ENVIRONMENTAL AUDITING

Background

Biodiversity may be broadly thought of as the variability among all living organisms existing on earth in various ecosystems and ecological complexes of which they are a part and includes diversity within species or between species and of ecosystems. This diversity is the basis of continuous evolution of life forms and in turn maintains the life-sustaining systems of the biosphere. Biodiversity is vital for the survival of this planet and for the continuation of evolutionary process. Biodiversity has direct consumptive value in food, agriculture, medicine and industry. The conservation of biodiversity and sustainable use of bio-resources is a common concern at the national as well as the international level and it is vital to anticipate, prevent and tackle the causes of loss or reduction of biological resources which includes plants, animals and micro-organisms or parts thereof, their genetic material and by-products with actual or potential use or value. A sustainable use of the components of bio-diversity in such a manner and at such a rate that does not lead to the long-term decline of biological diversity will help maintain its potential to meet the needs and aspirations of present and future generations. In this context bio-survey and bio-utilization means of survey or collection of species, subspecies, genes, components and extracts of biological resources, characterization, inventorisation activities are important aspects of bio-conservation measures.

This paper presents a case study of an audit undertaken recently by the Supreme Audit Institution of India. The audit focused attention on the issues of plant genetic resources conservation, bio-survey and agro biodiversity activities of a premier national research and scientific institute in India. The audit report was tabled in the Parliament of India in July 2004.

INTRODUCTION

 

India is one of the 12 mega biodiversity countries of the world. India has a rich and varied heritage of biodiversity covering ten bio geographical zones-the trans Himalayan, the Himalayan, the Indian desert, the semi-arid zones, the Western Ghats, the Deccan Peninsula, the Gangetic Plain, North-east India and the islands and coasts. India is well endowed at the three levels of biodiversity-the genes, the species and the ecosystem and accounts for 7-8% of the recorded species of the world with only 2.4 % of the global land area. Over 47,000 species of plants and 89,000 species of animals have been inventoried and two regions in India- the Western Ghats and the Eastern Himalayan region are included amongst the 25 global biodiversity hotspots of the world. This biological diversity is reflected in the cultural diversity of the people whose existence is tied to the continued maintenance and sustainable use of biological resources. India has a rich ethos of biological conservation and traditional knowledge systems and these practices have given rise to informal and localized in situ conservation. Traditional farming practices are directly responsible for the country's treasure trove of agro-diversity. This respect for nature continues to date, and the government has institutionalized biodiversity conservation by undertaking several activities for its conservation and sustainable use.

 

Article 48-A and Article 51-A (G) of the Directive Principles of State Policy in the Constitution of India emphasizes that "the State shall endeavour to protect and improve the environment and to safeguard the forests and wildlife in the country, and to protect and improve the national environment including the forests, lakes, rivers and wildlife and to have compassion for the living creatures." A focused articulation of these concerns in programmes and policies was intensified after the 1992 Rio Summit and India's becoming a party to the Convention on Biological Diversity (CBD). The CBD had three main thrust areas: conservation of biodiversity, sustainable use of biological resources and equitable sharing of benefits arising from its sustainable use. The CBD offered opportunities to realize benefits from biological resources and associated traditional knowledge. The contracting parties to the CBD were, therefore required to integrate considerations of conservation and sustainable use of biological diversity into relevant sectoral or cross-sectoral plans, programmes and policies. To translate the objectives of CBD, each country is required to bring in suitable legislation to facilitate in-situ and ex-situ conservation, sustainable use, research and training, awareness and education impact assessment, regulating access to genetic resources and transfer of technology.

 

In India, our policy makers felt that three broad activity areas could help achieve realizing the broad vision of biodiversity conservation and its sustainable use: -

 

Management issues dealing with the development of national level institutions, strategies, legislation, policies, plans and programmes for the conservation and sustainable use of biological diversity; measures to encourage a greater understanding and appreciation of the value of biological diversity; and environmental impact assessments;

Data and information needs, that is research, data collection, inventories and the networking and sharing of information through various means, and

International and regional cooperation and coordination for strengthening communication, technical and scientific collaboration and promoting co-operation between parties to relevant conventions.

 

The means of implementation for the above activities focus on financing mechanisms, scientific and technological means, human resource development, capacity building and partnerships with the local community.

 

LEGISLATION RELATED TO BIODIVERSITY

 

The Biological Diversity Act (BDA) was formulated after India became signatory to the CBD. The Biodiversity Act is an important mechanism for regulating access to biological resources and in establishing benefit-sharing arrangements. It was passed by the Parliament of India in December 2002 after a process of consultation among stakeholders. The Act received assent of the President of India on 5th February 2003. The legislation primarily addresses the issue concerning access to genetic resources and associated knowledge by individuals, institutions or companies, and equitable sharing of benefits arising out of the use of these resources and knowledge to the country and the people. The salient provision of the Act for regulation of access to biological diversity, its conservation and sustainable use are: -

Conservation and sustainable use of biological diversity;

Conservation and development of areas important from the standpoint of biological diversity by declaring them as biological diversity heritage sites;

Protection and rehabilitation of threatened species;

To respect and protect knowledge of local communities related to bio diversity;

Regulation of access to biological resources of the country with the purpose of securing equitable share in benefits arising out of biological resources and associated knowledge relating to biological resources;

To secure sharing of benefits with local people as conservers of biological resources and holders of knowledge and information relating to the use of biological resources;

Involvement of institutions of self-government in the broad scheme of the implementation of the Act through constitution of committees; and

Development of national strategies, plans, programmes for the objectives of the Act including measures for the identification and monitoring of areas rich in biodiversity, promotion of in situ and ex situ conservation and incentives for research and training.

 

3. INSTITUTIONAL MECHANISMS UNDER THE BIOLOGICAL DIVERSITY ACT

 

The legislation provides for setting up of a three-tiered structure at national, state and local level:-

the National Biodiversity Authority (NBA) which deals with matters relating to requests for access by foreign individuals, institutions or companies, and all matters relating to transfer of results of research to any foreigner; imposition of terms and conditions to secure equitable sharing of benefits and approval for seeking any form of Intellectual Property Rights (IPRs) in or outside India for an invention based on research or information pertaining to a biological resource obtained from India.

the State Biodiversity Boards (SBB) to deal with matters relating to access by Indians for commercial purposes and restricts any activity that violates the objectives of conservation, sustainable use and equitable sharing of benefits.

The Biodiversity Management Committees (BMC) at the local level to be set up by institutions of self-government in their respective areas for conservation, sustainable use, documentation of biodiversity and chronicling of knowledge relating to biodiversity. Biodiversity Management Committees are to be consulted by the National Biodiversity Authority and State Biodiversity Boards on matters related to use of biological resources and associated knowledge within their jurisdiction.

 

All foreign national/organizations require prior approval of the NBA for obtaining biological resources and/or associated knowledge for any use. Indian individuals/entities require approval of the NBA for transferring results of research with respect to any biological resources to foreign nationals/ organizations. Indian citizens and organizations are required to give prior intimation to the concerned SBB about obtaining any biological resource for commercial use, and the SBB may prohibit or restrict the activity if found to violate the objectives of conservation, sustainable use and benefit-sharing.

 

Another function of the NBA is to take measures to oppose the grant of IPRs in any country outside India on any biological resource obtained from India or knowledge associated with such a biological resource. For ensuring equitable sharing of benefits arising from the use of biological resources and associated knowledge, the Biodiversity Act, stipulate prior approval of the National Biodiversity Authority (NBA) before their access. While granting approval, NBA will impose terms and conditions that secure equitable sharing of benefits. Local people and communities of the area will have free access to use biological resources within the country. Issues relating to protecting, recognizing and rewarding traditional knowledge (TK) associated with biological resources are very complex. The modalities of protecting TK are still emerging and evolving. The nature of entitlements and share in benefits is also a grey area. Realizing the need to ensure that the holders of TK which is not still in the public domain should be able to get the benefits arising from the use of such knowledge, an enabling provision has been made for protecting the TK in the Biodiversity Act. The Act provides for protection of knowledge of local people relating to biodiversity through measures such as registration of such knowledge, and development of a sui generis system. While granting approvals for access, NBA will impose terms and conditions so as to secure equitable sharing of benefits. These benefits inter alia include:-

 

Grant of joint ownership of intellectual property rights to the National Biodiversity Authority, or where benefit claimers are identified, to such benefit claimers;

Transfer of technology;

Location of production, units in such areas;

Association of Indian scientists, benefit claimers and the local people with research and development in biological resources and bio-survey and bio-utilization;

Setting up of a venture capital fund; and

Payment of monetary compensation and other non-monetary benefits to the benefit claimers as the National Biodiversity Authority may deem fit.

 

The legislation provides for setting up of biodiversity funds at central, state and local levels. Benefits are to be given directly to individuals or group of individuals only in cases where biological resources or knowledge are accessed directly from them. In all other cases, monetary benefits will be deposited in the Biodiversity Fund which in turn will be used for the conservation and development of biological resources and socio-economic development of areas from where resources have been accessed.

 

4. NATIONAL POLICY AND MACRO LEVEL ACTION STRATEGY ON      BIODIVERSITY

 

India has also prepared a National Policy and Macro Level Action Strategy on Biodiversity through an extensive consultative process. This document is a macro level statement of policies, gaps and further actions needed for conservation and sustainable use of biological diversity. The main goals of the National Policy and Macro Level Action Strategy on Biodiversity are: -

Achieving conservation and sustainable use of biological diversity through consolidation of ongoing efforts and initiating new steps;

Securing participation of State Governments, communities, people, NGOs, industry and other stakeholders including women in the conservation and sustainable use of components of biodiversity;

Realizing consumptive and non consumptive value of biodiversity through necessary investments in R&D and biotechnology development;

Ensure benefits to India as country of origin of biological resources and to local communities and people as conservers of biodiversity, creators and holders of indigenous knowledge systems, innovations and practices; and

Ensure consideration of biodiversity concerns in other sectoral policies and programmes.

 

5. NATIONAL BIODIVERSITY STRATEGY AND ACTION PLAN

 

 In a major advancement for the cause of biodiversity conservation in the country and in compliance with requirements of the Convention on Biological Diversity, the National Biodiversity Strategy and Action Plan is being drafted with funding support from the Global Environmental Facility. The strategy and action plan are very broad in scope and comprehensive in coverage and detailed action plans are proposed at sub-state, state, regional and national levels based on the framework Policy and Action Strategy on Biodiversity. 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 the 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. The process is participatory, tapping into the knowledge of diverse stakeholders and incorporating a variety of strategies for its development such as workshops and public meetings, consultations, expert inputs, etc. The expected outcome of the NBSAP project is an implementable and realistic action plan, which can be easily translated into a number of projects at ground level in areas of priority that would contribute significantly towards conservation and sustainable use of biodiversity in the country.

 

AUDIT CASE STUDY- THE AUDIT OF NATIONAL BUREAU OF PLANT GENETIC RESOURCES

The Auditee

 

The National Bureau of Plant Genetic Resources (NBPGR), New Delhi, a constituent unit of the Indian Council of Agricultural Research (ICAR) was established in 1976, with the mandate of collection, introduction, evaluation, conservation, documentation and pest free exchange of Plant Genetic Resources (PGR). It is one of the earmarked scientific institutes in India for carrying out ex-situ conservation efforts related to plant and agro-biodiversity resources. The responsibility of carrying out quarantine tests to ensure that imported plant germplasm samples as well as germplasm samples to be exported are free from diseases and pests, rests with NBPGR. It also seeks to develop human resources for efficient management of PGR at the national level. NBPGR has four divisions, three units, eight regional stations, two base centres and a satellite station located at various places in India, besides an experimental farm and National Research Centre on Deoxyribonucleic Acid Fingerprinting at New Delhi. It also houses the headquarters of the All India Coordinated Research Project on Under-utilised Crops.

 

Rationale for selection of the audit

 

Article 9 of the Convention on Biological Diversity and Section 36(1) of the Biological Diversity Act 2002 of India emphasizes on the importance of ex situ conservation. Ex situ conservation efforts in India have been institutionalized in a number of ways. One of the important measures is the effort being made in a number of specialized scientific institutes set up in India. The National Bureau of Plant Genetic Resources is one such important constituent institute and houses the Indian Gene Bank for collection of indigenous germplasm, seeds, propagules, safe-keeping duplicate germplasm of other organizations and for carrying out distributions and exchange of material. The Gene Bank is a national facility available in this institute. Preliminary studies indicated that the gene bank has a repository holding of more than 150,000 accessions, a tissue culture repository of more than 800 accessions and more than 1000 samples cryo preserved in liquid nitrogen and various projects related to agro-biodiversity. Plant germplasm is the backbone of agricultural research and protection of agro-biodiversity. In the context of the large geographical area of the country and its rich biological diversity in different bio-geographic zones, it was thus felt that ex situ conservation efforts should be examined in-depth. Besides NBPGR is the authorized agency in India for import as well as export of plant material and germplasms for research projects. The audit was therefore undertaken to assess the adequacy of efforts in collecting and preserving the genetic resources in ex situ conditions and degree of attention paid for conservation of traditional varieties and breeds which provide valuable pool of genetic resources.

 

Scope of audit

 

NBPGR is audited under section 20(1) of the Comptroller and Auditor General of India’s (Duties, Powers and Conditions of Service) Act, 1971. The audit, covering the period from 1997-98 to 2002-03, focused on issues related to management of plant genetic resources by NBPGR, apart from financial and other aspects. A feasibility study was carried out in the period April–May 2002. The first stage of audit was carried out during the period July-October 2002. Based on discussions with the auditees and their responses, the audit study was further updated by more field visits, study and scrutiny of additional records and analysis to bring in completeness of examination. The findings were updated till November 2003 and brought out for print in the Audit report after collating all the relevant facts and figures. In addition to the main Headquarters in New Delhi, two regional stations of NBPGR at the Indian cities of Shimla and Hyderabad were selected for examination.

 

Approach & Methodology

 

The audit was carried out to assess both compliance and performance aspects and the team followed the standards and methodology of audit laid out for such audits by SAI India. Salient features included:-

 

Conducting audits of field units of the NBPGR to form consolidated audit opinion.

Compliance audit with reference to applicable statutes, agreements, standards, norms, and criteria of the auditee.

Examination of funding pattern in respect of projects undertaken by the Institute vis-a-vis budget provision, status of execution of works, operation and maintenance of related assets and outputs emanating from the projects.

Review of research project files, field visits, discussions with the concerned scientists and heads of the Divisions.

 

Objectives of the audit

 

The audit was conducted to assess the performance of NBPGR in respect of various activities conducted it. This included assessment and appraisal of: -

 

The progress of NBPGR’s Plant Genetic Resources research activities stemming out of its various in-house projects and externally aided projects.

Plant Exploration and Collection Division of NBPGR whose main responsibility is to plan, co-ordinate and conduct crop-specific, area-specific and multi-crop explorations for collection of germplasm samples of different agri-horticultural crops and their wild relatives from different regions of diversity within and outside the country.

Germplasm Evaluation Division responsible for preliminary evaluation, characterization, multiplication and identification of promising germplasm samples in agri-horticultural crops, their documentation and cataloguing in addition to production of breeder seed and quality seed of certain released varieties and seeds

Germplasm Conservation Division responsible for conserving germplasm samples of agro-horticultural crops in the long term (upto 50 years) and medium term storage (upto 25 years) and documentation of stored germplasm samples to facilitate easy retrieval and utilisation.

Gene Bank for Medicinal and Aromatic Plants for collection, conservation, evaluation and documentation, multiplication and distribution of medicinal and aromatic plants.

Plant Quarantine Division responsible for inspecting all germplasm samples for detection of associated insect-pests, plant parasitic nematodes and plant pathogens.

Germplasm Exchange Unit responsible for carrying out introduction, exchange and distribution of plant genetic resources for research, documentation and dissemination of information.

Project on Regeneration of Agro-biodiversity for characterization and documentation of the existing germplasm and annual regeneration of clonally propagated crops such as taro, greater yam, and banana till these were completely characterized, evaluated, classified and stored in-vitro. Monitoring of Plant Genetic Resources.

 

Audit planning

 

At the outset, an entry conference was conducted with the Director of NBPGR and the Heads of the Divisions to discuss relevant audit issues, scope, methodology, time frame, field visits, and reporting issues. Appraisal of the progress of audit was carried out at various stages during the audit so that emerging issues could be sorted out in time and audit completed as per the schedule. SAI India issued detailed guidelines, stipulating audit areas to be examined along with audit checkpoints, emphasizing the necessity of conducting audits of some of the field units of the NBPGR as well, within the specified time frame.

 

Major audit findings

 

a. Lack of monitoring and evaluation- During the audit, it was found that a number of in-house projects were not properly monitored for periods ranging from 15 to 25 years. The auditee also did not do project-wise costing to keep track of expenditure on the individual projects.

b. Poor progress in conducting explorations- India is bestowed with immense plant diversity. A major responsibility of the NBPGR is to plan, co-ordinate and conduct crop-specific, area-specific and multi-crop explorations for collection of germplasm samples of different agro-horticultural crops and their wild relatives from different regions of diversity within and outside the country.  During the audit it was found that several areas are still to be explored for collection of germplasm samples by NBPGR.

 

c. Non-evaluation of germplasm samples-All germplasm samples collected, indigenous as well as exotic (that is imported or collected from foreign countries) were required to be evaluated to ascertain their characters for Long Term Storage (upto 50 years) in the National Gene Bank. Audit scrutiny revealed NBPGR did not evaluate indigenous and exotic germplasm samples collected as well as conserved in the National Gene Bank. From 1997-98 to 2002-03, NBPGR collected 81,196 indigenous germplasm samples, which were required to be evaluated by the regional stations and 40 National Active Germplasm Sites located at ICAR Institutes and State Agricultural Universities. However, only 54,700 germplasm samples collected were received for evaluation. The status of the remaining 26,496 germplasm samples was not known to NBPGR.

 

d. Failure to achieve the objectives of scheme for production of breeder and quality seed - Production of breeder and quality seed of some released varieties and supply of such seeds to user agencies is one of the responsibilities of the NBPGR.

 

The targets fixed and achievements as evaluated during the audit showed  that the objectives of the scheme remained unachieved as exhibited in the table below:-.

 

Targets	Achievements
To produce 500 to 650 quintals of breeder and quality seed of wheat, mustard, pigeon pea, cowpea and dhaincha.	Did not produce seed of cowpea, dhaincha but produced untargeted crops like radish, toria, spinach, coriander and oats.
To multiply vegetatively propagated crops like mulberry, simarouba, peach, bail, ber and jojoba by 10,000 to 30,000 numbers.	None of the vegetatively propagated crops was multiplied in the last five years.
To raise nursery of vegetable, medicinal & aromatic plants and ornamental plants, tomato, brinjal, onion, rose, aloe and basil.	Not done.

 

e. Non-conservation of exotic germplasm samples-During the audit it was found that out of 439,000 exotic germplasm samples introduced from 1997-98 to 2002-03, NBPGR could conserve only 14,477 exotic germplasm samples as of March 2003 and NBPGR could not obtain adequate feedback on utilization of germplasm samples and supply of germplasm samples from the indenters for conservation in the National Gene Bank.

 

f. Non-Conservation of indigenous germplasm samples –During the audit it was found that 18,061 out of 51,130 germplasm samples collected during 1999-2000 to 2001-02 were not conserved. Each indigenous germplasm sample, after its collection, is required to be divided in two parts. One part is to be kept as voucher sample in the Medium Term Storage (MTS) module for reference and supply to other organisations and the other part is to be sent to the National Active Germplasm Sites and to the regional stations of NBPGR for evaluation and conservation in the National Gene Bank. Test check of records by Audit , revealed that out of 51,130 germplasm samples collected by the Exploration and Collection Division during the years from 1999-2000 to 2001-02, 18,061 germplasm samples were not kept in the MTS module as voucher samples, defeating the objective of making them available for reference and use.

 

g. Non achievement of objectives of gene bank for medicinal and aromatic plants -NBPGR undertook a project entitled “Establishment of Gene Bank for Medicinal and Aromatic Plants” in March 1993 for a period of four years. The objectives of the project were collection, conservation, evaluation and documentation, multiplication and distribution of medicinal and aromatic plants. Subsequently, another project entitled “Strengthening of National Gene Bank for Medicinal and Aromatic Plants” from March 1998 to March 2002 with similar objectives was also undertaken. The projects were extended up to June 2002 and subsequently upto the end of the Tenth Five Year Plan (2007). During the audit it was found that out of 1,463 germplasm samples collected, only 520 germplasm samples were evaluated and even those were not documented. NBPGR was yet to begin evaluation of the remaining 943 germplasm samples already collected. Thus, objectives targeted during the period from 1998-99 to 2002-03 were not achieved fully inspite of a total expenditure of around US$ 225,875 on the projects.

 

h. Improper quarantine clearance -NBPGR did not grow germplasm samples in the green houses for quarantine tests and did not obtain feedback from indenters. In terms of Plants, Fruits and Seeds (Regulation of Import into India) Order, 1989, germplasm samples which are imported into India are required to be tested for quarantine clearance. Similarly, germplasm samples meant for export are required to be tested for issuing a phytosanitary certificate, which is a certificate issued by the exporting country to the effect that the germplasm samples exported are free from all insects and pests. For this purpose, four quarantine green houses one each at NBPGR, New Delhi and its Regional Stations at Hyderabad, Bhowali and at the Indian Institute of Pulses Research, Kanpur, were established. Test check of records of the green house at NBPGR, New Delhi, revealed that out of 1,634 consignments of germplasm samples imported from 1997-98 to 2002-03, 1,518 consignments of germplasm samples were cleared without growing them in the green house for conducting post-entry quarantine tests (PEQN). Quarantine clearance by NBPGR without growing the germplasm samples in the green house for conducting necessary tests was fraught with the hazard of spread of pathogens, diseases and pests of other countries in our country.

 

i. Violation of plant quarantine regulations- NBPGR conducted quarantine test without import permits and phytosanitary certificates violating plant quarantine regulations. In accordance with the Indian Plant Quarantine Regulations namely the Plants, Fruits and Seeds (Regulation of Import into India) Order, no consignment of plants, fruits and seeds (germplasm samples) shall be imported into India without a valid import permit and a phytosanitary certificate issued by an official agency of the exporting country. This certificate is essential to test germplasm samples in the quarantine division of NBPGR. Test check of registers of import permits and quarantine tests revealed that contrary to the quarantine regulations, out of 1,634 consignments of germplasm samples for which laboratory quarantine tests (other than PEQN) were completed by NBPGR from 1997-98 to 2002-03, 304 consignments of germplasm samples were tested without phytosanitary certificates. Further, in 56 consignments of germplasm samples of private parties, 12 consignments of germplasm samples were tested without import permit. Thus, NBPGR did not observe plant quarantine regulations resulting in unauthorised import of germplasm samples besides improper quarantine clearance.

 

j. Non-utilisation of National Containment Facility- The National Containment Facility meant for processing transgenic germplasm samples, conducting quarantine tests, establishment of molecular biology laboratory and development of human resources was established at a cost of around US$ 917,500 in September 2001. But it was not put into use at all for want of a generator set. Consequently, 10 consignments of transgenic germplasm samples received after its establishment and upto September 2003 could not be processed in the Containment Facility to ensure that they were free from virus, pathogens and pests.

 

k. Issue of import permit without verification-NBPGR issued import permits for research purposes without verification. The Government of India, Ministry of Agriculture notified in March 1990 that the Director, NBPGR, was the competent authority for issuing permits for import of germplasm samples for research purposes authorized by ICAR and the International Crops Research Institute for Semi Arid Tropics (ICRISAT), Hyderabad. NBPGR issued 567 import permits to private companies for research purposes from September 1997 to December 2002. Test check of 35 import permits revealed that NBPGR had never verified before issuing import permits whether the purpose of research, for which germplasm samples were sought for import, was authorized by ICAR and ICRISAT. NBPGR had performed its statutory responsibility of issuing import permits without due care which led to import of germplasm samples without verifying whether the research had been authorised.

 

l. Non-documentation of germplasm samples imported by private companies-NBPGR did not obtain the feedback for documentation of 18,023 germplasm samples from private companies. A test check of the register of germplasm samples of private companies for research purposes revealed that 18,023 germplasm samples were imported between 1997-98 and 2002-2003. In terms of the import permit, the indenters were required to send the feedback and adequate quantity of seeds to NBPGR for further documentation and conservation. The feedback on establishment, multiplication and evaluation and seeds of these materials were not received from the indenters. NBPGR did not pursue the matter with the indenters and the purpose for which the germplasm samples were imported was not monitored.

 

m. Non-documentation of active germplasm samples- NBPGR did not obtain feedback for 18,580 active germplasm samples supplied to research organisations NBPGR had been supplying active germplasm samples of cereals, pulses, oilseeds, vegetables and medicinal plants to other research organisations to furnish the location and date of evaluation, germplasm samples utilisation and published information for further documentation. NBPGR supplied 18,580 active germplasm samples to various organisations and individual scientists from 1997-98 to 2002-03. A test check of records revealed that none of the organisations and scientists had furnished the required information at least for 5,961 germplasm samples supplied during 1997-98 to 2001-2002 nor had NBPGR followed up with them. Thus, the documentation of active germplasm samples had not been done.

 

n. Failure to allot indigenous collection and exotic collection numbers-NBPGR did not allot National Identity Number for 105,000 germplasm samples conserved in the National Gene Bank. All germplasm samples are required to be given National Identity Numbers for easy reference. For Indigenous Collection (IC), numbers with passport data (habitat, village, district, state, source, cultivator’s name, common name and species name) to be allotted to all the conserved germplasm samples including in-vitro culture, germplasm samples in the cryo-bank, and germplasm samples collected or developed by organizations other than NBPGR in the country. Similarly, Exotic Collection (EC) numbers are to be given to germplasm samples introduced by NBPGR through import from foreign countries. NBPGR had about 316,000 germplasm samples collected indigenously including germplasm samples kept in cryo-bank and Medium Term Storage and introduced about 439,000 exotic germplasm samples as of March 2003. However, NBPGR had not allotted IC/EC numbers for more than 100,000 germplasm samples. Resultantly, germplasm samples conserved in the National Gene Bank remained without any identity number.

 

o. Poor progress of project related to regeneration of Agro-biodiversity-Under the United States India Fund Research Programme, the Ministry of Agriculture, Department of Agricultural Research and Education, in May 1998 sanctioned a project entitled “Regeneration of Agro-biodiversity comprising of agro-horticultural crops, their wild and weedy relatives and other economically useful plants of South India” to NBPGR at a total cost of around US$ 159,900 for a period of four years. The objectives of the project included preliminary evaluation, characterisation and documentation of the existing germplasm and annual regeneration of clonally propagated crops such as taro, greater yam, and banana till these were completely characterised, evaluated, classified and stored in-vitro. Eight important crops namely rice, banana, okra, jackfruit, taro, greater yam, horse gram and sesamum spices were identified for study under the scheme. The progress reports revealed that a total of 4,033 germplasm samples of these eight crops were characterised till 2001. Thereafter activities as contemplated in the project could not be undertaken except maintenance and storage of germplasm samples as there were no research associates to carry out the work. Consequently, the important objectives like preliminary characterisation and evaluation of germplasm samples, screening of important diseases and pests under field conditions, annual regeneration of clonally propagated crops and documentation, communication and publication of research results could not be achieved.

p. Absence of monitoring of Plant Genetic Resources by Germplasm Advisory Committees-Germplasm Advisory Committees (GACs) are expected to advise NBPGR on the Plant Genetic Resources activities, prioritization of traits, germplasm samples to be kept in Long Term Storage, research and training needs and strengthening of linkages between NBPGR and user agencies. During the audit it was however found that the GACs were not in existence from 1997-98 till February 2002.

 

Audit impact and auditee's response

 

The above audit study received media attention and was the front page article in the November 2004 edition of “Down to Earth" a widely read Indian magazine focusing on environmental issues. The need to take serious note of the findings in the audit report was highlighted. Based on the lacunae in quarantine procedures as found during the audit, the importance for vigilance when dealing with invisible pathogens that are potential lethal and which could come into the country unless quarantine procedures are made more stringent, was also emphasized.

 

The auditee responded to the audit findings and observations and came out with a number of measures to strengthen the controls in the organization and act on the deficiencies brought out by Audit. Some of the key responses are summarized below: -

 

NBPGR stated that the exploration and germplasm samples collection would be intensified through collaborative explorations in priority areas like priority crops of national importance, under-explored and un-explored crops and areas, wild-relatives of crop plants, endangered economic species and other specific traits in the hot-spots of diversity and lesser known crops of tribal importance.

 

     A special project had been formulated in the Tenth Five Year Plan of India for evaluation of germplasm samples and efforts were underway to evaluate the unevaluated portion kept in the National Gene Bank.

 

A set of guidelines to handle exotic germplasm samples had been approved and its enforcement was being pursued vigorously.

 

NBPGR also mentioned that the feedback requested from the indenters earlier was being pursued vigorously and added that its scientists have been instructed to inspect the site of indenters as and when required It had also been decided to obtain an undertaking from the indenters for supply of feedback before the consignment was released.

 

National Identity Numbers would be issued after completing physical verification of germplasm samples in the National Gene Bank and 110,000 out of 316,000 germplasm samples of different crops had been physically verified.

 

Seven Germplasm Advisory Committees (GACs) were notified and the GACs have started meeting for playing their advisory role for different crop groups.

 

 

7. CONCLUSION

 

Habitat destruction, overexploitation, pollution and species introduction are some of the major causes of biodiversity losses in India. Besides these there are gaps and lacunae in economic, policy, institutional efforts and governance systems. Timely evaluation of efforts in conservation of biodiversity made by concerned government agencies is a requirement as the above audit case study indicates. Updated information and progress of conservation efforts by the scientific institutes need to be made available to the policy makers, the scientific and socio-economic agencies to support the evaluation and constant revision of the policies and legislations related to biodiversity conservation. There could be knowledge and information gaps of the magnitude, patterns, and efficacy of biodiversity laws at the ecosystem and landscape levels. These gaps could be filled in by timely audit studies and in this lies the importance of conducting environmental audits with a biodiversity focus.

 

REFERENCES

The Biological Diversity Act, 2002, India.

The Biological Diversity Rules, 2004, India.

The Convention on Biological Diversity.

Report of the Comptroller & Auditor General of India, Union Government (Scientific Departments), No 5 of 2004.

National Policy and Macro Level Action strategy on Biodiversity, Government of India, Ministry of Environment & Forests.

Empowering People for Sustainable Development, Government of India, Ministry of Environment & Forests.

Agenda 21- An assessment, Government of India, Ministry of Environment & Forests.

State of the Environment-India 2001.

 

SOME KEY WORDS

 

Germplasm- The sum total of the genetic material in plants. In the context of the gene pool, it includes the total variability present in a particular crop species including the related wild and weedy species.

Plant Genetic Resources- The genetic variability potentially useful in agronomy (crop production/crop improvement). Present in crop plants and their wild relatives.

Breeder seed- Breeder seed is the first stage of seed multiplication system and is produced from the nucleus seed (purest seed) obtained from breeders or developed by the seed-producing agencies under the direct supervision of experts.

In situ conservation- the conservation of ecosystems and natural habitats and the maintenance and recovery of viable populations of species in their natural surroundings and, in the case of domesticated or cultivated species, in the surroundings where they have developed their distinctive properties.

Ex situ conservation-the conservation of components of biological diversity outside their natural habitats.

Sui generis- Being the only example of its kind; constituting a class of its own; unique.

 

10. ACKNOWLEDGEMENT

 

The author gratefully acknowledges the help of the audit team for their valuable inputs in composing this paper. The SAI India audit team members who had carried out the above audit were:-

 

Mr. R.P Singh, Principal Director of Audit(Scientific Departments)

Mr. Biren Parmar, Director of Audit

Mr. P. Arumugam, Senior Audit officer

Mr. Surender Singh Rathee, Assistant Audit Officer

Mr. G.C. Tanwar, Senior Auditor