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,
