ASHA’s Response on Draft NMNF Guidelines

———- Forwarded message ———
From: ASHA Kisan Swaraj<asha.kisanswaraj@gmail.com>
Date: Sun, 15 Dec 2024 at 12:26
Subject: Draft Guidelines for National Mission for Natural Farming – Reg.
To: <agrimin.india@gmail.com>
Cc: <secy-agri@gov.in>, <yogitarana@nic.in>, <maninder.edu@nic.in>

Dear Shri Shivraj Singh ji,

Namaskaar! In our various capacities in the civil society world and in our engagement with the Government of India Task Force on Organic and Non-Chemical Farming (2015) as Members, we have been waiting anxiously for the agro-ecology/organic/natural farming paradigm to take firm roots in India, even as we seem to be running out of time. When you became the Minister for Agriculture and Farmers’ Welfare, hope soared high. The Cabinet approval to the National Mission on Natural Farming is a welcome development. We would like to compliment the Govt of India and your honorable self for ultimately boldly moving forward and dedicating the largest budgetary allocations so far for agro-ecological transitions in the country. From media reports, we gathered that you were personally keen on the National Mission taking off, that too with greater DBT allocations for willing farmers.

We had the opportunity to go through the Draft Guidelines of NMNF. We are cognisant of the fact that we have in reality only 1.5 years within which time at least two things would be attempted seriously:

(1) large scale human resource deployment in the form of thousands of Farmer Master Trainers (FMTs) and Krishi Sakhis at the grassroots for peer-to-peer motivating, learning and sharing of knowledge, supported by trained NARS scientists and department staff members;

(2) at least 2000 demonstration farms to be evolved, both in the NARS campuses and in chosen farmers’ fields. The rest of the institutional architecture can be evolved gradually.

This is clearly essential and useful as the springboard for the next phase of scaling-up, given that a 1.5 year program for any natural farming scaling up program is a completely inadequate time frame.

Against this expected outcome that too in very short time windows, we have some points to suggest and hope you will consider the same for slight revisions to the guidelines.

1. INCLUSION OF TWO BROAD STREAMS WITHIN NMNF RELATED TO (a) DEFAULT NON-CHEMICAL AREAS AND (b) TRANSITIONING FROM CHEMICAL FARMING: In India, we are losing default organic areas to chemical farming at the same pace as additions to certified organic areas. It is important to protect the default organic areas, which are rich in biodiversity including forest areas, and usually with the kind of communitarian ethos required for practising natural farming. In the default non-chemical areas, there is no need to limit a cluster to 50 hectares. After ground-truthing and social regulation norms at the grassroots, let Large Area Certification (LAC) processes take over, with regulation over sales of agro-chemical inputs (no licensing for sales of agro-chemicals and GMOs to be permitted). Here, intensification of natural farming will yield immediate positive results. In NMNF, let at least 500 clusters be those of such default non-chemical/organic areas, with the budgetary norms being different with discretion on the usage of around 7 lakhs per cluster being left to cluster-level decision-making. In the other stream of NMNF, which could be about transitioning away from synthetic-chemical-based-farming, a 50-hectare cluster is manageable as envisaged. In both streams, grassroots awareness campaigns through theatre, folk media, films, audio jingles etc., IEC materials etc., should reach the maximum number of farmers and not just the farmers enrolled in this phase. This is linked to a subsequent point on DBT to individual farmers to be converted into community-level investments.

2. CONCEPT OF NATURAL FARMING SHOULD BE KEPT BROAD – IT SHOULD EXHIBIT DIVERSITY OF PRACTICES, UNDERSTANDING OF KEY AGRO-ECOLOGICAL PRINCIPLES AND NON-NEGOTIABLE SHUNNING OF SYNTHETIC CHEMICALS AND GMOs: The definition of Natural Farming should not be made rigid, and should include numerous practices which exhibit an understanding of agro-ecological principles. Similarly, the insistence on livestock integration at each individual farmer level as a necessary condition is not appropriate, whereas it is certainly desirable. The definition can even define transitional phases like Non-Pesticidal Management (NPM) of crops etc. but should have the end goal defined of various progressive principles of agroecology incorporated in a highly inclusive fashion, including self-reliance or sovereignty at the farmer-level, community-level, cluster-level and upwards. However, such a definition should specify that it is not only synthetic chemicals like fertilisers and pesticides (incl. herbicides/weedicides) that are prohibited but also genetically modified organisms (GMOs) and products thereof. 

3. EXPERIENCED INSTITUTIONS TO TAKE A LEAD: A transition to Natural Farming is not just about technical knowledge, not just about farm re-designing and not just about new practices to be adopted, as you know. It is about transformed mindsets, and about adoption of an eco-spiritualist value framework. Such transitions need deep conversations at the grassroots. The transition that has happened so far in India (called as scaling-out) has been led by civil society in the country – individual pioneering farmers, farmer collectives and NGOs. CSOs have played a strong role in scaling out agro-ecology, to bring it to the scale it is at, and to make India the country with the largest number of practitioners. However, NMNF guidelines do not have appropriate space provided for such CSOs. It is not clear how the transition will happen when the existing government bodies (both research and extension agencies) currently do not have required perspectives, knowledge, experience and expertise with regard to natural farming. 

Given this context, two things should be incorporated: 

(i) the top-down cascading models where even experienced LNFIs and FMTs have to first be trained by some others needs to be reversed. LNFIs should be allowed to proceed with selection of training of farmers straightaway; 

(ii) this will obviously need re-apportionment of funds to LNFIs. The funds support provided for others including MANAGE and CoNFs can be reduced accordingly and re-distributed to output-oriented work from LNFIs. It will be unfair to expect practising natural farming institutions to help in this transition spending their own resources, and is not practical. 

Please also encourage deserving LNFIs to be included in different steering, executive and monitoring committees at all levels (national, state, district, block) to support the implementation of the program. 

It is also important to include as CoNFs institutions such as Sambhav in Nayagarh (Odisha), Krishna Sudha Academy/Centre for Sustainable Agriculture in Andhra Pradesh etc.

4. FMTs and KRISHI SAKHIS NEED GREATER OUTLAYS, WITH DOWNWARD ACCOUNTABILITY TO FARMERS: We are delighted to see the recognition that the government has accorded to peer-to-peer learning and sharing in the new extension model for NMNF. The accountability of FMTs and Krishi Sakhis should be towards their cluster of farmers, and reporting of their work should be primarily to the farmers’ collective and women’s SHGs/VOs, not to an online portal which is in any case not an effective way of ensuring accountability to willing farmers. Let us not unnecessarily increase the burden on the FMTs and Krishi Sakhis with these requirements, when they are supposed to maintain their own demonstration farms, build other demonstration farms along with NARS institutions, train farmers and also do hand-holding through constant visits to farmers’ fields. This is a lot of responsibility and for this, both the FMTs and Krishi Sakhis have to be paid more than 6000 rupees and 5000 rupees respectively per month. This human resource investment will be the most critical, for sustaining the entire program. For this, re-apportionment from the DBT amounts allocated per farmer per acre should be attempted.

5. DBT TO INDIVIDUAL FARMERS TO BE CONVERTED TO CLUSTER LEVEL DECISION-MAKING ON UTILISATION: We also urge you to keep the guidelines open, for state level, district level and cluster level decisions to be taken, about the farmers using the DBT incentive of Rs.4000/- per acre per year (which constitutes the largest chunk of 1500 crores in all in the budgetary allocation, which is five lakh rupees per year for a cluster) for community-level facilities like localised seed systems through community seed banks, for any small infrastructure facilities for storage and processing, for cluster-specific draught power to be introduced through bullock pairs, for small tool banks etc.    

6. NO NEED FOR A COMPLETELY DIFFERENT CERTIFICATION REGIME: A certification regime normally consists of Standards, Quality Assurance Mechanisms of ascertaining compliance to standards and Labels at the front end. In India, we already have NPOP and PGS-India regimes for agro-ecology. Both NPOP and PGS-India have same standards to be complied with, and at the consumer end, a unified logo or label is in the offing (combining two different logos). The quality assurance mechanisms are different, however, with their own advantages and disadvantages, but giving a choice to farmers to adopt either or both of the systems. At this juncture, to bring in a new regime with new standards and labels is not useful and will also confuse consumers in India and abroad. However, if the government feels the need, it might introduce new quality assurance systems with the same standards and unified label for natural farming also (same as NPOP/PGS-India standards and same unified logo). Even in such a scenario, part of the certification costs of 157.5 crores can be reapportioned, if participatory systems are adopted. 

7. SPECIFY IN THE GUIDELINES OTHER SCHEMES AND PROGRAMS WITH WHICH DOVETAILING IS DESIRABLE AND IMPORTANT: It would be important to specify in the guidelines itself all the other schemes and programs with which convergence and dovetailing will be ensured, so that implementation agencies across different states actively do this – NREGS, PM-PRANAM if an entire district or block converts itself into natural farming, JIVA, PKVY, state level or sub-state level schemes if any etc. We have also heard about a new scheme that the Government of India will introduce on community managed seed systems of traditional seed varieties which would be ideal to be taken up in NMNF clusters. Through such dovetailing, integration of natural resource management at landscape level including commons like water, forests, grazing lands and pastures, localised seed systems, livestock etc. can be improved. This will enhance the potential of landscape level transformation and make it easier for other farmers to follow suit.

We hope that you would consider the above points for inclusion in NMNF guidelines, since these guidelines will now set the basis for much-needed large scale transitions in Indian agriculture, and needless to say, the right kind of orientation will set a strong foundation for the path forward. We are available for any clarifications on the above points. Thank you. 

Sincerely,

Kapil Shah Umendra Dutt Kavitha Kuruganti

7567916751 9872682161 8880067772

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Alliance for Sustainable & Holistic Agriculture (ASHA-Kisan Swaraj)

FOOD – FARMERS – FREEDOM

www.kisanswaraj.in

www.indiaforsafefood.in