ALL GOA SMALL SCALE RESPONSIBLE FISHERIES UNION
190, Nauxim, Bambolim, Tiswadi, Goa. 403 206
March 08, 2022,
To,
The Chairman and all other Members of Expert Appraisal Committee of the MoEF&CC, Government of India
spiderconch@gmail.com
sukumaranjeyakrishnan@gmail.com
negims84@hotmail.com
sham.wagh@gmail.com
kharemukesh@yahoo.co.in
pachauri1945@gmail.com
drvkjain@hotmail.com
hota.manoranjan@gmail.com
rajesh-cgwb@gov.in
ramana2865@gmail.com
nirmalendu.soi@gov.in
neeraj.crri@nic.in
ad.raju@nic.in
ccb.cpcb@nic.in
Sir/ Madam,
Hello and Warm Greetings of Peace from Goa!
It has come to our attention that proposal from Kargwal Construction Private Limited, Mumbai to set AHOY Marina at fishing predominant Zuari river of Goa by using nomenclature as "MPT WATERS" is listed for the 290th meeting to be held on March 10, 2022.
It is in this regard that we make this timely intervention to let you know that each one of you are invited to visit us at Zuari river where we do our fishing activities. This will enhance your expertise before taking any further action to grant Terms of References to Kargwal Constructions Private Limited to move ahead with another EIA Study.
Kargwal Constructions Private Limited has already prepared EIA study and that was put out to hold Public Hearing through Goa State Pollution Control Board that did not take place and matter is pending before Goa Bench of Bombay High Court.
All Goa Small Scale Responsible Fisheries Union calls for scrapping of Marina project in Zuari river at Nauxim Goa on following grounds:
1. Lease deed of Kargwal constructions private Limited and Mormugao Port Trust (MPT) dated 12/10/2010 for approximately 1,00,000 square meters of water front of Zuari river for 30 years at the rate of Rs.4.87 per square meter per month is ill conceived from the beginning by vested interests to expel fishers from Zuari river and trigger food insecurity.
2. The lease agreement doesn't even acknowledge existence of fishing activities in Zuari river even though its permitted by Goa Fisheries department.
3. The lease agreement that is based upon the decisions of MPT that has ignored fishing activities in Zuari River as evident from their minutes. The sole criteria cited in the minutes to lease out Zuari River without consulting local traditional fishers is to generate incomes for MPT even if that requires expulsion of fishing activities.
4. The lease agreement that is based upon the Ports Land Policy prepared by the Union ministry of Shipping is based on unjust principles that ignore fishing activities in Zuari river.
5. The Union government wrongly claiming and asserting its Jurisdiction over Zuari river and bestowing powers to MPT through a gazette notification of May 24, 2000 was done in an unethical manner without consulting with communities who are involved in fishing inside Zuari river for time immemorial. The consequences of such a nefarious act are the expulsion of fishing communities from Zuari River. All notifications of Central government extending MPT jurisdictions over Zuari River must be immediately withdrawn to avoid expulsion of fishers from Zuari River.
6. The ecological dangers of Marina to marine ecology are officially placed on record by Goa Bio-diversity Board in case of neighboring Yatch Haven marina by Chowgules inside Zuari River on Sancoale river front. Same report are relevant to Nauxim Marina too.
7. Fishing communities are opposing marina at Nauxim based on their wisdom accumulated over the centuries. As per their understanding Marina project at Nauxim will destroy both human habitat at river coast as well fish habitats in Zuari River. Fisheries will suffer to an unimaginable extent.
8. The understanding of fishers that it will destroy fisheries is confirmed by the impact quantification calculations presented in the EIA report prepared for Nauxim marina and put out in public domain by Goa State Pollution Control Board.
9. The joint reading of Tables 5.2 and 5.9 of the AHOY Marina EIA reveals that Fisheries in Zuari River will have permanent negative impact of the nature that is major, long-term and irreversible. Fisheries can be destroyed in this manner only if marine environments are destroyed and the cited tables do indicate major long term negative impacts to marine environment. We do not desire this to happen to our Zuari river fisheries.
10. The laws and policies of India that provide powers to Ports overriding the existing fishing activities are based upon unethical foundations of injustice, inequality, impoverishment, livelihood destruction, damage to marine ecology and promoting food insecurity. These laws and policies needs to be done away with urgency.
11. AHOY Marina at Nauxim is combined assault on livelihood of fishing communities from several Coastal villages on Zuari river northern and southern bank and on food security of several people who are dependent upon fish as an ingredient of their food.
12. Ignoring all the above points on October 05, 2020 Kargwal Constructions private limited from Sion, Mumbai has filed Writ of Mandamus at the Goa Bench of Bombay High Court against State of Goa. Writ has called upon the Court to determine (a) whether Public Consultation is required as it is mandatory requirement by law, and (b) whether indefinite postponement of environmental public hearing in case of "Ahoy Marina" at Nauxim is unjust to the project proponent.
13. As the last 12 years of public struggle has ensured non-enforcement of marina at Nauxim it is now urgent that the project be scrapped totally by cancellation of the lease deed itself rather than put the issue languishing for further litigations causing tensions and unrest to the fishing communities of Goa.
The call of the fishing communities of Goa is complete abandonment of Marina project at Nauxim village and all the neighboring villages of Bambolim, Siridao, Agassaim, Cacra, Odxel, Marvel, Dona Paula, Caranzalem, Sancolale, Chicalim as well as Vasco municipal limits localities like Khariavaddo are going to face violations of the right of livelihood.
You are therefore called upon to act decisively on the above matter. We wish to let you know that installing of Marina at Nauxim water front is an open assault against livelihoods of fishing communities of Goa and we have resisted the same for dozen years. MPT/ MPA has not manufactured Zuari river to claim its Jurisdiction and to lease it to whimsically to anyone of their choice by ignoring fishing communities actively carrying on our livelihood practices.
We therefore advise you to refrain from issuing any Terms of Reference to the Project proponents - Kargwal Constructions Private Limited to conduct any further EIA Study and outright reject their File no. 10-38/2016-IA.III coded as proposal no. IA/GA/NCP/257252/2022 that is listed on the agenda of the meeting at point 3.5.
From the begining AHOY Marina is death knell to fisheries of Goa and you are urged to heed to our call. Do contact us anytime for any further queries if required, we will be eager to co-operate to get to AHOY Marina scrapped.
Thank you all.
Yours sincerely,
Sd/-
Shaila D'mello
President
M: 9765843743
Sd/-
Laximan Mangueshkar,
Secretary
M: 8888401385
Sd/-
Dr. S.A. Rodrigues
delegate to National Platform for Small Scale Fish Workers, representing All Goa Small Scale Responsible Fisheries Union.
M: 9923336347
Please send me a copy of the letter signed by the signatories under the union's letterhead so that NPSSFW forward the same to MoEF with a letter of protest.
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