To, Ms. Meena Gupta, Secretary, Ministry of Environment and Forests, C.G.O Complex, Lodhi Road New Delhi Subject: Objections to the CMZ Notification draft dated 1st May 2008 No S.O.No 1070(E) We, the undersigned, are concerned about conservation and livelihoods in the country. We totally disapprove of the process followed in bringing about this legislation and are dismayed to see the new Coastal Management Zone (CMZ) Notification in its current shape. In accordance with the provisions of the Environment Protection Rules, 1986 related to public notice before final notification, we have the following objections on the CMZ Notification, 2008: 1. It abuses the idea of human vulnerability Activities on the coast, according to this notification will be determined by setbacks which are based on human vulnerability. The setback is a concept for which the scientific methodology is not clarified and instead only some basic parameters are listed. All the parameters of vulnerability only relate to natural hazards and nothing is actually mentioned about manmade hazards. The current notification is regressive when compared to the Coastal Regulation Zone (CRZ) -1991 version as it allows large scale development in all the zones. The setback line is preferentially used in the cases of housing and settlements of coastal communities but not for other activities such as tourism and recreation facilities which have the same if not greater vulnerability, owing to large public investments in them. There is no mechanism of transparency, accountability and participation when drawing up the setback line. There is no indication if this setback line will be constant or dynamic, or a clear time frame to map the same. 2. Fisher communities will continue to lose their space A proper provisioning for the development of the fishing community needs to be made and this can only be in the coastal space. This can be done in accordance with conservation of the area in mind. The CMZ notification is basically a discriminatory document that allows a number of new stakeholders to enter the coast while ignoring the claims of those who have been traditionally linked to the sea and have been the real owners and protectors of the coast. 3. The notification has no protection and conservation measures Though the new notification has expanded the list of ecologically sensitive areas from those in the CRZ Notification, there is no protection and conservation of CMZ I areas as they are no longer