New Delhi: An open letter by 91 former civil servants to the environment ministry vehemently opposing its Green Credit programme has turned the spotlight back on the Modi government policy that experts claim leans more towards making it easy for corporations to get environmental clearances than encouraging them to fulfil environmental obligations.
Notified in October 2023, the Green Credit programme, the methodology of which was published on 22 February, aims at “incentivising” environmental action using market mechanisms, and allows companies or individuals to buy ‘green credits’ through actions such as tree plantation.
In their open letter to the Union Ministry of Environment, Forests, and Climate Change, the civil servants’ group known as ‘Constitutional Conduct Group’ called on the ministry to withdraw the notification, saying the assault on Indian forests was ”continual and unrelenting”.
Under the Compensatory Afforestation Fund Management and Planning Authority (CAMPA) Act 2016, any diversion of forest land needs to be compensated with afforestation on land of the same size.
However, under the new policy, such deforestation can be offset by purchasing existing green credits and doesn’t require companies to provide land in lieu, the letter said.
“…the government is trying to make it easy for entrepreneurs and industrialists to acquire forest land by permitting them to offer, in exchange, money (in the form of green credits), instead of land for land as was the case so far,” the Constitutional Conduct Group has alleged in its letter, adding that “quick, smooth, and easy diversion of our forest lands in favour of user agencies is apparently the sole intention” of these rules.
ThePrint reached Leena Nandan, secretary at the Union Ministry of Environment, Forests and Climate Change, for comment via email. This report will be updated if and when she responds.
Here’s a breakdown of the green credit policy and why experts are concerned.
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What are green credits
Green credits are similar to the voluntary carbon credits market that exists internationally. Like companies can purchase carbon credit to offset emissions, the green credit scheme permits an individual or company to plant trees or carry out afforestation activity in ‘degraded land parcels’ identified by the state forest departments to get green credits. They can then use these to offset any deforestation activity or to compensate for any non-forest use of forest land.
Under the scheme, companies can apply to the administrator, the Indian Council of Forestry Research and Education — the sole authority to provide green credits. The rules notified in October list eight activities that could secure green credits — tree plantation, water and waste management, sustainable agriculture, air pollution reduction, mangrove conservation and restoration, development of the government’s ecomark label to identify environment-friendly products, and sustainable building and infrastructure.
However, the methodology released last month only incentivises tree plantation at the rate of one green credit for every tree planted, “subject to minimum density of 1100 trees per hectare, based on the local silvi-climatic and soil conditions, on the certification of completion of tree plantation provided by the Forest Department concerned”.
According to this notification, state governments will have to identify ‘degraded land parcels’, including open forest and scrubland, wasteland, and catchment areas, under their administrative control and management. These will be ”made available for tree plantation to promote activities for increasing the green cover across the country for the purposes of generation of Green Credit under the said rules”, it says, adding that such land parcels “must be free from all encumbrances and must have (the) size of five hectares or above”.
Why experts are opposing it
One of the major points of opposition is the definition of “degraded land”. According to Naini Jayaseelan, a retired IAS officer and one of the signatories to the open letter, the term is a misnomer.
“The one document that’s paramount for information on Indian forests is the Forest Survey of India report that comes out every two years. That report only mentions three kinds of forests — dense forests, moderately dense forests and open forests. There is no mention of degraded forests, so how will the state governments define the area for tree plantation?” she asked.
The other problem is that the kinds of land mentioned under the term could bring under its ambit land parcels that several tribal and pastoral communities are dependent on for survival.
“So the proposal allowing the forest department to allocate degraded forests could potentially affect the diversity of land uses and community forest resources,” Tushar Dash, an independent researcher working on forest rights and governance in Odisha, said.
Another major concern is that the green credit rules, instead of encouraging corporations to fulfill environmental obligations and undertake voluntary actions, could make it easier for them to get environmental clearances for projects. According to Dash, the provision of generating a bank of ‘degraded forest land’ that could be used for trading green credits “provides multiple benefits to private companies”.
In their open letter, the former civil servants call the concept of green credits “anachronistic”, seeing it as a “tool for monetising the natural environment and handing it over to the corporates for exploitation”. Instead, the letter suggests that state governments could restore the lands using government funds instead of depending on the private sector.
The letter also calls the policy “unscientific”, saying that tree plantation isn’t always the best method for carbon sequestration. It also points out that different ecologies need different kinds of biodiversity, and uniform afforestation would actually “bring an end to the survival of many species” in Indian forests.
“We are a group of former civil servants who have served the Central and State governments in various capacities. We have no affiliation with any political party but feel strongly about upholding the provisions of the country’s Constitution,” reads the letter.
(Uttara Ramaswamy)
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