In early 2016, a 12-member committee of the Ministry of Environment, Forests and Climate Change (MoEFCC) drafted the National Wildlife Action Plan, consisting of 17 provisions and slated to go into effect from 2017 to 2031. This draft was open for comments and suggestions, and after reviewing the comments by several experts, a detailed analysis of the gaps and omissions in the key areas have been delineated below.
 
 I. Strengthening and Improving the Protected Area Network

The action plan should clearly define the definition of “Protected Area Networks” (PAN) in India based on various parameters. The ministry’s definition of a protected area is vague: any area that is considered by the central government or state government to be important for conservation is designated a status under the Wild Life (Protection) Act, 1972 and is then legally considered a protected area. The plan should clearly define “what constitutes a protected area in India” as it will help to understand on how the ministry arrived at the number of the 726 protected areas (PAs) from 400 PAs in the beginning of the previous plan. In essence, “definition clarity based on parametric evaluation” will help the central government track the progress and efforts of various states for increasing the number of PAs in comparison to the previous plan.

There is a need to look beyond PAs because in different Indian states, a portion of wildlife dwells and ventures beyond the protected areas and consequently are falling prey to local people and poachers. The draft fails to address this issue and the ministry should undertake measures that would protect the wildlife outside the range of protected area networks (PANs).

The plan also seeks to “enhance the PA network by including terrestrial, inland water and coastal/marine areas of high conservation values and by integrating PAs into wider landscapes and seascapes as per the Target 11 of the NBAP” but no heed has been paid to include grasslands under PANs. Data highlight that less than one per cent of grasslands come under the protected area network, making it one of the most neglected and abused ecosystems in the country. This issue should have been considered in this report as some of the most threatened and rare species of wildlife reside in the grasslands, such as the Bengal Florican, the Great Indian Bustard, one-horned rhinoceros, wild buffalo, swamp deer, the Lesser Florican and the Nilgiri Tahr.

II. Landscape Level Approach for Wildlife Conservation

As pointed out in the previous provision, even though the plan claims to have a landscape approach, it doesn’t recognize wildlife living beyond forest boundaries. Ecologists point out that various animal and bird species live in areas beyond forest boundaries, including grasslands. In this plan, there is no mention about how to protect and conserve the population of this wildlife.

This provision aims to “identify critical areas outside protected areas for wildlife conservation and initiate projects” but excludes the basis upon which these critical areas will be defined. This action point needs more clarification.

Another action point under this provision acknowledges the damage caused by feral and free-ranging animals around wildlife habitats. Strategies for this issue, particularly towards the free-ranging, domestic animals, carry tones of the ministry wanting to cull every free ranging dog or cat. This is neither possible nor desirable as people might take unfair advantage of this provision. It is possible to reduce free-ranging behaviour (by reducing population densities) for which sterilization camps can be made operation for a long-term to achieve sustainable benefits.

III. Rehabilitation of Threatened Species
 

This provision talks about threats to various species of flora and fauna due to overexploitation, habitat degradation and loss without explanation of strategies on protection from these threats.
 
 An action point under this provision talks about identification of endangered and critically endangered species of flora and fauna in the upcoming years, but various ecologists already know where the problem lies (species are already identified) and have pointed out that this draft could have taken the biologists” points into consideration before suggesting further mapping activities, seen by some as an excuse for further delaying action.
 
 There is no action point under this provision to prevent the entry of more foreign species in our country’s existing range of flora and fauna. Experts argue that this issue needs serious attention as many foreign species of fish and animals have entered India, which, if left unchecked, would pose serious risk to our native species.
 
 IV. Conservation of Inland Aquatic Ecosystems and Conservation of Coastal and Marine Ecosystems
 
 Many experts have pointed out that provisions under this section only talk about the protection/conservation of wetlands while ignoring rivers and river stretches. It must be noted that rivers inhibit an entire ecosystem (such as Gangetic dolphins, gharials, fishes, turtles, and Indian Skimmers) within itself and play an unparalleled role in wildlife conservation. But in India, rivers are perhaps the ecosystems in the most degraded state. Rivers that flow through various cities in India hardly have any fresh-water and are mainly filled with untreated, polluted water discharged from factories and sewer drainage systems. This plan needs a clear mandate on river protection and conservation of inland aquatic ecosystems.
 
 VI. Integrating Climate Change in Wildlife Planning
 
 This provision highlights the importance of adaptation to climate change and disaster risk reduction, and has vaguely described the technologies and process to do so. Since climate change adaptation technologies are mostly available in developed nations, it raises question on the financial feasibility of such intervention for a developing country like India.
 
 VII. Control of Poaching and Illegal Trade in Wildlife
 
 This provision could have mentioned the role of tribal people, other communities dwelling around the PANs, and NGOs to report crimes related to illegal animal poaching and trade. Awareness of the necessity for protecting wildlife could be spread among local communities, which would help track culprits and help mitigate hunting and poaching of endangered species of wildlife.
 
 VIII. Wildlife Health
 
 This provision should deliberate more on the cause of wildlife diseases and their prevention.
 
 IX. Mitigation of Human-Wildlife Conflicts
 
 This provision could have suggested upon the introduction of community-based insurance systems for crop damage caused by human-animal conflict. Also, the ministry could have promoted the concept of Payment of Environmental Services (PES), which is seen as a solution to reduce human-animal conflict.
 
 One of the action points under this provision states, “ensuring that Environmental Impact Assessment (EIA) of developmental projects takes into consideration potential wildlife-human conflict spin-offs that large landscape level land-use practices or alterations can cause.” Rather than just taking this action point into consideration, execution of this provision should be made mandatory for projects to get EIA clearance.