Tidal Error: Why Tamil Nadu's illegal coastal plan is a recipe for disaster

The Government of Tamil Nadu has uploaded what it calls a "Revised Draft Coastal Zone Management Plan." The “plan” is geared towards protecting errant officials of the Coastal Zone Management Authority from the ire of the National Green Tribunal, rather than protecting the coast and coastal communities.

Under CRZ Notification, 2011, all coastal states were required to have uploaded Coastal Zone Management Plans, including CRZ maps, for public comments within a year of the Notification. However, none of the states had prepared the plans despite several extensions prompting the National Green Tribunal to threaten severe action against the officials concerned. In their hurry to comply, the Government of Tamil Nadu is trying to push through a half-baked, incomplete and dangerous document as a "plan."

The plans are required to be prepared strictly in line with the guidelines presented in Annexure 1 of the CRZ Notification. All plans are required to clearly identify authorised construction within CRZ areas, present long-term housing plans for fisherfolk, identify the hazard line and spell out prospective plans for the CRZ area. The law also requires the planners to compare the present plans with the earlier Government of India-approved plans prepared under CRZ Notification, 1991. The reasons for any deviation from the erstwhile plan needs to be explained by the planners.

The documents uploaded in the Environment Department's website do not present any of this information. The Hazard Line which is to be marked taking into account tides, waves, sea level rise and shoreline changes is absent, opening up tens of thousands of acres of low-lying coastal wetlands for development as real estate. The point of the hazard line is to protect communities from seaborne hazards. Presenting a "plan" without a hazard line totally misses the point and puts communities and property in harm's way.

The documents uploaded on the website today also fall afoul of an order of the National Green Tribunal issued in a case where a petitioner challenged the holding of public hearings on the basis of incomplete documents that were uploaded to the website of the Tamil Nadu State Coastal Zone Management Authority (TNSCZMA). In 2013, as it has done now, the Authority uploaded incomplete and inaccurate maps, and declared them to be the draft management plan. The Tribunal ordered the withdrawal of the uploaded documents, cancelled public hearings already held in five districts and directed TNSCZMA to publish a Coastal Zone Management Plan prepared strictly in keeping with the guidelines contained in the Notification. 

The new draft document, wrongly referred to as a "plan" ignores violations of CRZ 1991, and regularises others that encroached into the intertidal areas by shifting the High Tide Line beyond the violating project boundary. Instead of presenting a conservation plan, the Department of Environment has presented a map that condones past violations, and facilitates a wholesale grab of coastal wetlands.

Commercial Capture

Rather than rely solely on scientific methodology in mapping the High Tide Line, the plan preparation agency appears to have accommodated the aspirations of commercial interests.

Two instances demonstrate this commercial taint most effectively. In the CRZ map for Ennore, where companies like Kamarajar Port, NTECL, TANGEDCO, HPCL and BPCL have encroached on salt pans, the remaining salt pans have not been shown as intertidal areas even though the map contains a specific legend for salt pans, identifying them as inter-tidal areas. This is to facilitate Kamarajar Port's Sagarmala designs to convert these areas into real estate. Ditto in Kanyakumari, where once again in the name of Sagarmala, VOC Port Trust intends to develop a International Container Terminal in the stretch of ecologically sensitive beach between Manakudi estuary and Kovalam. The Manakudy estuary on the western boundary of the proposed port has salt pans in about 1,000 acres of tidal wetland. In the aftermath of Cyclone Ockhi, the salt pans had close to 10 feet of standing water. These salt pans were all identified as CRZ 1 in the Government approved plan of 1996. In the revised Draft of 2018, the salt pans have been hidden.

Similarly, on the eastern edge of the port boundary lies another salt pan area belonging to Kovalam. This too is identified as ecologically sensitive area and declared a No Development Zone in the Government of India-approved 1996 plan. VOC Port would like to run a 100 metre rail-cum-6-lane-road corridor through this eco-sensitive area. The Revised plan uploaded today facilitates this by simply hiding the presence of salt pans in Kovalam.

Coastal salt pans are low-lying tidal wetlands that serve as a buffer absorbing storm surges from the sea or flood waters from the inland. Curiously, in both instances, commercial interests and not the gravitational pull between the earth and the moon seem to dictate the High Tide Lines in these instances.

What is presented as "Draft Revised Coastal Zone Management Plan" is an incomplete document. These documents cannot be the basis of any informed public consultation. If approved in its present form, this plan will seal the fate of coastal communities, future generations and the environment.

Note: Views expressed are the author’s own and not of The News Minute.