THE Government of India, in the last quarter of 2023, framed some controversial regulations called Green Credit Rules (GCR) under the Environment Protection Act (EPA) of 1986. Undoubtedly, at first glance, it appears to be a good initiative targeting crediting individuals or institutions imparting plantation activities across the country. The Government of India espouses these "climate positive actions" as part of its international commitment towards maintaining a clean atmosphere. The union government believes that, with the introduction of GCR, plantation activities will get a push. But, as often said, all that glitters is not gold; there are several pressing concerns hidden beneath this glamor.

Concurrently, the union government announced the Carbon Credit Trading Scheme (CCTS), 2023. The scheme is built on the amendments to the Energy Conservation Act, 2001, which created a legal framework for the establishment of the Indian Carbon Market (ICM) and the issuance of Carbon Credit Certificates (CCCs). The purpose of this scheme is to incentivise the reduction of greenhouse gas (GHG) emissions through market mechanisms while fulfilling India's climate commitments. In this light, the existing provisions of the Energy Conservation (Amendment) Act, 2022, set the necessary legal backing. One major provision allows the central government to specify a Carbon Trading Scheme according to Clause (w) of Section 14, whereas the amendment grants authorised agencies the power to issue CCCs, with a trading unit equal to one metric ton of CO₂ equivalent (tCO₂e) reduced or removed from the atmosphere. Based on this authority, the CCTS was notified by the government for the purpose of supporting the carbon market. This national scheme aims to price GHG emissions, decrease, remove, or avoid emissions via the trading of CCCs.

The CCTS has two pathways: it provides a compliance tool for regulated industries while offering a voluntary offset tool for the remaining ones. Under compliance, the obligated entity is expected to meet emissions intensity target levels. If targets are not met, energy is purchased with respect to the shortfall; any surplus amounts above those necessary for compliance with the targets can be traded. In the voluntary mechanism, non-compliance companies can redeem CCCs to neutralise their emissions. Therefore, any person or organisation can mitigate their carbon footprint while, at the same time, offering support for emission reductions at remote sites.

There is no doubt that carbon poses a serious threat to atmospheric stability and is a leading contributor to global warming. Only extreme right-wing administrations – such as that of US President Donald Trump and his supporters – have rejected the findings of the Intergovernmental Panel on Climate Change (IPCC) and its recommendations on emissions. As a global community, we must move toward net-zero emissions by simultaneously reducing emissions and enhancing carbon sequestration. However, the means to achieve this must be people-centric and equitable.

WHY CARBON?

Economists typically aligned with interests of the corporates have presented the carbon increasingly as just another tradable asset; according to them, carbon sequestration is the only ecological service provided by forests, natural ecosystems, and plantations. The addition of carbon to the list of commodities would also include the plant resources operated for carbon sequestration. The narrow definition of carbon will also mean overlooking other important ecosystem services, such as maintenance of soil, regulation of water, and conservation of biodiversity. Environmental groups and organisations strongly objected to and suggested amendments to the new notifications. But, as usual, the government chose to ignore those submissions. It should be noted here that the Green Credit System is applicable not only to plantations but also to areas of waste management, sustainable agriculture, and water management.

Carbon is central to the functioning of nature through a carbon cycle wherein all living organisms release carbon dioxide during respiration while plants additionally compensate through photosynthesis – the all-important carbon-sequestering process. A homeostatic balance is kept in nature because of the coexistence of these two processes. Despite our knowledge of it, recreating photosynthesis in the laboratory remains something we are unable to do.

As per Global Forest Watch, India's forests emitted around 510 lakh tonnes of carbon dioxide rather than sequestering it, between the years 2001 and 2022. During this time, forests absorbed 1410 lakh tonnes of CO₂ but could only store 900 lakh tonnes back, releasing the rest into the atmosphere. It is ironical that under the new GCR framework, forests could be cleared further to allow for plantations that qualify for tradable CCCs – a deeply disturbing idea.

HEADING TOWARDS AN ECOCIDE!

Carbon monetisation will make afforested areas – designated carbon sequesters – into commodities in the market. It, therefore, goes without saying that millions of people, who depend on forests for fuel, wild fruits, medicinal plants, and shelter materials, will be marginalised. Gradually, these forested areas may become inaccessible. It would throw much of the non-carbon ecological services from natural ecosystems into the pathway of accelerated degradation. Moreover, ancient trees, apart from classified forest zones (as termed according to the Forest Survey of India), and also existing plantation areas will be incrementally privatised.

The central philosophy of withdrawing governmental institutions out of environmental conservation into market-driven sustainability efforts has to be examined. According to the GCR itself, one other aim of the GCR would be “to encourage industries, companies, and other entities to meet their existing obligations.” One guidance stipulates credit eligibility by having a minimum of 1100 trees per hectare. Such high-density plantation is ecologically harmful: dominant tree species overshadow indigenous ground flora, reduce species diversity, and aggravate soil erosion and hydrological instability.

However, the ideal densities for plantation cultivation would favour the establishment of native species, promote carbon fixation within the topsoil, and offer habitat space for small-sized wildlife. Such good design also encourages natural and secondary ecological succession. Unfortunately, the current model rather mirrors a traditional, timber-focused model that has since been rebranded as carbon market-centric. Non-scientific plantation practices could possibly create a superficial ecological appearance known as "greenwashing" and have raised concerns about the so-called “green deserts” that GCR may spawn.

True conservation of natural habitat takes on many models and practices: natural regeneration, forest protection, wildlife management, and fire management. GCR, however, simply restricts eligibility for green credit to tree planting. In India, we have compensatory afforestation to restore forest land diverted for non-forestry purposes. Yet, this fund often remains unutilised due to land shortages.

GCR application in degraded lands like open forestry and scrublands, grass, wasteland, and catchment areas might invade the space of natural ecosystems and worsen degradation. Grasslands, savannas, and deserts – all hot and cold – coastal zones, wetlands, and marshes – are rich in diversity and hugely significant to millions of people. These ecosystems are complex and generally sit outside the purview of official forest definition. Even the Terai-Duars savanna and grasslands of the Himalayan foothills – which once sheltered species like the extinct Indian cheetah – are under threat of being converted into plantations in the name of carbon sequestration.

Till 2023 the green credit system did not have a standard unit of measurement for awarding benefits. The new rules state that plantations become eligible to generate credits only after an interval of two years. There's no indication of who would be responsible in case plantations fail, totally or partially. Can credits be recalled after issuance? The responsibility to evaluate and quantify the carbon credits rests with the Indian Council of Forestry Research and Education, (ICFRE). Small landholders, however, are left with limited capacity to access the carbon market due to the design of these rules, and are thus more likely to be exploited by intermediary labour.

Also flagged by experts is the possibility of green-washing if transparency and scientific rigor are lacking in the carbon credit framework. There can be a sort of undermining of the programme's intent in the absence of certain sound methodologies and regulatory safeguards. The question of giving an economic value to ecosystem services like carbon raises tough questions. Value from where? What are we conserving truly out there in a world where nature is viewed as a commodity? Conservation is important for the benefit of countries. The ecosystem services we need are irreplaceable – not tradable like carbon credits.