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The RP 2001 land use plan for Canacona taluka, which is presently in force (since RP 2021 land use plans are frozen by the Government), shows the land proposed to be acquired for the subject industrial estate as agricultural land. The Regional Plan is the legal basis to regulate land use and prohibits use of land demarcated as agricultural zone for industrial purpose. The subject land acquisition is in violation of the RP 2001, which is the existing law for land use. 2. The Draft Policy Document prepared by the Task Force and notified by the Government for RP 2021 had outright rejected all fresh acquisition proposals by GIDC, including the Poinguinim Industrial Estate (paragraph 3.7.4, c, pages 84 and 85). It further opposed 'current practice of acquiring land and proposing Industrial Estates along the coastal belt' (paragraph 3.7.4, d, page 85). The analysis of the issues concerning industries in Goa that 'Sizeable industrial land within indutrial estates has been occupied by sick units, non-operating units, vacant plots, projects for speculative purposes', and that '30% of the plots in the 21 Industrial Estates are lying vacant' have led the Task Force to conclude that the vacant lands in existing industrial estates are sufficient to provide for all the Industrial sector jobs required until 2021. The Final Reports for RP 2021 subsequently prepared by the Government have not modified or reversed the rejection of the Poinguinim Industrial Estate by the Draft Policy Document. These Final Reports are also subject to corrections and changes along with the RP 2021 Land Use Plans, and hence cannot be considered to be in force. The proposed acquisition for the subject industrial estate is therefore in violation of the Policy laid down by the Task Force and notified by the Government, which is in force as far as the new industrial estate at Poinguinim is concerned. 3. The proposal to acquire the common lands at Poinguinim plateau for industrial purpose is completely arbitrary, with no possible benefit, and destructive in all ways. The existing Industrial Estate at Canacona, which is less than 4 kms away from this proposed site, is almost non-functional - even decades after being fully developed! Just a handful of units are in operation, and most other units and lands are lying unutilized. The other industrial estates in the South Goa District are also full of sick and closed units, including the well located Margao Industrial Estate, which is in equally dismal condition. There is no Public purpose behind the subject land acquisition, since the Goa Industrial Development Corporation (Goa IDC) has totally mismanaged the existing industrial estates, and will require at least a decade to start using the existing lands and units under its jurisdiction satisfactorily. As such, the present proposal will give no benefit at all to the industrial sector (which it is supposed to serve), but will destroy all the other flourishing sectors for the entire Poingiunim Panchayat Area, such as water quality and quantity, forests, wildlife, housing, animal husbandry, erosion protection, biodiversity, agriculture, fishing, medicinal plants, social equity, protection of oppressed

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classes, religious and social fabric of the society, common lands, employment, social peace and social security. The impact of the proposed Industrial Area on some of these sector is described in the following paragraphs. The Poinguinim plateau is on a low altitude headland extending from the Cotigao Wildlife Sanctuary and reserve forests (Partagal aframento) on the east, and is bounded by the Arabian Sea on the west, the Talpona river on the north and the Galgibag river on the south. The headland comprises of the plateau, steep forested upper slopes, and a narrow inhabitable strip at the foot, bordering the river, the sea, or low-lying riverine fields. This headland and its extensive plateau froms a very important part of the forests which are protected under Cotigao Wildlife Sanctuary. The proposal to create an Industrial Estate on this plateau shall directly impact the Cotigao Wildlife Sanctuary by reducing its biodiversity significantly, and reducing the range for wildlife species that need this plateau for various purposes, including for movement (to and from the forests on the steep upper slopes of the sides of the plateau), water, food and social activities. The loss of the only low-lying plateau associated with the Cotigao Wildlife Sanctuary is therefore totally unacceptable in terms of negative impact on the forests of the Sanctuary. Local residents of Poinguinim have sighted the tiger on the southern side of the land proposed to be acquired on numerous occassions, even as recently as less than a year ago. The plateau is definitely crucial for the survival of the tiger population of Cotigao Wild Life Sanctuary, as verified by sightings and local folklore. The Poinguinim plateau is one of the few untouched coastal plateaus left in the State. These plateaus are the richest repositories of rare and endemic plants of the Western Ghats, and are under most serious threat on account of change in land use. The Poinguinim plateau cannot be used for any non-agricultural purpose before studies are carried out on these important and fast disappearing species, as we stand to lose rare species that have economic and social value far greater than those any industry can provide. The proposed site for the industrial estate is less than one km from the High Tide Line at the Galgibag-Talpona turtle nesting beach. Turtles are extremely sensitive to light from the landward side, and will not nest on beaches which are illuminated. The Poinguinim plateau directly overlooks the said beach, and the construction and operation of an industrial estate will require minimum illumination of the plateau, which will definitely drive the turtles away. Today, all other turtle nesting beaches of Goa have been turned into no-entry zones for these highly protected animals of great ecological signinficance, and only the Galgibag-Talpona stretch welcomes these ancient travellers of the sea with darkness at night. The Poinguinim plateau is bounded on three sides by saline water. The fresh water aquifer created by this plateau provides water to over 7000 residents of the villages, who mostly live in the narrow strips of settlements along the base of the plateau. The water from this aquifer sustains all the ancient communities settled in Borwalo, Gimnem, Bhatwado, Velwado, Durg, Mhalwado, Kateabag,

Mhagdal, Galgibag, Colsor, Dando, Ganebag, Gabitwado, Talpona, Muthal, Kulti (Dhangarwado), Paitod, Sadolxem, Bateagal, Caregoton, Khotawado, Natanguinim, Gudkomol and Ardhafond. It provides all the residents of these wards with drinking water and irrigation supply for sustenance agriculture, vaingonn cultivation and horticulture. Major perennial springs supplied by this aquifer are at the Pateapurush Temple (Bhatwado), Zarifond (Maddar), Dukrevholl, Mhashevholl at Mhalwado (Kond), Purandi, Mhalwado, belonging to Prabhugaonkars, Karmalya bain, Kateabag, Devatollem and vhoddlemtollem at Colsor, and at Muthal, Madian (Sadolxem), Songal, Velipwada and at Kulti. This aquifer is very sensitive on account of its tiny size and proximity to saline water on three sides. The existing settlements are located next to the banks of the rivers, and the wells and springs are also usually located in the narrow belt adjacent to saline water, emphasizing the fragile nature of the water regime of this particular headland. Any non-agricultural activities on the Poinguinim plateau shall seriously impact the water quality and quantity available to the settlements below, making the wards which are densely populated at present, uninhabitable by man in the future. 9. The Poinguinim plateau has been owned by the village Gaunkari, as common lands, since times immemorial. The environmental, economic and social wealth of Goan villages sprout from such common lands, which are all the more invaluable to a tiny State like ours. The importance of common lands is recognized by all, including the Hon'ble Supreme Court of India, which has disapproved other uses on common lands in past judgments. The forced transfer of common lands belonging to the gaunkars of Poinguinim in the name of the Communidade of Poinguinim, through the arbitrary use of the Land Acquisition act, 1894, to private individuals and corporations, shall gravely harm the interests of the society, and violate the Law in force. 10. The lands under acquisition have been traditionally used as grazing lands, agricultural lands and forests, since times immemorial. The Poinguinim plateau is also inhabited by a settlement of Dhangars, the most oppressed and threatened of the Goan tribes (they are still not recognized as a Scheduled Tribe within Goa). The Dhangars have been a part of Goan plateaus and forests for thousands of years, and live in total harmony with nature. The Dhangars are the protectors of these plateaus, which have always been regarded as their grazing lands, in addition to the other uses which are allowed for the others residing in the settlements below. However, just as in other parts of the State, their age-old settlement is not even identified on the Regional Plan for Goa. Their grazing lands have been partially alienated by construction of an electrical substation in front of their settlement, partially blocking their access to this part of the plateau. The proposed industrial estate will complete their alienation, bringing to an end all their age-old knowledge, traditions, culture, mode of production and way of life, which is much more precious to society than a successful industrial estate. Regardless to the economic reasons, the State is bound to protect the rights of the Dhangars to live their traditional lives, and to protect their traditional rights over the plateau lands.

11. In addition to the invaluable ecological services it provides to the region, the

plateau directly supports numerous economic activities of the villagers. Agriculture has always been a primary source of livelihood for most villagers, though some agricultural lands are presently not in use due to losses caused by artificially high costs, and lack of support from the State in the past. In spite of the odds being stacked against these small farmers, many are still dependent on agriculture for their primary or secondary sources of income, or for subsistence. The proposed industrial estate will directly impact the agriculture in many ways, including water scarcity, water pollution, loss of natural fertilizers, erosion of upper slopes and siltation, conversion of land for housing and other demands of families of industrial unit owners, industrial workers and other employees, solid waste, industrial pollution, sewage, etc. The fragile agricultural sector serving 7000 residents of Poinguinim village is certain to be devastated by the proposed industrial estate, irrespective of the kind of industries, or other non-agricultural activities, that will be undertaken on the plateau. 12. The plateau has always been used as grazing ground, not just by the Dhangars, but also by all the residents of the village. The present government has proposed to encourage dairy industry in the State. This plateau is essential for the fodder for the cattle to be reared by the villagers, if dairy farming is to be encouraged. Notwithstanding government policy, the right to livelihood of the villagers demands that the grazing grounds be retained in the present form of common ownership. 13. The plateau has traditionally been used for collection of firewood, construction material, fodder, medicines, other forest produce, and for numerous other economic purposes, in addition to agriculture and grazing, and the priceless ecological services it provides. The use of even a part of this plateau for industrial purposes shall also render the rest of this fragile plateau unfit for any of the multiple environmental, economic and social services it provides today. 14. The Poinguinim plateau is surrounded by many ancient temples which are all highly revered by all the residents. These temples, their ceremonies and the attached folklore and beliefs form the cultural heritage of the villagers. The renowned Betal temple lies at the foot of the plateau in Mhalwado and is associated with the two extremely important religious ceremonies of 'Toko' and 'Gadea Zatra', which take place in consecutive years, in a three year cycle. The ancient sacred pathways reserved for the Betal God and the religious processions, which mostly pass through this plateau, are completely sacrosant as per local tradition. The 'Toko' involves all of the numerous communities living here, including Velips, Carpenters, Fishermen, Deulis, Katkars, Dhangars and Brahmins. The 'Toko' is a ceremonial procession of the religious party, which following ancient sacred routes connecting various neighbouring villages, including Poinguinim, Loliem and Khargal. The 'Toko' visits the Navdurga temple (Mhalwado), Galiem, Sadolxem (Mohini temple), Kulti Moll at the plateau (Dhangarwado), Colsor (Sateri temple), Kulti, Betal temple

(Mhalwado), Sonsorem on the plateau and Chandanaped (along the Galgibag river bank), where Gabit fishermen take the 'Toko' across on canoes (sangod) from Poinguinim to Loliem. The 'Toko' travels to Bhagwati temple, Keshav temple, Kalshi, and finally comes back to Betal temple. The 'Toko' visits 250 locations to carry out religious ceremonies. There are numerous beliefs and great reverence associated with the 'Toko'. The land proposed to be acquired for the industrial estate directly conflicts with the sacred path of the 'Toko'. It is not possible to construct an industrial estate on the Kulti Moll at the Poinguinim plateau (where it is presently proposed), without disturbing the religious ceremony of 'Toko', thereby causing unforeseeable damage to the social strength and cultural wealth of the numerous communities living in Poinguinim village in peace and balance since times immemorial. 15. In violation of the policy laid down by the Task Force, the subject industrial estate was included in the Draft RP 2021 Plan prepared by the government. This Plan was sent to the Poingiunim Village Panchayat for corrections. Both the Gram Sabha and the Village Panchayat of Poinguinim totally removed the industrial estate from the the Land Use Plan they prepared and submitted to the government. However, the final RP 2021 prepared by the government, which was frozen subsequently due to numerous glaring errors and objections, again showed part of the plateau as industrial zone, to which the villagers objected through written submissions. It is clear that the villagers strongly oppose industrial use of land on the Poinguinim plateau. The proposal of the Goa IDC also completely fails to meet the legal and moral requirements of ensuring Public Participation in the process of taking a decision affecting the entire village in such a drastic manner.