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

                                                                                                      Date: 17^th October 2019

To,

Rohita R. Naik,

Superintendent of Fisheries,

Panjim, Goa.

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

Dear Rohita,

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

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

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

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

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

Thanking you,

Yours Sincerely,

        Sd/-

Maggie Silveira

President, Goa State

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

Date: 17^th October 2019

To,

The Collector (North Goa),

Panjim, Goa

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

Dear Madam/Sir,

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Thanking you in anticipation,

Yours sincerely,

       Sd/-

Maggie Silveira

President, Goa Unit

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

Copy to:

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

Waters sports excesses in Zuari river

Date: 24^th April 2018

To,

The Minister of Fisheries,

Government of Goa

Secretariat, Porvorim, Goa

To,

The Secretary (Fisheries)

Government of Goa,

Secretariat, Porvorim, Goa

To,

The Director,

Directorate of Fisheries,

Government of Goa,

Panjim, Goa

Subject: Terms and conditions violations of water sports N.O.C for Aquasail Distribtion Co. Pvt. Ldt

Sir

We hereby bring to your notice that there has been violation of terms and conditions no. 5 in Director of Fisheries N.O.C granted to Aquasail Distribution Co. Pvt. Ltd dated 13/10/2017 bearing registration no. ENF/WS/AQUA-SAIL/2017-18/4240 at Bambolim Beach as under:

1.    Water sports boats of Aquasail were out in river at 8.00 am itself on 14/04/2018 while they are not supposed to be in river before 9.30 am as per condition no. 5.

2.    Water sports boats of Aquasail were out till late in river at 6.45 pm on 19/4/2018 even though they are supposed wind up their activities at 5.30 pm as per condition no.5 of the N.O.C cited above.

Now as per the condition no.9 we call upon you that Director of Fisheries revokes the above cited N.O.C to Aquasail Distribution Co. Pvt. Ltd. In our earlier letters to you we have asked you to do the same with regard to violation of Condition no. 01 resulting in hindrance to the fishing activities.

Hoping for your early response,

Thanking you,

Yours sincerely,

Maggie Silveira

President, Goa State

Rohidas Andrade

Convenor, Bambolim Unit

Sanjay Pereira

Convenor, Cacra Unit

Soccorro Braganza

Convenor, Siridao Unit

Sitaram Pereira

Convenor, Odxel Unit

Milind Palkar

Convenor, Nauxim Unit

Anthony Cardozo

Convenor, Curca 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

Call to immediately revoke NOC for water sports in River Zuari

Date: 15^th 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