Tree growing is still harassed in India with old colonial laws. Good that govt is bring changes in FCA to remove the hurdles. My comments for FCA amendment

1. Comments on Forest conservation act - amendment
We, tree growing farmers, thank, recognizing difficulties created by
FCA for growing trees in farm lands and outside the govt’s forest land.
45000 crores worth of wood import is based on old wood log import
date, yet to account wooden products and related wood industry &
employment opportunities. Good that FCA amendment objectives
recollects, 33 year old forest policy commitment of greening 33%
India. Actually 40 % green is possible (Japan has 67% green cover),
with necessary changes in the act, policy, rules…..
1) As NITI Aayog mentioned in it's 2016, Agri reform, “ All tree
species grown in farm land shall be free from felling and transit
regulations” – as simple as that. For that there needs to be clear
definition of “Forest” and “Agroforestry (better say Treeculture or
Tree lands as mentioned in shri TSR Subramaniam, High Level
Committee report, 2014).
a. All wood that comes from farm lands shall be treated as
agriculture produce as per AGMARK act 1937, will not be
covered under FCA.
2) There should not be any restriction for growing, felling, selling,
export of our native valuable tree species, in the name of
scheduled trees. There is no basis for classification of scheduled
trees. Note: Scheduled trees list was created by British for their
use, yet to be reviewed after 75 years of independence.
Hardtruth, no organization has population details of any of the
tree species neither in forest nor in farm lands.
a. FCA shall mention that States shall declare any tree as
scheduled without any basis. Threatened species list shall
be derived from IUCN. If states feel, then it shall represent
to GOI to interact with IUCN and update.
b. There shall be forest trees, no permission to fell or use
except for research
c. FCA does not restrict FARM land Tree felling. Farmers grow
for their survival, a good deed benefits all.

2. 3) IUCN, International Union for Conservation of Nature, a good
international initiative, but India does not have interaction with
them. IUCN has got elaborate guidelines for classification of
threated species (endangered species). The hard truth is that no-
org in India has list of our native endangered tree species as on
2020, RTI. And also, there are no guidelines available for
recovery (at least conservation of the same). So, BSI and ZSI
shall create list of endangered plant species and animal species
of India and recovery guidelines shall be created within 2 years,
as conservation is mandate of MoEFCC. Note: as per IUCN
norms, a species is classified as endangered only based on it’s
population in wild, not concerned about it’s population in farm
lands.
a. FCA shall mention that conservation of endangered tree
species is mandate of MoEFCC in 20% lands in their
control.
b. FCA shall mention that MoEFCC shall list our native
endangered tree species, from IUCN Redlist.
c. MoEFCC shall create guidelines for conservation of
endangered tree species
d. Conservation parks shall be created by converting back
exotic eucalyptus in leased forest lands.
e. So, MoEFCC shall have a conservation of endangered
species division which shall be made in-charge to interact
with IUCN
f. Green India mission (div) has failed. Many more such
divisions in MOEFCC. All such ineffective division shall be
restructured for conservation.
Note: Clarity on conservation of endangered species will free
restriction for TREE growing FARMERS.
4) Farmers will take up tree growing only when it is profitable.
Polluting “knitting” is promoted, un-replenishable granite is
allowed for export, but not our native valuable, demanded woods
like Sandal. Now, Australia becoming major Sandal exporter,
reason is colonial FCA.

3. 5) Even though GOI, has allowed farmer’s Red Sanders wood for
export, due to cumbersome procedures, it has not picked up.
1000s of farmers eagerly waiting for removal of cumbersome
procedures. (Refer NBA’s Expert committee report 2017 for Red
Sanders).
6) The root cause for restriction is that there is no knowledge of
CITES (Convention on International Trade of Endangered species
of wild flora & fauna). The reason for IFS officers not familiar is, it
is not covered in their syllabus (ref RTIs). CITES norms clearly
says that there is no restriction for exporting from artificial source
(farm lands) even if it is critically endangered.
7) The fundamental of CITES is, it allows farm produce to meet the
need that will reduce damage to natural resources, a
Conservation model, CIRCA – SITUM. So, all woods from farm
land trees shall be allowed for export.
a. FCA shall mention that IFS syllabus shall be updated every
5 years in line with IUCN and CITES.
b. MoEFCC shall have endangered tree species conservation
division.
Note: Hard truth, biodiversity rich India is not member in plants
or animal committee of CITES, whereas Saudi Arabia is a
member.
8) There are no guidelines for what has to be done when an
endangered species is found in project alignment. It is creating
problem for land acquisition, many court cases, delays for project,
frustration for farmers. Need clear objective guidelines.
a. FCA shall say, compensatory plantation in land acquisition
shall be 1:3 for normal trees (Leased concern as per IUCN,
1:5 for Near Threatened, 1:10 for Vulnerable, 1:25 for

4. Endangered, 1:50 for critically endangered, 1:100 for extinct
in wild….
b. It is responsibility of forest department, not of farmers
9) Forest conservation includes, protecting it from any form of
damages / disturbances. To keep wilderness of forest, avoid
plastic pollution. No-one shall be allowed in the name of
ECOTOURISM inside the forest, except certified researchers...
There is no valid proof that ecotourism is profitable for the govt.
Even if it is profitable, it shall be avoided. A broken bottle can kill
an elephant, saw it in river bed of Avalanche, near Ooty – western
ghats. Ecotourism shall be encouraged only in private lands, in
every district, maybe with incentives to start with.
10) Eco-green parks shall be created in every town / city using
drainage waters. It shall have more of local native species in
mixer, at least 25 % of threatened species. A conservation model.
a. FCA shall mention that part of conservation of endangered
species, every dist forest dept shall publish threatened tree
species of that area and send copy to all govt offices,
collectors and shall provide saplings free of cost. Incentive
for surviving / living trees shall be considered.
Note: Biodiversity rich India should not have any tree in
Endangered list by 2050.
11) Forest lands shall not be leased except for important
strategic purposes, with approval of central govt. Note:
TAFCORN has 71000 hectares of forest land under lease for
monoculture plantation, growing monoculture eucalyptus, cashew
etc. It is fundamental against “1988 Forest Policy”, as forest is for
conservation only. So, There shall be no monoculture plantation
in forest lands, as monoculture plantation in forest land will
destroy biodiversity - against fundamental of forest (wilderness).
a. There shall be no monoculture even like native palm...etc.
b. Monoculture shall be allowed only for research or recovery
of endangered species.

5. Fundamentally, CONSERVATION is mandate of MoEFCC / forest dept
in forest lands / public lands, NOT of poor farmers.
Note: Allowing 10000s acres monoculture Tea / coffee plantation in
biodiversity rich western ghats and restricting tree growing farmers is a
blunder.
Meeting wood needs shall be through FARM LAND TREES, with
Silviculture ( agroforestry ). Silviculture need not to be part of IFS
syllabus, anymore.
All culturing is part of agriculture, Forest is wilderness – SIMPLE
Wish India becomes 40% Green by 2050
With such reforming acts & policies.
Draft by : RP Ganesan BE, Semmara Semmal,
Tree growing farmer & Policy Analyst
with a motive to make India 40 % green
and No Endangered tree species, native of India.
My struggle to remove hurdles for Tree growing in general
and Red Sanders in particular.
https://www.slideshare.net/GanesanRP/representation-to-
indias-members-of-parliament-on-hurdles-for-tree-growing