Will India’s interests be served by the Paris Climate Agreement?

COMMENTARY AND ANALYSES BY CPR FACULTY

 

A new climate accord- the Paris Agreement- was approved by the nations of the world on December 12, 2015. CPR faculty Shyam Saran, Lavanya Rajamani, Navroz K. Dubash and Radhika Khosla, have provided in-depth commentary and analyses on the Agreement and its implications for India.

Prior to the Paris Agreement, our faculty put into perspective India’s interests at the climate talks in Paris:

For an entire archive of the Climate Initiative’s work over the past year, view this interactive timeline.

Working in tandem: the informal septic tank emptying market in Aya Nagar, Delhi

NEW REPORT BY SWETA CELINE XESS AND MARIE-HÉLÉNE ZÉRAH

 

The aim of this research report is to explore the types of sanitation services that exist in non-networked settlements. Based on the case study of Aya Nagar in South Delhi, the research shows how households are primarily dependent on septic tanks, and rely on an informal market comprising small-scale local entrepreneurs for the emptying of faecal sludge.

We find that this sector’s functions are structured by the entrepreneurs themselves, who check competition, manage tariffs and mitigate operational risks through collective action. This arrangement relies on existing networks of kinship and friendship between operators.

Financially, the sector offers entrepreneurs a low but steady source of income given a recurrent demand for desludging service in the settlement. Nevertheless, the occupation remains a socially stigmatised activity as it deals with human excreta, which in India, is traditionally associated with low-caste communities.

The full report can be accessed here.

Workshop on ‘Little Box Retail’

FUTURE OF THE VIBRANT, ROADSIDE MARKETPLACES IN INDIA

Watch the full video (above) where Durba Chattaraj describes the world of ‘little box retail’, small roadside shops, which line a major national highway in West Bengal. She argues that while these retailers form the center of local economic and social life, a majority of them are unauthorized structures. She uncovers the unusual way in which the municipality taxes these unauthorized structures, through the creation of informal ‘trade licenses’ in an attempt to mediate the dissonance between the law and actual practice in everyday life in India.

As India proceeds on the path of highway modernization and road widening, it becomes important to question the future of these vibrant, and unauthorized, roadside marketplaces.

Workshop on lending to women with informal incomes and property titles

SEWA GRIH RIN’S EXPERIENCES IN HOME FINANCE
ECONOMY

Watch full video of the talk (above) where Shruti Savio Gonsalves, CEO at Sewa Grih Rin Limited (SGRL), explains the challenges and solutions that emerged during SGRL’s journey of financial inclusion of informally employed and housed people, in particular, women.

SGRL is leveraging an extensive membership network of over 2 million poor, self-employed, informal women in 14 different states of India to fulfil a dream of increasing access to decent housing and a sound living environment.

To listen to the lively discussion that followed, tune in to the Q&A Session

Workshop on Welfare and Poverty: Trends over a Quarter Century on Delhi’s Margins

Watch the full talk (above), where Devesh Vijay tracks changes in demography, occupations, incomes, consumption patterns in villages and slums on Delhi’s margins using surveys, focus group discussions, interviews and life sketches. The study was constructed in two working class communities within the National Capital Region, in 1988-89, and again in 2013-14.

To listen to the lively discussion that followed, tune in to the Q&A Session.

What ails Chhattisgarh’s welfare schemes?

ACCOUNTABILITY INITIATIVE ANALYSES PUBLIC DELIVERY OF SCHOOL EDUCATION AND NUTRITION IN THE STATE.
SOCIAL SECTOR SCHEMES BUDGET BUREAUCRACY

Context

In partnership with the Chhattisgarh government and UNICEF, the Accountability Initiative (AI) undertook its flagship PAISA (Planning, Allocations and Expenditures, Institutions Studies in Accountability) study to track the use of development funds in the state, with the data collection conducted in 2015.

As a first step, the study compared Chhattisgarh’s performance to its peers. As a result of the implementation of the FFC (Fourteenth Finance Commission) recommendations, designed to enhance fiscal autonomy to states, Chhattisgarh received a significantly higher proportion of untied funds from the Union government in 2015-16 (as per revised estimates or RE) compared with 2014-15 (Actuals) – overall central transfers increased by 65% in this period. Interestingly, Chhattisgarh appears to have used a significant portion of its untied money toward investments in social sector programmes. When compared with 2014-15 (Actuals), investments in social sector increased by 50% in 2015-16 (RE).

The study then took an in-depth view of the implementation of four important Government of India sponsored social sector schemes. These were – Sarva Shiksha Abhiyaan (SSA) for elementary education of children aged 6 – 14; the Midday Meal Scheme (MDM); Rashtriya Madhaymik Shiksha Abhiyaan (RMSA) for secondary education; and the Integrated Child Development Scheme (ICDS). The study evaluated the nature and effectiveness of public service delivery of school education and nutrition in the state. The data was collected from four districts – Rajnandgaon, Surajpur, Janjgir Champa and Bastar – which were decided upon in consultation with the state administration.

A mixed method approach was employed, wherein both quantitative and qualitative data was collected in order to achieve a comprehensive picture of the ground reality. The quantitative data illustrated the existing situation in fund flow and public service delivery and was collected through both primary and secondary sources. Additionally, qualitative interviews were conducted with both frontline workers and senior bureaucrats in charge of implementing the schemes at the block and district levels.

Rigorous analysis of the data reflected some overarching implementation gaps across all four schemes:

Limited human resources and weak internal management resulting in poor supervision;
Insufficient planning capacity and lack of prioritised resource allocation at the grassroots;
Delayed fund flows and a complicated disbursement process.
Key Findings

The key findings specific to each of the schemes are summarised below.

Sarva Shiksha Abhiyan and Rashritya Madhyamik Shiksha Abhiyan

Teacher shortage: Vacant teaching posts, compounded by absenteeism, impacting teacher ‘availability’, was a prominent concern faced by most schools. Multi-grade teaching (students of different grades sitting in the same classroom), particularly in secondary schools, led to an adverse effect on quality of education. This was particularly evident for subjects like Science and Mathematics where the same teachers had to double up to teach both subjects.

Moreover, while the state found it tough to recruit teachers for its secondary schools, those that were hired didn’t necessarily report in schools to teach. Measured as on the day of the survey visit, teacher absenteeism was high especially for subjects like Hindi, English, Science and Social Science, and more so in tribal districts. This was also true for primary school teachers where over 20% of all recruited school teachers were absent on the day of the main survey. Additionally, the study found that under RMSA, salaries of a decentralised teacher cadre – the Shiksha Karmis/Panchayat Shikshaks ­– were often delayed, and thus they had little incentive to work.

Gaps in infrastructure provision: With high rates of enrolment, Chhattisgarh has the lowest proportion of out-of-school children (4%) both in comparison to other states, as well as the national average. Yet, infrastructure provision remains poor. A survey of SSA in primary and secondary schools in the four districts studied showed that despite several years of the Right to Education being in place, gaps remained in provision of key infrastructure facilities. For instance, lack of usable toilets and absence of boundary walls were common problems.

Secondary schools seemed to fare better on infrastructure provisioning, but that was mostly on account of the older, non-RMSA schools included in the survey sample (31 of the total 62 schools surveyed) which were built by the state, primarily in the 1980s and 1990s (RMSA was launched in 2009). The most significant infrastructure gaps at the secondary school level seemed to be in the provisioning of boundary walls and computer labs. Interestingly, unlike SSA, there were significant variations across districts. For instance, while only 35% of all secondary schools in Surajpur and 58% in Bastar were found to have a separate and usable toilet for girls, such toilets were almost the norm in secondary schools surveyed in Janjgir Champa and Rajnandgaon (80-90% coverage).

Crucially, the schools were unable to fully exercise their right to demand provision of these facilities from relevant government departments. While there is provision for the School Management Committees or SMCs (primarily meant to represent parents) for making School Development Plans (SDP) – on the basis of which funds are released to schools – most SMC members are not trained in how to prepare these plans. In fact, they feel that developing an SDP is an exercise in futility as funds released are seldom in line with the needs of the school. This is often because the needs of each school are specific to its situation (which may depend on its location, geography, the local politics etc.) while the funds released by the government are often tied to the general perceived requirements of schools. At the same time, planning by government officials at the district level is done in an ad-hoc manner with little or no emphasis placed on the demands of the SDPs that are actually submitted to them.

Mid-Day Meal Scheme

Innovation in delivering mid-day meals: Chhattisgarh has clearly innovated in delivering the MDM within the state. It has introduced an online system of rice provisioning to reduce the time taken to deliver rice to schools and decrease pilferage. The state has also involved local women in the cooking of meals and pays them a higher honorarium to increase their incentive to work.

Delays in receiving money: There are still, however, substantial delays in receiving cooking cost money and Cook-cum-Helper honorariums. These lead to women buying items like vegetables, pulses, oil etc. on credit, a system that is not sustainable. There are district-wide variations too – for instance, the district of Janjgir Champa appears to be performing poorly on most parameters. Given that it is a populous district with significantly more children enrolled per school, the shortfalls warrant attention.

Moreover, official monitoring for MDM, which is closely linked with the overall monitoring of schools, is sparse. Monitoring visits by the last-mile points of government are not just few, but far between. Long distances and unavailability of public transport play some role in poor monitoring. MDM is often seen as an additional responsibility, warranting much vigilance, but with poor resources (both human and financial) being made available for keeping check. Existing mechanisms such as placing a complaint box in each school or providing MDM toll-free helpline numbers do not seem to work – not everyone seems to be aware of them.

Integrated Child Development Scheme

Infrastructure and equipment deficiencies: The survey conducted a census of the 240 anganwadi centres (AWC) present in the four districts. Serious deficiencies were found in infrastructure and equipment availability in anganwadis. The lack of usable toilets, equipment for cooking, essential drugs and material for health monitoring (such as child growth charts, immunisation charts, posters etc.), severely constrained anganwadi workers (AWW) and helpers

On a positive note, nearly all AWCs were found to be open when visited by the survey team. Attendance registers revealed that across districts, anganwadis were (on average) open for 26 days in the month prior to the survey, for 6 hours in a day (from 9/9.30 a.m. to 3/3.30 p.m.)

Overburdening anganwadi workers: The anganwadi workers have to also take on the role of being foot soldiers for delivery of multiple government schemes. This takes away from their focus on ICDS delivery, particularly the provision of pre-school education. In addition to their responsibilities at the anganwadi centre, AWWs and Sahayikas (anganwadi helpers or AWH) are drawn into delivery of social welfare programmes such as the Kishori Shakti Yojana (KSY) to educate teenage girls, and immunisation drives. They are also involved in other state work such as the Census and BPL (Below Poverty Line) surveys, enrollment for Aadhar, and so on. Additionally, to monitor delivery of ICDS and all services promised by it, they have to maintain a series of registers. For many of these activities, the AWW has to step out of the AWC, resulting thereby in noticeable absence, even though she is out for official work.

Moreover, the survey found substantial delays in the receipt of the honorarium for both the AWW and the AWH. These delays in honorariums may be explained by: (1) delays in release of funds out of budgeted allocation; and/or (2) low spending out of total ICDS allocation.

Conclusion

Administrative inefficiencies, poor targeting, high administrative costs and leakages characterise the implementation of many development programmes in India, and consequently, only a small fraction of development resources is said to reach their final destination. Although the problem is well-recognised, there is surprisingly little data or analysis in the public domain on how development funds travel through the system. It is often unclear what the systems and processes employed to implement state schemes are, and what their effectiveness in a given local context is.

This lack of understanding has an impact on public service delivery, which the study has sought to bridge. Chhattisgarh has taken a few steps to address some of the key concerns reported by the study. For instance, involving panchayats in selection of SHGs (Self Help Groups), implementation of civil works, and selection of teachers; having an online monitoring system to streamline grain allocation etc. These have already provided the state with the platform necessary for bringing about further improvements. Focusing on the small details of governance in this way can help the state bring about significant improvements in overall social sector delivery.

However, as per the AI study, these steps must critically be complemented by enhanced transparency in expenditure along with greater autonomy at the district-level. Key recommendations made in the report are as follows:

  • Improving public financial management in the state;
  • Empowering districts by providing block grants;
  • Balancing autonomy with bottom-up accountability;
  • Putting in place better data management systems and strengthening the ones that exist to enable better decision making by i) fixing roles and responsibilities clearly, and ii) strengthening capacity at lower levels.

The full report can be accessed here.

What are Countries Doing to Mitigate Climate Change?

DISCUSSION WITH AUTHORS OF THE UPCOMING 6TH ASSESSMENT REPORT OF THE INTERGOVERNMENTAL PANEL ON CLIMATE CHANGE
CLIMATE RESEARCH

On 1 October 2019, the Initiative on Climate, Energy and Environment (ICEE) at the Centre for Policy Research (CPR) and The Energy and Resources Institute (TERI) organised a discussion on climate policy and action with authors of the upcoming 6th Assessment Report of the Intergovernmental Panel on Climate Change (IPCC). This event was held in the backdrop of the second IPCC Lead Author Meeting for Working Group III (Mitigation of Climate Change), in which global experts met in Delhi to assess global progress toward reducing the rate of climate change.

The panelists included Fei Teng (Associate Professor and Deputy Director, Institute of Energy, Environment and Economy, Tsinghua University, China), Harald Winkler (Professor, University of Cape Town, South Africa), Heleen de Coninck (Associate Professor, Department of Environmental Science, Radboud University, The Netherlands), Karen Seto (Frederick C Hixon Professor of Geography and Urbanisation Science, Yale University, USA), and Roberto Schaeffer (Professor, Energy Economics, Universidade Federal do Rio de Janeiro, Brazil).

The conversation was moderated by Navroz K Dubash (Professor, CPR and Coordinator, ICEE) and Ritu Mathur (Senior Fellow, TERI).

About the Speakers

Fei Teng is Associate Professor and Deputy Director at the Institute of Energy, Environment, and Economy, Tsinghua University, and Lead Author (Chapter 17) for The Working Group III contribution to the IPCC Sixth Assessment Report. His research interests include energy and climate policy analysis using modeling tools, and the international climate regime.

Harald Winkler is Professor, University of Cape Town, and Coordinating Lead Author (Chapter 4) for The Working Group III contribution to the IPCC Sixth Assessment Report.

Heleen de Coninck is Associate Professor in innovation studies at the Environmental Science department at Radboud University, and Lead Author (Chapter 16) for The Working Group III contribution to the IPCC Sixth Assessment Report. Her research interests are international climate policy, energy technology and innovation. Before joining Radboud University, she worked for over 10 years at the Energy Research Centre of the Netherlands (ECN). She was one of the Coordinating Lead Authors of the IPCC Special Report on limiting warming to 1.5°C, which was published in 2018.

Karen Seto is the Frederick C Hixon Professor of Geography and Urbanisation Science at Yale University, and Coordinating Lead Author (Chapter 8) for The Working Group III contribution to the IPCC Sixth Assessment Report. She is one of the world’s leading experts on contemporary urbanisation and global change. Her research has generated insights on the links between urbanisation and land use, food systems, biodiversity, and climate change.

Roberto Schaeffer is Professor in Energy Economics at Universidade Federal do Rio de Janeiro, and Coordinating Lead Author (Chapter 3) for The Working Group III contribution to the IPCC Sixth Assessment Report. Dr Schaeffer’s main area of competence is in integrated assessment of climate change and coupled energy-economy climate modelling. In 2007, Dr Schaeffer was a co-recipient, with a number of scientists, of the 2007 Nobel Peace Prize for research contributions to the IPCC.

Navroz K Dubash – Professor, CPR, and Coordinating Lead Author (Chapter 13) for The Working Group III contribution to the Sixth Assessment Report. He is the editor of the forthcoming book, India in a Warming World: Integrating Climate Change and Development (Oxford University Press).

Ritu Mathur – Senior Fellow, TERI, and Lead Author (Chapter 4) for The Working Group III contribution to the Sixth Assessment Report. She heads the Centre for Integrated Assessment and Modeling at TERI, and her research focuses on examining and addressing the multiple connections between climate change, energy security and sustainable development.

What could be the upcoming amendments to the Environment Protection Act, 1986?

RTI PAPERS RECEIVED FROM ENVIRONMENT MINISTRY INDICATE LEVYING OF MONETARY PENALTIES FOR ENVIRONMENTAL DAMAGE
ENVIRONMENTAL JUSTICE RIGHTS

The CPR-Namati team recently received documents related to the proposed amendments to the Environment Protection Act, (EPA) 1986 following a year-long follow up through the Right to Information (RTI) process. The environment ministry has shared information only up to July 2016, indicating that the other documents are with the Law Ministry, undergoing scrutiny.

This information includes two detailed versions of the proposed amendments and note sheets related to the process of drafting the amendments – carried out between August, 2014 and July, 2016.

On 07.10.2015, the Ministry of Environment, Forests and Climate Change (MoEFCC) had made public the Environment Law (Amendment) Bill, (ELAB) 2015, inviting comments. The CPR-Namati Environmental Justice team made a submission to the MoEFCC when the ELAB was put out in public domain. Manju Menon and Kanchi Kohli discuss some of their arguments in this 2015 article in The Wire.

The documents received indicate that the 2016 version of the ELAB proposed to amend the existing EPA, 1986 by introducing monetary penalties for violations. The environment ministry’s justification is that the current legal structure in place for the protection of the environment is not effective. It is claimed that ‘available remedies under Section 5 and Section 15 are time consuming and not in the larger public interest because industry units have to shut down even in cases where contraventions are minor and reversible.’

The process for making amendments to the EPA had commenced in August 2014, with the appointment of Shri V K Bhasin, a former Law Secretary, as a consultant. It was following the presentation at the Prime Minister’s Office in September 2015, that the Draft Bill was made accessible to the public in October, 2015. The Bill received around 130 comments and Shri Bhasin was appointed for a second term in November, 2015 to revise the draft based on the comments received.

An analysis of the RTI papers by Debayan Gupta reveals that the October, 2015 version of the ELAB has been substantially altered. The earlier version proposed levying penalties for damage and violations based on the extent of the geographic spread of the damage. It also introduced the concept of spot penalties for minor violations, which caused neither substantial nor non-substantial damage to the environment. The April, 2016 version however has done away with both of the above mentioned aspects.

The key proposals of the 2016 version are:

A set of penalties for certain defaults in the Schedule to the Act, to be decided by the Adjudicating Officer;
Types and grades of environmental pollution specified in sections 14H to 14U, the quantum of which is to be determined by the Adjudicating Authority;
Imposition of a lesser penalty on Micro, Small and Medium industries;
The money collected by way of penalties to be credited to the Consolidated Fund of India;
The government can levy fees for carrying out the functions assigned under the Act.
Unlike the earlier draft Bill, the April 2016 version imposes only two sets of penalties with fixed upper limits. The determination of the actual amount is to be done by either the Adjudicating Officer or the Adjudicating Authority, both of whom are to be appointed by the government. It also does away with the idea of spot violations for minor violations and allows for the imposition of a ‘lesser’ penalty based on the size and turnover of the industry.

The RTI application, filed on 31.06.2016 by Kanchi Kohli asking for details of the process remained pending for a year. It was only on 07.6.2017 that the MoEFCC responded agreeing to provide the information within 15 days (the letter disposing the first appeal can be found here). However, only partial information up to July 2016 has been provided, indicating that the most recent file is under scrutiny by the Law Ministry. The documents provided by the MoEFCC include:

  • File notings from December 2014 to July 2016 (accessible here);
  • The first tentative working draft of the ELAB after 07.10.2015 (accessible here);
  • The third working draft after 07.10.2015 (accessible here)
  • The draft cabinet note dated April 2016 (accessible here)

The CPR-Namati team has analysed this information an article earlier this month in The Wire.

What do Bihar voters want?

NOTES FROM THE FIELD
ELECTION STUDIES POLITICS

Neelanjan Sircar, Ashish Ranjan and Bhanu Joshi share their notes from the field based on extensive travel across Bihar to get a sense of how voters are making up their minds.

A spate of contradictory opinion polls and an aggressive campaign between bitter foes, Nitish Kumar and Narendra Modi, and bonhomie between once bitter foes, Nitish Kumar and Lalu Prasad Yadav, have only served to confuse the situation further in the state.

They have focused on constituencies that went to the polls in the first two phases of the election, and tried to tease out what ‘vikas’ means for the people, and how caste influences their decision.

Read the full field notes here: What do voters want?

‘The Hindu’ carried a shorter piece on 28 October: It’s not about caste or beef, but vikas

What do the responses to the 2018 draft Coastal Regulation Zone (CRZ) notification reveal?

READ THE BLOG SERIES
ENVIRONMENTAL JUSTICE

Ministry of Environment, Forests & Climate Change (MoEFCC) issued the draft Coastal Regulation Zone (CRZ) Notification, 2018 on April 18, 2018. The draft came after yearlong indications that the current CRZ Notification, 2011 will be replaced by a new Marine Coastal Regulation Zone (MCRZ) Notification. The proposed changes to the CRZ regulation drastically alter the original provisions of the notification (Read about the changes proposed in the draft CRZ Notification, 2018 here). The draft was open for public comments till June 17, 2018. During this time the ministry received 471 submissions on the draft. Several of these submissions had multiple representations/ signatures in them. If the number of representations is factored into the comments received on the draft CRZ Notification, 2018, the total number of responses received becomes 1965.

Researchers from the CPR-Namati Environmental Justice Program have analysed these comments to understand that most submissions raise serious objections to the ministry’s proposal. On analysing these responses all together, it was found that of these 1965 responses, 1338 (68%) responses have objected to the finalsation of the draft CRZ Notification 2018. About 23% responses have been in favour of the draft CRZ Notification 2018 (see figure below).

Small percentages of responses have suggested changes or sought clarifications to the CRZ Notification and some are inapplicable due to the responses being in regional languages or concerning issues other than coastal regulation.

Specific comments have been received from coastal citizens, fisher groups, political parties, local institutions, government departments and industry associations. The highlights of these comments are presented below:

Representations from coastal citizens:

More than half (250) of the submissions are from coastal citizens. In these 250 submissions there were 414 additional representations/signatures. So total number of responses from coastal citizens becomes 664. Of these 54% (362) demand that the draft CRZ Notification 2018 should not be pursued by the ministry. 32% (216) are in favour of the draft CRZ Notification 2018.
Of the 216 responses that are in favour of the changes, 207 have even asked for further opening up of the coast for tourism projects, dwellings for locals and commercial constructions among others. Many of these responses are from Goa, Kerala and Maharashtra. While most respondents have only mentioned their names and addresses, a small number have identified themselves as advocates and doctors.
5-7 submissions from Sindhudurg and Malvan in Maharashtra seek clarification on the critically vulnerable area protection for these regions as required by the CRZ Notification 2011. This is especially so because no such special provisions are provided in the 2018 draft.
Comments from local institutions

The local bodies that have sent in their responses are from the states of Goa, Maharashtra, Diu, Karnataka, Kerala and Gujarat.

17 submissions have been received from local institutions that include Gram Panchayats, District Panchayats and Municipalities. Of these 13 have suggested changes in the draft CRZ Notification 2018. Many of these include the suggestion that instead of the proposed No Development Zone (NDZ) of 50 m for thickly populated areas and an NDZ of 200 for thinly populated rural areas, a uniform NDZ of 50 should be applied. In the current CRZ Notification 2011, a uniform NDZ of 200 m has been provided.
Some panchayats have demanded that their villages be turned into urban areas. One has demanded retention of provisions of the current CRZ Notification 2011.
Four submissions from local bodies could not be considered as the ministry noted that they were in regional language.
Responses from the industry

45 responses have been from the sectors of tourism, real estate and construction, mining, ports and harbours and industries. Of these 40 have suggested further dilutions in the draft and two have appreciated the draft. Some of the suggested dilutions are permitting mechanised mining, fish processing plants and storage of chemicals that are allowed to be transported through pipelines and jetties in the CRZ, lifting restriction on land use change for buildings in the CRZ. Remaining three responses have either sought clarifications or sought retention of certain biodiversity protections in the notification.
Submissions from fishing unions and associations

Of 28 fisher groups who have sent in their submissions, 24 have expressed their objections to the draft CRZ Notification 2018. They either ask for the draft to be scrapped or demand continuation of the current provisions. One such submission from Pavity Jinwar Kodi from Mumbai has 120 representations. The submission states that the CRZ Notification 2011 is better than the draft. It demands that the fishers be given importance and no draft should be considered without consulting the fishing community.
These 24 submissions also have 181 additional representations/signatures.
Several submissions suggest that the NDZ in rural areas and around the creeks should not be reduced.
3-4 fisher groups have demanded that CRZ Notification should be turned into an Act.
Comments from government departments

Ten government departments from the state of Maharashtra, one from Kerala, one from Karnataka and two central government departments have also submitted their comments. Of these two didn’t have any specific comments, 11 have sought more dilutions in the draft CRZ Notification 2018. This is with respect to their jurisdictions such as Maharashtra Metro Rail, Urban Development and Mining, Karnataka Tourism, and Coast Guard headquarter. They suggest changes pertaining to approval of buildings according to the local town and country planning norms, metro and allied activities, Indian coastguard stations and associated infrastructure in the CRZ, further reduction of the NDZ and no requirement for maintaining buffer around mangroves on private lands.
Representations from Political Parties

The ministry received six submissions from politicians and political parties. Four are from Daman & Diu offices of Bhartiya Janata Party (BJP), one from a member of parliament from the BJP and one from the Aam Aadmi Party (AAP), Goa. All of them, except AAP have requested for additional easing of the CRZ regulation. The suggested changes relate to further reduction of the NDZ and conversion of rural areas (CRZ III) to urban areas (CRZ II) so they have fewer restrictions for land use change. One submission suggests that mining of all minerals be permitted in water areas of the CRZ.
Besides these, submissions have also been received from academics, researchers, scientific and educational institutions and religions institutions. Find the compilation of comments as received from the MoEFCC here.

Changes to the CRZ Notification, have been under discussion for past four years- a special review by the Shailesh Nayak Committee followed by a series of amendments have been in the news. At CPR, we have continuously brought analysis of the same. For details see here, here and here.

All these efforts of the ministry at altering India’s coastal regulation have been characterised by opacity including a closed-door review and denied opportunities for public comments on amendments. But, such large number of responses on the draft CRZ Notification, 2018 is a reiteration of the fact that coastal regulation is an issue of citizen and public interest.

The above analysis of the comments shows that there is a diversity of viewpoints on the draft. The draft is yet to be finalised and as of October 2018, the MoEFCC had compiled these diverse comments for consideration. While finalising, the ministry is also going to strive to resolve the issues on which a difference of opinion was observed among its officers and ministers and weave those changes in. (Read about those issues here). The lack of consensus within and outside of the ministry is a clear indication that the contentious points of coastal regulation need public engagement larger than what is being practiced currently.

This is part 2 of a blog series on CRZ revamp in making since 2014.

In the third blog post of the series, views of different members from within the ministry and stakeholders from outside on certain contentious issues will be presented.