7th February 2015
Ministry of Environment, Forests and Climate Change,
Indira Paryavaran Bhavan,
Jor Bagh Road,
New Delhi 110003.
Subject: Suggestions/Objections to Draft CRZ Amendment dated 11th December 2014
Awaaz Foundation objects to the draft amendment to the CRZ Notification on the following grounds:
1. We understand that a proposal to set up a Shivaji memorial off the coast of Mumbai is under consideration and it appears that this draft Notification is the first step towards clearing this project. A Shivaji Memorial in the sea at enormous cost to the State funded by taxpayers’ money appears to be an unwarranted and frivolous expense at this stage when citizens of Mumbai are still lacking basic infrastructure such as adequate water, power and public transport.
2. The last phrase (Note) of the draft Notification makes it clear that construction for memorials/monuments in CRZ – IV would be discouraged. This strongly implies the damaging nature to environment of the proposed amendment.
3. It is not clear what kind of ‘adequate environmental safeguards’ would be sufficient to mitigate the environmental destruction which would result from construction of monuments/memorials in CRZ IV. No studies of existing projects of a similar nature or mitigation measures which are ‘adequate’ are conducted before the issue of this draft Notification. The word ‘adequate’ is also not defined.
4. Merely conducting EIAs and other studies would not be sufficient to address mitigation measures which should have been addressed even before issue of this draft Notification.
5. There is no clearly defined cap to the construction which would be permitted to each Memorial, the type of allied activities which would be permissible and the damage caused to environment by each of these proposed activities.
6. There is no study of the damage which would be caused to marine life and the fishing Industry as a result of destruction of fishing habitats.
7. There is no study of the quantity of sand required for this construction and the damage caused to the environment through sand extraction.