KERALA MATSYA THOZHILALI AIKYAVEDI (TUCI)
Reg.No.07-7-88
STATE COMMITTEE
Room
No.14, Maruthi Vilas, C.S. Road, Kochi – 11
President Secretary
Charles
George M.M.Gopalan
Mob:
9447168852 Mob: 8086998843
Email: charlestuci@gmail.com
To
The
Chairman
Technical
Committee to review the Duration of the
Ban
period and to Suggest Further Measures
to
Strengthen the Conservation and Management Aspects.
Sir,
Sub: On
withdrawal of the Report of the Technical Committee
It is very disheartening that the Committee Report submitted to DAHD
published to the public domain without hearing our views and without proper
consultation of stakeholders, especially the State of Kerala. It is sad to know that the Technical Committee
(T.C) had recommended to ban motorized cannoes and ring seines along with trawl
ban, which is extended from 47 days to 61 days in monsoon. As a
person who had maintained intimacy and respect to some of the members of
your committee in prolonged years, I was shocked to see their recommendations,
which would have deleterious impact on the lives and livelihood of lakhs of
traditional fishermen in Kerala. The
context is more important than the text, which will add fuel to the fire in the
lackadaisical situation of the state.
The report of the committee
headed by Dr.B.Meenakumari opened the
‘Pandoras Box’. Chaos and
confusion prevailed everywhere.
After the report, DAHD published an order on November 11 and a public
notice on 28th November, allowing foreign fishing vessels to operate
in the off-shore and deep waters of our
country. The common notion is that while Central Government is
opening up our waters to foreign poachers and allowing them all sorts of
legitimacy, your report is negating operation of the traditional fishermen of
Kerala, who is operating in the in-shore waters. We also fear that your report also reflect a
‘procrustus Bed’ approach to major issues which regate the very principle
of federalism of our country. Some
major limitation of the committee is cited below:
1) Stakeholders consultation
is not conducted in Kerala. This is very
important that the committees recommendations will inflict much impetus to the
coastal people of Kerala.
2) Fisheries Director of Kerala is not included
in the committee. As a state which hold
a prominent position in Indian fishery in respect of resources, production,
employment, foreign earnings and consumption
and which is known for its complexity, the inclusion of its director is must.
3) The committee surpasses
the norms of the TOR
Eventhough the committee
had the right to recommend on various aspects, the ban of traditional motorized
crafts and ring seines is not a direct nom in the TOR. More deliberations and consultations are needed
for this delicate matter. Hasty
conclusions without in depth enquiry will reproduce negative implications.
4) Pelagic Experts are not
included
in the committee – As the major recommendations of the Committees pelagic
fishery, inclusion of an expert in the concerned field is most desirable. But it is not happened.
5) Contradictory
recommendations of the institution in very same year will affect the
credibility of the institution.
In early 2014, the
committee headed by Dr.Sunil Muhammed, who is the principal scientist of CMFRI recommended a two term ban
for trawlers and a ban of ring-services in April, May, gave its recommendations
to Govt. of Kerala. Your committee ultimately criticize that position in the
name of practicability.
In 2005, Dr.Mohan Joseph
Modayil Committee recommended 67 ban for trawlers and motorized cannoes above
10 H.P. In 2010 CMFRI experts
recommended 47 ban and a ban of motiorised crafts above 25 H.P. All these contradictory reports damage the
image of Asia’s biggest scientific fishery research institution.
VI. Lack of a comprehensive
deep sea fishering policy and a central deep sea fishing ‘enabling law’, and
lack of an off-shore, in-shore marine policy is a major hindrance before the
committee. Even Dr.Meenakumari
Committee, which is entrusted to do so, leave aside this matter to the
future. In the absence of a comprehensive review, it is not good for a new ban, instead of the
existing ones.
VII Bio centric & Eco-Centric approach
Of cource, we admit that
sustainability is a major issue. But considering
the concrete conditions of Indian fishery, especially that of Kerala, a ‘Right-based’
approach is needed. In this context ‘Kerala
Aquarium Reforms Act (KARA) which is proposed in Kerala is also to be
considered.
VIII. Equating trawl ban with
that of ring seines and motorized is
biased and se…fically baseless.
The traditional
fishermen all over India and in
Kerala continuously asking for the
extention of the duration of trawlban.
Trawl ban is not only an ecological issue in relation with spawing. It is a socio-economic-environment issue
also. We feel that the committee lacks a
holistic approach on this particular issue.
XI. Wrong assumptions come up with wrong compilation of
statistics.
The statistics about the ring seine fishery in Kerala
is totally wrong. The committee had come
up with the conclusion of wrong analysis of this statistics.
Comments on some of the
recommendations of the committee:
Evolution of Ring – seines
The artisanal fisherman used species specific and
season specific gears for their fishing in the past. They use Ayila Kolli vala, Chala kolli vala,
Mathi kollivala, Chooda vala, Echam vala etc.
They modified these gears, canoes and fishing system according to the
situation. Now it is known as ‘traditionally
modified cannoes’ and ‘ring seines’ .
As per the physical
verification made by the fisheries department, Kerala in 2005, there are 9522
non-motorised crafts 14, 151 motorised crafts and 598 in-board vessels. All of them engaged in pelagic fishing. As per the verification made by Matsya fed in
2011, 22663 out-board engines are in vogue.
They are engaging in surface and column dwelling targeted smaller
pelagic fishes. In 2012 Kerala yielded
8.39 lakh tones of fishes out of which 98% is tapped by motorized and
mechanized crafts. If a ban is imposed
on motorized canoes along with trawl boats there will, in effect, be a total
ban in the state.
2) All fisher folk of Kerala
comes under the category of BPL
3) Importance of monsoon
fishery and ring seines
The reliability and
importance of monsoon fishery in Kerala is studied at length by so many experts in CMFRI (Rao etal). Leela Edwin, who is also a member
of this committee also studied prominence of ring seines (2010) Ring seines operated 18 days in June and 24 days in July
and 20 days in August, while in others months the fleet operation is between
8-12. This itself shows that a self
imposed restriction is existing .
Majority of ring service canoes are collective ownership and they come
under the purview of sustenance fishing
as per the 2004 comprehensive marine policy.
Majority of them are in acute financial crises. By banning them in monsoon is giving rope to
the man who is seeking suicide.
4) The phenomenal chakara is
peculiar to monsoon season in Kerala.
5) There is no uniform West
Coast in India.
6) Pelagic fishing during
monsoon is very essential in Kerala in several aspects:
a) To maintain daily earning
for supporting livelihood of the family
during rainy season.
b) Exploitation of major
pelagic fisheries scientifically proved essential to accommodate and rejuvenate
new recruiting to the growing fish
stocks.
c) To support industry on
fishery ( exports etc) in the state on monsoon months.
d) To minimize the affets of
trawl ban and by accommodate work force of trawl fishey in traditional cannoes
so that labour issues resolved in a way.
6) There is no significant depletion in pelagic fishery from
1987 onwards. Instead statistics shows
that pelagic stocks increased and significant growth is recorded in oil sardine
like fishes is seen in the statistics of
CMFRI.
In this situation we
pleaced you to continue the ban on trawl fishery in monsoon for the
conservation and management fisheris and
the withdraw the suggestion to ban ring services and motorized canoes. Instead of ban on tradition sector strict regulations and
management measures to be imposed and to produced in that sector. So withdraw the T.C. report as such and proper
consultations with the stakeholders especially with that of traditional sector
is in urgent need.
Yours
faithfully,
Kochi
12.02.15 Charles
George