Green Credit Rules: Death By Trees?

As the rain clouds gather darkly over the grasslands and fields of Shokaliya village in Rajasthan, throngs of birders congregate. In the monsoon of 2014, I joined the annual pilgrimage to witness the fabled jumping-jack breeding display of the lesser florican. With the rain angling down, we watched a slender black, white, and gold-sequinned male float up into the sky, arch his head with fluttery ribbons curling upwards, and let loose a volley of rattling calls to attract the female. This endemic nomad, about which little is known, makes a guest appearance to pirouette for the female in the rains before it rather mysteriously vanishes for the rest of the year. However, receding grassland habitats and seasonal variations in rainfall have caused its numbers to decline, leaving it critically endangered. But implementing the recently passed Green Credit Rules might contribute to wiping out the lesser florican, along with the great Indian bustard and other iconic species already on the brink.

The amendment of the 1980 Forest (Conservation) Act (FCA) in 2023 sent shock waves through the country. It was met with widespread protests and citizens have since challenged it in court. But the amendment also set in motion a concatenation of notifications and rules. These supposedly green epistles, especially the Green Credit Rules, could prove lethal to many of our natural ecosystems, turning them into tree-lined ecological graveyards.

The Centre issued the Green Credit Rules (GCR) in October 2023 under the Green Credit Programme (GCP), aimed at using market-based mechanisms to incentivise environmental protection. Industries and others can generate green credits for various activities, including tree plantations. A notification issued on February 22, 2024, indicated the method to earn credits via tree plantations. This notification specifies planting a minimum of 1100 trees per hectare according to local silvi-climatic and soil conditions, where each tree equates to a single green credit.

The GCRs are a double whammy for Indian forests. States must afforest land to compensate for diverting forests, including diverse and wildlife-rich ones, for non-forest use, under the rules of the FCA and its 2023 amendment. This is known as Compensatory Afforestation (CA). However, the GCR now allows green credits generated by growing trees to meet these CA obligations. Hence, the GCRs lack even the already limited latitude of compensatory afforestation. For instance, while CA does not stipulate ecological restoration to restore deforested areas, the Compensatory Afforestation Fund Act of 2016 allows using CA funds for several activities other than artificial regeneration (plantations). These include assisted natural regeneration, forest protection, wildlife protection and management and the Green India Programme. In contrast, the GCRs only apply to plantations, which, as any ecologist knows, could never replace the loss of natural forests.

Most alarmingly, the GCRs also promote growing trees over and above these CA requirements — such as for corporate social responsibility — on forest lands. For instance, the GCRs allow tree planting on degraded land parcels, including open forest and scrubland, wasteland, and catchment areas that are under the administrative control and management of the forest department.  The GCR ambit is far more expansive — and insidious — than CA since it allows tree planting on some of the most unique and fragile ecosystems, speciously written off as degraded lands or wastelands, should states choose to do so.

Misleading criteria

The prevailing use of canopy closure as the sole indicator of ecological worth relegates most non-forest ecosystems to degraded status, i.e., with either open canopies (densities <40%) or as scrub (<10%). But one could hardly expect ecosystems such as grasslands and savannahs, cold and hot deserts, coastal areas, wetlands, and marshes, harbouring their fair share of rare, endangered and endemic species, to be thickly forested. Such ecologically important open or treeless areas are labelled Open Natural Ecosystems (ONEs). Under the GCRs, ONEs under the administration of the forest department are fair game for industrial-scale tree plantations–if states decide to parcel them out for such activities.

The GCRs use subjective criteria to identify sites for planting – only partially based on an ecological or scientific foundation. Canopy closure is no barometer of the value of a non-forest ecosystem. Is a desert a degraded ecosystem that requires tree planting because it is branded open forest or scrub? If so, should one not shroud the Desert National Park with trees? This unscientific approach has led to the misplaced focus on planting trees in Ladakh, a unique and fragile mountain cold desert. Ladakh has evolved its unique set of adapted fauna and flora over countless years of evolution. Planting trees endangers this native biodiversity.

Misclassification of ecosystems is also rife. For instance, it is easy to erroneously label mesic savannahs as dry tropical forests because remote sensing spectral signatures of different ecosystems are sometimes difficult to distinguish– such as grasses with rainfed agriculture or forest plantations and woodlands.

The British played an instrumental role in tilting the bias against non-forest ecosystems, particularly grasslands. Grasslands were nothing more than a forest blank. Since then, undervalued grasslands, which support a high density of mammals and 500 million livestock and are also important for below-ground carbon sequestration, have been considered prime targets for afforestation. In the shola grasslands of the Western Ghats, this ill-advised planting of exotics has obliterated 23% of the total shola grassland, reducing populations of the endemic Nilgiri Pipit and Nilgiri Thar.

Tree-covered wastelands

The importance of non-forested Open Natural Ecosystems (ONEs) covering 10% of the land surface of India in the low-elevation arid and semi-arid regions – is recognised globally for biodiversity conservation and as the wellspring of pastoralist livelihoods. Not only are ONEs misclassified, but in large part, they are also officially labelled wastelands in the Wasteland Atlas of India. An astonishing 69% of semi-arid ONEs coincide with classified wastelands, while the protected area network provides refuge to less than 5% of the area under ONEs. Much of India’s fabled wildlife lives outside the protected areas, many in these so-called wastelands.

As mis-designated wastelands, ONEs are prone to tree planting. These areas may encompass some of the largest tracts of ONEs spread across the States of Rajasthan (30%), enveloping sand dunes, grasslands and thorn scrub of the Thar, and the savanna grasslands and open woody savannas of Madhya Pradesh, Maharashtra, and Gujarat. Planting trees will further attenuate their already precarious state. The State of India’s Birds (2023) report found that birds of ONEs have declined precipitously. For instance, there has been a more than 50% dip in grassland specialists due to existing habitat loss and degradation.

But the GCR may not only turn some ONEs into jungles of the dead. Tree plantations, especially monocultures of oil palm or rubber, may well replace parts of India’s most diverse forests in northeast India. The Wasteland Atlas pigeonholes regenerating shifting cultivation fallows as wastelands, despite a 2018 NITI Aayog report pointing to the fallacy of this approach. Shifting cultivation, or jhum, is carried out primarily in the Eastern Himalayan and Indo-Burma Biodiversity Hotspots. In jhum, patches of forests are cropped for a year or two and then left fallow to regrow forests. These so-called wastelands, consisting of active crops and regenerating fallows, span at least 8,446.76 sq. km of the northeast.

Figures from the Wasteland Atlas, which suggested a halving of areas under jhum in just two years, led the NITI Aayog to question the authenticity and accuracy of these figures. Despite the report suggesting that shifting cultivation lands with long fallow cycles should be classified as distinct land uses, not as abandoned land, wastelands, or unclassed state forests, they remain in limbo. The NITI Aayog’s analysis also highlights the unreliability of the current data designating an area as marginal. Based on this data and the odd notions of what constitutes wastelands, vast swathes of India’s most productive lands are just waste. These includes some of the most biodiverse jungles under jhum, permanent snow-clad mountains–the source of rivers–or marshes that are important for water recharge and have high ecological diversity.

Definitional issues complicate the picture.  There is no clear consensus on what constitutes a wasteland or how it differs from degraded lands. Hence, the Wasteland Atlas and the Atlas of Degraded Areas provide different areal estimates. As a result, it is impossible to quantify degraded or wastelands with any degree of certainty.

Missing the wood for the trees

The next issue is the questionable extent and quality of India’s existing forest cover. Open forests compose 9.34% of India’s geographical area (GA); scrub forests cover 1.42%. Together, they constitute almost 11% of the GA. Even if we exclude the forest cover comprising scrub, virtually half (43.2%) of the extant forest cover is in the open category. Are we going to convert half of what remains of forests–which includes non-forest ecosystems such as savannah grasslands and deserts, as mentioned earlier–to plantations for green credits? Or should we focus instead on regenerating, restoring, and rewilding ecosystems, which goes beyond merely planting trees? Ecological restoration aims to revitalise the structural integrity and functional niches of forests. As even a child knows, a forest is far more than trees. A forest includes the multi-layered tree canopy, the shrub understory, the herbs, and the soil–with their interlinked faunal assemblages.

Orchards, parks, and plantations that also count as forests already inflate the reported forest cover. Implementing the GCR would mean that significantly more than half of India’s forests could be just plantations in the foreseeable future.

Studies suggest that plantations cannot provide the same ecosystem services as a forest. Therefore, the tree-centric GC approach will be detrimental to the ecosystem services of carbon and water. Afforestation is not a panacea nor the most effective climate-mitigation solution. For instance,  plantation activities in ‘catchment’ areas, as envisaged in the rules, are unlikely to restore water flows or store as much carbon as natural forests.  The effects of afforestation on soil organic carbon are also context-dependent, according to a recent study. Afforestation increases soil organic carbon density in C-poor soils (lower in organic carbon), but decreases it in C-rich soils, especially in deeper soils. This overestimate the ability of afforestation to enhance soil organic carbon using the fixed biomass to soil carbon ratios assumed by previous studies.

Recent research shows that regrowing natural forests could mop up 23% of global CO2 emissions from the atmosphere each year because the ability of regrowing natural forests to capture carbon is higher than previously estimated. Current Intergovernmental Panel on Climate Change (IPCC) defaults underestimate carbon accumulation rates in young forests by 32% globally and 53% for tropical forests. Protecting, ecologically restoring and regrowing natural forests rather than planting fast-growing, non-native, and commercial monocultures would likely yield more benefits for biodiversity, local communities, hydrological water flows, and carbon sequestration and storage.

Rigid plantation norms

Uniform prescriptions of 1100 trees are best suited to commercial plantations of one to a few species that are best grown on private lands. Forest areas with existing rootstock, seed sources, and relatively intact soils need nurturing to regenerate. Tambe et al. (2022) argue that plantations fail to address the drivers of degradation in the first place. Unless we tackle these issues with the approval and involvement of local communities, plantations are doomed to fail, particularly in the absence of accountability for high mortality and low survival. In the words of Patton-Cook et al. (2021), it is best to “protect, manage,”–here I would also add regenerate–“and then restore lands for climate mitigation,” rather than simply growing trees. The February 22 guidelines excised even the few precautions–such as lists of tree species that would be appropriate to plant in specific rainfall zones–that appeared in the draft rules of October 2023. Plantation norms became even more rigid, from the more flexible 100-1100 to a fixed 1100 per ha.

Each forest type is unique, with its distinct species composition and abundance, fine-tuned to its local environment and ecosystem. Prescribing a fixed number of species to plant across ecologically distinctive areas is absurd. Rain-drenched tropical rainforests, for example, are heterogeneous, with bewilderingly high densities of trees and lianas compared with a dry thorn forest adapted to desiccation. In semi-arid areas, less than 100 trees per ha produce the most benefits for water recharge. The selection of tree species and numbers for plantation is context-specific and requires precise tailoring to the rainfall, forest type, soil, topography, and microclimate.

Poor track record of compensatory afforestation

But do pan-Indian tree plantations or afforestation drives work? We could look at India’s CA track record to gauge this.

There is sufficient and compelling evidence that CA, the principal afforestation programme in the country, suffers from numerous flaws, despite the availability of more than 50,000 crores. Government data indicates the diversion of 3.05 lakh ha of forest land between 2008–09 and 2022–23. To compensate, the forest department afforested 9 lakh hectares.

Critics have found fault with several aspects of CA, such as the questionable quality of lands selected for afforestation, failure to obtain the consent of tribals and other forest dwellers, and planting of lands in ecological zones distant from the diverted forests. For instance, the government intends to destroy the tropical rainforests of Great Nicobar Island to build a container port and then offset this loss with a zoo safari in the distant Haryana Aravalli Hills.

Significantly, almost 60% of the CA funds remain unspent. According to an analysis of CA from Himachal Pradesh, “over half of the state’s budget for tree planting is wasted on plantations that are unlikely to survive and/or are poorly designed to achieve the state’s goal of increasing forest cover.” Interestingly, the 2013 CAG compliance report on CA questions the absence of adequate safeguards for CA and the reliability of official data on CA.

Although field-based research on the efficacy of CA is scarce, current sources starkly underline the failure of CA on several fronts.  The evidence suggests that these plantations show poor survival rates and fail to simulate natural forests. CA often occurs in areas of high tree cover– defeating the very objective of afforestation–or where the biophysical situation is unconducive to plant survival. In the Kinnaur Division of Himachal Pradesh, locals uprooted tree seedlings from the grasslands where they traditionally grazed their cattle. Across the country, it is often impossible to trace plantations listed in government records.

The tree species fail to reflect either biodiversity values or the preferences of local communities. Instead, the focus is on fast-growing species. Most CA programmes ride roughshod over local people, failing to take their consent, ideas, and support. The GCRs fail to mention local communities or their rights over forests, which the Forest Rights Act (FRA) guarantees. The 2022 Rules of the FCA eliminated the need for consent from the Gram Sabha for forest diversion. The GC is also deafeningly silent on sharing the benefits with the communities. Empirical research suggests better outcomes where communities participate in monitoring and management and have access to secure community rights.

Beset with problems

The GCR is beset with numerous problems and lacks even a token exhortation to plant diverse native species or emulate the structure or composition of a forest. Industry can use forest lands and other productive ecosystems to raise industrial-scale plantations and generate compensatory afforestation credits.

All these changes signal a reversion to a British-origin, revenue-centric vision for India’s forests. These overturn decades of engagement to shift the policy needle to conserving forests for biodiversity, ecosystem services, and the rights of local communities, culminating in the enactment of the Forest (Conservation) Act of 1980 and the Forest Rights Act of 2006. We should repeal the GCR, recognise the value of open natural ecosystems in their own right, and alter our perceptions, mapping, and definitions of waste and degraded lands. Biogeographic and ecosystem-based approaches must supplement indicators like canopy cover.  Simultaneously, it would behove us to move from a plantation or even compensatory afforestation-driven focus towards ecosystem restoration in the current U.N. Decade on Ecosystem Restoration.

Or else, I might never again see the ballerina of the grasses dancing in the rain.

(Published under Creative Commons from Mongabay-India. Read the original article here)