Sunday 26 November 2023
Tuesday 21 November 2023
Applea jivitantle moladik onbhov ani vichar amche modem vantta Joao Manuel Pinto.
Siridao ani Nauxim ganvant 1961 vorsa adim jem hanvem dolleamnim dekhlam ani kananim aikolam tem lokamche nodrek hadtam. Siridao Ani Nauxim he karvi lokamche ganv. Portugues kaidea pormonem rampnim, xinzelam, magg doriantlem nistem dorunk, lahn toxem vodd poneuv ani vodeanchim lisiençam Captain of Ports hea kateantlean Kadchim podtalim. Lisiençam aiz pasum kadtat ani lokam laguim samballun dovorlolim asat.
Zallamchim vanxim (fish nets) bharik, lhan, modle ani motea zokachim astalim. Bharik vaxeamchea zalanim nistem mharpak vo dorunk bondhi asli. Oxe toren Portugues sorkar nisteacho sambal kori ani nisteachi vadd zaunk pautali.
Pausachea tempar June, July, Agost moineant rampnim, xinzelam, magg doreant ghali nasle, kiteak nistem zolmon evunk adhar zatalo. Uchamboll zalelea doreant nistem tondgar svateamcher doreache thodik evum rautalim mhonn amche sorgest kharvi bhau sangtale.
Nauxe Ani Bambolim Bay-acho (doreacho) zagho uchamboll axillea doreachea adosak podta ani nisteacho jiv prann vadonk sondhi meuta.
Agostachea moineant paus khomin zatoch Setembrache survatek Siridao, Bambolim , Nauxim veller nisteachi xeu (uvar) mhunn zatali ani bhorpur nistem zallamnim podtalem. Nistem polleun jivak umedh ani sontos bogtalo. Oxe porim nistem akhe Zuari nodient ani Arbi somdirant porsautalem. Captain-Of-Ports-ache odhikari oslea velar zallanchim topasnim (inspection) korunk goemchea vellancher bounvtale. Bharik vanxeanchea zallanim nistem dorlolem mheulear tim zallam zopt kortale.
1961 vorsa adhim zuari nodint motoracheo botti (motorboats) ani fishing trawlers nasle, fokot minacheo bharji choltaleo. Atam dista tosli uchanbollai, Zuari nodint nam mhunn Arbi somdhirant nasli.
Nauxe dhongrachem pont Zuari nodint (estuary) pauta. Te svatek amche kharvi bhav ‘Nauxe Bandear’ mhunntale. He svatecher doriant khoddpancher utpon zalelim kalvam, xinnaneo, mhendhieo (Window pane shells) kharvi bhav doriant budd mharun konchun kadtale. Toxench dorea-sukte velar Siridao Jesus Nazareth vadeant oddakodche veller lokh kubhe, tisreo, mhendhio Ani sutte chinklantle korpun kadtale.
Nistekar Zuari nodi ani Arbi somdhirachea udexim aplo ani aple familichem udharposon korun sukhi jietale. Tankam Govermentacho kosloch adhar naslo.
1961 vorsa uprant jednam fishing trawlers, motorboats, zuari nodint bhitor sorle ani boraboruch doriant tourism sports suru zaunk laglo ani vadot ghelo tednam, traditional kharvi bhavanchea pottar farr ievunk suru zalle. Itlench nuim, bhotinchea avazan ani bizlechea (light) uzvadan Siridao, Bambolim, Nauxe bay-ant nistem tant’tiam ghallunk bhivonk laglim ani oxe toren nistem komim zait vochonk laglem (Unauv zait ghelo).
Kaim vorsam fatim, Grand Hyatt Hotel, Bambolim velek tenkhun CRZ- ant bandhun kadlem. Tem ek illegal contruction mhonn goem bhor dass podleli. Atam legalise zalam ou Kellam astolem.
Bambolim veller aiz xinzellam ani lhan khantaeo dhovorpacheo bhond zait gheleo ani fudharak bhond zaupache vatter assa, karan veller vospacheo vatto oxhir ani bhond zait geleleo dista. Tea bhair highend touristank veller fishing kellelem bhilkul mandhonam kiteak veller zai toxi mouza touristank korunk mevonam. Itlench noim nisteacho vass hotelak lagta.
Hotelachi security rampnim-xinzelam ani magg dovrunk adkoll adunk laglea ani hadtatt. Akach lagun soimbim add udorghoticher goenkar avaz utounk fudem sorla ani sorot assa.
Corporate Houses, newspapers, TV channels (anchors), digital media, dis ani rath development projectancher advertisement ani conferences goddun haddun, projectam udexim boreponam ieunchim ani lokhank mhellchim assa tem lokamche nodre mukar dovrun , ek ‘Public Opinion’ toyar korta (manufacturing consent) fokot ‘political economink’ lagon ani he baxen lokamchim monan dixeabull kortat.
Dusre vaten projectam voir kritik (tika) khortoleank, NGO-ank, goemchem bhorem dektoleank projectam voir bhasabas korunk, newspapers, TV channels ani digital mediacher favo tho zaggo dinnant, karan tanche vichar ani ievzonneo projectam voir add vochot mhunn.
Dekik Nauxim-Marina Project
Nauxim-Bambolim bay-ant ho project bhandun haddunk MPT vo MPA -n lease deed contrad sign kelo mhunn kobhor podlea ani IPB-n (Investment Promotion Board), soimbim kaidhea add appli porvanghi dillea. Jedhnam ho project suru kortole tednam poilim Nauxi-bhandear thaun doriant ek robol fatrancho vado toear kortole (embankment/reclaim land). Uprant Bambolim resort-achea fudlean sukte velar doriant ek durig zalelea porim koddpam distat, taka Bambolimcho bhando munntat. Hea bhandeak thaun robolsancho bhand (embankment) toear zatolo ani uprant donuim bhandeam modhem ek khavtem (opening) doriachem udok bhair bhitor sorpak dhovortole. Tea uprant Nauxim bay kolaitole (ustitole) ani chikoll, mati kaddun Nauxi vele vatten doriantlean zomin borun hadtole (reclaiming land) boattink (yatchs,etc ) dock korpak.
Bottinchi suvidha korunk ek doko, Fuel house, water storage tanks, Toilets, maintenance yard, staff housing, warehouse/boathouse, training centre osleo souloti bandhun haddtole. Uprant shopping centre, tourist hotels, land casinos, adi, Nauxim dongrar bandhpachi goroz podttoli. Oxem zatoch drugs, prostitution, gambling, crimes, zaun ganv chi xhanti bigottoli zoxe porim goemchea sabar ganvamnim dixtti podtta .
Itlench noim, project toyar zatoch, nisteachi pik vadot kaii?
Zuari nodint nistem porsovtolem kaii?
Vo sorkar xetam puroun , xetanim nisteacheo hatcheries (farming) korun nisteachem bhiim doriant Ani nhodinim sodtole kaii?
Ani sorv bhonvtim vattaranim hacho faido vo luksonn zatolem kai? Osle sabar proxnn upzota.
Shirdonnchea kharvi bhavank Bambolim ani Nauxeche veller xinzelam Ani khanttalleo hea fuddem vodunk mellot Kai? Hea projectak lagon nauxechea lokak aplea garantle umttun kaddun uddoitole Ani tankam dusrea svateancher galtole. Oxem godot zalear te aplea nusteacho vaur he novea svateancher thaun korunk pavot Kai? Zori tor tankam Compensation legit dilem zalear, kitlo temp legun hea compensationacher te zogtole? Hea nustekar bhavanchea koxtank lagon sodeak sabar ganvchea lokank tajem nustem khaunk mellta, fudarak tem mevot Kai vo tankam formalinchench khauchem poddtolem? Monant Osle sabar proxnn upzotat.
Munxean apleaponank lagon soimbhacho duspott kelolo dolleam mukar dista. Desadesanim dornkamp, butteo, volcanic eruptions, sunamin, adol-moddam, adi zait assat. Apsuvartak lagon Goemchi doxea zaunk paulea. Atamcho somaz cronic capitalistamcho zala.
Adle purvoz, xinkonk nasle tori tankam zanvai asli. Zanvai-en te cholle ani goemcho fudhar boro zauncho ani goem sodanch bhangarachem urchem mhunn tamchea kallzachi axea asli.
Atamche xinklele ani amche amdhar (goemkaramche kamdhar) apponn bhudvont ani zannar mhunn somzotat ani goemchi durdoxea kortat.
Khori zanvai xinkpa udhexim azun tankam mheuli-nam, dekhun aiz bhangarachem Goa chiklachem Goa zaunk paulam.
Chint munxea korchea adhim uprant rodonn faido-nam.
Friday 15 September 2023
This video clip by anonymous went viral today on social media is from Naroa bank of Mandovi river in Bicholim taluka that captures illegal sand mining trade early morning on 15 September 2023.
This indicated active container of Department of Mines and Geology, Goa Police and Mamlatdars of Tiswadi and Bicholim Talukas.
Naroa has been one of the Hotspot of daily illegal sand mining from mid-night to dawn. Other notable Hotspot include Vanxim island and Chamerem in Chorao island.
Yesterday six more cannoes are lined up in chamerem for illegal sand extraction. Cannoes are hidden inside Mangroves at Chamerem, Chorao.
There are other places of sand extraction tentacles have reached. One such place is Tikhazan in Naroa, Bicholim.
Current illegal sand Mining is being carried on with active conniving of Politicians and Police. Week ago raid was conducted against illegal sand mining in Vanxim. More details are awaited.
Thursday 14 September 2023
Goa Government surrender Agricultural land to mining interests
It is saddening to note that Goa Government even though is preparing agriculture policy it has sabotaged Goa's farming interests through surrender to mining aggressions. Goa Legislative Assembly has not only committed blunder of the century but has also reduced themselves as merely executive committee of the mining companies. Long battle awaits us.
Section 30 of the Goa Land Revenue Code, 1968 "Permision for non-agricultural use.--- No land used for agriculture shall be used for any non-agricultural purpose; and no land assessed for one non-agricultural purpose shall be used for any other non-agricultural purpose or for the same non-agricultural purpose but in relaxation of any of the conditions imposed at the time of the grant or permission for non-agricultural purpose, except with the permission of the Collector under Section 32.
[Provided that the provisions of this section shall not be applicable to the land in occupation of the Government, Corporation of the City of Panaji, a Municipal Council or a Village Panchayat and land to be used for the installation of solar or wind power station.(inserted vide Ammendment Act 5 of 2021)]
[Provided further that, nothing in this section shall apply to the activity undertaken in pursuance of the permission/licence granted under the Mines and Minerals (Development and Regulation) Act, 1957 (Central Act No. 67 of 1957) and rules made thereunder.(Inserted vide Amendment Act 6 of 2023)]
2023 Amendment to section 30 of the Goa Land Revenue Code, 1968 carried on by Goa Legislative Assembly allows mining in agriculture land without any permision from Collector of the respective Districts in Goa.
So now it is legal to take over paddy fields for mining purpose. There is no need for mining companies even to pay any compensation for crop loss due to siltation of fields.
Matter of Choice
Goa Government has chosen mining over agriculture. Mining is all set to inflict artifical planned disaster in near future and Goa's legislature is complicit in it. People have to make their choice. Agriculture policy cannot supercede Land Revenue Code. Ģoa Agriculuture Minister Ravi Naik and the members of the drafting committee has to make their stand clear or no policy can work however good it may be if Amendment to section 30 allowing mining in agriculture is not withdrawn.
Kindly share this note further.
Dr. S.A. Rodrigues
Bharat Mukti Morcha,
Wednesday 16 August 2023
With Mining company ex-Environmental cum Public Relations officer as the Chairman of the Goa State Pollution Control Board in the form of Mahesh Patil (https://goaspcb.gov.in/constitution-of-board/) the autonomous institution has been drastically reduced in their capacity to deal with conduct of public hearing in suitable and efficient manner. At Sarvan on 11 August 2023 Public Hearing norms were flung to the winds. At the end of the Public Hearing minutes were to be prepared and shared. It was not done till 1.30 am on 12 August 2023. Notes taking capacity was in total mess. People had no idea as to whose names are omitted and whose names are included. Entire staff of GSPCB looked in total disarray. It looked that space given to the staff of London based Anil Agarwal's company Vedanta Limited staff on the stage were controlling the strings behind the scene behind the installed black curtain on the stage.
Minutes of the Public Hearing was declared by the North Goa Collector will be put out on the website in two days time. Finally today it is online after five days at https://goaspcb.gov.in/wp-content/uploads/2023/08/MINUTES.pdf. One look revealed that the entire page 12 is missing. Names of speakers and their contribution from serial no 33 to 35 has vanished. There has been careful deletion of contents and names of the speakers too. Nilesh Karbatkar from Mayem who is the Union leader of the Sesa Goa mining corporation has been marked absent "not present" at serial number 153 even though he not only was present and also spoke critically about Vedanta. Noted voice critical about mining in Goa Ramesh Gauns saw that his speech recorded at the minutes is nothing short of butchery at serial no.124.
There is no hope for improvement. Crisis that has set in has taken chronic proportions. As long as Vedanta has its ex-employees as the Chairman of GSPCB nothing really expected to change. As this is the first Public Hearing of the Auctioned iron ore mines things have become clearer than ever: mining industry has taken firm grip over the GSPCB and butchery in noting of minutes and writings of minutes will be sharpened as the days goes on, maturity of butchers increase.
A new league of money games has just become visible!
Sunday 13 August 2023
Dr. Sebastiao A. Rodrigues
Bharat Mukti Morcha, (Goa State)
48/2,Vanxim, P.O. Piedade,
Date: 11 August 2013
The member secretary,
Goa State Pollution Control Board,
Saligao, Bardez, Goa
Subject: Objections to the commissioning of Block-I Bicholim Mineral Block by Vedanta Limited
We strongly object to the commissioning of Block-I Bicholim Mineral Block by Project Proponent (PP)Vedanta Limited on following grounds:
1. PP applied to MoEF & CC for Terms of Reference to Prepare EIA report on 16 March 2023. In their application PP disclosed that their period of baseline data collection lasted from 01 October 2020 to 31 December 2020 covering one post monsoon season. Executive summery (Page 04) of Block-I Bicholim Mineral Block states that MoEF&CC accorded Terms of Reference on 16 June 2023 and Baseline Data was collected during the period from March to May 2023. So there is fraud committed by PP by providing two different dates of periods of baseline data collection. This is indeed a fraud because EIA report does not mention anything about baseline data collection period of 01 October 2020 to 31 December 2020. Moreover that was time of Covid-19 lockdown in Goa. In view of these fraudulent manipulations and inconsistencies observed baseline data collection period is a suspect. PP therefore be directed to prepare fresh EIA without any inconsistencies on period of data collection and conduct fresh Public Hearing as per ToR no.70.
2. Neither the PP nor the Goa Government has consulted local decision making bodies namely the Panchayats before going for auctioning of the mine. This way of functioning is completely anti-democratic. We therefore strongly object to the way auctioning process itself has been carried on.
3. We take strong objections to the Reference to this mine in EIA as "Green Field Project". This amangation of 05 mines is operating as per available records from the year 1941 and has completes 82 years of its functioning on 20 August 2023. Moreover as per online sources PP is associated with these Mines from 2009 and as per records with Department of Mines and Geology PP proponents logo appears on large number of correspondence concerning these amalgamated Mines like the letter of Agent M.K. Reddy to the Central Empowered Committee (CEC) dated 14 November 2012 denying illegal mining and encroachment by M/s Dempo & Souza (Sesa Resource). Moreover page 16 of EIA admits that there are totally 5 pits within the proposed mining lease and Table 2.5 even presents details of Active pits. Further Mines Minister and Chief Minister of Goa Dr. Pramod Sawant on 09 August 2023 has stated on the floor of the Goa State Assembly that these amalgamated Mines in under EIA consideration are granted for the same company who used to operate before 2012 Supreme Court ban. Video online Facebook link to the entire mining debate under reference here is available here: https://fb.watch/mjb2PK3tbt/?mibextid=Ol9HDD
4. PP therefore inherit all the liabilities of all the five Dempo amalgamated Mines: 11/1941, 12/1941, 13/1941, 14/1941 and 15/1941. Dempo mining corporation private limited was renamed as Sesa Mining Corporation Limited on 18 November 2010. There already exists sufficient evidence of public nuisance and environmental security threats already created by these amalgamated Mines over the past 82 years of which PP is associated directly and indirectly from 2009 for 14 years. Research Article published in Research Journal of Environmental and Earth Sciences 11(1): 1-13, 2019 titled "Impact of Past Iron Ore Mining on the Sediment Ore of Rivers of Goa: West-coast of India by N.T.Rane and V.M. Matta of the Department of Marine Science, Goa University has made critical observations regarding Bicholim River that according to the Executive Summery flows at the distance of 0.23 kms from the Lease boundary carry large amount of polluted water into its waters. Abstract of this scientific study notes "the study revealed that the Bicholim river is strongly polluted with Fe & Pb...High contamination of Fe and MN and considerable contamination for Pb and Cr in Bicholim River sediment core can be attributed to enormous mining activities and discharge of wastes in this region." In the light of this study commissioning of Block-I Bicholim Mineral Block will further aggravate ecological health of Bicholim River that connects Mandovi river. Thus study has been ignored by PP thereby for their ulterior motives to contaminate and pollute Bicholim River.
5. North Goa Disaster Management Plan 2023 on page 184 foresees landslides due to mining in three Villages due to this amalgamated mine. In Mulgao survey numbers 116 and 117, 80 houses and 55 hectares of land is forecasted to be impacted. In Maem 30 houses and 25 hectares of crops are predicted to be negatively affected. In Sirigao survey numbers 81 & 85 are classified to be likely damaged due to mining triggered landslides. Goa Government has already accepted landslides threats due to mining. Actual threats are much more serious and dangerous. On this ground too Block -I Bicholim Mineral Block must not be permitted to be commissioned.
6. Modification to Approved mining Plan dated 26 October 2017 presented on the floor of the Goa Legislative Assembly by Chief Minister Dr. Pramod Sawant in response to LAQ from Yuri Alemao states name of this mining lease as M.L. No. 08/AMLG(MG-5)SMCL/17. This information is concealed in EIA. Further page no. 07 states that out of 478.5206 Ha lease area of this mining lease 407.7446 Ha is acquired. That means 70.7446 Ha of land is not aquired. Which are the survey numbers and villages where this yet to be aquired land is located? This information is concealed in presented EIA report by PP. Further Page no. 09 of the modification to Approved mining Plan states that Bicholim Amalgamated mine was granted lease on 20 August 1941 and expires on 21 November 2027. All these details are concealed from EIA report. Information furnished in EIA Study is defective and misleading and PP be directed to prepare fresh EIA and hold Public Hearing afresh.
7. This amalgamated Mine PP is involved illegal mining activities and owes more than 100 crores of Rupees to the Goa State as revealed from the LAQ discussion on the floor of Goa Legislative Assembly on 09 August 2023. Print copy of the colored Google map attached as Annexure I in the 11/1941 mining lease file at the Goa Department of Mines and Geology, reveals investigations by Shah Commission revealing expansion of mining activities beyond lease boundary taken by hand held GPS and Sesa Goa Limited Lease boundary taken by DGPS. Its illegalities are confirmed. EIA reports has not attached any document certifying that PP are not involved in illegal mining at this amalgamated mining site. This I in violation of ToR no. 07 and among major grounds for rejecting PP application to commission mining at the proposed site.
8. EIA report does take into account destruction of paddy fields, drying of ground water of 60 wells in Sirigao village due to mining activities of the PP together with other two existing Mines of Chowgules and Bandekars. Cummilitive impact of the village due to operation of these Mines is already a mega disaster encompassing human habitation and religious structures. The to Assanora river due to seepage of river water into mining pit is grave and have not been dealt with in adequate manner. Moreover objections of the villagers against commissioning of auctioned Mines in the village filed before the Goa Government authorities are ignored by the PP. NEERI report has already proved thar siltation of Sirgao paddy fields is due to mining leases operating in the village including the mine that PP desires to commision.
9. PP has pathetic track record in treatment of people and ecology. They are involved in Nadidihi Iron Ore mine of ESL Steel Limited in Jharkhand, India. Currently people residing nearby are compeled to use polluted and untreated beneficiated water from its mines for drinking purpose.
10. Such glaring violations are carried on by PP by efficient Public Relations. In fact one ex-officer of PP is currently Chairman of the Goa State Pollution Control Board named Mahesh Patil.
11. Conduct of the PP can be understood from the observations made in its Judgement in T.N.Godavarman Thirumulpad....(Petitioner) versus Union of India....(Respondents)and in the matter of Vedanta Alumina Ltd ...(Applicant) of 23 November 2007. Four observations of construction Supreme Court we quote here. (1) NORWAY has dropped British mining and metals group Vedanta Resources from its $ 350 billion oil fund at the recommendation of the Fund's Ethics Council, which blamed it for environmental damage and human rights violations, the Finance Ministry said. (2) Vedanta Resources is accused of having caused environmental damage and contributed to human and labour rights violations. (3) We cannot take the risk of handing over an important asset into the hands of the company unless we are satisfied about its credibility. (4) In the corvumstances keeping in mind the totality of the above factors, we are not inclined to clear the Project. Company with such a dubious record must not be allowed to commission the amalgamated lease.
12. Major water bodies such as lakes five lakes in Mulgao and seven lakes in Lamgao village are not included in the baseline data of the presented EIA/EMP report. Lakes in Mulgao occupy 21,050 square meters of land covering survey nos. 71/0, 69/1, 61/2, 257/1 and 117/1. In Lamgao seven lakes cover area of 6,925 square meters of land covering survey nos. 5/18, 8/1, 14/1, 14/3, 22/9 and 25/1. Additionally several fresh water springs in Maem village is excluded from baseline data in EIA. Total lake area amounts to nearly 03 ha. PP be directed to conduct fresh EIA with correct baseline data and go go for fresh Public Hearing.
13. Maem lake springs numbering two dried up. Before the mining pit was excavated for the ore for more than 50 years resulted in drying up of two springs that emptying water into Maem lake. This is because ground water regime got disrupted as the depth of the mining pit increased steadily.
14. In the close proximity of this mining project there are 25 wells in Bicholim with water. PP carried on the study on ground water from the various villages beyond Bicholim Town. Wells are the indicators of the ground water existence in the region. There are at least 25 wells in the close proximity of mining area. Consultants should have studied water levels in the wells in the lean period of summer that is May but this is not done as per EIA. Sirigao and Pissurlem are classic example where wells have dried up due to the mining pits which have gone below 50 to 60 meter depth and resulted in drying up of wells. This fact has been denied by all the mining companies in Sirigao that their mining pit caused it. Histoy of wells going dry will repeat in all the wells situated in close proximity to the mine and trigger off blame game between the locals and the PP. PP should have consulted Water Resources Department, Government of Goa on the question of ground water. In Maem at the foot hill of 2 Top Hillock there are 2 small lakes ( tanks) which go dry in the month of March, April and May. Springs also dry up due to the mining pit on the other side of 2 Top.
15. EIA Executive summery page 07 states “Mine does not have any forest land within the lease. The area is located on the foot hills of western ghats belt.” It is not true that the area is located on the foot hills of the western ghats belt. The distance between this mining project and the foot hills of western ghats is around 22 kms. In the foot hills of the Western Ghats is Taluka of Sattari. Whereas the Bicholim Taluka where this mine is located is Plateau region. Therefore the baseline data appears to be the cut and paste job. Hence this EIA study cannot be accepted for this Public Hearing to avail EC.
16. EIA Executive summery comment on page 07 “Mine does not have any forest land” is misleading. Name of at least one of the amalgamated mine 12 of 1941 indicates that there was forest here when the lease was granted 82 years ago. The name of this mine is Vagachiper that mean tiger favoured spot.. Tiger need forest as habitation and this mine was forest in 1941 until mining destroyed the same. Similarly mining lease 14 of 1941 that is part of amalgamated mine is named Toticho mor which means Peacock with a beak. This indicate that then existed forest where there were plenty of Peacocks. There is still Government Forest that is encroached by mining company in Mayem village. Boundary limit of 2 top in Maem is covered under forest land currently under company’s illegal possession.
17. Mining as serial disaster:This amalgamated mine has a history of triggering disasters. BIcholim was flooded on 13 June 1981 causing huge damage to the property. Government appointed expert committee to investigate the occurrence of flood in BIcholim. Page 236 of Fish, Curry and Rice: A source book on Goa, its ecology and lifestyle (2002) has reported that government appointed committee concluded that 1981 Bicholim floods were because of nearby mine. Nearby mine then belonged to Dempo Mining Corporation. In Accident of 1991 at Valshi in Bordem wherein 04 pople were killed, 06 injured and 144 farmers lost their paddy crop. Mining accident on 20 November 2011 in Mulgao caused breach of bund leading to siltation of paddy fields, siltation of arecanut plantations and silt entered nearby village temple. There was huge run off in 2009 at Paj wadda, Bicholim during rainy season. Water gushed down into locality carried mining silt, stones, mud on the entire road from Zantye Cashew factory to the building where LIC office is located. Cause stretched upto Petrol Pump and Shops. Nearly all the houses in Paj wadda had generous deposit of mining silt.
18. Page 07 of Executive Summery notes “The general elevation of ML area varies from 169.14 m to -37.24 m above MSL.” With 169.14 m elevated location disasters cannot be managed. In spite of all the precautions disasters are bound to occur. We recommend that since disasters cannot be avoided this mining project must be closed.
19. EIA does not mention anything about beneficiation plan. It gives an impression that ore will be exported without washing. However the approved modified plan tabled in the Goa State Legislative Assembly mentions wet beneficiation plan for at Mine portion at Top Pit 1.
20. Page 16 of EIA notes that the “slope of Overburden and Mineral benches shall be maintained at 70 degree and overall slope of <26 degrees respectively.” What is the gradient of highest point of the core zone with respect o Town of BIcholim, River Bicholim, villages of Lamgao, Mulgao, Sirigao, Bordem and Maem? With 3500 mm of rainfall mentioned in the EIA report with 70 degrees gradient of overburden disaster in monsoon season is inevitable with elevation of 169.14 meters. Gradient of mining site without overburden is not given in EIA study.
21. Page 17 of EIA has Table 2.7 Raw Ore Material (ROM) quantity if given as 3000000 tonnes. According to Vedanta letter dated to the Director General (Statistics), Nagpur ROM was reported as NIL. Letter is filed as page 277/C in Mining lease file of 11/1941 at Goa Department of Mines and Geology. In 2015 there is no ROM and then suddenly PP has reported huge quantity of ROM as 3000000 tones. How this discrepancy can be accounted?.
22. EIA of 2003 of Dempo mining corporation gave ore to waste ration as 1:2.5 and the production of 2 million tonnes per annum. The present PP is trying to win 3 million tonnes per annum and also encountering ore to waste ratio as 1:8.39. This is absurd. Possible the exaggerated figure of the ore to waste ration is intentionally given to go for robbing of ore. Considering that illegalities committed by Vedanta in parts of the world and in India too the possibility of the PP carrying day light robber of Goa’s ore is highly possible.
23. Page 149 of EIA at point 4.10 has table that provides trips per day as 1205 tones of iron raw. On calculation it was found that for 30 days it is 36150 tones. Therefore figure for 12 months is 433800 tones. PP has given figure as 3000000 tones. But based on calculations of trips per day annual production doesn’t touch half a million tones per annum. The figures given of tones per day and trips per day do not match the quantity given of 3000000 tones.
24. From 2011 to 2013 Vedanta was alleged by Directorate of Mines and Geology of carrying on illegal mining of 2076746 tones worth Rs. 97.48 crore. Vedanta is habitual perpetrator of economic crimes related to mining. Therefore PP cannot be expected to function at any point without committing illegalities.
25. According to Supreme Court of India Vedanta land for University in Odisha was illegal along Puri and Konark marine drive. Supreme Court stated “It is not appreciable why the government offered such an undue favour in favour of one Trust/Company”. Replica of the this situation has happened in Goa. Vedanta owes 100 crore to Goa Government as per the proceedings of the Goa legislative assembly on 09 August 2023.
26. PP has not consulted any bio-diversity registers at any of the 56 Panchayats and 12 Municipalities in core zone and buffer zone of the mine. Therefore flora and fauna baseline data collection method is faulty and strong ground to reject EIA and direct to prepare fresh one with correct method.
We hereby suggest that EIA having more than 600 pages to read for a common people is very difficult but beyond that to expect common man to study and participate in the Public Hearing is an impossible task. So either the Pollution Control Board or the consultant of the concern EIAs should bear the responsibility to explain how to study and comprehend technical data by going to the Panchayat or Municipalities. Or if the EIA study exceed 300 pages Public Hearing should be conducted after 60 days.
Dr. Sebastiao A. Rodrigues
Monday 26 June 2023
Call up Old Goa Police Station on its landline and lodge your protest: 0832-2285301
Entry into Goa: June 24, 2023
The couple Mahendra Shamba Solekar (Ramnagar) and Akshata Anandu Velip (Joida) from Ramnagar, Karnataka entered Goa 24th June 2023.
Man (Agent) named Uday Deshpande (from Belgaum?) With mobile number 7411275974 contacted wife Akshata Valip at home in Joida for job at Old Goa.
Agent contacted through wife's cousin Deepa Unjekar.
Agent took wife from Panjim at 5.30 pm to Old Old directly while husband proceeded to Parcem, Pernem to reside.
Day Ordeal begins: June 25, 2023
Wife contacted husband at around 9.00 am on June 25, 2023 saying that it's time for her to join duty on shop. Then again she called up at 2.30 pm same day with normal conversation. Then she called up at 7.30 pm wife called husband crying pleading that she is terribly disturbed at work. Then she shared address on WhatsApp to husband on where she is kept captive.
8.00 pm husband called wife. Phone answered by Madhavi Pai (mobile number: 9309523479) is where wife is working calling husband to Old Goa police station.
Husband went to police station at 11.30 pm and waited till 01.00 pm. Investigating officer Loreen Dias, it was informed by police staff to husband that said PSI has finished her duty.
Aggrevating situation: June 26, 2023
Address of the working shared by wife to husband at 4.44 pm on June 25, 2023 as :
Sardhina coop housing society, F1,F2, Corlim, Old Goa, Mollar, opposite lndian overseas Bank Old Goa.
Sunday 28 May 2023
Today May 28, 2023 I received certificate of participation in Konkani literature competition organised by Herald Konkani Daiz editors Vincy Quadros and Fr. Myron Jeson Barreto. I had submitted a Poem in Konkani. I received my certificate from the hands of Herald Chief Editor Sujay Gupta in the presence of former Chief Minister Luizinho Faleiro.
I met Sujay Gupta for the first time after all the turbulence from June 2008 onwards. Sujay and I were both part of that turbulence (but on opposite sides) triggered by mining greed wanting to silence voices articulating dissent at www.mandgoa.blogspot.in. This piece of writing is motivated by my meeting with Sujay Gupta at the award ceremony at Fernandes House near International Centre, Dona Paula.
When questioned Sujay Gupta was in denial mode on controversial role he played between June 2008 right up to middle of 2009 in repressing opposition to mining in Goa in his capacity as Vice-President (Communications) of Sociedade de Fomentos. He has gone on such drastic denial overdrive that he even denies his even presence in Goa until late December 2008.
When I reminded him about certain facts he claims that he doesn't remember. Yet he remembers that I am associated with GAKUVED whose blog he targeted with defamation suit at Calcutta High Court for 500 crore rupees. But that was last thing he did as corporate shotgun before moving to start Goan, newspaper of the Fomentos which he remembers, admits, regrets as mistake of his life and all this because there is his name - on records. And if the records were not put out in public domain he would have denied that too. All the mercenary work that he did for mining industry without leaving trace of his name he denied to me! It is precisely because of his denials today to several facts an effort is warranted to bring all the facts on record here so that history is not presented in distorted manner. In this situation my life is a document of history.
Sujay Gupta took over as an Editor of English newspaper in Goa named Gomantak Times that has ownership history with Chowgules in Goa and Sakal group in Maharashtra. Sujay Gupta's enterprising policies added dynamism that was visible in public domain that time around 2006 or 2007 onwards. He established reputation for himself and was soon popular. It has to be checked in archives as to when he took over as an editor of Gomantak Times and when did he leave. Any of you'll can do this and post it as comment below.
The first encounter
My first encounter with Sujay Gupta was on telephone call he made to me on June 05, 2008. That day GAKUVED had organised World Environment Day Program at Don Bosco Farm house premises in Sulcorna, South Goa. I was traveling to the venue in Car with Dr. Claude Alvares. I answered his call thinking that he is speaking to me in his capacity as Journalist. He asked me if village people and others from all over Goa are going to attack the Mines directly on June 05, 2008. I replied him negatively. Then he questioned me whether I know CPI-ML. I said yes I know and Kavita Krishnan is good friend of mine. At that moment I did not find anything suspicious in his questions and I answered them as matter of fact. He did not come for the program nor published my interview anywhere but he channeled information he got from me to some strategy team operating clandestine to suppress dissent against mining. Program was good and even Architect Kamalakant Sadhale was present with large number of local people. At later reflections I realized that Sujay Gupta had read my interview with Rajaram CPI-ML General Secretary, Jharkhand on openspaceforum blog. This information was passed on to Manohar Parrikar who shared it at the Public Hearing of Legislature sub-committee of Home Ministry tagging me as Naxalite on June 19, 2008.
The second encounter
I received phone call at 9.30 pm on June 19, 2008 from Derek Almeida, Editor of Gomantak Times informing me that I have been accused of being Naxalite by the Leader of the Opposition Manohar Parrikar. He said none of the journalists knew me and were surprised to know about my alleged Naxalite activities in mining belt. Derek informed me that he finally received my contact number from Dr. Claude Alvares. Derek requested me to meet him and his colleagues at Gomantak Times next day.
Next day was June 20, 2008. I picked up the copy of Gomantak Times and found my photograph printed on front page with a story headlined "Parrikar targets anti-mining activist". I read through story found something strange with my photo on front page. Photo was doctored and fangs were inserted in my mouth. I visited Gomantak Times office and met Editor Derek Almeida. First thing I brought to his attention about my photo on front page thst shows fangs in my mouth. I opened my mouth and let him do check up to find out the fangs. He couldn't find any. He then disclosed to me that it was Sujay Gupta who had shared that picture with all media offices. He told me that Sujay Gupta was earlier with Gomantak Times but recently has joined Fomento mining company. I wasn't aware of recent change in his status of employment and I had shared information in good faith under the impression that he was still a journalist. It was a betrayal of trust. Derek further had informed me that Sujay had emailed my pictures seated with students from Nirmala Niketan College of Social Work in Mumbai misrepresenting them as naxalites from Jharkhand. Later when Sujay came to know about the identity of these four students he wrote to the Principal of the college and protested their students visit to mining sites in Goa.
Derek then requested his Chief reporter at Gomantak Times Vithaldas Hegde to interview me. Hegde interviewed me for five hours non-stop but made sure he published not even five sentences from that interview. Interview was totally blacked out. Few years later when I questioned Hegde about it he told me that he lost his notepad! Currently Hegde is Chief Reported at Herald where Sujay Gupta is Editor. You can draw your own inferences. I have stated facts.
On June 21, 2008 at 3.00 pm Pravin Sabnis called press conference in which I was called to face the media at Tourist hostel in Panjim. Several media reprentatives were present for this press conference and amongst them was Sujay Gupta. Several media personnel questioned me and I answered them. I remember question asked by Sujay Gupta: Where was I working in New Delhi. I answered him that I worked at CACIM at A-3, Defence Colony. Sujay Gupta scribbled these details on a piece on his notepad.
At around 4.00 pm on the same day of June 21, 2008 there was another press conference organised by Sujay Gupta for Venkatesh Prabhudesai who attempted to tarnish my reputation with baseless allegations. Next day June 22, 2008 reports of both the press conferences were published. On this day it became a public knowledge that Sujay Gupta has joined Fomentos who were running several Mines in Goa with Hiralal Khodidas mining lease being in focus due to documented destruction of agriculture and protests from local people of Colomba.
On November 12, 2008 locals and others from across Goa marched Hiralal Khodidas mining site. Sujay Gupta was on site on this day supervising lathicharge carried on by company's security agency causing injuries to many including to Gajanan Raikar, then executive committee member of GAKUVED.
Protests against mining industry continued and reached its peak. It is at this moment on December 24, 2008 that Sujay Gupta filed civil defamation suit against me for 500 crore at Calcutta High Court in his official capacity as Vice-President (Communications) of Fomento mining company. It is amongst the highest claimed amounts in India. Petition is listed on Calcutta High Court website but hasn't come up for hearing since September 2009 after three Hearings.
Sujay Gupta received hostile reception at several places in Goa. He was thrown out from Times of India first anniversary party by late Wendel Rodricks the fashion designer. Writer Hartman de Sousa launched online signature campaign against him with over 1,200 people signing and commenting. Floriano Lobo of Goa Su-Raj Party organised public protest meeting near then Sujay Gupta's residence in Moira village. Venita Coelho has been vocal in her writings against Sujay Gupta due to his alliance with mining industry.
In 2012 Sujay Gupta started off GOAN as weekly for Fomentos, then turned it as daily and then got into Herald. One man who publicly protested then against Sujay Gupta taking over as Editor of Herald is Anthony D'Silva from Ambelim, Assolna.
This is memory of politics outlined here so that politics of memory is firmly grounded as and when it is activated. This piece is prepared after Sujay put himself in denial mode in communications with me today as mentioned above. Next time if Sujay Gupta goes in denial mode this has to be brought to his attention.
In my today's conversations with him I found him not honest. That's the reason for me to be honest and bold. For we are both connected in the opposites. Can Sujay Gupta turn honest too and afford honest conversation? Or will he be forever fugitive to his own deep self? What are those people called when they refuse to be honest and persist in denial? Let Sujay Gupta be the privilege one to answer this at his calling after deep pondering.
Saturday 27 May 2023
With recent proposal of Amendment of TCP Building rules realization has downed that Goa's Town and Country Planning Department has come under the firm grip of mafia. Important hallmark of mafia operation is secrecy. Recent analysis of those who pushed TCP department to proposed April 2023 Ammendments indicate that at least in five instances lid of secrecy is maintained.
Analysis carried on by Tahir Noronha, Urban Planner posted online. Here we present our interpretation of Tahir's analysis.
Goa Chief Minister Pramod Sawant is behind the proposed Ammendment to get migrant workers to reside within industrial zones. This certainly is in violation of safety norms. Nevertheless his name is on record.
Similarly Babu Kavlekar, former Deputy Chief Minister of Goa is found on records as the one who pushed for allowing legalization of prevailing unauthorized structures greater than 500 square meters in size. He has openly advocated case of those posh people who has stolen land. We can imagine how much he has been favored in cash and kind by rich who are politically connected and confidently constructed more than 500 square meters of unautorised constructions.
Steering committee has taken upon itself as decision makers with regard to pushing of Ammendments connected with Charging of Electric Vehicles, and relaxation on minor changes while constructions of buildings encroaching in setback areas.
Confederation of Real Estate Developers in India (CREDI) are recorded as being the behind the scene pushers against Changes in rule concerning 5% Utility spaces in building complexes and making the utility spaces commercial thereby affecting open spaces negatively.
Ammendments concerning reduction of road widths regarding multi-family housing projects. Road with less than 08 meters width can service 180 housing units as per the proposed ammendments that has dubious origin as the records indicate "someone informed the Committee". Who is thst someone? Why identity is kept hidden? Obviously mafia don't reveal its identy! 08 Meters road will have to shed is edges to half meter shoulders and half meter gutters on each side as per the specifications of Goa TCP. That leaves 06 Meters right of way to service 180 housing units. This is a planned move towards making Goa intensely congested destination. In case roads are without gutters then sanitation and flooding issue will multiply. In case roads are without shoulders then traffic safety is compromised. In both instances TCP regulations stands violated.
Records traces use of phrases such as "Committee was informed" and "Committee was appraised" to cover up the source being recorded. This secrecy on the proposed ammendments are suspicious to be of mafia origin. Mafia origin ammendments that have been channelized through Steering Committee of TCP that is chaired by Goa Chief Minister. This means that mafia has gained upper hand over not only over Goa TCP but also over Goa CM. Let's have details of these mafia pushed Ammendments.
Steering Committee was "informed" to create giant farm houses of 1000 square meters. Who informed? Obviously this is mafia operation to steal away Goa's farmlands. Irrespective of which other Indian State has this kind of provision the very fact that identity of the informer is kept secret makes the intention of this proposed Ammendment malafide.
Similarly the proposed ammendments allowing for other usages in A1 and A2 zones (Agriculture and Forest/Orchard/ Eco-sensitive Zones) has attribute "Committee was informed because other States have it". If TCP is incapable of recording the names of those are pushing these ammendmends then it is clear indicating that TCP has become an epicentre of mafia activities that even Chief Minister is found to be incapable to tackling. Blazing fires to Goa's Forest that began in March 2023 doesn't look accidental but the handy work of these mysterious creatures known at least to TCP Minister Vishwajit Rane. Fires are most primary steps to execute change in Forest land use.
Next proposed ammendment from undisclosed source is to allow Farm Houses in rice fields provided it is not low lying fields. And records mention "Committee was appraised". Who appraised the committee? Records are full of Ghosts.
Similarly proposed Ammendment to allow unlimited sub-division of agricultural land is from ghostly source. Records mentions "Committee was informed". Who informed? Informer has been made invisible and mysterious alien in records. In 2019 sub-division of agricultural land was restricted. Now restriction is proposed to be revoked.
Several objections are filed before Chief Town Planner (Administration). These objections will be considered and decided if they are worthy by sub-comittee. Director of Panchayat as well as Minister of Panchayat are members of this gatekeepers. Mouvin Godinho is the only Minister and of it's kind who is member of both the sub-committee as well as steering committee.
As it stands today degeneration of Panchayati Raj in Goa is going on under active supervision of by the Panchayat Minister Mauvin Godinho and Director of Panchayat Siddhi Halarnlar. They effectively has sabotaged Gram Panchayat Development Plan. Now both of them has moved inside the TCP sub-committee. We can only imagine the disaster that is awaiting to unleash. In all probability most if not all the objections are likely to be aborted even before reaching the Steering Committee, at the level of sub-committee itself.
It is now clear as to how mafia operations at Goa TCP department. If mafia plan has to succeed through TCP Department then Gram Panchayat Development Plan (GPDP) has to be stiffed. That's reason Panchayat Minister along with Director of Panchayats has found their way inside the sub-committee.
In case you are still confused then click here to know the composition of Steering Committee.
And click here to see who are members of the sub-committee who are to consider public objections.
Thursday 25 May 2023
Dr. Sebastiao A. Rodrigues
Goa State Convenor,
Bharat Mukti Morcha,
48/2, P.O. Piedade, Vanxim,
ILHAS, Goa 403 403
Mobile No.: 992 333 6347
The Chief Town Planner (Administration),
Town & Country Planning Department,
2nd Floor, Dempo Tower, Patto Plaza, Panaji – Goa. 403001
SUBJECT: Objections to the Amendments of the Goa Land Development & Building Construction Regulations, 2010 vide notification 21/1/TCP/(A)/2021/Steering Committee/675 published in Official Gazette- Govt. of Goa, dated 27/04/2023
We place before you our OBJECTIONS/ SUGGESTIONS regarding each amendment as follows;
1. Amendment of Regulation 2: Clause (52), (52A), (52B) appears to have been amended in interest of the safety and good planning of buildings, by increasing the experience requirements of Graduate and Diploma Engineers, however we request that on similar grounds the Diploma in Architectural Engineering and Diploma in Architectural Assistantship pass outs also be recognised for planning of Residential buildings within similar limits. As otherwise the Government recognising its Diploma Civil Program for allowing planning which has no subject studies of regulations and not recognising its architectural program for the same planning is a conflict of not treating its Diploma programs on par to allow trained architectural pass outs their entrepreneurship options. Besides, these Building Regulations are treating Civil Engineers as eligible for both the regulations certificate and structural liability certificate, but not allowing the Architects for the same, on par with the same reasoning.
2. Amendment of Regulation 6.A.3.1: Clause (e) is regarding housing to be allowed in Industrial zones of I-1, I-2 and I-3. The condition of minimum 10,000 m2 plot and maximum 2.5% of built up area has been relaxed to include plots with minimum 5000 m2 and increased the maximum extent to 7.5% of built up area, thereby defeating the very reason why a wide variety of utility spaces are being provided within the 15% and limiting the residences within the Industrial zones due to conflict in favourable and normal living conditions. Residential use is one of the uses prohibited in Industrial zones due to odd working hours, possible environmental pollution levels being on higher side affecting health conditions of the vulnerable and high risk people. This proposed amendment will undo that and convert all the utility spaces into residences thereby not just limiting the utilities availability but also adding residences in unfavourable and hazardous conditions. We therefore strongly object and demand that the said clause (e) be retained without any change as suggested by the said notification.
3. Amendment of Regulation 6.A.3.1: Clause (i) has been added with (iii), (iv), (v). This completely threatens the very idea and objective of Eco-sensitive zones in the Regional Plan of Goa. The meaning of the word Agriculture and the use allowed in the existing paras which are proposed to be numbered (i) and (ii) is being completely contradicted, corrupted and will mislead the very concept of Agriculture which has been one of our traditional occupations. All the 3 new uses proposed in the 3 new clauses (iii) to (v) are all in complete contradiction to the meaning of agriculture, threatens the eco-sensitivity of our fragile coastal ecosystems, our traditional livelihoods and occupation, exposes the local communities to increased coastal risks, accelerates climate change crisis, contradicts many other mandated authorities who have painstakingly provided us well researched documents like the National Building Code, and completely tears down the defence protection that our eco-sensitive zones have built around us against climate change risks. This is a complete disaster of the environment in the waiting and if land use planning is not risk directed can be the sole cause of irreversible damage to the local environment which will prove to be very costly for Goa. The very basis of land uses or zones is supposed to be on the nature of the soil, but this amendment will force construction on cultivable soil as extensive as 30% which will be lakhs of sq.m. thereby exposing vast indigenous population to life threatening risks. We demand that to know from whom has all these proposals been received by your department or on whose request this is being inserted and the locations of such proposals which are under consideration by the authorities. The 3 talukas of Tiswadi, Bardez and Salcete are already listed as highly vulnerable to climate change risk and the impact will affect 50% of the state population. Is the TCP department prepared to take such a risk? Has it a disaster management plan for such eventuality. All this is also against the fundamental right to life and against the directive principles of the State being custodian of the environment against risks. We therefore very strongly demand that this said amendment to clause (i) be completely dropped and the original be maintained without any change.
4. Amendment of Regulation 6.A.4: Note (4) is being substituted by “ Farm houses within A1 and A2 zones shall be permitted with maximum permissible FAR as provided in Annexure–XI, provided these lands are not classified as “Rice” (Paddy field) in Survey Records and “Forest”. However, in case of elevated land, recorded as rice in the Survey records and the land is not low lying and also not a “Forest”, farm houses shall be permitted, provided the minimum area of such land is not less than 10,000m2, the maximum ground coverage shall be limited to 2.5% and the maximum built up area shall be limited to 500m2 with a maximum height of 7.60m from the ground level to the eaves of the roof.” This dilutes the restriction of no construction in Rice fields and merely by the elevation of the rice fields it is free from such restriction actually exposes all the low lying rice fields to get illegally “elevated” as the ground reality of elevation will be undisputable proof, in light of no mention of any such elevation documents or records of the government which are suggested as proof of the elevation which the Note emphasizes on. Interestingly, the Morodd cultivated land of Rice in Goa will also be open to construct upon with farm houses of 500 sq.m. each thus destroying the sustainable cultivation model that Goa evolved with as per its soil conditions. Farmers of Goa are very well planned communities and have high integrity of protecting their cultivable lands from corrupt practices. It’s the approach of the builders lobby who are cashing on the poverty and innocence of the farmer to usurp his land against offer of money against the backdrop of no sustainable agricultural crops and income. If A1 and A2 is considered for construction, where will be the exclusive zones left for posterity, with roads built in, machinery requirements, etc the rest of the agricultural areas also will die a slow death as a consequence. We demand to know who are the proposers of such needs and where are these locations. The farmers’ Rice fields will get purchase offers with high bidding prices causing increasing pressure on the farmer to sell off. We therefore demand there should be no dilution of allowing farm houses in Rice or forest lands and the substitution of said Note be limited to “(4) Farm houses within A1 and A2 zones shall be permitted with maximum permissible FAR as provided in Annexure–XI, provided these lands are not classified as “Rice” (Paddy field) in Survey Records and “Forest” under Forest Act.”
5. Amendment of Regulation 6.A.4: Note (16) proposes to substitute “Further, at the time of approval of development plans, minimum 6 meters wide right of way should be available on the site.”, with a new Annexure-XII, proposing new minimum width of road for Settlement, Industrial and Hotels/Resorts uses. Please note that in Table-VIII, the same 3 uses are listed with minimum road width as 6, 10 and 8 meters respectively and the existing Note (16) as existing regulation merely states that this minimum should be existing/available on site at the time of development. So overall it is noted that all the road widths proposed in the Annexure-XII are less than what is applicable now and the that too the effect of available on site at the time of development is deleted, meaning whatever Annexure-XII says can even be in proposed state and the project with such compromised road conditions will still get approved and constructed. At this rate all our villages are going to face a huge road safety impacts, congestion and pollution and a social unrest with the crowding and density increase without any supporting infrastructure. We strongly condemn the dilution of the Road widths, selectively only to the settlement, Industrial and Hotel/Resort uses, ambiguity in the language adopted “upto” “or”, no reasoning and study analysis is the background of such a proposition, why levels have been decided as 8 units and 180 units and what road widths to follow if it is 9 or 179 units, the increasing pressure on the existing road conditions, safety and security of the vulnerable local population, unprecedented increase in population density, social and economic unrest and huge health implications. We demand that the Note (16), should be retained as it is and no such change or addition of Annexure-XII be done to have a super riding effect on the minimum road widths available on site.
6. Amendment of Regulation 10: Clause (f) inserted suggest that 20% Car park spaces will have to be made “Electric Vehicle Ready”. This will involve expenditure and consumption of power across the state. Is the state ready for the additional power needs and the resulting regulations to be put in place for its management? We convey that although this is in sync with the overall policy of phasing out conventional fuel consumption, it will also have burden on the power needs which itself is a concern and a bit more consideration for renewable energy policy could be made in this area. We highlight this approach required on this issue and the same may be conveyed to the respective departments for consideration.
7. Amendment of Regulation 10: Clause (f): The inserted clause (f) is actually substituting the existing clause (f) which is about the ramp to the basement floor and the conditions governing its sizes and number. As such with a new clause inserted as (f), it is obvious the the existing one is being silently deleted without revealing it in the notification. Such practices in a public notification speaks of bad governance and needs to be not just corrected but publicly apologised for and renotification be issued in this regard.
8. Amendment of Regulation 12.4: Clause (d) is substituted with new provisions to allow the 5% public utilities in open space in one parcel instead of multiple parcels. This will lead to concentration of construction areas in open spaces, lead to centralised locations of utilised, and completely overusing the open space instead of what it is meant for. No such proposed changes should be attempted and the clause should be retained as it is.
9. Amendment of Regulation 12.6: Clause (b) (iii) has been omitted and content is in context to regulating the sub-division of A1 and A2 zone. Omission of this clause omits the Table – XII(A), which will open the sub-division of the eco sensitive zones of A1 and A2 in any manner or rather diluted manner of 4000 sq.m. minimum plot size which otherwise had condition of minimum plot size of 10,000 sq.m. and 20,000 sq.m. for the higher area properties. Additionally, the ban of any further sub-division of plots partitioned after the 2021 effective regulations will get lifted subjecting to a number of plotted developments of the Eco-sensitive zones into small parcels and thereby creating pressure on the cultivable and eco-fragile land. These conditions are required to be maintained to deter sub-divisions of eco-sensitive zones and to retain them in an undisturbed manner. We demand that the omission of the said clause (b) (iii) be reconsidered and the same be retained without any change.
10. Amendment of Regulation 12.7: Clause (a) (i) is proposed to be substituted with provisions of commercial utilities accommodated in the community spaces. All this is allowed to the owner, which effectively means the plot area of 5% in a property equal to 50,000 sq.m. is 2500 sq.m. and of 500,000 is 25,000 sq.m. such areas actually be in collective ownership of the plot holders in the sub-division and the commercial nature of the utilities amounts to allowing commercial uses as a back door entry to the project developers. These provisions are actually meant for the needs of a community which is large as the sub-division involves large areas between 5 ha. to 50 ha. Understandably if these uses are expanded then the 5% reserved areas for community utilities will get sublet as business models by the developer and ignore the community needs. 5% area of such large sub-division development is very justifiably needed to accommodate the community needs for their well being which is the main objective of Town and Country planning regulations. We demand that the clause (a) (i) be retained.
11. Amendment of Regulation 22.4 (a): Sub-clause (i) has been numbered as (a) and then added with a sub-clause (b), which state that any unauthorised construction with area more than 500 sq.m. built before 31-12-2020 can be regularised with submissions of certain listed documents. This provision serves no purpose other than creating and complicating disputes on illegal possession, encroachment and construction on land which could belong to different individuals, organisations or communidades. Regularising an illegal unauthorised structure itself is against any form of justice and presenting a cut off date and compounding fees are mere cosmetics and flexible conditions which can be revised forever to accommodate all under the sun. Besides there have been number of court judgements which prohibit such provisions which are against the law, like the Hon’ble Supreme Court Judgement dated 28/01/2011 in Civil Appeal No.1132/2011 @SLP(C)No.3169/2011 (arising out of SLP(Civil) CC No.19869 of 2010, in which even the Government of Goa has presented a say that all encroachment on community land will be identified and the land restored to its original state. Also, the provisions being for construction above 500 sq.m. to be regularised suggest that the rich builders who have engaged in illegal constrictions will get protection under these regulations. The documentation condition mentions electricity/water bills and tax receipts conveniently not specifying what tax, bills which are in fact fundamental rights of any individual and has no bearing on the ownership rights in the land. We therefore, demand that this addition of (b) to the sub-clause (i) should be dropped and even the regulation 22.4 (a) be omitted. It also implies that the sub-clause (ii) does not continue to exist with all the new numbering, which means that the 3 times compounding fees to be levied on the less than 500 sq.m. regularisation proposals deems to be deleted. Thus implying that the unauthorised constructions are encouraged by the Town and Country planning department of Goa. These amendments are unacceptable and all proposed changes are to be dropped.
12. Amendment of Regulation 22.5: Note to be added for this regulation allows a shift of 5% in building height and in setback area that too without any compounding fees. This is completely against the National Building Code and the fire safety parameters. Any interference or reduction in the setback areas is completely out of question as there are provisions to ensure that the building alignment is approved by the authorities before work gets started so there could be no such case of shift. And if at all there is, it can be detected early before starting construction and the same can be rectified to maintain the sanctity of the minimum setback areas. We therefore demand that the original provisions as in regulation 22.5 be retained without addition of any such said Note.
13. Amendment of Regulation Annexure-XI: Clause 2 and 3 has been substituted with certain increase in coverage and FAR from 5% to 10%. This is regarding farm house regulations which are being increased 3 times of the original, thus subjecting the green eco-sensitive zones to construction activity which is 2 times more. The maximum built up area of the farm house has also been proposed to be increased from 500 sq.m. to 1000 sq.m. This is the builders or second home building lobby requirement because 1000 m2 farm house will never be the requirement of a genuine farmer living in the green zones. This merely exposes all the eco-sensitive zones to a lot of purchase and construction activities in addition to all that we have commented in the earlier points. The green areas of Goa will be up for sale in plots of minimum 4000 sq.m. each with farm houses possible of 400 up to 1000 sq.m. each. Is this the green area model which the TCP department is planning for? We demand that this increase in Coverage and FAR to 10% be dropped and the increase of 1000 sq.m. of farm house area too be dropped. The Annexure-XI clauses 2 and 3 be reverted back to its original state without any change.
14. Amendment of Regulation Annexure-XII: This Annexure has been completely replaced by another. The original Annexure as existing in the regulations provides for controlling excessive demand of power and in event of crossing a pre-established threshold of 500 kW the project proponent was encouraged to generate his own renewable energy. The applicability also has been listed in it, thus making the construction industry realise that power comes at a huge environmental cost and there has to be an equally huge effort in sustainable means of power. The Bureau of Energy Efficiency is mandated to this cause and under the PAT scheme of the Central Government already different category of buildings are listed as designated consumers for filing their energy consumption returns so as to monitor and regulate the energy consumption by efficiency passive and active measures. Dropping of these Energy Conservation Building Code from applicability to Goa is a very regressive step and is not in sync and mandate of the BEE and also the Government. Climate change crisis is at our doorstep and Goa which does not produce its own energy is proposing to build more in green zones extensively and with freely available and uncontrolled power to be provided on demand. We demand to know the reasons behind this change and whether the National Building Code and the BEE policies are not a mandate in Goa. We demand to restore the said Annexure-XII as is in existing regulations.
Regarding the proposed replaced draft amendment for Annexure-XII allows relaxation of road widths for settlement, industrial and Hotels/Resorts. This reduction in road width has also diluted the “available on site” criteria and the carriage width having reduced further will increase the road problems leading to a social, economic and environmental crisis in our villages. Life will be at risk and congestion will be the norm of our village planning and development as suggested by the percentage of accidents and deaths on the roads. Besides more has already been commented in the point. No. 5 earlier. We demand that the effect of the Table VIII be restored and the proposed Annexure-XII be dropped and consequently the overriding effect also be dropped.
It is also to be noted that the sub-committee and steering committee who are in charge of all these amendments are more populated by political leaders and business leaders rather than ecologist, environmentalist, sociologist and planners. This is a complete conflict of interest and positions are used as liasoning agents by all who have financial stakes in the construction industry. Land use planning which is so crucial in this age of climate crisis is in the hands of lobbies who will expectedly think of self interest than that of the communities or the land as a whole.
This is completely reflected in the overall observations of construction in eco-sensitive zones, regularisation of large constructions, road widths compromised to smaller widths, open spaces sacrificed, farm house allowed are larger, sub-division of green zones conditions deleted, etc. None of these proposals appear to be an evaluated response from real time study nor from the risk informed climate crisis management point of view. Even the Energy efficiency code has been done away with, is the extent the business lobby is taking our small fragile eco-sensitive land of Goa for granted. The amendments ignore ground data and bypasses planning context laid out by the Regional Plan, create conflict in the regulations within themselves as well as in the very visionary exercise the regulations are supposed to be in any land use planning.
Finally, these amendments expose the Town and Country Planning Departments INABILITY to;
· Control illegalities and rather approve them,
· Improve the basic infrastructure and rather stress it out beyond levels of well being
· Encourage construction activities in eco-sensitive zones against the very objective of identifying such zones in the Regional plan for their protection
· Uphold the various court orders to stop illegal, unauthorised and encroached land and construction issues
· Comprehend the increase in road accidents as a fallout of bad planning of road and the unavailability of proper widths for the carriage ways
· Understand the power crisis in our state and the environmental damage we are facing to get power from long distance and yet not make energy efficiency provisions more compulsory than be dropped altogether
· Understand that above all, land use planning should be risk informed in this age of climate crisis with high coastal vulnerability risk for Goa.
In view of all the above, we demand that all the above amendment proposals be scrapped and the same be prepared in a holistic manner by planning the Land use at the state level, district level and regional level along with the impacting land use regulations with the participation of the people of Goa as per their constitutional right.
Development in Goa be carried ahead through Gram Panchayat Development Plan (GPDP) enforcement through activation of State Level Empowered Committee headed by Chief Secretary of which Chief Town Planner is one of the 28 members.
Kindly take take note of the content of this letter and act accordingly without ignoring or bypassing.
Dr. Sebastiao A. Rodrigues