Submission made by the Human Rights Forum (HRF) before the panel conducting public hearing in Visakhapatnam on 2-09-2026 for finalisation of the draft Andhra Pradesh Coastal Zone Management Plan (APCZMP) for Visakhapatnam district.
Subject: Human Rights Forum (HRF) demand for rejection of proposalsseeking to reclassify the CRZ-III area from Madhurawada in Visakhapatnam Rural mandal to Nerellavalasa in Bheemunipatnam mandal as CRZ-II and for due consideration of all objections, suggestions and representations received from the public before finalisation of the Draft APCZMP
The Human Rights Forum is a citizens’ forum committed to protecting and promoting constitutionally guaranteed and internationally recognised rights of the people.
Our fundamental submission before the panel is, in fact, an objection to the manner in which this public hearing is being conducted. We are of the view that unless and until the issues relevant to this exercise are made public in a form that is intelligible and accessible to the people likely to be affected, in one way or another, by its outcome, this hearing will remain a mere formality, if not a farce. Making such information available is the minimum necessary to ensure that the hearing is transparent, meaningful and capable of yielding a genuine public consultation.
A public hearing under the CRZ regime cannot be reduced to a gathering at which members of the public are permitted to speak, their statements are recorded and the authorities thereafter proceed substantially as they had intended. The CRZ Notification, 2019 contemplates genuine public consultation in the preparation and finalisation of the CZMP. The Draft CZMP is required to be given wide publicity and the public must be afforded a meaningful opportunity to offer suggestions and objections. HRF believes that consultation presupposes knowledge, which presupposes disclosure and any meaningful disclosure, in turn, presupposes adequate time and an intelligible presentation of the relevant material.
The manner in which this hearing is being organised makes this concern all the more serious. The notice of the public hearing and the material relevant to the Draft CZMP were uploaded on the APPCB website only a few hours before the scheduled hearing on 2 Sept, 2026. This is not a minor procedural lapse. In our opinion, it strikes at the very heart of meaningful public consultation. It is difficult to understand how members of the public can be expected to study a complex coastal management plan, examine its maps and classifications, understand their implications and formulate considered objections when the very material on which they are expected to participate is placed in the public domain virtually on the eve of the hearing. This cannot reasonably be described as “wide publicity” or as meaningful public consultation.
A hearing conducted in these circumstances risks reducing the public hearing to a ritual designed merely to satisfy a procedural requirement rather than a genuine exercise in consultation. The public is being invited to speak after being denied a reasonable opportunity to understand what it is being asked to comment upon. At the very least, the hearing should not proceed to any final determination until the public has been given adequate time and opportunity to examine the complete material and make informed representations.
This is particularly important here because the proposed change from CRZ-III to CRZ-II is not a mere change of nomenclature. It alters the regulatory regime applicable to the coastline and can facilitate substantially greater development pressure and construction activity in areas presently subject to the more protective CRZ-III regime. The draft CZMP itself recognises the ecological sensitivity of Visakhapatnam’s coast, identifying sand dunes, turtle-nesting areas, reserve forests, eco-sensitive zones and archaeological and heritage sites. It also records the protective No Development Zone applicable to CRZ-III areas, including a 200-metre No Development Zone (NDZ) for CRZ-IIIB areas. Reclassification would therefore be far more than a mere technical change in coastal classification. It would weaken an existing layer of regulatory safeguards and potentially expose a relatively protected coastal landscape to substantially greater development pressure.
HRF’s concern is heightened by recent statements from the State’s Tourism Minister and other functionaries of the ruling dispensation portraying CRZ safeguards as an obstacle to tourism and development along the coast. As we have repeatedly pointed out, such an approach dangerously reverses the purpose of coastal regulation, treating environmental safeguards as impediments to commercial expansion rather than as protections for fragile ecosystems, coastal communities and public safety. Reclassification risks opening relatively protected coastal commons to intensified tourism, real-estate and other commercial development, weakening natural buffers against cyclones, storm surges and erosion, while seriously threatening the customary rights and livelihoods of fishing communities. Once such protection is diluted, the consequences may be difficult, if not impossible to reverse. The question is not whether the coast should develop, but whether development should be made subordinate to the ecological and social limits of the coast. The burden must therefore lie squarely on those seeking reclassification to demonstrate, transparently and with credible evidence, why this dilution is necessary, environmentally sustainable and in the larger public interest.
The gram panchayats of Kapuluppada, K. Nagarapalem, Chepala Uppada, Nidigattu, J.V. Agraharam and Nerellavalasa were subsequently brought within the Greater Visakhapatnam Municipal Corporation (GVMC). However, as on 18 January 2019, their formal incorporation into GVMC had not been completed in all respects. Consequently, when the CRZ Notification, 2019 was issued, these areas continued to remain within CRZ-III. Even today, their mere inclusion within GVMC cannot, by itself, justify any dilution of coastal safeguards. These areas continue to suffer from inadequate sewage treatment, drainage, roads and other essential urban infrastructure.
The significance of this coastal belt extends far beyond its classification as an urban area. It contains areas of truly exceptional ecological, strategic, historical and cultural significance, including INS Kalinga, the Buddhist archaeological sites of Bavikonda and Thotlakonda and the Erra Matti Dibbalu (Red Sand Dunes). The coastline is also home to thousands of traditional fishing families whose livelihoods are intimately connected with the coast and its resources. Intensified construction and urbanisation can directly affect coastal ecology, access to the coast, fishing activity and the social and economic security of these communities.
HRF urges the APCZMA and the government to:
- Reject outright all proposals to reclassify the coastal stretch between Madhurawada and Nerellavalasa from CRZ-III to CRZ-II and retain its existing CRZ-III status as the more appropriate and environmentally protective classification.
- Do not treat the mere inclusion of these areas within GVMC jurisdiction as sufficient grounds for reclassification. Any proposed change must be supported by clear, publicly disclosed, legally sustainable and scientifically credible reasons demonstrating that it will not compromise coastal ecology, environmental safeguards, public access or the livelihood rights of traditional fishing communities.
- Treat this public hearing as a substantive process of consultation rather than a procedural formality. Every objection, suggestion and representation received must be properly considered and the reasons for accepting or rejecting the issues raised must be transparently recorded before the APCZMP is finalised.
- Undertake a comprehensive review of the proposed CRZ classification in light of the ecological, social, cultural, historical and strategic significance of the coastline and incorporate appropriate protections for its sensitive landscapes, archaeological sites, fishing communities and other significant features in the final APCZMP.
- Ensure that no proposal to dilute CRZ protection is incorporated into the final APCZMP unless the complete supporting material, maps, rationale and likely consequences of the proposed change have first been placed in the public domain and the affected public has been given a genuine and reasonable opportunity to examine and respond to them.
- Keep finalisation of the APCZMP in abeyance until the deficiencies in public disclosure and consultation have been adequately addressed and ensure that the final Plan genuinely reflects the objections and concerns raised by the public, rather than treating this hearing merely as a statutory step to be completed before implementing a predetermined decision.
We therefore request that our objection regarding the adequacy and manner of public consultation be formally recorded in the proceedings. The coast between Madhurawada and Nerellavalasa is not merely land awaiting urbanisation. It is an ecological, social and cultural landscape of immense public significance and its protection is a matter of legitimate public interest. Urban administrative boundaries cannot and must not become a justification for diluting existing safeguards that protect this landscape and the communities that depend upon it.
Y. Rajesh – HRF AP State general secretary
VS Krishna – HRF AP & TG Coordination Committee member
02-09-2026,
Visakhapatnam.