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EQUATIONS raises concern on the way in which public consultations have been arranged by CEE. It is noted that in many places CEE failed to include complete participation from all stakeholders. The question arises whether CEE had sent letters to a wide range of the stakeholders in the state and had informed them about the dates of the meeting and the venue? While the schedule is available on the website of CEE, many communities and movements do not have ready access to internet or use it as the regular mode of communication. Informing them sufficiently in advance and ensuring that they participate, their voices are heard and their concerns are documented and responded to is most critical, as they represent the most vulnerable communities on the coast.

To:
Dr. Shriji Kurup
Secretariat for CMZ Notification, 2008 Consultative Meetings
Centre for Environment Education (CEE)
Karaikal
E-mail: shriji.kurup@ceeindia.org

Re :        Consultative Meetings organised by CEE on the draft CMZ Notification 2008: Concerns and Objections

Dear Dr. Kurup,

This is to bring to your notice our deep concerns and objections about the way in which Centre for Environment Education (CEE) has organised Consultative Meetings on the draft Coastal Management Zone Notification, 2008.

To introduce ourselves, EQUATIONS is a research, advocacy, and campaigning organisation working since 1985 on the impacts of tourism, particularly in terms of rights and benefits to local communities. We envision tourism that is non-exploitative, sustainable, where decision-making is democratised and access to and benefits of tourism are equitably distributed. We have been closely involved in looking at implementation of the CRZ Notification, 1991 in relation to tourism. We have also responded to the Ministry of Environment and Forests on every occasion that the Ministry has solicited a response from civil society on amendments made to the CRZ Notification 1991, including that on CMZ Notification 2008.

MoEF has commissioned CEE to organise a round of consultations with coastal communities including fisher folk, coastal organisations, civil society and other interested parties to understand and document their point of view, comments and concerns about the new proposed Draft CMZ Notification. Therefore, CEE should have taken utmost care to ensure that the local communities and the civil society are well informed in advance of the public consultation dates and venues so that true representation takes place. Moreover CEE is entrusted with the responsibility of documenting peoples' voices and their concerns in true spirit.   

It is of concern to us that the way in which these public consultations have been arranged have in many places failed to include complete participation from all stakeholders. The question arises whether CEE had sent letters to a wide range of the stakeholders in the state and had informed them about the dates of the meeting and the venue? While the schedule is available on the website of CEE, many communities and movements do not have ready access to internet or use it as the regular mode of communication. Informing them sufficiently in advance and ensuring that they participate, their voices are heard and their concerns are documented and responded to is most critical, as they represent the most vulnerable communities on the coast. 

We are aware that CEE's website speaks about Coastal Management Zone 2008 as "a regulation to ensure protection of coastal population and structures from the risk of inundation due to natural hazards and for ensuring that the livelihoods of coastal populations are strengthened", a stand that you may be aware is countered by most civil society groups and communities from the coast. Since CEE has been commissioned to link and bridge the concerns raised by the local communities and larger civil society with that proposed by the MoEF, it is expected that you would approach this with a more open position to hear and document in a non-partisan way the views of those who attend the workshops. CEE's own perspective, we believe should not influence this process in any way, It is critical that you communicate through your methodology and processes to many groups that you will play your role in a fair manner. It may be evident to CEE by now that many groups have chosen to "boycott" the consultations because the manner in which they have been organised has not inspired confidence of local groups of CEE's objective role. This has also to do with the experience of these groups and movements (many of which EQUATIONS has been in solidarity with in their struggles). The lack of interest and total unresponsiveness of the MoEF thus far, to many of the concerns voiced these past years and the impunity with which the CRZ notification has been diluted is part of the ground experience. We hope that CEE has taken these contextual factors into account when it has accepted to play this role, as this history is what informs groups on the ground.

Unless the consultative meetings are arranged in the right spirit, holding such meetings is only an attempt to dilute the opposition to the CMZ Notification. By referring to the reports of various consultations organised by CEE on CMZ notification, we also observed that the minutes do not properly reflect the discussions from the reports that we are getting from some of the participants who have attended the meetings. Moreover, while the concerns raised have been documented, a clear outcome of the meetings is missing, except for the reports of Kanyakumari and Bhadreshwar where the participants have objected to the CMZ Notification and asked for strengthening of the CRZ Notification, 1991.

We urge CEE to re-conduct the consultative meetings in Gujarat, Andhra Pradesh, Goa and Orissa, which have resulted in huge public outcry about complete failure of democratic process in both inviting for the consultations as well as documenting dissenting view points from the communities and larger civil society organisations in the state. We further urge CEE to clearly document the outcomes of the meetings so that a more realistic view is presented of the response to the draft CMZ Notification of the MoEF.

Thanking you
Sincerely

Rosemary Viswanath
Chief Functionary