Ecological Concerns in India’s Green Credit Programme: A Critical Analysis of Tree Plantation Modalities

The absence of a universally agreed definition of degraded land across Indian agencies has led to inconsistent estimates and potential misidentification of ecologically significant areas.

Introduction

The Ministry of Environment, Forest and Climate Change introduced the Green Credit Programme (GCP) through the Green Credit Rules, 2023 under the Environment (Protection) Act, 1986, with the stated objective of incentivising voluntary environmental measures.¹ However, the implementation modalities for tree plantation, initially notified on 22 February 2024², and subsequently revised on 29 August 2025³, have sparked significant ecological and legal concerns that threaten to undermine the biodiversity conservation efforts and compromise the integrity of India’s environmental regulatory framework.

The degraded land dilemma: Misclassification and ecological erasure

The fundamental ecological concern stems from the GCP’s approach to identifying “degraded land” suitable for plantation. The Ministry has relied on the National Forest Policy, 1988, to justify time-bound afforestation,⁴ adopting a definition that classifies any very dense or medium dense forest reduced to scrubs or open forest as degraded land.⁵ According to the India State of Forest Report 2023, forest area under open and scrub category comprises 348,789 sq km, constituting 10.61 per cent of the country’s total geographical area.⁶ Between 2011 and 2021, 40,709 sq km of very dense forest and medium dense forest within recorded forest area degraded to open forest category, while 5573 sq km degraded to scrub category.⁷

The absence of a universally agreed definition of degraded land across Indian agencies has led to inconsistent estimates and potential misidentification of ecologically significant areas.⁸ Most critically, this approach fails to recognise the importance of open natural ecosystems (ONEs), which are globally acknowledged for biodiversity conservation and pastoral livelihoods.⁹ In India, nearly 70 per cent of areas with open natural ecosystems overlap with government-designated “wastelands”,¹⁰ demonstrating the systemic misclassification that has persisted since the Indian Space Research Organisation began mapping wastelands in 2000.¹¹

The ecological consequences of this misclassification are severe. Grasslands, wetlands, deserts, scrub forests, and open forests constitute distinct ecological entities whose afforestation would irrevocably alter their ecology, destroying unique flora and fauna including critically endangered species such as the Great Indian Bustard¹², Lesser Florican¹³, wolves, and blackbucks¹⁴ endemic to the Indian subcontinent.¹⁵ The assumption that such ecosystems are unproductive or marginal is fundamentally flawed; grasslands alone sequester 15-20 per cent of the world’s carbon in their soil,¹⁶ while plantations and monocultures favoured by afforestation programs are demonstrably less effective at carbon sequestration than natural ecosystems.¹⁷

The scientific community has identified additional concerns regarding misclassification. Remote sensing spectral signatures of different ecosystems can be difficult to distinguish, leading to erroneous labelling, for instance, mesic savannas being classified as dry tropical forests.¹⁸ The decline of ONEs has already resulted in documented population declines of bird species,¹⁹ underscoring the urgency of preserving these ecosystems rather than converting them.

The unclassed forest problem: Regulatory gaps and vulnerabilities

The selection of unclassed forest as eligible land parcels presents another critical ecological concern. Rules 13(3) and (4), Van (Sanrakshan Evam Samvardhan) Rules, 2023 create a special regulatory regime permitting compensatory afforestation on revenue forest lands, deemed forests, unclassed forests, and similar categories including Zudpi jungle, “chhote-bare jhar ka jungle”, Jungle-Jhari land, Civil Soyam, and orange forest lands.²⁰ These categories often lack the legal protections afforded to notified forests, making them particularly vulnerable to inappropriate interventions.

The September 2025 Guidelines for using afforestation raised under GCP explicitly recognise that “degraded forest lands as identified by the respective States/Union Territories that are recorded as forests in government records and are under the control and management of the State/Union Territory Forest Department” shall be eligible for exchange under compensatory afforestation.²¹ This broad definition encompasses unclassed forests and other vulnerable categories, extending the reach of the program into ecologically sensitive areas lacking statutory forest protection.

The participation of private entities in plantation drives on such lands compound these concerns.²² As Vidhi Centre for Legal Policy research has documented, mis-designated wastelands and ONEs are particularly prone to tree planting initiatives that disregard their ecological significance.²³ Historical evidence demonstrates that State afforestation programs have faced allegations of corruption, with incomplete efforts or misreported data falsely appearing to comply with compensatory afforestation mandates.²⁴

Methodological flaws: Non-scientific approaches and perverse incentives

The original 2024 modalities prescribed plantation blocks with potential for 1100 trees per hectare,²⁵ a figure without scientific assessment that drew considerable criticism from ecologists.²⁶ In semi-arid areas, for example, less than 100 trees per hectare produce optimal benefits for water recharge,²⁷ demonstrating how blanket density requirements ignore geographic, climatic, and ecological variability.

The revised August 2025 methodology addresses some concerns but introduces new complications. The revised rules now require a minimum canopy density of 40 per cent and that trees be at least five years old before Green Credits can be issued.²⁸ While this represents an improvement over the immediate issuance framework, the methodology still fails to adequately address ecological suitability. The revised modalities mandate that “afforestation activities undertaken on degraded forest lands shall use a mixture of indigenous species based on site suitability”,²⁹ but provide no specific guidance on species selection, density variation based on ecosystem type, or verification mechanisms to ensure native species are actually used.

The Detailed Project Report format annexed to the revised modalities requires extensive baseline data including soil characteristics, water availability, existing vegetation, and fauna.³⁰ However, the format lacks provisions for assessing whether plantation is ecologically appropriate for the identified land parcel. The emphasis remains on achieving 40 per cent canopy density rather than on restoring ecosystem functionality or preserving native biodiversity.³¹

Critics have noted that if the objective were ecological restoration, the methodology should measure native biota preservation; if carbon sequestration, it should measure additional carbon sequestered; if livelihood engagement, it should measure capacity and production increases.³² The current metric of awarding one Green Credit per tree aged five years or more³³ fails to capture these nuanced ecological outcomes and potentially incentivises monoculture plantations over diverse ecosystem restoration.

Double counting concerns: Intersection with India’s carbon market

A critical integrity concern emerges from the intersection between the Green Credit Programme and India’s Carbon Credit Trading Scheme (CCTS). Rule 14(5)(i), Van (Sanrakshan Evam Samvardhan) Rules, 2023 mandates that all entities registered for accredited compensatory afforestation must register with the Green Credit Registry, making such afforestation eligible for Green Credits. Simultaneously, the CCTS offset mechanism explicitly permits projects to maintain exclusivity except for the Green Credit Programme,³⁴ allowing dual participation.

This creates substantial double counting risks. The CCTS provides for fixed (10 year) or renewable (5+5+5 year) crediting periods³⁵ and can issue credits based on projected sequestration, while the revised GCP methodology requires a five-year waiting period and 40 per cent canopy density before credit issuance.³⁶ A project developer might calculate that their forest sequesters 1000 tonnes of CO₂ (earning 1000 Carbon Credit Certificates) while simultaneously having 800 surviving trees aged over five years (earning 800 Green Credits).³⁷ The same tree is thus credited for its carbon sequestration value (CCC) and again as a physical tree unit (Green Credit).

When companies use CCCs to claim carbon neutrality in reporting and use Green Credits for corporate social responsibility (CSR) or compensatory afforestation compliance, they essentially claim credit twice for the same environmental action, undermining both systems’ integrity.³⁸ The August 2025 Notification attempts to address concerns by specifying that Green Credits “shall be non-tradable and non-transferable except for the transfer between the holding company and its subsidiary companies”,³⁹ and “may be exchanged once” for specified purposes.⁴⁰ However, this distinction does not resolve the double counting problem, as both credits claim environmental benefit from the same underlying activity.

The additionality principle mandated by the CCTS offset mechanism, i.e., that activities mandated by law are not eligible⁴¹ becomes meaningless when projects can simultaneously generate mandatory compensatory afforestation credits and voluntary Green Credits from identical activities. The September 2025 Guidelines further complicate this by establishing exchange ratios for using GCP restored land for compensatory afforestation, with ratios varying from 2:1 to 4:1 depending on project type and location.⁴² This creates a complex layering of credits and offsets from the same land parcel, with no clear mechanism to prevent environmental claims from being counted multiple times across different regulatory frameworks.

Institutional concerns: Maintenance and long-term viability

The revised modalities introduce a 10-year maintenance requirement with the September 2025 Guidelines specifying that “the user agency shall bear the cost of maintenance and protection of afforestation raised under Green Credit Programme for a period of 10 years”.⁴³ If Green Credits are availed prior to completion of the 10-year period, “the maintenance cost of the remaining period shall be deposited with the administrator”.⁴⁴ While this addresses concerns about short-term plantation survival rates, it raises questions about institutional capacity and accountability.

The memorandum of understanding template provided in the revised modalities places significant responsibilities on District Nodal Officers (DNOs), including facilitating access to land parcels, providing technical support, conducting joint inspections, and taking over plantation maintenance after Green Credit issuance.⁴⁵ This assumes substantial State capacity and resources which may not be available in practice. Historical evidence of incomplete State afforestation efforts and misreported data⁴⁶ suggests that relying on the same institutional framework for GCP implementation may reproduce existing failures.

Conclusion

The ecological concerns surrounding the Green Credit Programme’s tree plantation modalities remain substantial despite the August 2025 revisions. While the revised methodology addresses some procedural issues by extending the waiting period and requiring higher canopy density, fundamental ecological problems persist. The misclassification of degraded land continues to threaten biodiverse ONEs, the inclusion of unclassed forests creates regulatory vulnerabilities, the methodology still lacks rigorous ecological criteria, and the potential for double counting with carbon credits undermines system integrity.

The September 2025 Guidelines’ provisions for exchanging GCP restored land for compensatory afforestation, combined with the lack of clear boundaries between GCP and CCTS, create a complex web of environmental credits that may enable multiple claims for the same ecological benefits. Comprehensive reform is necessary to ensure the GCP serves genuine environmental restoration rather than becoming a mechanism for ecological degradation disguised as conservation. This reform must include scientifically rigorous definitions of degraded land that exclude ONEs; ecosystem-specific restoration criteria rather than uniform density requirements; clear separation between GCP and carbon market mechanisms to prevent double counting; and strengthened institutional capacity for monitoring and verification.