In a letter to Prime Minister Manmohan Singh dated August 2, Jayalalithaa suggested amending of the bill so that allocation of food grain to the states that are implementing a public distribution system delivering a higher level of coverage than the ordinance provides for, is protected.

"This provision should ensure that the present total allocation of food grains to the state under the Antyodaya Yojna, BPL (below poverty line) and APL (above poverty line) categories is not reduced," Jayalalitha said.

According to her, the supply of food grains by the centre should be guaranteed and not restricted for a period of three years. She said that due to the Ordinance, the monthly allocation of food grains for the state will decline by nearly 100,000 tones, from the current level of 296,000 tones.

"Preserving the Universal Public Distribution System in Tamil Nadu will then cost the state exchequer a net additional Rs.3,000 crores per annum.  An even graver concern is the uncertainty of availability, which would expose the state to higher vulnerability of physical shortage, especially during scarcity periods," Jayalalithaa said.

She also said that the ordinance is not clear as to how Union Government will maintain the level of subsidy on the supply of food grains to the states three years after the commencement of the ordinance."This will only increase the uncertainty in ensuring food security over the long run and expose the state's finances to an even greater risk," she said.

Citing Section 8 of the ordinance that requires state governments to pay a food security allowance when food grains cannot be supplied, Jayalalithaa said that such a situation would arise for Tamil Nadu only when the centre fails to allocate and supply food grains."This provision does not answer the fundamental question of making adequate food grains available. The provisions contained in Section 23 are also inadequate to meet such a contingency. Hence, I suggest that Section 23 should be amended to make it incumbent on the Government of India to take all necessary measures, including import of food grains when warranted, to ensure continued supply of food grains and not leave the states to fend for themselves after providing limited financial assistance," Jayalalithaa said.

She said that the centre has taken up the Socio Economic Caste Census (SECC) in 2011 which should form the data base for identification of households."This census process has not been completed and the data is yet to be shared with the state governments in a final, usable form. It is learnt that the Government of India is yet to prescribe guidelines on the manner in which BPL families and eligible families are to be identified based on the SECC data base," she said.

"In these circumstances, the requirement of finishing the identification of eligible households in six months' time is unrealistic and is bound to create many administrative difficulties, exposing the state governments to needless criticism. Hence the first proviso to Section 10(1) may be deleted from the ordinance," Jayalalithaa further suggested.


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