Bhutan

Report on participatory processes in the development and revision of National

Biodiversity Strategy and Action Plans in Bhutan

Prepared by: Lam Dorji

Endorsed by: Karma C. Nyedrup, CBD National Focal Point, Bhutan

Acronyms BAFRA – Bhutan Agriculture and Food Regulatory Authority

BAP – Biodiversity Action Plan

BCCI – Bhutan Chamber of Commerce and Industry

BEA – Bhutan Electricity Authority

BTFEC – Bhutan Trust Fund for Environmental Conservation

CSO – Civil Society Organizations

CSOA – Civil Society Organizations Authority

DAHL – Department of Animal Husbandry and Livestock

DAO – District Agricultural Office

DDM – Department of Disaster Management

DEO – District Environment Officer

DFO – Divisional Forest Office

DGM – Department of Geology and Mines

DLG – Department of Local Governance

DLO – District Livestock Officer

DOA – Department of Agriculture

DOFPS – Department of Forest and Park Services

DOFS – Department of Forestry Services

DOI – Department of Industry

DOR – Department of Roads

DPO – District Planning Office

DRC – Department of Revenue and Customs

DzFO – Dzongkhag Forestry Office

EUDC – Environment and Urban Development Committee

FMU – Forest Management Unit

GAO – Gewog Administrative Officer

GNHC – Gross National Happiness Commission

INGO – International Non-Governmental Organization

IPCC – Intergovernmental Panel on Climate Change

MOA – Ministry of Agriculture

MOAF – Ministry of Agriculture and Forest

MOEA – Ministry of Economic Affairs

MOF – Ministry of Finance

MOHCA – Ministry of Home and Cultural Affairs

MOWHS – Ministry of Works and Human Settlements

NA – National Assembly

NBC – National Biodiversity Centre

NBSAP – National Biodiversity Strategy and Action Plan

NC - National Council

NEC – National Environment Commission

NECS – National Environment Commission Secretariat

NRDCL – Natural Resource Development Corporation Ltd.

NREC - Natural Resource and Environment Committee

PPPD – Public Policy and Procurement Division

RNR – Renewable Natural Resources

RNRRC – Renewable Natural Resources Research Council

RSPN – Royal Society for Protection of Nature

RTO – Regional Trade Office

UNDP – United Nations Development Programme

WWF – World Wildlife Fund

1 Introduction: Country Situation Analysis

1.1 Brief introduction to the country

1.1.1 Location

The Kingdom of Bhutan is located in the eastern Himalayas between latitudes25045’N and 28010’N and longitudes 88045’E and 92010’E. It is a landlocked country wedged between Tibetan Autonomous Region of China in the north and Indian states of Sikkim to the west, West Bengal and Assam to the south, and Arunachal Pradesh to the east. Extending about 350km west to east and about200Km north to south, the country has a total land area of 38,394 km2.

1.1.2 Geology

The topography and geology of Bhutan is primarily an attribute of the young fold Himalayan Mountains. Straddled on the convergence of northern Palearctic realm and the southern Indo-Malayan realms, the country is defined by rugged and fragile mountain terrain ranging in elevation of around 300 meters above sea in the southern foothills to over 7000 meters of the high mountains in the north. Bhutan’s physical features comprise of i) the southern foothills rising from the plains to heights of about 1500 meters above sea level, ii) the inner Himalayas further north up to about 3000 meters above sea level, and iii) the higher Himalayas extending to the high snow capped mountains that separate Bhutan from China. Four major river systems namely the Amo chu, Wang chu, Puna-tsangchu, and Drangme Chu and their tributaries drain north to south through intra-montane fluvial valleys and gorges into the plains of India.

1.1.3 Climate

Bhutan’s general climatic conditions may be described in the context of spring, summer, autumn, and winter seasons. The months of March, April and May denote spring as temperatures gradually rise to recover from the winter cold; June, July, and August represent summer season dominated by the monsoon rains; September, October and November represent the Autumn season depicting end of monsoon with dipping temperatures that gradually yield to cold winter months of December, January and February. Within the context of the four seasons, temperatures and rainfall vary immensely along latitudes influenced primarily by the topography and elevation (T. Eguchi, 1991). Temperature and rainfall also vary along slopes of intra-montane valleys wherein the altitudes, slope, and slope aspects contribute immensely to varying microclimatic conditions. In the context of climate change, Bhutan falls within the IPCC’s South Asia sub-continental region extending to 50o N latitude where rise in temperatures are projected to be higher in high altitude areas.

1.1.4 Natural resources

Bhutan is richly endowed with both renewable and non-renewable natural resources. The renewable natural resources comprise of the natural ecosystems and the species contained in them. Owing to the variations in climatic conditions across short distances, the ecosystems and vegetation also vary immensely over short distance. There are three common classifications of ecosystems in Bhutan. Grierson and Long (1983) and Roderet. al. (2001) classify Bhutan into eleven vegetation zones based on species dominance. In making comparisons with temperate vegetation of east Asia easier, M. Ohsawa (1987) classified Bhutan’s vegetation into six zones based on the elevation boundaries of dominant species. From the perspective of relevance to agriculture and socioeconomic way of life of the

people, classification of Bhutan into six agroecological zones (K. Dorji, 1995) is widely accepted and used (Table 1).

Table 1: Agroecological zones of Bhutan

Agro-ecological

zones

Altitude

(m.a.s.l)

Temperature (0C) Rainfall

(mm) Max Min Mean

Alpine >3500 12.0 -1.0 5.5 <650 Cool temperate 2500-3500 22.0 1.0 10 650-850 Warm Temperate 1800-2500 26.0 1.0 13 650-850 Dry Sub-tropical 1200-1800 29.0 3.0 17 850-1200 Humid Sub-tropical 600-1200 33.0 5.0 20 1200-1500 Wet Sub-Tropical 150-600 35.0 12.0 24 2500-5500

Source: Dorji, K. 1995

Although information on Bhutan’s biodiversity is not comprehensive, over 5000 vascular plant species, 200 mammal species, over 700 species of avifauna, 36 species of

amphibians, 83 species of reptiles, and 91 fish species have been recorded in the country1.

27 of the mammals and 18 of the avifauna recorded in the country are globally threatened. In addition, the country also possesses rich agrobiodiversity (MOA, 2008). 94.5% of the recorded seed plants are known to be native and 105 are endemic to Bhutan.

Bhutan is also richly endowed with water resources. Its water resources lie in the form of snow and ice/ glaciers, freshwater lakes, rivers, streams, and underground aquifers. The average flow is estimated at 2,325 m3/s (73,000 million m3/s per annum) and an estimated hydropower generation potential of 30,000 MW.

Only 33% of the country is geologically mapped and prospected (RGOB, 2010)indicating the potential for further discovery of minerals in the unexplored parts of the country. The known non-renewable natural resources primarily includes minerals such Copper ore, Lead – Zinc ore, Tungsten ore, Coal, Dolomite, Graphite, Gypsum, Limestone, Marble Slate, Talc, Ferro Silicon grade Quartzite, Shale and Iron ore. Most of these minerals are being exploited for industrial needs.

1.1.5 Economy

Bhutan is primarily an agrarian society with 68.5% of the country’s 708,265 (NSB 2011)population still engaging in subsistence agriculture and forestry. Communities living in the different agro ecological zones have evolved diverse farming practices. Livelihoods of this proportion of the population are directly dependent on ecosystem services such water for drinking and irrigation, timber for housing, fuel wood for cooking and heating, and non-wood forest products for consumption and income. The country has a per capita GDP of exceeding US $ 2500. In 2012, the per capita GDP at current prices was US $2509. The major sources of revenue for the government are earnings from hydropower exports and tourism supplemented by mineral based industries such as cement, calcium carbide, ferroalloys etc.

1.1.6 Governance, Development Policy, and Institutional structure

Bhutan’s political system transitioned from absolute monarchy to parliamentary democracy in 2008. The parliament comprises of the apolitical 25 members National Council (house of

1 Information derived from Bhutan Biodiversity Portal (http://biodiversity.bt/), an initiative of a consortium of

biodiversity related agencies under the Ministry of Agriculture and Forests of the Royal Government of Bhutan and the College of Natural Resources, Royal University of Bhutan.

review) and the National Assembly with 47 members. The bureaucracy is comprised of ten Ministries2, four constitutional bodies3, and several autonomous agencies4. As a latecomer to modern economic development, the country is known to have had the opportunity to learn lessons from development mistakes of the global community. Today, it is known for its proactive approach to modern development characterized by its emphasis on environmental preservation in development process and more recently the pursuit and promotion of Gross National Happiness (GNH) as an alternative approach to modern development. This development philosophy is based on four pillars of GNH namely 1) equitable socio-economic development, 2) preservation of the environment, 3) promotion of culture and traditions and 4) Good governance. The emphasis on preservation of environment may be traced back to the hereditary monarchs especially the fourth King during whose rule environmental policies and institutions were developed and strengthened. This legacy is manifested in Article 5 of the Constitution that requires every Bhutanese to be a steward of the environment and that 60% of the country will be maintained under perpetual forest cover (Constitution of Bhutan, 2008).

With transition from absolute monarchy to parliamentary democracy since 2008, balancing the four pillars in the pursuit of development appears to pose a challenge to the people elected governments especially in the context of individual voters prioritizing economic development. Today, the country has 72% of the country under forest cover and over 50% of its territory is designated as protected areas. It is also party to many international environmental agreements.

In keeping with the above commitments and obligations to safeguard the environment, a number of laws have been enacted. Some of the prominent ones include the Forest and Nature Conservation Act (RGOB, 1995), the Biodiversity Act of Bhutan (RGOB, 2003), the National Environment Protection Act (NEPA) (RGOB, 2007), the Environmental Assessment Act (RGOB 2000), The Waste Prevention and Management Act (RGOB, 2009), and the Water Act of Bhutan (RGOB, 2011).

A number of Institutions in the government are mandated of regulate, plan, coordinate, and implement programmes to safeguard the environment and promote sustainable utilization of natural resources.

National Environment Commission (NEC):The National Environment Commission is an independent authority and the highest decision-making body on all matters relating to the environment and its management in the country (NEPA,2007). The Commission is composed of high level multi-sectorial representatives chaired by the Honorable Prime Minister. Some of the roles and functions of the NEC is to recommend ratification of bilateral and multilateral environmental instruments to the Parliament for subsequent enactment; mainstream environment into the national policy, plan and program; comment on all draft policies, legislations, programs, plans and proposed activities prepared by other government agencies which are likely to have an impact on the environment and the sustainable use of natural resources; and recommend to the Parliament to declare any species of plant and/or animal as endangered species including their habitat and thus protected in consultation with

2Ten Ministries are: Ministry of Agriculture and Forests, Ministry of Economic Affairs, Ministry of Education,

Ministry of Finance, Ministry of Foreign Affairs, Ministry of Health, Ministry of Home and Cultural Affairs, Ministry of Information and Communications, Ministry of Labor and Human Resources, Ministry of Works and Human Settlements. 3 The constitutional bodies are: Royal Civil Service Commission, Royal Audit Authority, Election Commission of

Bhutan, and Anti Corruption Commission. 4 Autonomous Agencies: Bhutan InfoComm& Media Authority, Bhutan Narcotics Control Agency,Cabinet

Secretariat, Center for Bhutan Studies, Construction Development Board, Dzongkha Development Commission, Gross National Happiness Commission, National Commission for Women & Children, National Environment Commission, National Land Commission, National Statistical Bureau, Office of the Attorney General, Royal Education Council, Royal Institute of Management, Royal University of Bhutan, and Tourism Council of Bhutan.

relevant agencies and organizations. Further, recommend any part of the country to be a national park, wildlife reserve, nature reserve, protected forest, biosphere reserve, critical watershed and such other categories meriting protection.

The Ministry of Agriculture and Forests (MOAF):MOAF functions to ensure sustainable social and economic wellbeing of the Bhutanese people through adequate access to food and natural resources. Within the Ministry, the Department of Forest and Park Services has the primary function of regulating and ensuring sustainable management of forest resources, efficient and effective forestry administration and service delivery. The Forest and Nature Conservation Act (RGOB, 1995) and the associated rules provide the legal basis for its functions. The functions are discharged through the park managements, Wildlife Conservation Division, and Divisional Forest Offices based in the districts. The National Biodiversity Centre (NBC) seeks to provide approaches for sustainable use of natural resources, ensure balance between conservation and utilization of natural resources and between in-situ and ex-situ conservation. Through its gene bank and herbarium, the institution is the repository of biodiversity genetic materials of the country. In recent times, NBC has been spearheading the development of National biodiversity Strategy and Action Plan for Bhutan. The Ministry, through its Renewable Natural Resource Research Centres (RNRRC) and the Ugyen Wangchuck Institute for Conservation of Environment (UWICE), fosters environmental research and capacity building of the Ministry’s in-service/ extension staff.

The Gross National Happiness Commission (GNHC): GNHC as the national planning commission has a significant role in mainstreaming environment in development plans, ensuring the integration of environmental conservation priorities in the five year plans, and mobilizing and allocating resources for the implementation of the plans.

Local governments: The local governments comprising of the Dzongkhags represented by the Dzongkhag Tshogdu and the Gewog Tshogdu (sub-district committee) are mandated to promote conditions that will enable the pursuit of Gross National Happiness, implying preservation of the environment as one of the four pillars of GNH. Specifically, the Local Government Act of Bhutan 2009 requires the local governments to ‘undertake any activity consistent with other relevant laws and policies of the country which may conserve and enhance the environment within the limits of the areas under its jurisdiction’(RGOB, 2009).

Non-governmental sector: UNDP and WWF Bhutan Program are two primary agencies involved in supporting the Royal government’s conservation initiatives. The Royal Society for Protection of Nature (RSPN) promotes environmental education, conservation of endangered species such as the Black-necked cranes and White-bellied herons, sustainable livelihoods, and research and advocacy. The Tarayana Foundation engages in far flung disadvantaged communities to alleviate poverty and promote sustainable development.

1.2 Convention on Biological Diversity

Bhutan has consistently engaged with the international community in fostering environmental preservation. It is party to multilateral environmental agreements such as the Convention on Biological Diversity (CBD), the United Nations Convention to Combat Desertification (UNCCD), and the United Nations Framework Convention on Climate Change(UNFCCC).

Bhutan became a signatory to the Convention on Biological Diversity on 11 June 1992. Upon ratification of the convention during the 73rd National Assembly session, Bhutan became a

party to the convention on 25 August19955. Bhutan is also party to the Cartagena protocol

since 11 September 2003. Further, it signed the Nagoya protocol on Access to Genetic

5 Source: http://www.cbd.int/information/parties

Resource and the Fair and Equitable Sharing of Benefits arising from their utilization on 20 September 2013 and ratified the protocol on 30 September 2013.

The National Environment Commission has since the beginning been the focal agency for CBD in Bhutan. Mr. Karma C. Nyedrup, then Joint Director and now environment specialist at NECS has been the national focal person in relation to matters pertaining to the CBD.

1.3 National Biodiversity Strategy and Action Plan

Article 6 of the Convention on Biological Diversity specifies the National Biodiversity Strategy and Action Plans (NBSAPs) as the principal instruments for implementation of the convention at national levels. Countries are required to prepare national strategies that are adequately integrated into the plans and activities of biodiversity related sectors. In keeping up with its commitments to the convention, Bhutan has so far developed and implemented three Biodiversity Action Plan popularly known by the acronym BAP. The first BAP I)was developed in 1997, the second (BAP II) in 2002, and the third (BAP III) in 2009.

The preparation of the BAP I was delegated to the NCS by the Chairman of NEC, Minister for Planning Commission, since the NECS was formulating the National Environment Strategy Document, "the Middle Path," during the same time. However, there were adequate representatives from the NECS on the taskforce for the preparation of the BAP I. The preparation of BAP I was initiated in 1996 as a project funded under Global Environmental Facility Small Grants Programme of the United Nations Development Programme(UNDP/GEF SGP) to developing the National Biodiversity Conservation Strategy. Within the overall objective of developing a framework for consolidation, strengthening, and improving programmes and activities of the Royal Government in biodiversity conservation and sustainable use of natural resources, the project also assisted the Royal Government in fulfilling the obligations to the CBD. The Nature Conservation Section (NCS) of the Forestry Services Division under Ministry of Agriculture was designated to undertake the preparation of BAP I. Released in 1998, BAP I consisted of five chapters dealing with the status of country’s biodiversity resources, direct conservation actions, measures, strategies and recommendations for enhancing biodiversity benefits.

The subsequent BAP II was essentially a revision of BAP I in keeping with the concept of BAPs as living documents. It was coordinated, by the same agency renamed as Nature Conservation Division (NCD) of the Department of Forest under the Ministry of Agriculture (MOA).

The development of BAP III saw the transfer of responsibility to the National Biodiversity Centre (NBC), which was established in 1998, three years after Bhutan became a member of the CBD, with the primary mandate to coordinate biodiversity conservation and sustainable utilization programs in the country, as envisioned in the first BAP. A similar process was adopted in formulating BAP III, with the engagement of a consultant and technical group engaging stakeholders throughout the formulation, action planning, and review process. BAP III was brought out in 2009. Apart from the conventional BAP chapters such as introduction, status of biodiversity and conservation efforts, the document outlines the issues and threats to biodiversity. The last chapter presents an exhaustive list of strategies and actions for biodiversity conservation.

The Vice-Chair, NEC, Minister for Agriculture and Forests, delegated the responsibility of developing the fourth action plan called National Biodiversity Strategies and Action Plan (NBSAP) in line with the Aichi Targets and national priorities. This time, the NBC has adopted an approach where the Technical Working Group (TWG) is delegated with the responsibility of preparing the national document instead of a consultant. The TWG comprise members from government, Civil Society and donor agencies. The revision process till date

has included more than 15 meetings among the task force members, three sub-national consultation workshops and a national level stakeholder workshop amongst relevant central as well as local stakeholders. A draft document is already posted on the websites of the Ministry of Agriculture and Forests and the National Biodiversity Centre for comments. Considering that this document is being prepared post Nagoya process, the draft document integrates the relevant provisions of the Nagoya protocol, derives lessons from the past BAP development and implementation, and seeks to address the gaps. The document also includes an implementation mechanism along with Monitoring and Evaluation and resource mobilization and communication plans. Unlike the past, the current document is expected to be endorsed as a national guiding document on biodiversity management in the country.

2 NBSAPs coordination and institutional structure

Article 20 of National Environment Protection Act (NEPA)states that NEC shall be thehighest decision making body on all matters relating to the environment and its management in the country. The commission is an inter-ministerial agency with the representation from civil society and the private sector. Further, Article 29 (f) states that ‘the role of the Commission is to set the policies and to coordinate the actions required to a) Implement the principles enshrined in this Act; b) Protect and promote a safe and healthy environment; c) Prevent, control and abate environmental harm, including pollution; d) Ensure conservation and sustainable use of natural resources; e) Institutionalize the environmental assessment process as an integral part of the development planning process through implementation of the Environmental Assessment Act, 2000 and; f) Negotiate and enforce bilateral and multilateral environmental agreements.”

It is clear from above that the legitimacy of spearheading or coordinating programs and activities to meet the obligations under international environmental agreements lies with the NEC. However, the process engaged in the development and implementation of the three BAPs suggests that the institutional mechanism adopted in meeting the obligations of the CBD were delegated without clear reporting procedures. The NEC had fulfilled all other national reporting to the CBD. The following arrangements exists under the CBD:

2.1 CBD National focal agency and national focal person (NPF) Mr. Karma C. Nyedrup is the National Focal Point for CBD in Bhutan. Mr. Karma is also the NFP for the Intergovernmental Committee for the Nagoya Protocol on Access and Benefit Sharing. However there is no clear delineation of roles and responsibilities including authorities for implementation and fulfillment of the obligations under the CBD. In being the CBD focal agency, the NECS has not assured consistent participation of the NFP in the CBD pre COP and COP meetings. While Karma C. Nyedrup remains the NFP, his attendance at the pre COP and COP meetings has not been consistent owing to the typical practice of such opportunities being availed by officials other than the NFP. At the same time, there have not been adequate initiatives to facilitate the participation of biodiversity implementing agencies in the CBD meetings.

2.2 NBSAP/ BAP coordinating agencies As the institution in which the NFP is based, one would likely expect the NECS to assume the responsibility of developing or coordinating the development and revision of BAPs. However, institutions other than the NEC/NECS carried out the development and revision of the three BAPs.

The Nature Conservation Section (NCS) under the Forestry Services Division was designated as the agency for development of BAP I. The same agency, later renamed as Nature Conservation Division (NCD) under Department of Forest, coordinated the

preparation of BAP II. Upon its establishment in 1998, the National Biodiversity Centre (NBC) under the Ministry of Agriculture took up the role of revising the BAP. This transfer of coordination role to NBC follows from the BAP I recommendation for establishment of an operational level institution to coordinate biodiversity conservation in Bhutan. Since then, the NBC produced BAP III and is currently coordinating the revision.

From the above, there has essentially been only one but different agency that took the lead role in coordinating development of each NBSAP. It appears that the documents were developed based on funding availability rather than emanating from an institutional mechanism. The lead agency and the process adopted were entirely context based and differed from one lead agency to the other.

2.3 National Reporting to the CBD The NECS has consistently been the official entity to report to the CBD. So far, the NECS has submitted four national reports to CBD Secretariat. The BAPs were also submitted to the CBD Secretariat. The first and second national communications to CBD were the BAP I and II documents while the third national report was submitted in the form of responses to the questionnaire format provided by CBD Secretariat. The fourth national report (RGOB 2009) was prepared independently by the NECS and includes the extent of achievement of the 2010 targets and the challenges faced in fulfilling the principles of CBD. Chapter 2 of the report revisited BAP II. The assessment included 1) an indication of whether and where the CBD targets have been incorporated in the BAP, 2) how BAP activities contribute to implementation of the provisions of the convention, 3) progress made in implementation of priority actions in terms of concrete achievements, and 4) indication of the domestic and international funding for priority activities. In terms of the effectiveness of the BAPs, the report point out the need for greater focus on the key priorities with time bound objectives and targets.

2.4 Overall institutional arrangement Based on the above, the overall institutional arrangements in meeting the obligations to the CBD may be best described by the vague linkage between the NBSAP development, revision, and implementation level and the reporting to CBD level. This aspect is illustrated in the diagram below:

Figure 2. Diagrammatic representation of the institutional arrangements in NBSAP

development, revision, implementation, and reporting to CBD.

The National Biodiversity Centre (NBC) under the Ministry of Agriculture and Forests has developed the third action plan and is currently in the process of revising the document. The organization’s Biodiversity Information Management Division is entrusted with the functions to coordinate the development and implementation of NBSAPs (see NBC organogram below).

Figure 3. Organogram of National Biodiversity Centre of Bhutan

Conference of Parties

CBD Secretariat

National

Environment

Commission (NEC)

Ministry of Agriculture and

Forest

NEC Secretariat

National Biodiversity

Centre

Nature Conservation

Division, FSD

Forestry Services

Division

GNH Comm.

Secretariat

International CBD level

Policy and Planning level

Implementation level

Past engagement in NBSAP

Institutional linkages

Legend:

As an institution that was established for the purpose of coordinating implementation of BAPs, the NBC is constantly seeking to refine the institutional coordination mechanism pertaining to the implementation of biodiversity conservation especially the NBSAPs and the linkages to CBD. It has prepared and submitted to its Minister, who is the vice-chair, NEC, a ‘report on the implementation of the obligations under the Convention on Biological Diversity and proposal for appointment of National Biodiversity Committee which would guide the implementation of CBD obligations, including the NBSAP (technical)’ (NBC, 2014).

3 Communication, public awareness and participation

In describing the communication, public awareness and participation in the NBSAP process, it is essential understand the process adopted in the development of NBSAP. Hence, this section is an attempt to summarize the processes engaged in the development of the BAP II, III, the ongoing and I BAP IV. This will allow better understanding of the extent of communications, public awareness, and participation.

3.1 NBSAP development process

The process adopted in the development of BAP I served to guide the subsequent BAP processes. The process followed is summarized below:

3.1.1 Identification of the BAP coordinating agency

As described earlier, the planning commission identified the NCS as the agency to coordinate the first BAP process. The same agency carried out the revision and produced BAP II. Based on BAP II recommendation for establishment of an operational level institution to coordinate biodiversity conservation in Bhutan, the NBC was instituted by the Royal Government in 1998 as a non-departmental agency under the Ministry of Agriculture. The agency is mandated to coordinate biodiversity conservation and sustainable utilization programs in the country, and the implementation of BAP(s).Thereafter, the agency undertook to coordinate the development of BAP III and continues the responsibility in developing the fourth BAP.

3.1.2 Coordination mechanism

The coordination mechanism adopted in the development of BAPs began with putting in place three main entities:

Hiring of consultant: An international consultant (Prof. Lee Talbot) was hired to facilitate the BAP I and II development process. For BAP III, the NBC hired a national consultant to facilitate the revision. With regard to the ongoing development of BAP IV, the coordinating agency has switched from a consultant driven exercise to technical working group driven approach, whereby members of the technical working group are engaged in writing of chapters.

Formation of core group: At the inception stage, a core group comprised of representatives of key agencies in the Ministry of Agriculture was formed. The core group for BAP I and II included representatives of Department of Forestry Services, Department of Agriculture and Livestock Support Services, and Research, Extension and Irrigation Services. The primary function of the core group was to coordinate the entire process of BAP development, guide the consultant, and determine the content of the document. BAP III did not employ a core group.

Formation of task force/ technical working group: All BAP processes engaged a task force or a technical working group. The task force for BAP I and II comprised of individuals representing other stakeholders from the government ministries and agencies, NGOs, and the UNDP. BAP I had eleven members and BAP II process engaged eighteen members representing the various stakeholders. The task force functioned as the steering committee for the project and provided the platform for consultation, discussion, and review of earlier BAPs, analysis, and coordination of the BAP process. Instead of task force, BAP III engaged a technical working group comprised of key conservation and conservation related agencies to guide and support the national consultant. In the ongoing BAP IV process, no consultant has been hired. The technical working group has assumed full responsibility in the development of BAP IV whereby every member is actively engaged in facilitating consultative processes and writing the document chapters. According the NBC, this approach encourages full engagement of the technical group members.

3.1.3 Consultation process

BAP I and II adopted an extensive consultative process engaging stakeholders at the national and regional levels. Consultations were carried out in the form of following consultation processes:

Individual interactions and meetings: Primarily undertaken by the consultant, this process sought views and opinions from selected individuals such as ministers, officials, and individuals in the government, NGOs and the private sector in relation biodiversity conservation concerns, issues, and efforts.

Consultation workshops: Consultations workshops were organized at the national as well as regional district levels. Types of consultative workshops included:

Formulation workshops: At this workshop, the stakeholders discussed the approach to be adopted in the process of preparing the BAP, reviewed terms of reference of the core team, the task force, and the members. Such workshops are also the appropriate platform to agree on the outline, conceptual features, and process for preparation of the document.

Regional stakeholder workshops: With the purpose of being inclusive, far reaching, and educative, stakeholder workshops were held in western, central eastern and southern regions of the country. Different stakeholder representatives were invited to the workshop. Such workshops integrate education and awareness about biodiversity

conservation, CBD, and national obligations to CBD as well as consultative process on biodiversity issues, strategies and actions. Hence, such workshops are primarily action planning workshops.

3.1.4 National stakeholder workshops

In a way, the national stakeholder workshops are review workshops. This is the forum at the national level where the draft report is shared and presented to secure feedback, comments, and endorsement.

3.1.5 Government approval

The reports are finalized after incorporating the comments and feedbacks from the national stakeholder workshop and submitted to the government for approval. Approvals are granted at the Ministry level with signatures accorded by the Ministers. The first BAP was signed by Lyonpo C. Dorji, Minister of Planning Commission as well as Chairman of NEC; the second BAP by Her Majesty, queen Dorji Wangmo Wangchuck and the third BAP by Lyonpo Pema Gyamtsho, Minister of Agriculture and Forest.

3.2 NBSAP process communication/public awareness The development and revision of the BAPs did not involve a defined communications and public awareness strategy. Although there were slight variations, BAP processes in general aligned with the BAP I processes, which appeared to be more elaborate and inclusive. The overall process of communications and public awareness employed in the BAP development and revision may be described as follows:

3.2.1 Initial communication on BAP process

BAP process generally begins with public announcements in the media (newspaper, television or radio) usually calling for consultancy services. That is perhaps the first time when the BAP information comes in the public domain. Further, information on BAP process also goes out in the form of official correspondences when seeking appointments for consultants, invitation for participation in stakeholder workshops and meetings. Such correspondences usually contain background information on BAPs.

3.2.2 Educational components of stakeholder workshops and meetings

The consultation workshops organized at the national and local levels had educational sessions that allowed two way flow of information i.e., introduction of the concepts of biodiversity, sustainable development, importance of biodiversity conservation, the CBD and Bhutan’s obligations to the CBD to the participants. On the other hand, it provided the platform for participants to share their concerns and opinions.

Although the level of engagement and outreach varied from one BAP to the other, subsequent BAPs conducted the stakeholder workshops and meetings for similar purposes. The series of workshops and meeting conducted churn out information that is communicated to the participants for feedback and comments. The issues raised at the regional workshops were further deliberated and incorporated by the task force or technical working groups. The findings were then integrated into the draft reports of the focal persons, which in turn were compiled and the draft shared and finally presented at the national workshop. In addition, the draft reports are put in the public domain for wider communication. The final reports, after integrating the recommendations from the national workshop, were submitted for approval of the Royal Government. In the process of approval, the policy and decision makers in the government are educated and aware of the BAPs. Such consultation and communication processes help the organizers to refine and update information while being more inclusive and participatory thereby fostering acceptability at various levels.

While appreciating the inherent nature of consultations as a continuous process of facilitating communications and public awareness, the coverage seemed to be limited to the

participants only. Participation was by invitation and no provisions exist for interested people to attend. The process was therefore entirely set within the sphere of primary stakeholders at the national level. Initiatives did not exist to constantly inform the general public. With majority of the population being Internet illiterate and still engaged in subsistence farming, the only popular far-reaching media in Bhutan is radio followed by television. Events to attract the attention of radio and television remain effective means to informing the public. It is worth noting the strategy adopted for the launch of BAP II has helped publicize the document and its contents to the general public. For example, Queen Mother Her Majesty Dorji Wangmo Wangchuck launched BAP II document that enabled press coverage. In addition to the news coverage on radio and television, newspaper article provided good coverage of the BAP process and contents (Kuensel June 7, 2002).Hence, inviting the engagement of renowned high profile people are effective in garnering attention of television and print media in creating public awareness.

Internet technology and availability of associated gadgets have immensely expanded in Bhutan in the last few years. This has allowed people’s access to websites, e-mails, allowing easy platform for information sharing through the Internet. This platform has been increasingly used in the publicity of BAP processes and outcomes. Most of the related publications and reports are now available online and therefore accessible from any part of the country. For example, the current revision and draft, this time called NBSAP, is available on the website of the NBC at http://www.nbc.gov.bt/news/seeking-comments-on-draft-national-biodiversity-strategy-and-action-plan-nbsap-2.html. Despite all the efforts to communicate, BAP documents are commonly known or available for access to IT literate individuals and employees of agencies regularly engaged in biodiversity conservation.

3.3 Stakeholder identification Stakeholders mapping as such was not employed in the identification of stakeholders. As pointed out earlier, the first BAP document provides an exhaustive list of stakeholders who participated in the process of developing the document. BAP I processes garnered participation of wide range of stakeholders. The subsequent BAPs seem to have followed suit. Considering that the BAP I and II were coordinated by the Department of Forest and BAP III by NBC, it is appropriate to look at how the two agencies identified different agencies and individuals for engagement in the BAP process. The stakeholders identified may be explained in terms of:

3.3.1 Core team and task force/ technical group composition

Since the Core team and task force were two entities fully engaged in the development of BAPs, the composition was identified ahead. The following table shows the composition of the core group/ management:

BAP I BAP III

Core team

Management, advisory support and

Supervision

Mr. T N Acharya, Crop and Livestock

Division, MOA

Singay Dorji, Senior Biodiversity Officer,

National Biodiversity Centre

Mr. Karma Tsering, Research Extension

and Irrigation Division, MOA

Dr. TashiYangzom Dorji, Programme

Director, National Biodiversity Centre

Mr. TenzingDhendup, Research

Extension and Irrigation Division, MOA

Dr. UgyenTshewang, former Programme

Director, National Biodiversity Centre

Ms. Durga D Sharma, Forestry Services

Division, MOA

Mrs. DekiYonten, Forestry Services

Division, MOA

The task force/ technical group for BAP I and BAP IIIwere comprised as follows:

BAP I BAP III

Task Force Technical Group

KunzangNorbhu, Planning Ministry Ganesh Chhetri, Department of

Agriculture

Karma C. Nyedrup, National

Environment Commission (NFP)

Dr. TashiYangzom Dorji, National

Biodiversity Centre

Dorji Thinley, National Institute of

Traditional Medicine

Dr. Sonam W Wang, Nature

Conservation Division, Department of

Forests

Ugen P Norbhu, World Wildlife Fund SonamChoden, Nature Conservation

Division, Department of Forests

KunzangYonten, Royal Society for the

Protection of Nature

Kaka Tshering, Forest Resources

Development Division, Department of

Forests

ThinleyWangchuk, Ministry of Trade

and Industries

SonamLhundrup, Policy and Planning

Division, Ministry of Agriculture

SonamTobgay, Tourism Authority of

Bhutan

TandinWangdi, National Biodiversity

Centre

MedonYaganagi, National Biodiversity

Centre

Asta M Tamang, National Biodiversity

Centre

RinchenYangzom, National Biodiversity

Centre

Singay Dorji, National Biodiversity

Centre

Mahesh Ghimiray, RNR-RC Bajo,

Ministry of Agriculture

Dr. LhamTshering, Department of

Livestock

Karma C. Nyedrup, National

Environment Commission (NFP)

ChukeyWangchuk, Bhutan Trust Fund

for Environmental Conservation

TsheringLhamtshok, Royal Society for

the Protection of Nature

Vijay Moktan, WWF Bhutan Programme

Dr. Michael Tobias, Dancing Star

Foundation, United States

3.3.2 Stakeholders identified for consultations

The stakeholders were identified for the purpose of one to one meetings and for group consultations or workshops. BAP I defined the purpose of consultations and workshops as follows:

provide a forum for participation for local people who use, affect, study and conserve biodiversity, in order to assure a wide participation in the BAP process;

assure the differing needs and perceptions of people from different regions isincorporated in the BAP process through local participation;

seek to build understanding and support for the BAP;

compile information from the different regions to assure that the BAP reflects differing conditions in the differing parts of the country.

The above objectives seem to have guided the coordinating agency to determine where and which stakeholders should be consulted or invited to participate or engage in the process. Towards the above, BAP I process identified stakeholders for consultation so as to secure ‘the widest participation from groups using and affecting biodiversity’. The following stakeholder groups were identified for the consultation process:

representatives of the local people such as Gups, Chimis, and Mangmi from eachdistrict

Divisional Forest Officers, District Agricultural officers

District Animal Husbandary Officers

Dzongkhag Forest Extension Officers

Selected District Education Officers

Research Officers from the Renewable Natural Resource

Selected Dungtsos (traditional medicine practitioners)

Lecturers from the Bhutan Forestry Institute for Forest Guards, Natural ResourceTraining Institute, and Sherubtse College

Project Officers

Sawmill owners, paper industry owners

For BAP III, only stakeholders at the national government level were identified for consultation. In seeking appointment for one to one consultations or for the purpose of extending an invitation to participate in the national and regional workshops, alist of potential organizations and individuals is prepared and invitations extended. A typical list of stakeholders and their agencies involved in the BAP III process included:

Additional People Who Reviewed/Contributed Information:

SonamTamang, National Biodiversity Centre

Rinchen Dorji, National Biodiversity Centre

Tshewang, National Biodiversity Centre

UgyenPhuntsho, National Biodiversity Centre

NgawangGyeltshen, National Biodiversity Centre

ChekiWangmo, National Biodiversity Centre

DechenLham, National Biodiversity Centre

Dr. SangayWangchuk, Nature Conservation Division, Department of Forests

Dr. SonamWangyel Wang, Nature Conservation Division, Department of Forests

Dr. Tashi Dorji, RNR-RC Bajo, Ministry of Agriculture

SonamWangdi, Nature Conservational Division, Department of Forests

UgyenNamgyel, Nature Conservational Division, Department of Forests

RalingNgawang, Royal Botanical and Recreational Parks Division, Department of Forest

G. B. Chetri, Department of Agriculture

TsheringTashi, National Environment Commission

Dr. D. B. Rai, Department of Livestock

Dr. J.B. Gurung, Department of Livestock

Dr. PemaWangda, RNR-RC Yusipang, Ministry of Agriculture

DawaPenjor, National Mushroom Centre, Ministry of Agriculture

MedonYaganagi, National Mushroom Centre, Ministry of Agriculture

Dorji, National Mushroom Centre, Ministry of Agriculture

L.B. Tamang, National Mushroom Centre, Ministry of Agriculture

Dr. Tashi Dorji, RNR-RC Jakar, Ministry of Agriculture

Tshewang Dorji, RNR-RC Yusipang, Ministry of Agriculture

PhurpaWangchuk, Institute of Traditional Medicine Services, Ministry of Health

Sonam Dorji, Institute of Traditional Medicine Services, Ministry of Health

KuengaJamphel, Institute of Traditional Medicine Services, Ministry of Health

Tashi, Institute of Traditional Medicine Services, Ministry of Health

DoleyTshering, United National Development Programme

Karma L Rapten, United National Development Programme

Tashi Dorji, United National Development Programme

Sonam Y Rabgye, United National Development Programme

Rebecca Pradhan, Royal Society for Protection of Nature

AshitChhetri, Natural Resources Development Corporation Ltd.

Narayan Pradhan, Natural Resources Development Corporation Ltd.

From the above, it is evident that the stakeholders in the government and conservation sector were identified to play the primary role of steering the development of the BAPs. Further, because a proper mapping was not carried out, the stakeholders outside of the government and conservation sector were not identified for inclusion in the task force or working groups.

Although a comprehensive stakeholder identification entails a full-fledged stakeholder mapping exercise, an attempt has been made to present an understanding of the stakeholders at various levels of engagement. A simple stakeholder map is presented below:

Level of engagement

State District

Gewog (sub-district)

Policy making

and regulatory

NREC of NC;EUDC of

NA; GNHC; NEC; MOAF

(DOFPS, DOA, DAHL);

BAFRA; MOF (DRC,

PPPD); MOEA (DGM,

DOT, DOI); MOHCA

(DLG, DDM); CSOA;

DEO

(Environment);

DPO; DFO;BAFRA;

DzFO

Gup, Mangmi, GAO;

Forest Range Offices

Biodiversity

conservation

entities

MOAF (DOFPS; NBC,

RNRRC) INGOs (UNDP,

WWF); CSOs (RSPN;

Tarayanaetc); Thromde

Environment Offices;

DratshangLhentshog

(Monk Body)

National Park

management;

RNRRC; CSOs;

DAO; DLO;

Thromde

Environment

Offices; Rabdey

(District Monk

Body)

RNRcentres; Park

Range offices; CSOs;

religious institutions

Biodiversity

users

NRDCL;Municipalities; RTO, BCCI,

NRDCL; FMU;

Municipality water

and sanitation

offices

Farmers; Businesses;

User Groups

(Community Forest,

Water, women etc);

town

Entities

affecting

Biodiversity

Hydro power Authorities;

BCCI; MOWHS (DOR);

Municipalities

Industries (mines,

quarries,

manufacturers),

Hydro power

projects; DOR

Mines; quarries;

Industries

Media and

academia

Bhutan broadcasting

radio, television; Print

media (Kuensel, Bhutan

times etc.); Academia

(RUB);

BBS regional

bureaus; Media

stringers; Academic

institutions

(schools, colleges,

institutions)

Schools and

institutions

Note: Refer to acronyms for full name of entities

3.4 Stakeholder engagement Because a stakeholder mapping exercise was not undertaken specifically for identifying the stakeholder in biodiversity conservation, it is difficult to tell how inclusive the BAP processes have been in engaging stakeholders. However, information on the methodology adopted suggests that efforts have been made to reach out to all regions of the country. The BAP

processes engaged the stakeholders identified in the earlier section at various stages of the development process. Based on BAP development process, stakeholder engagement in the development of last three BAPs may be described in terms of:

Coordinating agency:

The NCS/ NDC and NBCare important stakeholders as regulators of biodiversity conservation. As coordinating agencies, they facilitated engagement of other stakeholders through the consultation processes and played the primary role of shaping the outcome of the process.

Core team, task force and technical committees

Focal persons from biodiversity related organization in the government (NEC and agencies under the MoAF), NGOs like RSPN, UNDP and BTFEC) and consultants were engaged as members of core team and task force and technical committees. These representatives not only employed their individual skills and knowledge in facilitating the process but also brought the perspectives and concerns of their own organizations. The processes adopted so far suggest that the stakeholder engagement was most inclusive during the BAP I process and minimal consultation at the local levels during subsequent BAPs. The level of stakeholder engagement seemed lower in the BAP II and III where the revision process concentrated on stakeholders in and around the capital city

3.4.1 Participation in consultations

Stakeholders identified by the coordinating agencies participated in the consultations processes by learning about biodiversity conservation, providing individual knowledge and perspectives on biodiversity issues and actions to address them. Although it was made explicit in the BAP I, the stakeholders generally comprised of representation from groups using and affecting biodiversity. The participants included local leaders and representatives (Gup, Chimi, Mangmi), district officials representing the forest, agriculture, animal husbandry, education, health practitioners, academia and research, and private sector businesses. The participants were engaged were not only engaged as learners but also as providers of local biodiversity related information and perspectives. The participants learned about concepts of biodiversity, sustainable development, CBD, and Bhutan’s obligations to CBD while contributing context based perspectives and concerns.

Stakeholder engagement was relatively inclusive and far reaching during the BAP I and the ongoing NBSAP development process where regional stakeholder consultations were prioritized. BAP II and III revisionsdid not prioritize consultations at the local level resulting in reduced stakeholder engagement. Stakeholders primarily at the level of government ministries, NGOs, and the scientific community in and around the capital city were engaged. The entire process of updating information and developing contents revolved around the task force or technical group members.

3.4.2 Factors influencing stakeholder engagement

The major motivation for stakeholder participation comes from their feasibility to participate. From the experiences of the BAP processes, the feasibility of stakeholder engagement was primarily dependent on:

Financial resources: To the agency coordinating development of the BAP, fund availability is a major though not the sole factor determining the extent of stakeholder participation and engagement. Inadequate funding and resulting lack of consultations at the local and regional level may render the process inadequate in securing

representation of all five major groups (as per COP guidance) especially the private sector and local indigenous groups. After all, ‘no small group of officials or expert ‘biodiversity planners’ will ever have the understanding, experience and knowledge to be able to successfully identify all the issues’ (UN Decade on Biodiversity, 2012). While there was funding available for development of the BAPs, the limited financial resources allowed stakeholder engagement only to certain extent.

The approach and processes adopted: Within the limits of available funds, stakeholder participation is also dependent on the approach and process adopted to foster stakeholder participation and engagement. BAP I and current NBSAP process reached out to the different parts of the country by taking the consultation meeting closer to the stakeholders. BAP I charted out the approaches at the first workshop based on which the regional workshops were organized. On the other hand, BAP II and III did not prioritize regional consultations. This led to lack of local representation owing to lack of platform for consultations at the local level.

Identification and engagement of stakeholders: The inclusiveness of stakeholder participation and engagement depends on how well the stakeholders were identified. In the absence of proper stakeholder mapping, it is likely that some stakeholders are not identified and therefore left out of the process. In cases where stakeholders have been identified, it is still important that the representative is interested and knowledgeable about the subject of consultation. Therehave been instances when stakeholders do not consider their participation to the level deemed by the coordinating agency. This generally happens when the participating individuals representing a stakeholder organization arenot interested or knowledgeable about the subjectresulting in minimal contributions to the process. This is further aggravated when diverse stakeholders with different levels of understanding are brought into the same forum.

4 Integration of different societal actors’ views in the NBSAP

4.1 Management of societal actors’ input Input from the societal actors was generally facilitated by a consultant with support of the task force or technical committee members. Though a comprehensive identification of stakeholder was not carried out, the consultants and the coordinating agency usually prepare a list of individuals and organizations to be consulted. Thereafter, one to one meetings and stakeholder workshops are planned and implemented as follows:

One to one consultation: During this process, the consultant and a focal person from the coordinating agency would secure appointments with professionals in different organizations and agencies. Interactions would include introduction to the undertaking and responses to a set of questions aligned to feed into various sections of the report. Views, opinions would also be sought on the implementation of last BAP and considerations to be made for the revision. BAP II and III relied immensely on this process since regional workshops were not prioritized.

Workshops: Information was generated through regional and national stakeholder workshops to which the societal actors are invited to participate. The regional stakeholder workshops generally comprised of thematic and interactive sessions. Further, group work comprised of thematic discussions and deliberations in groups and presented at plenary. Rapporteurs compile the information to be further discussed by the task force or technical group and the consultant. Apart from the process documentation contained in BAP I, there are no documented records elaborating the process and criteria used in filtering the information. It appears this aspect was left to the judgment of the task forceor technical committees. In the absence of established mechanisms for

choosing the right issues, the decisions about what to include ultimately lay with the task force and core group members.

It is also noteworthy that there are no reports of opposing views that required reconciliation. Though it cannot be confirmed, such opposing views are not expected when the stakeholders engaged are primarily from similar sectors i.e. government agencies and the conservation sector. For example, the participants or people consulted were mainly from the conservation sector. NGOs and private sector representation was relatively low. Since existence of civil society organizations (CSOs) emerged only with the enactment of CSO Act in 2007, substantial engagement of civil society was not expected. Even today, CSOs are in nascent stage lacking the potential to contribute to the process. However, under-representation of private sector could have curbed the potential for opposing views. Hence the need for reconciliation and consensus mechanisms seemed unnecessary.

4.2 Mainstreaming The environment is one of the four pillars of GNH. Hencethe GNH Commission (GNHC) has the obligation to prioritize mainstreaming of the four pillars into Five Year Plans (FYP). Concerning the environmental mainstreaming efforts, the National Environmental Strategy (NEC 1998) outlines a middle path approach to development of the country. Accordingly, the GNHC has integrated environmental prioritiesin the tenth FYP and Eleventh FYP. The tenth FYP specifically mentioned the development and implementation of BAP III but does not draw the priorities from the BAP II. Desirably, BAP priorities must form the basis for sectorial priorities on biodiversity and accordingly reflected in the FYPs. In other words, the FYP priorities on biodiversity conservation must adequately align with the priorities set forth in the BAP. However, this logic seems to have suffered in the lack of ownership of the BAPs. It is not possible to associate the biodiversity priorities in the BAP III with the priorities of the Eleventh FYP. It appears that BAP priorities were identified through the BAP development process while a separate process was initiated to identify priorities for the FYPs. In this context, BAP documents were a reference but not a guide for setting biodiversity priorities.

A ‘Framework for mainstreaming Environment, Climate Change and Poverty into Eleventh FYP’ has been developed to aid the process of integrating environmental concerns into sectorial plans (GNHC,2012). The word ‘BAP’ or ‘NBSAP’ does not even feature in this document. Because the framework does not require BAP priorities to be mainstreamed, the biodiversity priorities in the Eleventh FYP could not have resulted from the BAP III priorities.

In the context of the above gaps in mainstreaming NBSAP, the opportunities for mainstreaming NBSAP exist in three areas:

4.2.1 Define Institutional structure

The lack of defined institutional structure is the main cause of lack of ownership over BAPs. The institutional arrangements need to start at the NEC from where the authority for NBSAP development is delegated to an appropriate organization. It is also the entity with the authority to endorse and forward the NBSAPs to the Royal Government for final approval. Once the documents are approved, the commission must adopt a mechanism for coordinating implementing and reporting of the NBSAP. The national reports to the convention must also be tabled here before submitting to the CBD Secretariat. This opportunity could be availed by tabling to the NEC a proposal on the desired institutional arrangement and could be initiated as part of the ongoing NBSAP development.

4.2.2 National Environment Strategy Revision

The Revision of the National Environment Strategy is underway. The revised strategy could potentially include the importance of NBSAPs in guiding national efforts in biodiversity conservation. This opportunity must be availed before finalizing the revision of NES.

4.2.3 Framework for mainstreaming environment, poverty and climate change in FYPs

NBSAPs must also adequately feature in the ‘framework for mainstreaming environment, poverty and climate change’. The opportunity for integrating the NBSAPs may come during the revision of the framework.

5 Conclusions Bhutan’s has done extremely well in conserving the country’s rich biological diversity. However, it is not possible to attribute this achievement to BAP/ NBSAP given the low ownership and poor implementation of BAPs till date.

BAP documents have not adequately served the purpose of guiding biodiversity conservation in the country. In looking forward, the way to go about is to be self-reflective. This is the first time that an assessment has been undertaken to study the NBSAP processes. From the study of past BAPs and ongoing NBSAP development processes, the following conclusions have been derived:

Ad-hoc institutional arrangements and processes

The Royal Government has always accorded high level of importance to environmental preservation and acknowledged the development and implementation of NBSAP as an obligation under the CBD. However, the institutional arrangements to support this commitment are not optimized owing to:

weak institutional linkages between the institution to which the NFP belongs, the NBSAP coordinating agency, national planning commission and implementing agencies.

Inconsistency in the NBSAP coordinating agency and the processes adopted.

poor implementation. The existing institutional arrangements do not allow logical and sequential flow of work from the time of developing the action plan to implementation to form the basis for the national communications to CBD.

As the CBD focal agency and apex body for all environmental matters in the country, the NEC is well positioned to address the constraint and strengthen the institutional mechanism.

The lack of ownership of the document

The lack of implementation of the plan has meant many strategies and actions are repeated from one BAP to another. Hence, it is not possible to ascertain that biodiversity achievements are a direct result of planned implementation of BAPs. Further, BAP I, II, and III lacked specific implementation arrangements where specific strategies and actions lacked specific implementing agencies and timelines.

BAP is a living document living by itself

BAPs have the salient feature of being looked upon as a project where the process ends with the final endorsement of the document. Thereafter, no mechanisms exist to implement or monitor the status of implementation of the strategies and actions. Revisions are undertaken under funding initiatives from the donors.

Lack of ownership of BAPs

The BAP coordinating agencies were neither legally nor financially empowered to enforce implementation of the BAP/ NBSAP. With low implementation of BAPs/ NBSAPs,

achievements under other governmental plans form the basis for meeting CBD obligations of.

Private sector under-represented

While every effort was made to engage a range of societal actors, NGOs and private sector representation was relatively low. With low engagement of the CSOs and local groups, it can fairly be said that the NBSAP processes were dominated by civil servants particularly those from the conservation agencies. It is advisable to undertake a stakeholder mapping exercise to identity and engage a balanced representation for consultations.

Financial and technical resources

The extent of fund availability is the single most factor determining the comprehensiveness of stakeholder engagement in development as well as in the implementation of NBSAPs. Unlike the funding provided for development and implementation of National biosafety framework under the Cartagena Protocol, funding for implementation of NBSAP was not available. Similar situation in the future may result in non-implementation of the NBSAPs risk that it may remain a document. Further the lack of technical expertise in the country may mean some of the actions requiring technical expertise may not be feasible for implementation.

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