Reply from MoRD on issues raised by RTF - Right to Food Campaign

By Luis Hunt,2014-08-04 10:43
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Reply from MoRD on issues raised by RTF - Right to Food CampaignRepl

     Replies to points raised by Right to food Campaign on SECC 2011

    Right to Food Campaign (RFC) have made two sets of comments, one, opposing the BPL approach and two, regarding the methodology of the SECC 2011. The observations of the organizations and our comments are given below:


    Approach to BPL targeting:

    RFC: The RFC states that the official poverty lines are very low and hence BPL Census does not serve the purpose of identifying these households. It also states the BPL Census is highly unreliable and the criteria are conceptually flawed with enormous exclusion error especially in the last three BPL Census. It also restricts the entitlement of functional public services like TPDS etc.

    Response : The Joint Press Release of Deputy Chairman, Planning Commission and MRD, states that the state-wise poverty caps as estimated by Tendulkar Committee will not be used to impose any ceilings on the number of households to be included in different government programmes and schemes and that the eligibility and entitlements of rural households in the country for different central government programmes and schemes will be determined after the SECC, 2011 survey results are available and have been analysed. Therefore the concerns of the RFC on these issues have been addressed.


Problems that need to be sorted out before the SECC can proceed

1. Enumerating Household:

    The SECC survey proposes to use the household as defined as 'a group of persons who commonly live together and would take their meals from a common kitchen unless the exigencies of work prevented any of them from doing so', which would leave out a large number of migrant and vulnerable households who do not have a separate dwelling. The new guidelines allow the household to identify themselves as a separate household for the survey but it will not have meaning unless an alternative definition is provided to the enumerators.

Use the definition used by the MNNREGS Operational guidelines wherein the household’ will

    mean a nuclear family comprising mother, father, and their children, and may include any person wholly or substantially dependent on the head of the family. Household will also mean a single-member family

    RESPONSE: The SECC survey is using a flexible definition of households which allows migrant and vulnerable households even if they share food from kitchen to be treated as separate households. Single member households are also allowed and those households who want to use the definition of nuclear households to identify themselves as part of a household are allowed to do so. The relevant sections of the instruction manual are pasted below.


Page13 section 2, definition of household


    above. For example, a person living alone in a Census house, whether cooking meals or not, will have to be treated as a single member household.

    she should be recorded as a separate household. Widowed, separated, second wives, single women are some examples of women who could declare themselves as a separate HH. living together and taking food from her/his master’s household are not eligible to be treated as a member of her/his master’s household. For the purpose of the SECC, such persons are to be treated as a separate household(s) and the enumerator must enter them as separate households and canvas the questions to them separately.”

    Guidelines provided for developing the Abridged House List also clarify that households that were canvassed during the NPR may be split into two or more households (if for instance, any of the situations listed above arise), and provision is made to record each of these separately.

These points will be further emphasized during training of enumerators.

2. BPL Criteria Questionnaire Disconnect

    These are points for which a post-survey data processing will not be able to correct any errors and which require changes in the questionnaire and/or instruction manual for enumerators before the commencement of the survey.

Side A Type of Household: The definition for Households without Shelter lists only those

    sleeping in the open or in certain kinds of public buildings. (Houseless household: Houseless

    household is defined as ‘households which do not live in buildings or houses but live in the open or roadside, pavements, in hume pipes, under fly-overs and staircases, or in the open areas near places of worship, mandaps, railway platforms/stations etc.’) . Thus households that are nomadic

    and live in tents on public land or on private land belonging to other people, are not to be listed as ‘Households without Shelter’. Similarly any household that is effectively without shelter but has raised a temporary shelter on land not owned by it should be treated as being without shelter. The questionnaire does not collect any information on whether or not a household owns homestead land. Survey with the current questionnaire and instruction manual will not ensure that households without shelter are effectively listed.

    RESPONSE: The SECC is expected to cover all households, including nomadic households who are present in the enumeration block at the time of the survey, and those living with or without shelter. For nomadic households, instructions will be issued to enumerators to record that the household is nomadic and not a permanent resident of the panchayat in the comments section.


    All houseless households are expected to be canvassed on a specific day of enumeration in each EB/sub-block (typically the last day). The definition of houseless households provided in the instruction manual lists some examples of such households. It makes no assumptions about whether tents/temporary shelters are on public versus private lands. However, as pointed out, it is possible that a household that is living without shelter but has raised a temporary shelter on land not owned by it, may get classified as a ‘Normal’ (i.e., not houseless) household. For all such households, information is being collected on the type of material used for wall and roof, and ownership status of house. These two questions will be jointly used, in a back-end exercise, to identify those households that live in temporary shelters (like plastic/polythene or grass/thatch etc.), on land that they neither own nor rent (ownership status is ‘other’).

    Side A Column 4: There are only two Sex Categories, Male / Female. The survey will thus miss out on recording information on even the existence of transgender individuals.

    RESPONSE: The questionnaire will be revised to include a separate code for transgender. In states where data collection for the SECC has already been completed, or are in the process of partial completion, instructions will be given whereby those who wish to declare themselves a s transgender can come forward at the time of filing claims and objections

    Side A Column 11: There are only 6 religion Categories and no space for those answering ‘Other’ to the religion question. This goes against Census norms and will most likely force many households to choose among the 6 listed religions. This will have the most negative consequence for Tribal people.

    RESPONSE: There are no codes for religion in the questionnaire or in the instruction manual for rural areas. The SECC is collecting the actual name of the religion as reported by the respondent. In addition, it should be noted that religion is not used either as an exclusion indicator or as a deprivation indicator.

Side B Column 1 and Column 2: The questionnaire asks about the predominant material of

    wall and the predominant material of roof. A household with different rooms built with different material will have the predominant material listed. For instance a household with an IAY house with two pucca rooms and a kutcha room in addition to that will logically have predominant material of wall as well as roof listed as pucca materials. Such a household will be excluded on the basis of the ‘Three Pucca Room’ criteria. On the other hand a household with three pucca rooms and four kutcha rooms will have predominant material of roof as well as wall listed as kutcha materials. Such a household will naturally not be excluded.

    RESPONSE: The questions on type of roof and wall have been included in this format for two reasons. First, the SECC questionnaire is structured, wherever possible, to be consistent with the questionnaire that was canvassed during the population census. This will allow a village-by-village cross-check of the data produced by the SECC against the population census, and provide a mechanism to re-check information when there are major discrepancies between the two sources of information. It provides a valuable cross-check on the quality of SECC


    information that is collected. With this objective in mind, the SECC asks about predominant material of wall and roof, in the same way as the Census did. Second, the questionnaire is kept as simple as possible; collecting information on walls and roof of each room separately will make the questionnaire more complex. The examples mentioned above are likely to be exceptions.

Side B Column 1 and Column 2: The questionnaire lists burnt bricks as a category and mud as

    another category. Presumably while the former will be treated as pucca, the latter will be treated as kutcha. There are large number of rural households which are made from burnt brick with mud used as mortar. As per the instruction manual such households will be treated at par with houses made of brick and cement mortar and the only information available from the questionnaire will be the material code 8 for wall.

    RESPONSE: Thank you for alerting us to this issue. We note that the SECC is only collecting information on the predominant material for construction, without using the word pucca and kutcha anywhere in the questionnaire. Classification of predominant material into pucca and kutcha is a back-end exercise, and the concern raised should be kept in mind while deciding on the exact definition.

    Side B Column 4: The count of how many rooms are in possession of the household will be based on the definition of a living room as at least 2 metres long, 1.5 metres wide, and 2 metres high. Unless this is corrected the enumerators will keep counting even goat sheds as living rooms. Interestingly one pucca room of the aforementioned size will mean that the household will get no point for being short of home space while three pucca rooms of this size will exclude the household from the BPL List. Three such rooms will total 96 square feet. NABARD’s norm for space needed for male goats is 20 square feet per animal. A 96 square feet house with 5 members means 19 square feet per person. A single pucca room of 32 square feet (6 square feet per person) or two kutcha rooms of 64 square feet (12 square feet per person) will in any case ensure that the household gets no deprivation score. The questionnaire also does not collect whether the houses were built as part of disaster response programme in which case the size of the house would not reflect the economic situation of the household at that time. For instance in the 2004 Tsunami rehabilitation programme, many poor fishing households have been provided pucca houses with two bed rooms, one living room and a kitchen apart from toilet and bathroom. Such households will be excluded from the BPL List as per the current survey. The size of houses provided by Red Cross, for instance, was about 330 square feet excluding toilet and bathroom. Three rooms as per the SECC norms, could total under 100 square feet.

    RESPONSE: In response to feedback from you and others, a revised instruction manual was issued in August. The current instruction manual does not specify any size for room. It is also specified that rooms used for Kitchen, bathroom, latrine, store room, passageway and verandah will not be treated as dwelling rooms.


    Side B Column 11: Different states have different levels of exemption for Professional Tax. There are many states where PT is levied on salaries below 10,000 rupees. In Kerala PT is applicable on a salary of 2,000 rupees, while in Gujarat and West Bengal PT is payable on a salary of 3000 rupee; in Tamil Nadu and Assam PT is applicable on a salary of 3500 rupees; in Maharastra, and Andhra Pradesh it’s applicable on a salary of 5,000 rupees. In the first five states mentioned, the salary at which PT is applicable, is less than the minimum wage rate for unskilled workers. As information on whether the household pays income tax or professional tax is collected in one column, the survey will not be able to identify if a household is an income tax payee or only a professional tax payee.

    RESPONSE: In this context, a separate question is being asked on salary earned. Thus as a back-end exercise, households that pay professional/income tax but do not have any member earning Rs 10000 or more can be exempted from exclusion based on the tax indicator.

Side B Column 13: The question on ‘Main Source of Household Income’ clubs too many

    different types of occupations under ‘Non-Agricultural Own Account Enterprise’. For instance it

    lists a factory owner under this criteria as well as weaver. Once the survey is over it will not be possible to identify whether a household’s main source of income is from low-income

    occupations such as of weavers/ barbers/fishers etc. or from higher income occupations such as ownership of a hotel / factory. For instance Sri Mukesh Ambani and a weaver household will be clubbed under the same category. It also includes those working under the Jajmani system which is a violation of the Bonded Labour Section 2G of the Bonded Labour System Abolition Act 1976. In fact by not including such households as Bonded Labour the MORD will be violating the Bonded Labour Act as well as recent NHRC order in the matter under case no.13/18/2006-07.

    RESPONSE: For the purpose of simplicity and ease of data collection, the codes listing different household occupations have been limited to a small number. The listed codes and information collected elsewhere in the questionnaire are sufficient to measure the list of exclusion and deprivation indicators.

    However, we should also note that in the present format, if more detailed information on household occupations is needed (e.g., differentiating weavers from the rest), the information will be available from Block D which also collects information (un-coded) on occupations for every individual in the household.

    Side B Column 14: Small shopkeepers even in villages sometimes have refrigerators to store items for sale. The survey does not differentiate between households that own a refrigerator for domestic use (indicating a better standard of life) and those which own one for their livelihood.

    RESPONSE: although the concerns expressed are valid, there is no way to verify the use of the assets. This is not only applicable for refrigerator but for all other assets.

    Side B Column 15: There are poor households, especially persons with disability who have been given licenses to operate telephone booths as a livelihood activity. The income from such


    activities is not very high. The survey will not differentiate between such households and households that have taken a landline connection for their personal use. In case the survey is done in the present manner, the ‘landline’ criteria cannot be used to exclude any households.

    RESPONSE: This is a valid concern. Ownership of landline and motorized vehicles as an exclusion criterion for households with disabled members will be examined. Thank you for drawing this to our attention.

    Side B Column 16: The census collects a Yes / No answer for whether the household owns a motorised two-wheeler/three-wheeler / four-wheeler. Once the survey is over, it will not be possible to distinguish between owners of two-wheelers from owners of four-wheelers. Its already becoming clear that many poor households own two wheelers that they have bought for as little as 5,000 rupees and below and which they use for petty trade. This especially affects tribal people le living in hilly areas for who a motorised two wheeler is a greater necessity than plains people who may be better able to do with bicycles. In case any changes to the criteria are to be made subsequently and two wheelers (or three wheelers) are taken out of the Exclusion criteria, it will not be possible to get information on which households own two wheelers / three wheelers and do not own four wheelers.

    An even more unfortunate outcome of the current survey process would be that motorised three wheelers and modified two wheelers used by orthopedically handicapped persons will be not treated differently from two wheelers and three wheelers used by the non-disabled. This would mean the exclusion from the BPL list of all such disabled person who have received motorised mobility vehicles from the government or from non governmental organisations.

    The caste census handbook specifies that only motorised boats requiring registration will be used as an exclusion criteria. But the instruction manual asks the enumerators to write the response as th‘Yes’ whether or not the boat requires registration or not (Page 36 of Instruction manual of 20

    June 2011, as uploaded at the ministry website). Thus at the end of the survey information on which are the households with motorised boats requiring registration and which are the households with motorised boats that do not require registration will not be available.

    RESPONSE: The survey is collecting information separately for two, three and four-wheelers.

    Regarding motorised fishing boats, both the questionnaire and the manual (p.36, column ‘Asset’) clearly state that information is being collected on boats requiring registration. This will be emphasized in training.

    Side B, Column 22: While the exclusion criteria mentions exclusion on the basis of ownership of pump-set along with tube well / bore well, the questionnaire only records information about pump-sets and not about tube/bore wells. At the end of the survey there will be no information available to exclude any household on the basis of ownership of irrigation infrastructure.


    RESPONSE: The SECC collects information on the possession of irrigation asset which is diesel pumpset or electric pumpset. It does not collect information on possession of wells nor is possession of wells a criterion for exclusion. The confusion arises because of difference in nomenclature of diesel operated pump-sets and electric pump-sets (in some states they are called tube wells).

3. Suggested by Pilot Process but not incorporated in the SECC

    The Pilot Survey had suggested that information on Chronic Illness be collected and used for assigning BPL Status. The SECC does not collect any information on Chronic Illness and hence it will not be possible to address this concern once the survey is over.

    RESPONSE: The pilot survey did not suggest that chronic illness be used as an indicator.


Overall Process Issues

    The original instruction manual circulated to the enumerators (the basis for the survey for all states in which survey has already started) had asked the enumerators to ensure that no one other than the enumerator, the data entry operator and the members of the given household should be present during the canvassing for any given household. The new guidelines say that enumerators can be accompanied by Gram Panchayat / Gram Sabha members as well as by other citizens. Even now in the absence of a pre-survey mandatory Gram Sabha the process will essentially keep the Gram Panchayat / Gram Sabha and others in the dark about when and how the survey is going to take place. In such a situation how can they send representatives to accompany the enumerator? It is essential therefore that no survey should take place till Gram Sabhas have been organised to intimate them about the process and the rights and responsibilities of the Gram Panchayat and the Gram Sabha in the process. The Gram Sabha should come up with the list of representatives of the Gram Sabha who should accompany the Enumerator. Gram Sabha should also be the point where new households are identified.

    Response : The state governments have been requested to give wide publicity to the SECC. Similarly Gram Sabhas will also be directed to give wide publicity to SECC and encourage their representatives to accompany the enumerator. Separately the Ministry is readying media tools such as posters, radio clips etc to spread the awareness on SECC.. Also the draft lists of households are placed in the gram panchayts and other public places. The modalities for claims and objections of households at the time of gram sabha will be posted on the website and sent to the state government for wide dissemination.

    Most households and Gram Panchayat members will not be able to read what has been entered in the Tablet Computer. This will ensure that the process is not-transparent. Unless it is proven that


    the household or a Gram Panchayat / Gram Sabha representative accompanying the enumerator is comfortable with a tablet computer, there paper forms should be used to ensure transparency. Tablets are not proven technology and there are no reports of these having been successfully used for pilot runs. Also it is interesting that the Population Census process was done with paper and not with Tablet Computers.

    Response: The tablet PC has a number advantages which include that once the data is saved after enumeration, the same cannot be retrieved which prevents subsequent manipulation of data. The data is also uploaded on the local server and then on to the main server which can be viewed by all the stakeholders on a daily basis so as to correct any anomalies as and when they are found..

    The Tripura Survey must have been completed by now. It would be an ideal time to take a break and look at how the survey has performed. The big issue in a BPL Survey is not whether any household is surveyed or left out of the survey. The big issue is if it has been properly identified as poor or non-poor. For all its technological innovations this is one area that might not have been addressed properly. A close look at the Tripura process will help correct problems with the survey before it moves on to other areas of the country. Else like 2002 the government will end up pushing the process because it has made preparations to do so and leave it for the next government to point out that this survey was full of exclusion and inclusion errors in the same manner as the 2011 survey seeks to dub the 2002 survey as a faulty process without taking lessons from what made that process as faulty as it was.

    The Abhijit Sen Committee formed to oversee the SECC does not have representatives of any of the deprived groups that are likely to get left out. Two such groups are Person with Disability and Single Women. Members.

     Response: All the States/ UTs have launched or are launching SECC by December 2011 and the work of enumeration is under way .Data is flowing in and the same is being looked at to ensure that corrective action is taken on a continuous basis. Also a decision has been taken that number of households to be included in different government programmes and schemes and their eligibility and entitlements for different central government programmes and schemes will be determined after the SECC, 2011 survey results are available and have been analysed. Therefore all possible efforts are being undertaken to ensure that the poor households will be included in the lists .



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