Regulatory research
Coastal Regulation Zone (CRZ) in Dholera SIR
What government records establish about coastal regulation in the region — its recorded extent, the approvals that apply, and the questions those records do not answer.
- DSIR total area
- 920 km²DSIR total area
- Recorded as CRZ
- ~400 km²Recorded as CRZ
- For town planning
- 520 km²For town planning
- Primary sources
- 8Primary sources
This page does not establish the CRZ status of any parcel. That is set by the approved Coastal Zone Management Plan for the stretch, read together with the applicable notification. Aggregate figures below describe the region, not individual land, and no map here shows a CRZ boundary.
Published by DholeraMaster.com — a research and informational publication. Not a government publication. Reviewed: · Sources: 8 government documents, listed in full at the foot of this page.
What this page can establish
- Regional CRZ figures as recorded in government documents
- CRZ categories and No Development Zones as defined in the notification
- Dholera projects that went through CRZ appraisal, with dates
- Which authority decides which question
- Where the official records can be read in full
What it cannot establish
- The CRZ status of any specific survey number
- Ownership or title
- Whether a particular parcel is agricultural or NA
- Whether construction may proceed on a given site
- The legality of any specific proposed project
How much of Dholera SIR falls under CRZ?
Expert Appraisal Committee minutes from January 2019, repeated in July 2021, record: "Total land area of DSIR is about 920 sq. km of which 520 sq. km has been allocated for town planning and approximately 400 sq. km falls under coastal regulation zone (CRZ) of Gulf of Khambhat." A separate figure appears in the 2014 Environmental Clearance, which describes 38% of the total area as demarcated for CRZ. The two are not directly comparable — one is a measured area, the other a development-plan allocation share — and neither is a parcel-level map.
Is the entire Dholera SIR under CRZ?
No. Government records describe roughly 400 km² of a 920 km² region as falling under CRZ, and 520 km² as allocated for town planning. Which specific land falls inside is set by the approved Coastal Zone Management Plan for the stretch, not by these aggregate figures.
Does CRZ land require NA permission?
The two are separate permissions under separate instruments. Permission for non-agricultural use is sought from the Collector under section 65 of the Gujarat Land Revenue Code, 1879 — a revenue permission. CRZ is a central environmental regime under the CRZ Notification, administered through the State Coastal Zone Management Authority and MoEFCC. Neither instrument reviewed here states that one substitutes for the other, and nothing reviewed states that CRZ status changes whether NA permission is required. Whether a particular parcel needs NA permission, and how CRZ status bears on a specific application, requires confirmation from the competent revenue authority.
Can development take place in a CRZ area in Dholera?
Specified activities can, subject to category, conditions and clearance. The 2014 Environmental Clearance states: "No industrial activity should be undertaken in the CRZ area, except the activities which are permissible in the CRZ area under CRZ Notification 2011 after taking due clearance from the concerned authority. The matter related to CRZ issues shall be considered only when the recommendation from the State CZMA is received by the Ministry." In practice, DSIRDA obtained CRZ clearance for a solar park in CRZ areas of the SIR, so it is demonstrably not a blanket prohibition — but it is activity-specific and requires approval.
Does environmental clearance for Dholera SIR mean any parcel can be developed?
No. The 2014 Environmental Clearance for the region states that "Each industrial unit coming up in the industrial area has to seek separate environmental clearance individually." A region-level clearance does not carry down to every unit or parcel within it.
What the records say
How much of Dholera SIR is recorded as CRZ
The clearest statement appears in Expert Appraisal Committee minutes of 25 January 2019, and is repeated unchanged in the 13 July 2021 minutes:
“Total land area of DSIR is about 920 sq. km of which 520 sq. km has been allocated for town planning and approximately 400 sq. km falls under coastal regulation zone (CRZ) of Gulf of Khambhat.”
The same minutes describe the setting: “The site touches the Gulf of Khambhat on the Eastern side and river Sukhbhadar passes through the northern side of the SIR area. In addition, river Lika passes through the middle of the SIR area before meeting the Gulf of Khambhat.”
Why two different CRZ figures exist
The 19 September 2014 Environmental Clearance gives a different-looking number — it describes the proposed land-use split for the region as follows:
| CRZ area | 38% |
|---|---|
| Green space | 30% |
| Residential | 13.3% |
| Industrial | 12.5% |
| Transportation and other zones | 6.2% |
38% of 920 km² is roughly 350 km², against the ~400 km² stated in the later minutes. These are not necessarily in conflict: one is a development-plan allocation share, the other an area described in a project appraisal five years later. Mapping methodology, date and purpose all differ. Neither is a parcel-level determination, and this page does not attempt to reconcile them into a single figure.
The framework
How CRZ categories relate to the coast
A section rather than a map. A map would have to place a line across Dholera, and no line drawn without the approved CZMP would be the real one.
Categories in practice
What the Dholera records show about category assignment
Rather than restate the notification in the abstract, this is how categories were actually applied to a real project in this region.
When DSIRDA sought CRZ clearance for a solar park, the appraisal record broke the project area down by category. This is the most concrete published example of CRZ classification inside Dholera SIR:
| Category | Area |
|---|---|
| CRZ-IB (inter-tidal zone) | 7,949.17 ha |
| CRZ-III | 204.34 ha |
| CRZ-IVB | 5.03 ha |
| Non-CRZ | 436.40 ha |
| Total project area | 8,594.95 ha |
Source: 207th EAC (CRZ) meeting minutes — 4400 MW Solar Power Park, Dholera SIR, 25 January 2019. These are figures for one project area, not for the region, and not a map.
What the committee said about the intertidal land
Permissibility
What the records show about activity in CRZ areas here
The 19 September 2014 Environmental Clearance attaches this condition:
“No industrial activity should be undertaken in the CRZ area, except the activities which are permissible in the CRZ area under CRZ Notification 2011 after taking due clearance from the concerned authority. The matter related to CRZ issues shall be considered only when the recommendation from the State CZMA is received by the Ministry.”
Two things follow. Activity in CRZ areas is not blanket-prohibited — it is limited to what the notification permits, and requires clearance. And the State Coastal Zone Management Authority’s recommendation is a precondition to the Ministry even considering a CRZ matter.
The clearest worked example is the solar park. The 13 July 2021 minutes record that Phase-I CRZ clearance was granted on 26 February 2019, and that for Phase-II: “The Committee noted that the area is in inter-tidal zone however, the activity is a permissible one as per para under 3(i) (c) and 4 (ii) (h) of the CRZ Notification, 2011.”
Permissibility was established by pointing at specific paragraphs of the notification for a specific activity — not by the land’s zoning, and not by its location inside the SIR.
Current status
The applicable Coastal Zone Management Plan
The CZMP is the document that actually determines CRZ status on the ground. Its status for this district is now established.
Dholera SIR lies in Ahmedabad district, as recorded in each of the clearance documents above. Minutes of the 49th meeting of the National Coastal Zone Management Authority, held 8 May 2026, record:
“CZMP of Eight (8) Coastal districts (Vadodara, Anand, Ahmedabad, Porbandar, Junagardh, Dev Bhumi Dwarka, Jamnagar and Gir Somnath) already approved on 23/10/2025.”
A Coastal Zone Management Plan covering Dholera’s district was therefore approved on 23 October 2025, in the process aligning plans to the 2019 notification. The same minutes record a second group of eight Gujarat districts being recommended at that May 2026 meeting, which indicates how recently this framework has been moving.
An approved CZMP exists — this page does not reproduce it
The notification itself
Categories and No Development Zones, as defined
Reproduced from the 2019 gazette notification rather than summarised.
CRZ-I A
Ecologically sensitive areas and geomorphological features — mangroves (with a 50 m buffer where the mangrove area exceeds 1,000 m²), corals and coral reefs, sand dunes, biologically active mudflats, protected areas, salt marshes, turtle nesting grounds, horseshoe crab habitats, sea grass beds, bird nesting grounds, and areas of archaeological importance.
CRZ-I B
The intertidal zone — the area between the Low Tide Line and the High Tide Line.
CRZ-II
Developed land up to or close to the shoreline within existing municipal limits or legally designated urban areas, substantially built up (more than 50% of plots), with drainage, approach roads and other infrastructure.
CRZ-III
Land areas that are relatively undisturbed — rural areas, and those not falling under CRZ-II. Sub-divided into III A and III B by population density.
CRZ-IV A
The water area and sea bed between the Low Tide Line and twelve nautical miles seaward.
CRZ-IV B
The water and bed area of tidal-influenced water bodies, from the mouth up to the limit of tidal influence — salinity of five parts per thousand in the driest season.
The No Development Zone, and the condition attached to it
The distinction between CRZ-III A and III B turns on population density at the 2011 census, and it changes the No Development Zone substantially:
“Such densely populated CRZ-III areas, where the population density is more than 2161 per square kilometre as per 2011 census base, shall be designated as CRZ-III A and in CRZ-III A, area up to 50 meters from the HTL on the landward side shall be earmarked as the ‘No Development Zone (NDZ)’, provided the CZMP as per this notification, framed with due consultative process, have been approved, failing which, a NDZ of 200 meters shall continue to apply.”
“All other CRZ-III areas with population density of less than 2161 per square kilometre, as per 2011 census base, shall be designated as CRZ-III B and in CRZ-III B, the area up to 200 meters from the HTL on the landward side shall be earmarked as the ‘No Development Zone (NDZ)’.”
Two things follow that are routinely got wrong. The headline “50 metres” applies only to densely populated CRZ-III A areas and only where a CZMP under the 2019 notification has been approved — failing which 200 metres continues to apply. A separate provision earmarks land up to 50 metres from the HTL, or the width of the creek whichever is less, along tidal-influenced water bodies in CRZ-III. The notification also records that the NDZ does not apply within notified port limits.
Specific to this coastline
The Gulf of Khambhat is named in the notification
Most coastal regulation is generic. One provision is not: clause 3.1 of the 2019 notification lists areas accorded special consideration, and names this coastline directly.
“Sundarban region of West Bengal and other ecologically sensitive areas identified as under Environment (Protection) Act, 1986 such as Gulf of Khambat and Gulf of Kutchh in Gujarat, Malvan, Achra-Ratnagiri in Maharashtra, Karwar and Coondapur in Karnataka, Vembanad in Kerala, Gulf of Mannar in Tamil Nadu, Bhaitarkanika in Odisha, Coringa, East Godavari and Krishna in Andhra Pradesh shall be treated as Critical Vulnerable Coastal Areas (CVCA) and managed with the involvement of coastal communities including fisher folk who depend on coastal resources for their sustainable livelihood.”
Dholera SIR fronts the Gulf of Khambhat, which the notification treats as a Critically Vulnerable Coastal Area, to be managed with the involvement of coastal communities including fisher folk. That is not a Dholera-specific rule, but it is a Dholera-specific fact: the coastline this region sits on is one the notification singles out.
It connects to the appraisal record too. The intertidal land at the solar site was described as highly eroding mudflats — and biologically active mudflats and salt marshes are listed under CRZ-I A, the most restricted category.
The question most often asked
CRZ and NA status are different questions
This section deliberately does not resolve the NA question, because the documents reviewed here do not resolve it.
Four separate regulatory questions are routinely collapsed into one. They are decided by different authorities, under different instruments, and one does not substitute for another:
- NA status. A revenue and land-use question under Gujarat revenue law, decided by the competent revenue authority.
- CRZ compliance. A coastal environmental question under the CRZ Notification, involving the State CZMA and MoEFCC.
- Environmental Clearance. A project-level environmental approval. The 2014 EC states each industrial unit must seek its own.
- Development permission. A planning question, decided by the planning authority for a specific proposal.
On the revenue side the route is identifiable: permission for non-agricultural use of land is sought from the Collector under section 65 of the Gujarat Land Revenue Code, 1879, with related provisions at sections 65-A and 65-B. That is a revenue permission, granted by a revenue authority.
Coastal regulation runs on an entirely separate track — the CRZ Notification, made under the Environment (Protection) Act, 1986, administered through the State Coastal Zone Management Authority and the Ministry.
Where this page stops
That the two are separate instruments under separate authorities is established. What is not established by anything reviewed here is how they interact in practice: whether CRZ status affects an NA application, whether an NA order has any bearing on CRZ obligations, or whether CRZ clearance changes a parcel’s revenue classification.
No document reviewed states that one permission substitutes for another — but absence of a statement is not the same as a rule, and this page does not convert it into one. The position for a specific parcel requires confirmation from the competent revenue authority, read alongside the approved CZMP for that stretch.
Authorities
Who decides what
Populated only from the documents reviewed. Where a record does not state a role, the cell says so rather than assuming one.
| Authority | Primary role | CRZ role | Land-use role |
|---|---|---|---|
| MoEFCC | Central environment ministry; issues Environmental Clearance and CRZ clearance for covered projects | Issues clearance; considers CRZ matters on State CZMA recommendation | None |
| Expert Appraisal Committee (CRZ) | Appraises CRZ proposals and recommends to the Ministry | Appraisal and recommendation | None |
| State CZMA (Gujarat) | State coastal zone management authority | Recommendation to the Ministry — the 2014 EC makes this a precondition | None |
| DSIRDA | Regional development authority for Dholera SIR; project proponent in the CRZ solar proposals | Applicant, not the deciding authority | Development plan and town planning schemes |
| DICDL | Special purpose vehicle between the Central Government (DMICDC Trust) and DSIRDA, created to implement the project | None stated in the records reviewed | Implementation |
| Collector (Gujarat revenue) | Grants permission for non-agricultural use under section 65, Gujarat Land Revenue Code, 1879 | None | Grants NA permission; land records |
| NCZMA | National authority; recommends state Coastal Zone Management Plans for Ministry approval | Recommends CZMPs — recommended eight further Gujarat districts in May 2026 | None |
Four different questions
CRZ, NA, planning and development permission are not the same question
Each row is decided under a different framework by a different authority. One answer does not supply another.
| Question | Framework | Establishes | Does not establish |
|---|---|---|---|
| Is the land agricultural or NA? | Gujarat Land Revenue Code, 1879 — s.65, Collector | Revenue land-use status | CRZ status or clearance |
| What is the planned land use? | Development plan and town planning scheme | Planning designation | Environmental or coastal approval |
| Is the site within CRZ? | Approved CZMP read with the CRZ notification | Coastal regulatory status and category | NA status or title |
| Is the proposed activity permitted? | CRZ notification and the clearance process | Whether that activity may be considered | Ownership or planning permission |
| Is environmental clearance required? | Environmental framework, MoEFCC / SEIAA | Whether the project needs EC | NA status |
| May construction proceed? | Development and building permission | Permission for a specified development | Exemption from CRZ obligations |
A second worked example
The expressway corridor and CRZ
Roads are the other Dholera activity with a published CRZ record, and it is more specific than the solar one.
NHAI asked the National Centre for Sustainable Coastal Management to prepare a project-level CRZ map for the corridor. That study records:
“The part of proposed Ahmedabad - Dholera expressway alignment crosses through Bhogawa creek and Golsar creek, which is under CRZ region.”
The villages named are Valinda, Anandpur, Pipli and Bholad, in Ahmedabad district. On categories, the study concludes:
“The proposed Ahmadabad-Dholera expressway route passes through CRZ categories such as CRZ IB, CRZ III and CRZ IV. The categorization of CRZ in the approved CZMP may be followed for categorization of CRZ.”
Two points are worth drawing out. The study states that mangroves — CRZ I A — are not present along the route, and it gives a creek-specific extent rather than a single blanket distance:
“The landward extent of CRZ is equal to the width of the creek/river subject to a maximum of 100 m in the case of creek and river.”
That is a government source stating a 100-metre maximum for creeks and rivers — which is why a flat “CRZ is 500 metres” is not a safe generalisation.
The study also notes that HTL, LTL and CRZ categories were presented at 1:4000 cadastral scale with survey plot information — so parcel-level CRZ mapping does exist for corridors that have been surveyed, and it is prepared by a government institute rather than inferred from a satellite image.
Verification
How CRZ status of a parcel is actually established
- Identify the village and survey number
- Establish whether the land is inside the notified SIR boundary
- Identify the applicable town planning scheme and final plot, where one exists
- Check the development plan land-use designation
- Check the approved Coastal Zone Management Plan for that stretch — this is the document that determines CRZ status
- Identify the CRZ notification in force for that stretch, and any amendments
- Establish whether the intended activity is a regulated activity under that notification
- Check NA status separately, through the revenue record
- Establish which approvals the specific activity requires, and from which authority
- Obtain written confirmation from the competent authority where the position is unclear
A coloured map is not evidence of CRZ status
Corrections
Common misconceptions
“The whole of Dholera SIR is CRZ.”
Government records describe roughly 400 km² of a 920 km² region as falling under CRZ, with 520 km² allocated for town planning.
“CRZ means no development is possible.”
The records show specified activities being cleared — DSIRDA obtained CRZ clearance for a solar park in CRZ areas. Permissibility is activity-specific and conditional.
“Environmental clearance covers every parcel.”
The 2014 EC states each industrial unit must seek separate environmental clearance individually.
“A final plot number means construction is permitted.”
Planning status is one question. Environmental and coastal approvals, and development permission, are separate ones.
“CRZ is always 500 metres from the sea.”
The applicable distance and category depend on the notification in force and the approved coastal mapping, not on a single universal figure.
“Outside CRZ means developable.”
Other planning, revenue, environmental and statutory requirements may still apply.
Primary sources
Government documents this page relies on
Each was opened and read. Quotations above are verbatim from these documents.
| Document | Authority | Date | Establishes |
|---|---|---|---|
| Environmental Clearance — Dholera Special Investment Region (DSIR)Environmental Clearance letter | Ministry of Environment, Forest and Climate Change | 19 September 2014 | DSIR extent of 920 km² across 22 villages; the proposed land-use split including the CRZ share; and the conditions attaching to activity in CRZ areas. |
| 207th EAC (CRZ) meeting minutes — 4400 MW Solar Power Park, Dholera SIRExpert Appraisal Committee minutes | Expert Appraisal Committee (CRZ), MoEFCC | 25 January 2019 | The 920 / 520 / ~400 km² breakdown; the project-level CRZ category split; and the river and coastal setting of the SIR. |
| 267th EAC (CRZ) meeting minutes — Phase-II Solar Park in CRZ areas, Dholera SIRExpert Appraisal Committee minutes | Expert Appraisal Committee (CRZ), MoEFCC | 13 July 2021 | Confirmation of the 2019 figures; the date of the Phase-I CRZ clearance; the CRZ-IB intertidal finding; and the paragraphs of the CRZ Notification 2011 relied on for permissibility. |
| Coastal Regulation Zone Notification, 2019 — G.S.R. 37(E)Gazette notification | Ministry of Environment, Forest and Climate Change | 18 January 2019 | The CRZ category definitions (I A, I B, II, III A, III B, IV A, IV B), the No Development Zone distances and the condition attached to them, and the designation of the Gulf of Khambhat as a Critically Vulnerable Coastal Area. |
| 49th meeting minutes, National Coastal Zone Management AuthorityAuthority meeting minutes | NCZMA, MoEFCC | 8 May 2026 | That the Coastal Zone Management Plan for Ahmedabad district — the district containing Dholera — was approved on 23 October 2025, and which Gujarat districts were still pending at May 2026. |
| HTL, LTL and CRZ for the Ahmedabad–Dholera Expressway, GujaratProject-level CRZ demarcation study | National Centre for Sustainable Coastal Management (NCSCM), MoEFCC | Undated in the copy reviewed | That the expressway alignment crosses Bhogawa and Golsar creeks in CRZ; the CRZ categories the route passes through; the creek-width rule for landward CRZ extent; and that cadastral-scale CRZ mapping with survey plot information exists for this corridor. |
| The Gujarat Land Revenue Code, 1879 (Bombay Act No. V of 1879)Act | Government of Gujarat / India Code | As amended | That permission for non-agricultural use of land is sought from the Collector under section 65 — a revenue permission, administered separately from coastal regulation. |
| Non-Agriculture Use PermissionGovernment department page | Revenue Department, Government of Gujarat | Accessed September 2026 | The administrative route for non-agricultural use permission in Gujarat. |
Limitations
What this page does not establish
- The CRZ status of any parcel. Determined by the approved CZMP, which this page has not sourced.
- The contents of the approved CZMP. Its approval date for this district is established — 23 October 2025 — but the maps themselves have not been retrieved, and it is the maps that assign categories to land.
- How CRZ status and NA permission interact. The separate legal bases are identified; their practical interaction is not addressed by any source reviewed, and requires confirmation from the competent revenue authority.
- Whether the 2014, 2019 and 2021 positions still hold in 2026. These are dated records. Notifications are amended and clearances carry conditions; a document from 2014 does not automatically describe the position today.
- Any legal conclusion about a specific proposal. This is a summary of public records, not legal advice.
About this research
Method and disclosure
Figures and quotations on this page were taken from the government documents listed above, each of which was retrieved and read in full. Quotations are verbatim. Where those documents do not answer a question, this page records the gap rather than closing it from general knowledge or secondary coverage.