All Goa Small Scale Responsible Fisheries Union (AGSSRFU) strongly objects to the Goa Government proposal to Central government to remove fish breeding areas from the CZMP on the ground that Goa Fisheries Department and Indian Council of Agricultural Research (ICAR) doesn't have scientific studies or information in this regard.
AGSSRFU also further objects to the promotion of Sand mining and tourism inside Goa's rivers on the same grounds of lack of data. Lack of scientific studies and information about fish breeding areas in Goa - if Goa Environment Minister's claim is true - is not due to any fault of rivers and fishing communities in Goa. It may be for other reasons like lack of focus of research scientists on fish breeding sites in Goa or lack of sanctioned funds for such scientific studies involving Fish Breeding Areas.
AGSSRFU was party to the consultation called by erstwhile Director cum Secretary to Fisheries in Goa Mr. Govind Jaiswal few years ago with scientists from NIO as well as ICAR. At that consultation Scientist from NIO revealed that entire Coast of Goa and riparian coast witness fish breeding and consequently entire coast and rivers needs to be protected.
Fisheries Department in Goa is subsidies oriented and schemes oriented since its inception, and more recently enforcement is attempted to be added as an additional component with moderate success. Research component is completely absent from the essential daily routine of Goa Fisheries Department. Goa's Environment Minister Nilesh Cabral is totally and completely wrong in accusing Goa Fisheries Department of lacking scientific studies on Fish Breeding Areas in Goa. Goa Fisheries Department doesn't even have rudimentary in-house study team to regularly scan various anti-fisheries policies and practices affecting Goa. In this context Fisheries Department carring on scientific studies on fish breeding areas is beyond posibility for Government has neither sanctioned budget nor appointed competent researchers in Fisheries Department. Hence Goa Government - of which Nilesh Cabral is part of - is totally and completely responsible for the absence of scientific studies on fish breeding areas in Goa.
Goa Fisheries Department is in possession of data of Zuari river fish breeding areas submitted my fishing communities and same should be presented to Environment Minister Nilesh Cabral.
Various Coastal bio-diversity committees and other organisations has submitted detail maps of rivers displaying fish breeding sites in Goa's rivers. These are submitted to Goa Coastal Management Authority (GCZMA) under Ministry of Environment in Goa that Nilesh Cabral is heading. He should call first all these maps and access them for information on fish breeding areas.
Moreover if Goa Government is not satisfied with the submission from bio-diversity committees and other organisations on fish breeding areas in Goa then it should appoint scientific institutions to locate fish breeding areas in Goa like the was Goa State Bio-diversity Board (GSBB) appointed National Institute of Oceonagraphy (NIO) to identify sand clusters in Various rivers of Goa. It is rather bizarre that GSBB is more interested in identifying sand inside Goa's rivers for mining purpose rather than identify Fish Breeding Areas. It is even more surprising that Nilesh Cabral chose not to mention whether GSBB does or doesn't possess studies on Fish Breeding Areas in Goa in his press briefing reported in print media on October 25, 2022.
NIO studies submitted to GSBB and put out in public domain by the Director Mines and Geology, Government of Goa has important clues in this regard. It's Mandovi Survey Report notes that sand provides habitat to numerous forms of aquatic and riparian fauna. Second NIO study titled EIA/EMP for sand mining in Zuari Estuary, on page 138 notes "sand mining affects the area by limiting the ability of mined areas to function as a nursery area, and/or feeding ground for the fauna". Just because of demand for Sand from various commercial sources seeking to expand urbanisation Goa's rivers should not be pushed towards peril the way Goa Government is currently moving on to do.
AGSSRFU calls upon the Goa Environment Minister to withdraw the proposal sent to the Central Government to erase Fish Breeding Areas and entrust the responsibility to clarify status of natural fish breeding in Goa coast and rivers. AGSSRFU suggests that team of scientists from various competent research institutions in Goa be formed to Carry on full fledged short term and long tern study on fish breeding areas in Goa. Till it is completed and put out in public domain all the plans for erasure of fish breeding areas from CZMP 2019 and plans for Sand mining be put in abeyance.