CITES is trying to resolve ambiguities and inconsistencies in trade in specimens Flora and Fauna of NOT OF WILD SOURCE. As a stack holder, a threatened species grower, sent my comments to them. They also acknowledged

1. Comments on
REVIEW OF CITES PROVISIONS RELATING TO THE TRADE IN
SPECIMENS OF ANIMALS AND PLANTS NOT OF WILD SOURCE
Refer notification no. 2018/048 dt 15 May 2018
By Ganesan RP - A stack holder
( An Endangered species Tree grower)
Communication address
H 96, New ASTC Hudco,
Hosur 635109,
Tamilnadu state, India
ganesanrp@gmail.com

2. A Big Thanks
For recognizing the ambiguities and confusion in
Artificially propagated source and related regulations
1000s of dry land endangered Red Sanders tree growing
farmers in India are suffering due to these ambiguities &
confusion
Refer our struggle
https://www.slideshare.net/GanesanRP/red-sanders-
action-required-by-govt-of-india-and-progress
(google Red sanders action required by govt of India)

3. Nurseries, Line - 454
• In India nursery is referred to place where tree
sapling are produced not the trees grown.
• So better to use some other word
– Farmlands or
– Private farm land by farmers / companies.

4. Distinguish Wild Vs Farmers land clearly
• In parties like India there is no separate policy
& procedures for wild and farmers land
(propagated source)
• FAO itself is under the process of defining
“Forest”.
• CITES uses word wild
• So please add definitions for wild, forest and
farmlands including in article I of CITES.

5. Please specify clearly
• Even though CITES encouraged artificially
propagated material particularly by farmers to
meet the demand & additional income for them.
• So, please clearly specify “ All species artificially
propagated by the farmers in their private land
should not be restricted for international trade”,
just ensure only the authenticity of felling at
farmer’s land. Preferably in article III, IV, V & VII
It is very easy for trees.

6. Better sub-classify forest land
• Forest land in India is
– Govt land
– Comes under the control of Forest department of
Ministry of Environment , Forest and climate change
– Subclassification
• Reserve Forest, may be wild as per CITES
• Plantation forest, Artificially propagated
• But no semi-natural forest classification in India
• Need not allow felling and trade of appendix I, II &
III species from plantation forest also.
• Shall be allowed once it comes out of IUCN Redlist.

7. A permanent setup for CITES
• The official in MA / SA are often get transfer. So, they
are not getting familiar with CITES provisions.
Solution
• Better insist for permanent setup like National
Biodiversity Authority
• And insist for CITES certification in MAs, SAs and
Colleges
• Insist at least 5 persons from SA and 5 Persons from
MA for CITES certification

8. Permission / Certification
• Tree growing farmers are bombarded with many
certification from many departments.
• Simplify, as small farmers like India (small
holding), can not understand complex
procedures
• One certificate from SA, after verifying with
revenue records proving famers private land shall
be allowed for export.
• We find forest range officers are not familiar with
any of CITES provisions.

9. Born Vs Bred Line 45 (table)
• Needs more clarity and clear definition
between born and bred
• This table is good.

10. Define Treeculture (Agroforestry)
• Like agriculture, horticulture, sericulture,
apiculture, define “Treeculture”
• Treeculture is better than Agroforestry
• The word forest implies “wilderness”
• The word culture implies “artificial
propagation”

11. Sub- classify Artificially Propagated
source code ‘A”
• Under artificially propagated source, there
shall be difference between
– Propagated at Farmers land (A1),
– Propagated at Non forest public lands (A2)
– and Propagated at forest lands (A3).
• A1, source materials should be facilitated for
easy trade.
• A3, forest wood should be restrictive

12. Conservation measure
• Even if is artificially propagated in forest land,
don’t allow it export as long as the species in
Endangered list / Redlist
• At least insist them to plant 5 times of tree to
be felled in the planted forest 5 years before
applying for permission to fell.
• Even for confiscated source, insist them as
above before trade.

13. Confiscated source
• Govt gets income while exporting confiscated
endangered materials.
• Insist to propagate 5 times of the trees that
would been felled.
• Next permission shall be after proving that the
planted species has grown at least 10 ft
height. ( similar method for other species)

14. Software / On-line
• Create a software, incorporating provisions
and explanations.
• Online application with required details and
proofs.
• Monitor the permissions with time frame.
• If permission are denied, let them record the
reason.
• The reasons shall be monitored by CITES HO
Expert group

15. Table, Line 236
• The table is good
• Better to create such table for easy
understanding, compare and choose.

16. Thanking you
• IUCN / CITES objective are good
• Needs to make it more clear with simple
language and on-line software application
method
• These provisions shall shall be made part of
education at college levels