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We appreciated your government’s acknowledgement of the looming issue of climate change and listened with hope to Mr Javadekar’s public pronouncements of “environmental balance” and “sustainability”. Photo: Mint
We appreciated your government’s acknowledgement of the looming issue of climate change and listened with hope to Mr Javadekar’s public pronouncements of “environmental balance” and “sustainability”. Photo: Mint

An open letter to the Prime Minister

As a group of professionals in ecology and conservation, we are writing this open letter to express our concern regarding the recent reconstitution of the National Board for Wildlife

Dear Mr Prime Minister,

As a group of professionals in ecology and conservation, we are writing this open letter to express our concern regarding the recent reconstitution of the National Board for Wildlife (NBWL). This reconstitution was much needed and was due from September 2013, but the notification S.O. 1886(E) dated 22nd July 2014 has curtailed the strength of NBWL.

Instead of the mandatory 47-member panel, the board only has 11 members (excluding yourself and the Minister in-charge of Forests and Wild Life), a move in clear contravention of the provisions of the Wildlife (Protection) Act, 1972 (WPA; amended 2002). This unconstitutional move has been brought to your notice by a number of conservationists and ecologists (for example, here and here). On 25th August 2014, the Hon’ble Supreme Court of India stayed decisions taken by the NBWL on grounds of inappropriate composition of this body which renders its assessments moot. Recent reports suggest that you intend to reconstitute the NBWL.

In this letter, we provide reason and context for such a move, emphasizing that although the current system of delayed clearances needs to be fast-tracked, no lasting development can be achieved by putting our national heritage at risk.

The Indian Constitution states that it shall be the fundamental duty of every citizen to protect and improve the natural environment, and mandates that the state shall endeavour to safeguard the forests and wildlife of the country. The NBWL plays an important role in executing this mandate, being a statutory body that assesses the environmental impact of projects located within, and in the immediate neighbourhood of Protected Areas (PAs).

Although these lands dedicated towards wildlife conservation comprise a mere 4% of the geographic area of our country, they contribute immensely through the watershed and ecosystem services that are critical for ecological security in many regions of India. The NBWL is envisioned to facilitate a balance between development of our nation and conservation of natural resources, ensuring adherence to legal provisions for wildlife conservation in our country. Its role is critical to maintain the integrity of PAs and the persistence of wildlife species in the face of immense pressure from multiple stressors, including the infrastructural and developmental needs of a burgeoning economy.

In recognition of the importance of making informed and transparent decisions, Section 5(A) of the WPA mandates inclusion of five representatives of NGOs and 10 independent scientists in the NBWL. Yet the current NBWL, as constituted by the Central government, has only two conservation experts. The sole representative of NGOs, the Gujarat Ecological Education and Research Foundation (GEER), was established in 1982 by the Gujarat government and is chaired by the Gujarat chief minister. As such, the ability of this organisation to fulfil a role that is intended to be independent of the government is questionable. Nor does the current NBWL have representation from 10 states and union territories, by rotation, as needed by the law.

It may be argued that this may not be NBWL itself but just its standing committee, but we would like to bring to your notice that the standing committee performs only those duties that may be delegated by the NBLW. It cannot be substituted for the same. We hope, in national interest, you will judiciously appoint a new NBWL with the full mandated representation of independent experts and non-governmental bodies.

There is a good reason for inclusion of as many as 10 independent qualified and reputed experts in ecology and conservation in the NBWL. The interdisciplinary nature of conservation is increasingly recognized. Scientists from different backgrounds can bring to the table a healthy spirit of debate, constructive criticism, and much needed diversity of experience and expertise. The diversity encompasses not just the plethora of ecosystems and the rich variety of species present in our country, but also differing conservation paradigms, local governance contexts, and viewpoints of multiple stakeholders from a pan-Indian perspective. A reduced Board, no matter how experienced or talented, is unlikely to encompass the gamut of this diversity.

For instance, the current board has no representation of scientists or conservationists with expertise in fragile freshwater or grassland ecosystems. Such considerations are critical, given the immediate threats faced by wildlife in these ecosystems as a consequence of the proposed interlinking of rivers or diversion of non-forest lands for commerce. When such expertise is available in our country, with multiple Indian scientists and organisations of international repute, it is a travesty of environmental justice that these experts are not consulted on environmental and conservation policy or decision-making.

A democracy runs on governments responding appropriately to concerns posed by its constituents. The Indian Press, numerous civil society organizations, and citizens have voiced their dissent and criticism of the current NBWL. The government has responded with silence, an arrogance reminiscent of UPA-II. Disregarding objections of the civil society, Mr Javadekar convened two meetings of the new NBWL. The Board reportedly cleared nearly 133 development projects in and around PAs in a marathon assessment of 160 projects during these two meetings, rejecting but a single project! Despite promises of transparency in the process of clearing projects, the ministry is yet to make public the details of these approved projects.

India voted your government with great hope and desire not just for development, but also to improve governance, transparency, and inclusion of diverse voices. You have been lauded for your good governance; this move on the part of your government is hardly an example of the same. On the other hand, it lends credence to some of your critics, worried about upholding corporate interests without paying heed to long-term sustainability, and lack of concern for dissenting voices. We appreciated your government’s acknowledgement of the looming issue of climate change and listened with hope to Mr Javadekar’s public pronouncements of “environmental balance" and “sustainability". These promises need to be supported by action, and so far there is apparent discordance. We hope that when you reconstitute the NBWL, you will prove your dedication towards inclusive progress and sustainable growth of our nation.

On Independence Day, you brought to light 10 aspects of governance and progress you deem important. One of these was a “zero defect and zero effect" industry. We appeal to you to make good your word and enable India to set the global standard for sustainability. We propose the following first steps, with specific regard to the NBWL, to initiate this process.

1. Re-constitute the NBWL in tune with the mandatory provisions of the Wildlife Protection Act, such that it comprises a diverse and appropriate group of independent scientific experts and civil society representatives, who have demonstrated expertise in the field.

2. Make the agendas, minutes of the meetings, project appraisals, and decisions of the NBWL public, and make amenable responses to these decisions by concerned citizens, furthering the transparency of environmental decision-making.

3. Enhance the capacity of the NBWL by making it mandatory for the government to state specific and justifiable reasons for vetoing decisions made by this advisory Board.

As scientists, educators, and administrators working in partnership with various state forest departments across India, we have witnessed the damaging and irreversible consequences of unplanned and unsustainable development. As citizens of modern India, we call for a more current view of development and progress to be incorporated into governmental development planning, such that it encompasses environmental health, ecological justice, and sustainable futures. As participants of a movement to stop corruption, we ask that you bring your mantra of good governance to the sphere of environmental conservation. In doing so, we believe that India can set the highest standard of ecologically sustainable and environmentally friendly progress. As a collective of citizens keen on seeing India take a sustainable path towards progress, we write appealing to you to extend your reputation of efficiency and effectiveness to the field of wildlife and environmental conservation.

Researchers for Wildlife Conservation

Researchers for Wildlife Conservation is a collective of ecologists and conservationists working on diverse aspects of wildlife conservation throughout India.

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