Draft of India’s upcoming National Wildlife Action Plan (NWAP) has been put in open domain for comments. A perusal of this Draft indicates that although it is a detailed document, it has nothing to offer for our Rivers, which receive next to no protection, despite them supporting rich freshwater biodiversity, as well as livelihoods of millions. We hope the Final NWAP addresses this critical lacuna. If you agree, please do send in your comments to firstname.lastname@example.org. Last date for comments is over ( 17th February 2016), but it may still be a good idea to push for this issue. ( Access draft here: http://envfor.nic.in/sites/default/files/NWAP%20-COMMENTS_0.pdf)
SANDRP’s submission on Draft NWAP, sent to GOI:
Mr. S.P. Vashishth,
Deputy Inspector General of Forests (WL)
Ministry of Environment, Forests and Climate Change,
Subject: Comments of the Draft National Wildlife Action Plan (2017-2031)
It is good to see that the MoEFC and CC has worked on a Draft National Wildlife Action Plan (NWAP) (2017-2031) which comes after the NWAP (2002-2016) and has put it out for comments. A brief perusal of the Draft NWAP suggests that it is detailed and has outlined various themes and under each themes: Action Required, Priority Projects, Timeline and responsibilities for a number of themes, which is commendable.
Following are our comments on the Draft National Action Plan (2017-2031). We hope the submission is acknowledged and we are informed about how the suggestions have been considered. We are willing to discuss the points mentioned below in person before the drafting committee for further consideration.
- The Document starts with the first thematic area of work (Strengthening PA Network), without going into Preamble, Policy Imperatives and Strategy of Action, which have been mentioned in the Contents. Sections like “Policy Imperatives” are essential in the Draft as they provide grounding of the NWAP, its scope, its strength, its implementability and enforcement. We hope that these sections are included and there is a brief round of comments again.
- Review of NWAP (2002-2016): One of the critical parts of the Plan was the review of the last NWAP (2002-2016), its successes and failures and lessons learnt. It would have been worthwhile to include the entire review in an Annex. However, there is very little discussion around the performance of the past plan. (Limited to Page 70 and 79)
The past NWAP had some important suggestions like: Section II: Effective management of Protected Areas: Action Required: Restoration and enhancement of water sources to be done in all terrestrial PAs. Listing of streams and rivers in these terrestrial PAs, with estimates of flow and seasonal duration must also be done.
It will be important to take stock of the status of suggestions like these.
- Overarching suggestion:
No focus on Riverine Systems: Bastions of endangered wildlife and invaluable Ecosystem Goods and Services
The NWAP opens with reassuring statements. It does not seek to protect wildlife in isolation. It clearly states that ecosystems are “our Life support systems” and they provide “support to millions of rural communities.”
It further states: “National planning has not taken serious note of adverse ecological consequences of reduction and degradation of wilderness areas from the pressures of population, commercialization and development projects. Accordingly, the plan has brought to focus the alarming erosion of our natural heritage comprising of rivers, forests, grasslands, mountains, wetlands, coastal and marine habitats arid lands and deserts “
“The plan is alive to communities, inhabiting forest lands and other wilderness areas, to be treated appropriately in the light of Forest Rights Act and their inadequacy of resources and strong dependence on natural biomass resource.”
This provides a grounded and nuanced background for discussing conservation and wildlife issues.
While we were happy to see that the NWAP (2017-2031) has dedicated an entire chapter to Conservation of Inland Aquatic Ecosystems (Chapter IV), we are disappointed to see that the Plan deals with Wetlands, framed in a way which excludes rivers. The Further Chapter (Chapter V: Conservation of Coastal and Marine Ecosystems) deals a bit with Mangroves and estuaries, but no where has the plan dealt with river systems or even river stretches.
In the Draft NWAP, there is no focus on the status of Rivers, their unparalleled role in Wildlife conservation, their contribution to livelihood security of millions and the daunting challenges they face today. As a result, the Action Plan has next to no specific recommendations which can help rivers. This is a huge lacuna in the Draft NWAP. We urge the drafting committee to address it holistically.
The Draft Plan specifically mentions endangered aquatic species like Mahseer, Gangetic Dolphins and species which are partly dependent on riverine systems and floodplains like Wild Buffalo, Bengal Florican, etc., but does not discuss the important role of rivers and floodplains in providing habitat to these species. Most of the discussions are around mudflats in the drawdown of lakes and reservoirs and not extensive river floodplains.
In this context, we request the Drafting Committee to consider the following issues:
- India is a mega-diverse country with respect to freshwater fish species (650+ species) (Molur and Walker 1998). With respect to freshwater fish diversity, India is eight in the world (Kottelat and Whitten 1996).
- No other major component of global biodiversity is declining so fast and massively as freshwater species and ecosystems. In the 30 years between 1970 and 2000, populations of more than 300 selected freshwater species declined by ~55% while those of terrestrial and marine systems each declined by ~32%.However, given our limited understanding and knowledge of freshwater ecosystems, this decrease is supposed to be massively underestimated.
- India is losing its aquatic biodiversity, endangered species dependant on rivers and riverine habitats at an alarming rate due to hundreds of hydroelectric, multipurpose and Irrigation projects being built on its rivers
- The past NWPA, the WLPA (1972) or its subsequent amendments lay no specific emphasis on protecting freshwater habitats, especially rivers for protecting freshwater organisms. India has only a few riverine Protected Areas, which too are under increasing stress, like National Chambal Sanctuary and Ken Ghariyal Sanctuary (due to the proposed Ken Betwa Link Project).
Critically Endangered Gharial (Gavialis gangeticus) in National Chambal Sanctuary ( Photo from: nationalchambalsanctuary.in)
- Except these, Rivers are only protected under the WLPA (1972) for parts that flow through other protected areas. This has resulted in fragmented, polluted rivers, severely affecting aquatic biodiversity and wildlife that depends on the rivers and associated habitats (like sand banks, riparian areas or mangroves). The case of river dolphin declines in Sunderbans, and also decline of species like Sawfish (Pristis sp.) are documented in this regard.
- Only clause for protection of rivers flowing through sanctuaries stated in the WLPA amendment Act (2002) gives powers only to the Chief Wildlife Warden to sanction modification of water flow into or outside the Protected area
- Large Hydropower projects and dams are being proposed, affecting river flow through protected areas. (Examples: Siang Valley Projects affecting D’Erring Sanctuary and Dibru Saikhowa National Park, Lohit Valley Projects affecting Dibru Saikhowa National Park, etc.,)
- Cases are referred for discussion to the National Board for Wildlife only if the project is within 10 kms radius of the protected area. However, hydropower/ irrigation/drinking water supply projects which are more than 10 kms away from a protected area also have a deleterious impact on the PA if flows are changed drastically. A landscape-level approach in looking at the ecological interconnections of freshwater systems is strongly advocated in such cases.
- Schedule of Species annexed to the WLPA (1972) or its subsequent amendments, does not provide sufficient attention to several freshwater organisms, including some fish. We would suggest that a thorough research project be undertaken with the help of organizations like WII, ZOO and MCBT to identify freshwater species across multiple taxa that need priority protection in the schedules, and the schedules to be then amended based on these reviews and surveys.
India is a signatory to Convention on Biological Diversity and Freshwater biodiversity has been one of CBD’s overriding conservation priority. International Decade for Action – ‘Water for Life’ – has just been concluded in 2015. However, although the International definition of “Inland Waters” (as in Ramsar Convention and CBD) prominently includes Rivers in its ambit, India has conveniently neglected any focus on rivers. Our reporting to CBD through Ramsar Convention also excludes Rivers as we have shockingly excluded Rivers in our definition of Wetlands, as is clear from the Wetland Rules (2010).
This is reflected in the NWAP (2017-2031) too. Although it talks at length about lacustrine and palustrine wetlands, it does not mention rivers and the daunting challenges they face. Nor does it mention the need to increase the ambit of protection of rivers systems outside the PA network.
However, in keeping with protection of endangered wildlife and India’s position as a signatory of various international conventions like Ramsar Convention, CBD Program on Inland Waters Diversity, decisions taken in COP 10, COP 7, COP 4, Aichi Protocol on Biodiversity and Akwe Kon Voluntary guidelines for the conduct of cultural, environmental and social impact assessments regarding developments impacting on, sacred sites and on lands and waters traditionally occupied by indigenous and local communities, we urge the NWPA to include a dedicated Chapter and Action Plan to further River Protection in the country.
Due to their importance to communities, a number of conservation and community reserves are being proposed by the communities and local agencies along rivers like reserves protecting parts of Kali, Aghanashini, Tungabhadra Rivers in Karnataka.
In this context, what does the new NWAP have to offer for rivers? How does it aim to strengthen the protection of riverine systems for wildlife and communities? Sadly the Draft NWAP has no answers to these questions.
Work on drafting the upcoming NWAP is an excellent opportunity to address these issues and it should not be missed. Indeed, the Draft NWAP is incomplete without the inclusion of rivers.
We therefore urge that the NWAP (2017-2034) have a separate section on rivers and freshwater biodiversity, with measures to protect it.
We would be happy to help in this task in any way we can.
Looking forward to your response.
Thanks and Regards,
Parineeta Dandekar, South Asia Network on Dams, Rivers and People.
Parts of Submission by Nachiket Kelkar, raising strong concerns about the exclusion of Rivers and Fisheries from the ambit of Draft NWAP.
Nachiket is a wildlife researcher studying freshwater and marine ecosystems and conservation issues over the last 8 years. (email@example.com)
The Draft National Wildlife Action Plan (NWAP 2017-2031) is a well-intentioned attempt to address together multiple issues that threaten the wildlife, ecology and ecosystems of India. There are some welcome changes in the NWAP, as seen in its proposals to involve scientific researchers and NGOs in meeting priority objectives in a timely manner, its inclusion of some new issues such as wildlife health, invasive species, and internationally compliant regulations to wildlife policies in the country. Though fairly spread out in its breadth, the NWAP has some major shortcomings.
The proposed focus of the NWAP still remains strongly terrestrial and forest-based, and requires greater inclusion of issues facing neglected ecological systems such as grasslands, scrub forests, rivers, wetlands, and oceanic/coastal systems.
Chapter 4. Conservation of Inland Aquatic Ecosystems
1. Although it recognizes the need to increase the conservation of freshwater ecosystems which are highly threatened, there are serious shortcomings with this Chapter. First, it considers only wetlands worth protecting, and not rivers! It includes multiple confusing terms that keep making a reference to riverine ecology, but clearly stops short on the idea of conferring protection regimes on actively flowing river channels. At present, rivers are perhaps the ecosystems that are in the most degraded state in the 4 country. Flows are highly altered and poor, there is no water in many rivers, and where there is water it is extremely polluted and unfit for direct use. Yet the plan clearly steps out of any mandate on river protection.
2. It is quite obvious to me why rivers have not received any attention in the NWAP. This is because the current Indian government is set to completely destroy the rivers that remain somewhat alive in India, through its dangerous and unhinged proposals for developing inland waterways by constructing locks all along rivers such as the Ganga and building river-links. The NWAP seems to have conveniently realized that if rivers are protected under the new priority to include more wetlands under PAs, the Plan will conflict with these big but ecologically dangerous projects being planned. An effort is much needed to include many rivers under active protection regimes in the NWAP.
3. The maintenance of ecological flows does not even find a single mention in the plans to conserve freshwater ecosystems. The National Water Policy makes mention of the need to maintain ecological flows in all rivers for supporting populations of wildlife such as Gangetic dolphins, gharials, fishes, turtles, and Indian Skimmers. But no such priorities are stated in the NWAP: this reeks of great ignorance about the imperilment of freshwater ecosystems today.
4. This objective, yet again, prioritizes wetland protection for terrestrial species. Species such as the Gangetic Dolphin and gharial critically need water to survive. The Chambal River alone does not have Gangetic Dolphins, but rather, these dolphins occur throughout the Ganga River and almost all the north-south flowing tributaries of the Ganga.
5. Fishing by local people is downright treated as illegal. This is a blanket statement which stands to some deliberation and scrutiny. The same point mentions that fishing is an important livelihood need. I would add that fishing is not only important, but for millions of people, it is the ONLY livelihood option. If fishing is treated as illegal without context, there might be serious conflicts and injustices to people that might follow. At the same time, fishing is also a fairly serious threat to wildlife in rivers and wetlands both. I recommend that having regulations in place for a more sensitive and locally involved form of fisheries management needs to be a priority of this Chapter.
 29: No person shall destroy, exploit or remove any wild life including forest produce from a
sanctuary or destroy or damage or divert the habitat of any wild animal by any act whatsoever or divert,
stop or enhance the flow of water into or outside the sanctuary, except under and in accordance with a
permit granted by the Chief Wild Life Warden, and no such permit shall be granted unless the State
Government being satisfied in consultation with the Board that such removal of wild life from the
sanctuary or the change in the flow of water into or outside the sanctuary is necessary for the
improvement and better management of wild life therein, authorises the issue of such permit
 Inland waters include lakes, rivers, ponds, streams, groundwater, springs, cave waters, floodplains, as well as bogs, marshes and swamps, which are traditionally grouped as inland wetlands. From: https://www.cbd.int/waters/inland-waters/default.shtml