activities conducted by the traditional fishermen in the area”.
v  After issuing N.O.C department of Fisheries has not carry on any study to know whether conditions laid down in N.O.C are complied with or not.
v  After we filed compliant to the Director of Fisheries and Captain of Ports dated 17/11/2017 no reply was given to us so we remained in dark.
We wish to place also on record three good practices followed by the Directorate of Fisheries that we came not know recently:
ü  Director of Fisheries kept further N.O.C for expansion of water sports in Zuari due to our objection dated 17/11/2017
ü  Minister of Fisheries processed our letter to him dated 07/02/2017 about delay in withdrawing NOC to water sports in Zuari river.
ü  Director of Fisheries called meeting with us on 05/03/2018 and another meeting on 09/03/2018 and had frank discussions.
Now we are informed about the inhibition Director of Fisheries is facing over quick revocation of granted N.O.C is the fear that it may be challenged in Court. To this we have certain responses:
·         There is a preceding practice of Department of Fisheries few years ago of issuing notifications beneficial to the fishermen even in situations of absence of any scientific studies. The example is the way LED ban was imposed in Goa even when department had no scientific study to prove that LED fishing is bad. In fact there was study of CMFRI supporting LED enabled fishing. It is only later when current Fisheries Minister of Goa Mr. Vinoda Paliencar convinced central government to ban LED all over India within 12 nautical miles.
·         The above example explains clearly that the agenda and rhythm of fishermen and scientists often differ and even contrast. And to rely upon scientific research to initiate while Fishermen in Zuari suffer is a dangerous idea and may lead to dangerous consequences as scientific studies take long time to get competed and assumes that Fisheries department has no in-house scientist to dedicate exclusive attention even though there are few Ph.d qualified are on department employment including deputy director of fisheries. We are not in position to take responsibility in case ground level situation deteriorates due to delay in revocation of N.O.C. under reference.
·         This situation implicitly imply that we need to come to Fisheries department in order to agitate and provoke provoke lathi charge like in LED agitation few years ago and only then Fisheries department will cancel N.O.C to water sports in Zuari. This is really bizarre and bad governance practice and must be stopped forever.
First revoke NOC and then carry on Scientific Study
We place on record our appreciation for all the efforts Secretary (Fisheries) has taken to defend fisheries in Goa. We request you after revocation of N.O.C to consider seeking assistance for study from the following in addition to Dr. G.B. Shrikant of ICAR, Director (ICAR) and Director (NIO) depending upon their willingness but surely they have expertise:
1.    Dr.Baban Ingole of NIO who has worked and documented fishing activities in Zuari river.
2.    . Aaron Savio Lobo, Marine ecologist from Goa and actively involved in defending fisheries in various parts of India including in Tamilnadu. He has earlier completed project for Goa Fisheries Department on Chorao Island.
3.    Dr. Savita Kerker, Head, Department of Microbiology, Goa University who has worked on fishing pollution issues in Goa’s rivers like Mandovi. She recently (November 2017) published in an Internationally reputed Journal joint paper on multi-sourced pollution of Mandovi river causing DNA destruction of Zebra fish in Salt panes of Ribandar providing several key citations and hyperlinks to other studies on Goa’s rivers. (If your office does not have copy then we will submit the same, let us know)
4.    Dr.Srikant Mutnuri, Head, Department of Biological Sciences, BITS Pilani, Goa Campus, Sancoale, Goa. He currently has a project on cleaning up of Sal River polluted due to various factors.
5.    Dr. Antonio Mascharenhas who has served many years with GCZMA, Government of Goa with distinction and uprightness.

Few suggested Terms of References for Study

1.    To identify relationship between water sports and marine ecology in Zuari River
2.    To identify implications of oil leakages to marine ecology of Zuari
3.    To identify nature of damage to fishing practices due to water sports practices.
Put Environmental Ethics as guiding principle
Evaluating fishing conflicts with water sports in Zuari from point of Environmental Ethics is most likely to provide clarity and subsequently solution. It is therefore requested that Paul W. Taylor’s book “Respect for Nature: A Theory of Environmental Ethics”, Princeton University Press, Princeton and Oxford, 1986 (2011) be used as guide to break through various contentions in the conflicts speedily.
To begin with you may procure the copy of the book. If needed, we will share soft copy of book to you via department email.
We advise you to initiate following actions:
A.   Immediately revoke Director of Fisheries N.O.C. issued to the managing director, Aquasail Distribution Co. Pvt. Ltd. dated 13/10/2017
B.   Initiate Scientific Study on “Impact of Water Sports on Fishing and marine ecology in Zuari river”
C.   Frame the issue of water sports-fishing conflicts in Zuari from the perspective of Environmental Ethics for clear solutions.
We extend our support to you in the wider interest of defence of fisheries in Goa and offer our collaboration in whatever way possible in the wider interest of Justice to traditional Fishermen of Goa.
Thanking you,
Yours sincerely,


Maggie Silveira
President, Goa State

Rohidas Andrade
Convenor, Bambolim Unit

Sanjay Pereira
Convenor, Cacra Unit

Soccorro Braganza
Convenor, Siridao Unit

Anthony Cardozo
Convenor, Curca Unit
Sitaram Pereira
Convenor, Odxel Unit

Milind Palkar
Convenor, Nauxim Unit

Ms. Kalpana Diukar
Co-convenor, Odxel Unit

Chandrakant Lotlikar
Secretary, Siridao Unit

Hanuman Dias
Co-convenor, Odxel Unit
Honu Divkar
Co-convenor, Odxel Unit

Deu Kankonkar
Secretary, Nauxim Unit

Yeshwant Shirvoikar
Co-convenor, Odxel Unit

Manguesh Sawant
Co-convenor, Odxel Unit

Amir Mardolkar
Co-convenor, Nauxim Unit

Francis Coelho
Co-convenor, Nauxim Unit

Jaya Kuttikar
Co-convenor, Odxel Unit

Jonu Shirvoikar
Co-convenor, Odxel Unit

Ms. Sheila D’mello
Co-convenor, Cacra Unit

Ashok Kukalkar
Co-convenor, Odxel Unit

Ganashyam Diukar
Co-convenor, Odxel Unit

Uttam Martins
Co-convenor, Odxel Unit

Rohit Hadkonkar
Co-convenor, Bambolim Unit

Sanju Diukar
Co-convenor, Odxel Unit

Chandranath Rosario
Co-convenor, Cacra Unit

Vijay Sawant
Co-convenor, Cacra Unit

Ragunath Sautodkar
Co-convenor, Cacra Unit

Mahadev Andre Rosario
Co-convenor, Nauxim Unit

Laximan Mangueshkar
Co-convenor, Siridao Unit

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