Repairs or Reconstruction of commercial buildings in CRZ Area Permissible?

Repairs or Reconstruction of commercial buildings in CRZ Area Permissible? 
വാണിജ്യ കെട്ടിടങ്ങളുടെ അറ്റകുറ്റപ്പണികളും പുനർനിർമാണവും CRZ പ്രദേശങ്ങളിൽ അനുവദനീയമാണോ ?

Obviously the coastal regulation zone notification published in 1991, 2011 hand and 2019 does not provide any retrospective mandate for its implementation. Even before the restrictions imposed in coastal area as per CRZ notifications several buildings including residential and commercial were in existence. In the efflux of time, these buildings require timely repair and renovation. 

Rennovation or reconstruction of  residential buildings are permissible without any increase in existing plinth area. The regulation that Building in 90s shall be renovated only with the existing plinth area is absolutely a violation of the principles of natural justice. However nobody has challenged it and it remained same. 

Here the question is, if the renovation application is for a commercial existing building, the authorities (KCZMA) are not permitting it.  The reason states for the rejection of the application is seen by quoting  the clause 8 of the presently following 2011 Notification. The relevant portion read so-

"No construction shall be permitted within NDZ except for repairs or 
reconstruction of existing authorized structure not exceeding existing Floor Space Index, existing plinth area and existing density and for permissible activities under the notification including facilities essential for activities; Construction/reconstruction of dwelling units of traditional coastal communities including fisherfolk may be permitted between 100 and 200 metres from the HTL along the seafront in accordance with a comprehensive plan prepared by the State Government or the Union territory in consultation with the traditional coastal communities including fisherfolk and incorporating the necessary disaster management provision, sanitation and recommended by the concerned State or the Union territory CZMA to NCZMA for approval by MoEF."

It can be understood, if change in classification from residential to commercial or vice versa is prevented on account of the above said clause. But it cannot be justified if the repair or renovation of existing commercial building is not permitted by citing the "permissible activities" in CRZ III category. Several such instances are reported and if the same are not addressed, livelihood and income generation of coastal communities will be affected indefinitely.  

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