In February 2009, the Ministry of Environment and Forests (MoEF) finally released India's National Biodiversity Action Plan. For all the delay in producing it, one would have expected a thoughtful, even insightful document. But this plan is vague in text, contradictory in intent and worrisome in its agenda. Unfortunately, despite these shortcomings, it will form the basis of policies and plans for biodiversity use in the years to come.

Revisting the facts

In August 2004, I wrote in India Together about the stalemate between the MoEF and the Technical and Policy Core Group (TPCG) that had spent four tedious years putting together the draft National Biodiversity Strategy and Action Plan (NBSAP) for India (see here). The tussle was unfortunate but predictable. The draft NBSAP came up at a time when MoEF was busy fitting its agenda to India's economic development priorities. Along this trajectory of putting the economy first, MoEF had initiated a new National Environment Policy (NEP), changes to th Environment Impact Assessment notification process, as also as new Coastal Regulation Zone notifications. All these documents, notwithstanding their very environmental sounding names, were clearly against the grain of environmental stewardship which is the ministry's raison-d'etre.

The process of creating the NBSAP was initiated in 2000, in response to India's commitment to the Convention on Biological Diversity (CBD). This process of planning had invovled thousands of actors, used diverse methodologies and presented a transparent mechanism to work towards a plan that could bring forth a critical roap map for biodiversity conservation in the country. It was internationally recognised, even by the MoEF whose officials who were happy to own the process and were coordinating in unison with the technical coordinating team at Kalpavriksh, an NGO based in Delhi and Pune as well as the 15 member TPCG (Full disclosure: I am a member of Kalpavriksh).

But as was determined by the Government of India's priorities, the draft NBSAP was first reduced to a 'technical report'. The MoEF and TPCG had agreed to this compromise during the final meeting of the NBSAP Steering Committee in January 2004. But then the MoEF decided that even this dilution was not enough to block some very critical and forward looking strategies and actions proposed by the Plan. At this stage, the report underwent its second demotion - to a 'consultancy report' - by the then Secretary of the ministry, Pradipto Ghosh.

Also, in response to a question in the Lok Sabha in December 2004, when indirect pressure was put on the MoEF to explain why the report was not acceptable to the ministry, MoEF called the report "scientifically inaccurate". Activists had resorted to questioning the MoEF through the Lok Sabha, as there was simply no formal word from MoEF on what it proposed to do (or not) with the report submitted by the TPCG. Nor was MoEF's lack of interest in the TPCG's report unique - 71 other plans that had been prepared as part of one of India's largest planning exercises were similarly languishing without attention; these included several state, ecoregional, substate site and thematic level plans.

The draft NBSAP was first reduced to a 'technical report' and underwent a second demotion to a 'consultancy report'.

 •  Read the fine print
 •  Twists in a tale of planning

In 2005 the TPCG decided not to wait any further for the MoEF's wheels to move, and instead released the draft plan document as a people's plan. It took MoEF another 2 years to release a formal draft NBAP, which happened in August 2007. This was put up on the ministry's web site (upon request), seeking public comments.

Problems of intent

And now, another year and a half after the draft plan was put on its web site, the MoEF has finalised the NBAP and released it to the public. The earlier NBSAP planning process - which MoEF had spoken about extensively in international circles - now finds a one line mention. In 2001, India's Second Report to the CBD had stated,

"NBSAP is India`s biggest planning and development process aiming at conservation and sustainable use of Biological Diversity. A decentralized approach has been adopted for developing the NBSAP. Under NBSAP, about 20 local micro-planning process at village to district levels, 33 State and Union Territory level processes, 10 planning exercises at ecological regions cutting across States, are engaged in collecting a variety of area specific information and perspectives. In addition, national working groups are preparing action plans on 14 themes. About 75 Executing Agencies at various levels across the length and bredth of the country are involved in the preparation of NBSAP."

In the end, all this turned out to be fluff; the final MoEF NBAP has two authors - Dr. Sujata Arora and Dr. J R Bhatt, both MoEF officials.

But other than undermining its own history and the effort of thousands of people, NBAP is problematic in its content too. A critique from Anand C Shekhar, who works with the Bombay Natural History Society (BNHS) States that the "NBAP has devoted space to bird conservation including special references to Great Indian Bustards and vultures ... However, no mention has been made of the Important Bird Areas (IBA) programme that was incorporated in the earlier NBSAP final technical report 2005. "

His critique also highlights "The NBAP is also guilty of being unscientific, an allegation used to justify the non-incorporation of the NBSAP final technical report 2005. For example, in the section dealing with the decline in vultures in India, no mention has been made of the drug Diclofenac which has been scientifically proven to be the single major cause of the vulture population crash. Ironically the MoEF-endorsed 'Action Plan for Vulture Conservation in India' clearly states that Diclofenac is responsible for vulture declines and that phasing out of veterinary Diclofenac is a top priority ."

The NBAP includes 140 'actions', clubbed under various heads and sub heads like 'conservation of biodiversity in the wild', 'augmentation and sustainable use of bio-resources', 'managing alien species', 'dealing with climate change', and so on. But the headings do not lead us to concrete ways forward. Most of them include material only in the nature of recommendations and have identified corresponding government agencies (in an annexure) to take these forward. There is also no looking into where the gaps lie, which really need to form the link between initiatives and actions. Critically, efforts of communities, scientists, researchers, conservation and livelihood organisations - which were all a strong part of the NBASP report - miss a mention in this official version.

Several of the new strategies and actions added are questionable - such as the emphasis on valuation of goods and services provided by biodiversity, and the use of economic instruments in making decisions that impact biodiversity. This line of thought stands towering over the spiritual, cultural and intrinsic associations that we need to view the diversity of life forms with. Another stance that raises eyebrows is the view that those who can pay more for the use of biodiversity resources can use more of them; such a premise in a policy document is alarming, and does not bode well for the protection of biodiversity in the future.

Very disturbingly, the NBAP in several places also justifies the use of biotechnology, which promotes monoculture and stands in complete contradiction to the variety of life forms the term 'biodiveristy' encompasses within itself. In the same breath, the NBAP opines that is it important to "ensure that survey and bio-prospecting of native economically important biological resources is undertaken on a priority basis. " In classical parlance the word bio-prospecting is embedded in the language of access for the purpose of trade, which is what the MoEF has in store for India's biodiversity.