Presentation on the "Development of Coal Sector in Central India - Sustainable Coal Mining - Forest, Wildlife & Environment Perspective Coal Mining Plans" made in the "Coal Summit, 2018" organised by the Ministry of Coal, Government of India, in 2018

1. WELCOME TO THE PRESENTATION
ON
STATUTORY & NON-STATUTORY REFORMS FOR
SUSTAINABLE COAL MINING –
FOREST, WILDLIFE & ENVIRONMENT
PERSPECTIVE COAL MINING PLAN – 2025 & 2032
BY
Ravindra Nath Saxena
Former Principal Chief Conservator of Forests,
Madhya Pradesh

2. Theme: Can India Grow Sustainably without Green Coal?
• Nymex crude, Brent crude, WTI crude and all 150 crude
Indices are moving upward – predicting tough time.
• Trade wars among US – China – Russia – Iran; fragile,
unstable political situation in the Middle East Asia,
• India imports 82% of the crude demand.
• Rupee sliding vis-a-vis US$ - every increase in crude by
1US$/B, import bill of India is increased by 1billion US$.
• Availability of coking & non-coking coal is declining
sharply in the international market.
• Uranium-235 is not available to India. Hydel power
uncertain due to receding / uncertain rainfall.
The only ray of hope is “sustainable coal mining in
Central India with Mitigation Planning”

3. At the time of promulgation of the Constitution of India,
subject of “forests” was kept in the “State List”.
There was no entry of “wildlife”.
“Forests” transferred to the “Concurrent List”, List-III as
Entry–17A and “Wildlife” as the Entry-17B by the
42nd Constitutional Amendment Act, 1976.
Article-251 & 254 of the Constitution provides that state
statutes cannot be repugnant to Central Acts. If there is any
repugnancy, state statutes automatically becomes
“null & void”.
Constitutional provisions related to
“forest” & “wildlife”
All forest & wildlife statutes - FCA, WLPA, IFA, PESA, STOFDRFRAct
are Central Acts. The statutory reforms are in jurisdiction of the
Parliament. Statutory reforms virtually impossible for next 2 years.

4. PRECARIONS CONDITION OF MINING UNDER THE
CONSTITUTION OF INDIA (SCHEDULE – VII)
Environment & Residuary
Power
Entries–6,24,27,53, 54 & 97
Union List, List-I
SPCB’S/PCC’S Under State
Government
Mines & Mineral Development
Entry – 54,
List-I, Union List
Entry – 50, List – II
State List
Forest & Wildlife, Land
Entries – 17 A, 17B
Concurrent List
List – III
Entry – 18 State List, List-II
Articles – 245 to 254 deal with Union-State relations. Sometimes
Statutes have overlapping jurisdictions; rarely repugnant also.
Constitutional amendments shall take very long time.
Efficiency and attitude of civil services are the key words for success.
Perfect “project planning” to reduce timeline is must for success.

5. TWO STAGE “FOREST CLEARANCE” MECHANISM UNDER
FOREST (CONSERVATION) ACT, 1980;

6. Flow chart for obtaining “environment clearance”

7. Post “environment clearance” monitoring mechanism

8. Barrier Analysis to Forest (Conservation) Act, 1980 and
Environment (Protection) Act, 1986;
• Intricately woven “forest clearance” and “environment clearance”,
but impact assessment carried by different departments of State
Government & MOEF, and two different committees – FAC and EAC
examine project proposals.
• Land is having heterogeneous origin – forest, revenue forest,
dictionary meaning conforming forests, blanket notifications.
• Frequent modifications of constitution of committees.
• Absence of specifications of “parameters of impact assessments” in
FCA and EPA. Parameters of “impact assessment” modified
frequently by committees without any justification. Same parameter
assessed by two committees.
• Cumbersome, lengthy case assessment at several levels.
• No well established co-relation between “forest clearance” &
“environment clearance”.
• Move to amend IFA and make it PESA and ST&OTFD(RFR) Act
compliant – shall lead to lots of local socio-political interference.

9. Forest Cover of India (S.F.R., 2015 of Forest Survey of India)
Diversion of about 300 sq.kms. forest areas (0.04%) in next 20 years
can solve the energy problems of the country. Most of these coal
blocks are situated in different micro & milli-watersheds –
consequently it would not cause great ecological problems.
Coal Blocks are site specific projects and should get priority
Mineral rich areas
of coal and coal bed
methane (CBM).
Also inhabit large tribal
population - FRA

10. Scheduled Tribe & Other Traditional Forest Dweller
(Recognition of Forest Right) Act, 2006

11. • STOTFD(RFR) Act, 2006 enacted and became operational on 1st
January, 2007.
• Jurisdiction over all types of forest areas – RF, PF, revenue
forests, village forests, dictionary meaning of forests etc.
• Two types of rights can be claimed:
A. Individuals can claim upto 4.00ha per person.
B. Community can claim any area (without limit).
• Open ended Act. Claims can be put-up any time.
• Forest areas not to be de-notified i.e. both STOTFD(RFR) Act,
2006 and Forest (Conservation) Act, 1980 shall apply.
• No involuntary eviction / settlement – huge cost shall be
involved.
• Linear projects e.g. roads, transmission line, skyline crane,
conveyor belts, pipelines etc. shall be almost impossible.
Scheduled Tribe & Other Traditional Forest Dweller
(Recognition of Forest Right) Act, 2006

12. Forest Areas Assigned under Forest Rights Act, 2007*
 Individual Forest Rights – 4119650 Acres
 Community Forest Rights – 9985095 Acres
 Total Forest Area - 14104744 Acres
 Total Forest Area Assigned - 5876976 Hectares
 Total Forest Area Assigned - 58769.76 Square Kilometer
 Percentage of forest area assigned - 8.66%
* All data obtained from the “Administrative Report - 2017”, Ministry of Tribal Affairs, GoI.

13. Linkage of F.R.A. with M.M.D.R. Amendment
Act, 2015
• The M.M.D.R. Amendment Act, 2015 have been
acted to amend M.M.D.R. Act, 1957.
• The “non-captive mining leases” shall expire in 2020
and renewal of these ML will face the issues of
“forest right pattas” assigned in “unbroken
mineralized zone of ML”.
• Since involuantary “acquisition” not possible – shall
become serious constraint.
• Studing what shall be the linkage of F.R.A. with Coal
Bearing Areas (A&D) Act, 1957; Coking and Non-
Coking Coal Amendment Act, 2001.

14. Panchayatiraj Extension to (Scheduled Areas) Act, 1996.

15. Background Scenario of Statutory Clearances
• There are 584 coal blocks in the country, almost all are situated in forest
areas. About 30-40 small coal blocks are located in Teak forests, rest
approximately 524 coal blocks situated in Sal forests.
• Forest (Conservation) Act, 1980 & Environment (Protection) Act, 1986 (EIA
Notification, 2006) provides for assessment of the cases; but parameters for
assessment are not defined. Artificial & complicated parameters adopted by
FAC, EAC, Standing Committee of NWB etc. Parameters change with the
modification in composition of committees. Root cause of delay.
• Amendments in Forest (Conservation) Act, 1980; Wildlife (Protection) Act,
1972; Indian Forest Act, 1927; Environment (Protection) Act, 1986 are not
required for reforms.
• The target production (Integrated Energy Policy) of 2600mt by 2032 is not
possible without development of indigenous, greenfield coal resources.
• Diversion with effective mitigation planning is possible (11.3% of opencast
production cost). Alternate wildlife corridors [Section-38O(g) of WLPA] can
be developed, fragmentation & porosity can be taken care-off. Indigenous
coal still much cheaper than imported coal.
• All factors are under the control of GOI.

16. FORESTS AT A GLANCE
• Geographical area – 32,87,263 sq. kms.
• Forest area – 7,57,740 sq. kms.
• Forest cover – 6,78,333 sq. kms. – the eco-resource for livlihood.
• Legal status of forest area –
A. Reserve Forests (RF) – 3,99,919 sq. kms.
B. Protected Forests (PF) – 2,38,434 sq. kms.
C. Un-classed forests – 1,36,387
• Un-culturable non-forest areas – 2,11,286 sq. kms.
• Growing Stock – 4740.858 million cubic meter
• Growing Stock / ha. – 74.42 cubic meter
• Current Annual Increment – 8.76 million cubic meter
• Current C.A.I. - 0.69 cubic meter / ha.
• Potential CAI possible - 3.60 cubic meter / ha. (Peterson’s formula)
• Simpson’s Biodiversity Index, Berger-Parker Species Richness Index,
Shannon Weiner Biodiversity Index not provide promising picture.
• Forest cover stagnant with cyclical change, qualitative
deterioration of ecological resources due to scarcity of finances.

17. Complicated nature of Coal Mining Projects, require
meticulous planning at the landscape level

20. Location of the Tara Coal Block &
1920 M.W. Thermal Power Plant of I.C.P.L.
Tara Coal Block
located at the
fringe of Hasdeo
Arand
ICPL Power
Plant site
Submit only one “forest application” for entire project

21. Status of mining & infra-structure projects in the
Central India
• Important States – Madhya Pradesh, Chhattisgarh,
Jharkhand, Uttar Pradesh, Jharkhand, Odisha, Telangana and
Maharashtra - Most of the minerals available except
petroleum. Coal rich districts are having 40-55% forest cover,
hence minimal adverse impact on “regional ecology”.
• 584 coal blocks, 17 CBM blocks (all in Sal forests, area more
then 600 sq.kms.)
• Resisting forest area diversion is impossible – develop
“Mitigation Planning Techniques” – Greenbelt Plan, Safety
Zone Plan, Cluster Approach in Mining, Reclamation
Planning, Landscape Plan, Biodiversity Indexing, Wildlife
Habitat Management Plan, Wildlife Rehabilitation &
Resettlement Plan, Ecological Risk Analysis, Corporate Social
Responsibility (CSR) Plan, Tree Transplantation Plan, etc.

22. Composite Maps of Forest Cover and Geological
Maps – Divert areas with scrub forest cover with
rich Coal Reserves on the priority
Focus on degraded, low crown density, violate forest areas in Perspective Coal Plan -2025
and leave high crown density, inviolate, wildlife sensitive forest areas for
Prospective Coal Plan – 2032.

23. Diver
sion
Site
Composite Map of Wildlife Protected Areas and Coal Blocks
Buffer
Zone
Distance
from
protecte
d areas
Wildlife
Activity
Areas

24. Tree Enumeration & Biodiversity Assessment
• Biodiversity indexing – Shannon-Weiner Index ,
Brillouin Index, Brillouin Eveness Index, Simpson’s
Index , Margalef Index, McIntosh's Measure of
Diversity, Berger-Parker Index etc.

25. Forest Satellite Imagery – only land-use discernible,
legal status cannot be ascertained
“Gap Light Analyser” is available for Crown Density
Determination. The forest crop should be analysed on crown
density, site quality, regeneration, Yield Table parameters,
Basal Area calculation based on Wedge Prism.

26. Sample Plots & Biodiversity indexing
To carry-out biodiversity indexing to obtain baseline data
– Shannon Weiner Index and Importance Value Index

27. * N.B. Kind attention invited to blanks, under stocked and encroachments
Leave aside areas with High Ecological Index
and phased felling to reduce adverse impact

28. Projected future of trees in various girth classes
S.
No
Type of area Number of
trees below 60
cms.
Number of trees above 60 cms. Total
Number
of trees
1. Protected forests 63460 103893 167353
2. Revenue forests 6652 13750 20403
Total 70112 117643 187756
3.
Status of future of
trees in next 30
years in Tara Coal
Block
70112 trees
are being
transplanted
There are 43299 trees in “pre-selection girth classes”
shall achieve selection girth in next 30 years. Tara Coal
Block is having 15184 trees above “selection girth” of
150 cms.; achieved “economic rotation” and eligible
for felling.
4.
Net impact of tree
felling in 30 years in
Tara Coal Block
No impact on
70112 trees,
since these are
being
transplanted
About 58483 trees are in either “pre-selection” or
“selection girth classes”. eligible for felling in current
working plan or become eligible for felling in next 2
working plans (total period 30 years).
187756
5.
Net number of
trees to be felled
due to Tara Coal
Project
There are 187756 trees – 70112 trees being
transplanted, 58483 trees shall be harvested in next
30 years in working plans. The impact felling of Tara
Coal Bloc is 59161 trees or 1972 (59161 trees / 30
years) trees per annum.
59161

29. Regional Eco-restoration Measures Planned
S.
No.
Activity Area of
activity
(in ha.)
Number of
seedlings
per ha.
Total
number of
seedlings
Remark
1. Reclamation of OBD
in “diversion area”
1801.31 1600 28,82,096 Multi-tier
reclamation
2. Compensatory
Afforestation
1301.19 1600 20,81,904 Medium density
plantation
3. Landscape
Management Plan
2200.00 2500 55,00,000 High density
eco-restoration
4. Tara Wildlife
Management Plan
3000.00 2500 75,00,000 High density
fodder plots
5. Safety Zone 39.73 2500 99,325 High density
with SMC works
Total 1,80,63,325
Note - A. Approximately 34.57 times seedlings shall be planted in the very first phase .
B. Total tree felling in 30 years – 117643
C. Total seedling plantation – 1,80, 63,325
D. Eco-restoration ratio – 1: 153.54

30. Issues related to wildlife and Wildlife (Protection) Act, 1972
National Parks - 85 Conservation Reserve - 2
Wildlife Sanctuaries - 602 Community Reserve - Nil
Tiger Reserves - 49 Elephant Reserves - 64
Denotification virtually impossible (HSC order dated 13th November, 2000

31. Present & Potential “Protected Areas” of India

32. Contraction of Asian Elephant Range Over-time

33. Wildlife Corridors & Satellite Imageries

35. Most threatened wildlife species - I
Use electrified fencing, if
required.

36. Most threatened wildlife species - II

37. Most threatened floral species - I

38. Global Temperature Range

39. Indicators of Human Influence

40. Spatial patterns of the changes in annual mean
surface air temperature
[2071-2100 (baseline 1961-1990 : A-2 scenario)

41. Spatial patters of the changes in summer
monsoon rainfall
2071-2100 (baseline 1961-1990 : A-2 scenario

42. CHANGES IN ANNUAL NUMBER OF RAINY DAYS
(A-2 scenario)

43. Impact of Climate Change on Forest Biomes
Distribution of Forest Biomes
in 1975
Projected distribution of Forest
Biomes in 2085

44. Impact of Climate Change on Forest Biomes
Distribution of Forest Biomes
in 1975
Projected distribution of Forest
Biomes in 2085

45. Red indicates that a change in vegetation is projected at that grid in the
time-period of 2021-2050 and 2071-2100 (under A1B scenario). Green
indicates that no change in vegetation is projected by that period.
Climate Change and Forests
Vegetational changes projected by 2021-2050 and 2071-2100
Based on computer simulation models of National Remote Sensing Agency & ICFRE

46. PROJECTED
IMPACT OF
CLIMATE
CHANGE
ON
FORESTED
GRIDS IN INDIA
A2 SCENARIO
Source: Chaturvedi et al., 2011
39% of the forest grids likely
change under A2 scenario by
2085 causing loss of Carbon
stock and biodiversity
1 = stable grids
2=forest grids
undergoing
change

47. Biodiversity Vulnerable Grids of India (marked red) in
the A1B scenario – for India - 2035 and 2085
Climate Change and Biodiversity
Vegetational changes projected by 2021-2050 and 2071-2100

48. Forest type distribution and extent
simulated by IBIS for the baseline case
and A1B (2035 and 2085) scenarios. (VT –
refers to Vegetation Types. The numbers
refer to the following vegetation types
1: Tropical evergreen forest / woodland,
2: Tropical deciduous forest / woodland,
3. Temperate evergreen broadleaf forest /
woodland,
4: Temperate evergreen conifer forest /
woodland,
5: Temperate deciduous forest /
woodland,
6: Boreal evergreen forest / woodland, 7:
boreal deciduous forest / woodland, 8:
mixed forest / woodland,
9: Savanna,
10: Grassland/ steppe,
11: Dense shrubland,
12: Open shrubland,
13: Tundra,
14: Desert,
15. Polar desert / rock / ice)

49. NPP distribution (kgC/m2/year) simulated by IBIS for baseline and A1B scenarios
Impact of CC on Net
Primary
Productivity (NPP)
Current NPP –
835 g C/m3
A2
GHG scenario –
doubling of
NPP predicted
B2
GHG scenario -
73% NPP
increase
predicted
NPP Increase in
all the forest
grids projected
due to CO2
fertilisation
effect

50. LOCATION & FOREST COVER

51. Coal
Block
Study baseline data of district & project location, satellite Imagery
map depicting protected area, wildlife activity areas and
compensatory afforestation sites
Thoroughly study climatic and edaphic factors
before starting reclamation planning

52. Maps and satellite imageries
Forest maps are vital for silviculture crop assessment and
determination of prescriptions for reclamation planning

54. Sample Plot Photographs for crown density and
basal area determination by Wedge Prism

55. Limitations of Satellite Imaging in India
 Species composition cannot be determined.
 Forests stand composition cannot be determined –
Every forest stand is having a different “Different
Reflectance Signature” (Hyper Spectral Signature,
256 spectral signatures being used in USA, but not
being used in India).
 Mostly satellite imageries of October /
November is used in India – thus seasonal and
phenological occurrence is very
importance because “Chlorophyll Reflectance
Index” is related to – total rainfall, rainfall
distribution, temperature pattern, long and
intermittent rainfall season is likely to interfere in
canopy density determination.

56.  Coppice composition in the canopy cannot be
assessed. However 2 new interpretation
techniques have been developed:
A. Natural Vegetation Differential Index (NVDI).
B. Leaf Area Index (LAI)
But certainly conclusion cannot be inferred whether
these 2 canopy assessment techniques have
been used in satellite maps of FSI.
 Site Quality Assessment could not be possible
earlier. Recently LIDAR (Laser Detection And
Range) has been developed for height assessment.
Sensitive height assessment tool i.e. can measure
10 cms changes. But IRS-C data is not having
compatibility with LIDAR. Serious drawback as
canopy height from the ground is concerned.

57. Stratum wise Estimated Growing Stock of of Sal & Teak
forests in different States
S. No. States Teak Sal
1. Andhra Pradesh 19603 -
2. Assam - 17848
3. Bihar (including
Jharkhand)
- 68970
4. Gujarat 36174 -
5. Haryana - 699
6. Karnataka 22810 -
7. Kerala 1000 -
8. Madhya Pradesh
(including CG)
122644 141706
9. Maharashtra 110308 520
10. Manipur - 260
In 000 cubic meters

58. S. No. States Teak Sal
11. Meghalaya 640 6148
12. Orissa 902 149509
13. Rajasthan 337 -
14. Sikkim - 413
15. Tamilnadu 315 -
16. Tripura 1402 832
17. Uttar Pradesh (including UA) 2561 124383
18. West Bengal 1302 4171
19. Dadra & Nagar Haveli 549 -
Regeneration, senescence, repeated coppicing,
fragmentation, porosity and juxtaposition are serious
issues for longevity of Sal & Teak species
in the country

59. Landscape Atalas of Madhya Pradesh

60. INVIOLATE FOREST ECOSYSTEMS

66. Degradation & opening of Sal forests
 Sal forests are now open, crown density reduced to 0.4
or less, degraded, suffering from soil erosion.
 Absence of regeneration, no seedlings or saplings.
 Sal crop is only consisting of pre-selection girth
classes. Death of Sal forests is certain after achieving
senescence.
 Virtually no control over grazing. No Class-I Protected
Area in the administration.

67. Soil erosion in Sal forests
 Due to senescence in Sal crop, it is desirable to
promote associate species.
 Conserve Sal seed by rotational closure or collection or
blanket ban to promote regeneration.
 Demarcate & monitor “Sal Borer Plots” for disease
surveillance. Sporadic attack still continuing.

68. Analysis of Crop Assessment

69. Analysis of Crop Assessment – Phoenix Infestation
 Large scale crop dried and died after Phoenix sylvestris
infestation in Nagri & Sihawa (Dhamtari district, CG) and
Narharpur, Keskal, Korar, Pharasgaon Ranges (Kanker &
Kondagaon district, CG) in 1980s.
 Sal Regeneration absent except Kanha National Park, MP.
 “Sal seed collection”, huge threat to Sal regeneration.
 Critically small “germination period” of 7 days. Monsoon is
shifting to July and August. Genetic incompatibility.

70. Phoenix sylvestris and P. acualis infestation in Sal forests

71. Invasive species in Sal forests, CG - 1
 Invasive species of Opuntia and Cactaii observed in
Korba and Surguja districts of C.G. These species
were not found about 30 years ago.
 These invasive species signify drying of Sal forests.
 Serious “genetic erosion” observed in Sal crop.

72. 72

73. Effect of opening of canopy in Sal forest
Encroachments are opening canopy in Sal forest, leading to
drying of forest floor and consequently invasion by invasive
species – making Sal seed germination and
regeneration impossible.

74. Invasive species in Sal forests, M.P.
Calotropis procera, C. gigantia, Argemone maxicana, one more
species of Argemone genus observed recently.

75. Invasive species in Sal forests, M.P.
 Invasive species of Ocimum grandisimum (new
invasive species) observed in Mandla, Dindori,
Shahdol and Umaria districts. These species were
not present about 30 years ago.
 Signifying drying of Sal forests.
Solidification of forest floor and baking due to recurrent forest
forest fires biggest hurdle in Sal seed
germination & regeneration

76. Dried Sal Forests

77. Dried Sal Forests

78. Underground Mining versus Opencast Mining
All “assessment committees” are pressuring project
proponents not to undertake opencast mining in
diversion area.
Compartment RF 830, Beat Karkatti Compartment RF 825, Beat Sironcha

79. Trees and other vegetation are drying & dying within 10 years
of underground mining – study may be carried-out to
establish truth.
Compartment RF 825, Beat Sironcha Compartment RF 830, Beat Karkatti
Leave this technical matter on the wisdom of MOC, MOM
and State MRD for appropriate decision

80. Assessing Stem Condition in Timber Depot

81. Assessing Stem Condition in Timber Depot

82. Teak logs exhibiting signs of senescence and fire
damage

83. Teak logs exhibiting signs of senescence and fire
damage

84. Impact of Sal Borer & consequent heavy
mortality in crop
Caused by larvae of Haplocerambyx spinicornis, Order
Coleoptera. Insecticide or fumigation not possible since
infestation is caused in Monsoon.

85. Impact of Sal Borer & consequent heavy mortality in
crop
Promote “Biological Control” or increase proportion of
associate species to reduce vulnerability of “Pure Sal” crop.
Root cause of Sal Borere attack – Removal of associate
species of Sal and consequent creation of monolith Sal stands,
polyculture Sal less susceptible to Sal Borer attack.

86. Sal Regeneration Technique to be adopted on
Technically reclaimed sites and degarded sites
• Protection against biotic interference.
• Deep soil working upto 45 cms depth.
• Collection of winged Sal seed and direct sowing of five
kilogram seeds per ha.
• Monitoring of germination of Sal seeds and
maintaining soil moisture regime if monsoon is
delayed. The soil moisture regime shall be maintained
with the use of geo-textiles, if required.
• Humus enrichment by farm yard manure / sewage
sludge.
• Standardise Sal Nursery and plantation technique for
wide spread application.

87. Assisted Sal Regeneration
Forest School, Distt. Jagdalpur, Chhattisgarh

88. Assisted Sal Regeneration
Site Ambikapur Nursury, Distt. Surguja, Chhattisgarh. Sal Crop raised in 1984-85

89. Sal Plantation
Rajgamar Plantation,
CG Forest Department,
Korba Range,
Korba Division,
Chhattisgarh
Chotia Mine,
Prakash Industries
Hasdeo- Arand Coalfield,
Distt. Korba,
Chhattisgarh
Urgently develop “techniques for Sal plantations”

90. Typical Teak forests in the country
Site quality degrading very fast, soil fertility going down,
depleting moisture regime

91. Typical Teak forests in the country
 Economic value fast declining.
 Re-assess site quality of these Teak forests.
 Root-Shoot planting technique is required to be
replaced by Pre-sprout or poly-pot.
 No reduction in “selection girth” below 120cms gbh

92. Effect of repetitive coppicing in Teak crop
Stump vigor seriously declined due to repetitive coppicing

93. Effect of repetitive coppicing in Teak crop

94. Serious Phoenix sylvestris infestation in Teak
plantations in Mixed forests

95. Serious attack of Teak Powdery Mildew on Teak
Crop

96. Serious attack of Teak Leaf Skeltonizer and
Teak Leaf Defoliator in Teak crop

97. Serious attack of Teak Leaf Skeltonizer and
Teak Leaf Defoliator in Teak crop

98. Gall formation and un-sustainable resin
exploitation in associate species
Sterculia urens Boswellia serrata Butea monosperma

99. Recommendations
• Get prepared “Perspective Coal Mine Plan – 2025 and
2032” to increase production to 2600MT, as mandated in
the Integrated Energy Policy. Phase-wise planning.
• Important States – Madhya Pradesh, Chhattisgarh,
Jharkhand, Uttar Pradesh, Jharkhand, Odisha, Telangana
and Maharashtra - Most of the minerals available except
petroleum. Coal rich districts are having 40-55% forest
cover, hence minimal adverse impact on “regional
ecology”.
• 584 coal blocks, 17 CBM blocks (all in Sal forests).
• Resisting forest area diversion is impossible – develop
“Mitigation Planning Techniques” – Greenbelt Plan, Safety
Zone Plan, Cluster Approach in Mining, Reclamation
Planning, Landscape Plan, Biodiversity Indexing, Wildlife
Habitat Management Plan, Wildlife Rehabilitation &
Resettlement Plan, Ecological Risk Analysis, Corporate
Social Responsibility (CSR) Plan, Tree Transplantation Plan,

100. • Submit only one FCA proposal consisting of coal
mine, Transmission line, demand additional forest
area for placing first over-burden dump (OBD),
hydro-structure, water linkage for thermal power
plant, water pipeline, tram / covered conveyor
belt / railway etc.
• Submit “Mitigation Planning Techniques” –
Greenbelt Plan, Safety Zone Plan, Cluster
Approach in Mining, Reclamation Planning,
Landscape Plan, Biodiversity Indexing, Wildlife
Habitat Management Plan, Wildlife Rehabilitation
& Resettlement Plan, Ecological Risk Analysis,
Corporate Social Responsibility (CSR) Plan, Tree
Transplantation Plan, etc.
• Resettlement & Rehabilitation Plan.

101. • Forest crop assessment – Stratified sampling statistical
design, use technical data of working plan to analyse
longevity of forest crop, senescence issues, at least 5%
of crop assessment, sample plot size 100MX100M,
photographs and video of sample plots, Biodiversity
Indexing of sample plots; separate enumeration of
timber, half sound and firewood trees, coppice should
be recorded as one tree,
• Use State Volume Table to assess “growing stock”, Basal
Area Assessment of sample plots, Rare, Endangered &
Threatened (RET) species found in the diversion area,
status of regeneration,
• Depending upon fault lines, the coal mining area may be
divided into 5-6 phases to reduce ecological foot prints.

102. • Coal Mine Plan – Once it is approved by the Ministry
of Coal, GoI; this issue should not be reopened by
Forest Appraisal / Expert Appraisal Committee.
• Diversion with effective mitigation planning is
possible (11.3% of opencast production cost).
• Wildlife Impact Assessment, Wildlife Habitat
Management Planning; assessment of nocturnal
wildlife, alternate wildlife corridors [Section-38O(g)
of WLPA] can be developed, fodder plots, water
holes, etc. Submit separate “wildlife proposal” to
CWLW, State Wildlife Board and Standing Committee
of the National Wildlife Board.
• Fragmentation & porosity can be taken care-off.
Indigenous coal is still much cheaper than imported
coal.
• All factors are under the control of GOI.

103. • The Forest (Conservation) Act, 1980 (FCA);
Environment (Protection) Act, 1986 provides that
the cases should be examined before according
sanctions; but parameters are neither provided in
the Act or Rules. As a consequence Forest Appraisal
Committee (FAC) and Expert Appraisal Committee
(EAC) are framing their own Guidelines for
examination of cases leading to disastrous results.
This darkness has created confusion for judicial
review also.
• The parameters under Section-38O(g) of Wildlife
(Protection) Act, 1972 have not been provided,
leading to lots of confusion and ultimate delay in
according sanctions. This darkness has created
confusion for judicial review also. Recently Hon’ble
Supreme Court has issued injunction against the
proceeding of the National Wildlife Board.

104. • That in “forest clearance” unwarranted linkage has been
developed with Scheduled Tribe & Other Forest Dwellers
(Recognition of Forest Right) Act, 2006 (ST&OFDRFRA) and
Panchayati Raj Extension to Scheduled Areas Act, 1996 (PESA)
in contravention of the General Clauses Act. The ST&OFDRFRA
is an open ended Act, but subjected to provisions Limitation
Act; this important missing link has not been sorted out due to
certain reasons.
• The Forest (Conservation) Act, 1980 is 4 jurisdictions i.e.
denotification of forest land, diversion of forest land for non-
forest purposes, assignment of forest land and treatment of
forest area under duly sanctioned working plan. The ignorance
level is so high in the country that even Forest (Conservation)
Rules, 2003 (framed after 23 years of enactment of FCA) are
silent about the procedure for de-notification of forest land,
assignment of forest land and treatment of forest area under
duly sanctioned working plan.

105. • That hundreds of circulars have been issued under Forest
(Conservation) Act, 1980 in past 33 years leading to chaos. One
“Statutory Manual” is absolute necessity for clarity of the vision.
There is absence of Scoping Manual, Screening Manual,
Mitigation Planning Manual, Guidelines for Wildlife Impact
Assessment, and Guidelines for Wildlife Habitat Management
Planning and Wildlife Rehabilitation & Resettlement Planning.
There is urgent need to address these issues.
• That it has been estimated that FCA cases are processed at 35
levels in the State Government and Government of India. Most of
these layers don’t contribute anything for correct analysis of the
FCA case. There should be strict instruction that ministerial staff
shall not make assessment of the case (because these low
ranking officials are not trained for assessment of forest,
biodiversity or wildlife) and only senior officers should be
allowed to make assessment of the FCA case. There are 7-9
layers of assessment in secretariat of the State Government,
even ministers are authorised to accord “administrative
approval” to the FCA case. These are root-causes of delay and
not contributing to the correct assessment of FCA cases.

106. • Most of the coal / CBM blocks require 600-2000ha. for
sustainable mining for 30 years and operation of thermal
power plant for 45 years. The FCA clearance can be
accorded in one stroke and forest felling can be carried-out
in 5-6 phases to reduce adverse ecological impact. The
safety zone should be increased to 20 to 50 meters along
perennial streams / nallahs with adequate “soil moisture
conservation measures” to reduce pollution of water
bodies. The reclamation should be carried-out in phased
manner, it would reduce cost of reclamation operations and
ecological foot-print as well.
• The trees upto 60 cms girth classes can be transplanted
without much problems. The fruit bearing species like
Mahua, Achar, Bel, Aonla, Sitaphal, Tendu etc. should be
transplanted on the rehabilitation sites of oustee families.
This would reduce drudgery of oustees families to a
considerable extent. Definitely reduce intervention by Left
Wing Extremism (LWE).

107. • All the project proponents should be forced to
collect seeds from the mature trees, likely to be
felled due to the project. The seeds from these
mature trees should be sown in the local forest
nursery to conserve “gene pool” for propagation
in the adjoining area.
• The Corporate Social Responsibility (CSR) should
start as pre-operational project activity. The
provision of Section-135 of Companies Act, 2013
is topsy turvey, which entail that the company
should spend 2% of profit after tax (PAT) on CSR.
Suppose the company is unable to achieve profit,
then rural & tribal communities shall suffer due
to damage to natural resources.

108. • Issue instructions through Reserve Bank of India to allow
“financial closure” of the coal / thermal power project,
because probability of not getting Stage-II clearance is very
little; unless the project proponent has committed some
gross violations.
• Same parameter is examined by FAC and EAC e.g.
biodiversity, wildlife, opencast versus underground mining
etc.
• The issue of mining methodology of opencast versus
underground mining is beyond the jurisdiction of FAC and
EAC; but still these assessment agencies are wasting
considerable time. Once “mining plan” has been
sanctioned by the Ministry of Coal, GoI the issue should
be closed at all levels. The ecological issues can be
examined even without sanctioned “mining plan”; mostly
there is not much variation in draft mining plan and
sanctioned mining plan.

109. • The sanctioned mining plan can be used after Stage-I sanction
for preparing “Reclamation Plan”. The Reclamation Plan can be
submitted before issuance of Stage-II under FCA. Most of the
mining companies are not carrying-out “technical
reclamation” of the mined-out site and doing “biological
reclamation” of the site or skipping all reclamation operation
at all. Root cause of PILs and bringing bad name to the mining
companies. There is no Guideline issued for the preparation of
“Reclamation Plan”.
• The FAC and EAC should develop, their own libraries for “site
assessment operations” (including working plans, forest stock
maps, data of wildlife impact assessment, biodiversity
indexes; Red Data Books of International Union for
Conservation of Nature, Wildlife Institute of India, Zoological
Survey of India and Botanical Survey of India). Forest satellite
maps of Forest Survey of India should be compulsorily made
available to FAC and EACs. Mostly absence of relevant data
causes inordinate delay in processing of cases.

110. • The FAC and EACs are not preparing “cause list” of
the cases for hearing; the project proponent is not
invited to make presentations about the case. The
proceeding of the FAC and EAC should be made
available outside the room for public view. After the
proceedings are over and the cases have been
decided finally, the videos ofthe proceedings should
be made available on the website of MOEF, GOI.
• That, at present there is no proceeding sheet on the
case, this lacuna is suppressing the identity of the
officer(s) responsible for delay in processing of the
cases. The objections raised by the assessing officers
should be made available to evaluate, whether the
project proponent has been harassed or not.

111. Thanks for your kind Attention