New Delhi: A group of 60 former civil servants has written to Ministry of Environment Forests and Climate Change (MOEFCC) over the flawed methodology and concerning revelations of the Indian State of Forest Report (ISFR).
ISFR is a biennial assessment of the state of forests in the country. The 2023 report was released a year late, the Constitutional Conduct Group’s letter said, adding that it gives a “false impression” about the ‘increase’ in forest cover in India.
“The projected increase of 156.41 sq km forest cover and 1445.81 sq Kms of total forest and tree cover appear to be an incorrect assessment.
We observe with great alarm that while our forests are steadily deteriorating, with reports that India ranks second, globally, in deforestation, losing, in 10 years from 2013 to 2023, 1.49 million hectares of trees, the ISFR presents a rosy picture, lulling us into a state of complacency,” it states.
The letter described the report’s methodology as “full of flaws”.
“Between ISFR 2021 and 2023, 1488 sq Kms of unclassed forests were lost as per the data of the ISFR 2023 which reveals a decrease in forest area and not an increase of 1445.81 sq kms as is being claimed in the ISFR,” it states.
The former civil servants also questioned the report’s disregard for Supreme Court orders and promotion of flawed green credit schemes.
The letter in full is produced below.
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CCG Open Letter to Union Minister for Environment on Indian State of Forest Report 2023
February 3, 2025
Honourable Minister for Environment, Forests & Climate Change
As you are aware, the Indian State of Forest Report (ISFR) is a biennial assessment of the health of India’s forests by the Forest Survey of India (FSI), a premier institute under the Ministry of Environment Forests and Climate Change (MOEFCC). The ISFR is mandated to provide, through scientific methodology, a factual assessment of the state of forests in the country, once every two years. This allows science-based policy decisions to ensure the ecological security of the country and safeguard forests and wildlife.
It is therefore important that the ISFR is released regularly, and on time. The ISFR 2023, was not only released a year late, on 21/12/24 instead of in January of that year, it reveals many areas of concern.
We, members of the Constitutional Conduct Group (CCG), feel deeply unhappy about this, and feel compelled to write to you. The CCG is a group of former civil servants who have served the Central and State governments in various capacities, and who feel strongly about upholding the provisions of the country’s Constitution. We have no affiliation with any political party.
It appears to us, as well as to many forestry experts, that the ISFR (2023) has not been scientifically prepared and seems to convey the false impression that our forests are in good health and that the forest cover is increasing. The projected increase of 156.41 sq km forest cover and 1445.81 sq Kms of total forest and tree cover appear to be an incorrect assessment.
We observe with great alarm that while our forests are steadily deteriorating, with reports that India ranks second, globally, in deforestation, losing, in 10 years from 2013 to 2023, 1.49 million hectares of trees, the ISFR presents a rosy picture, lulling us into a state of complacency. The reality is that deforestation is contributing in a major way to the climate crisis leading to frequent extreme weather events, forest fires, great loss of human and animal life, and huge economic losses.
The ISFR 2023 worries us on two counts: firstly because of its flawed reporting; and secondly because it reveals a significant reduction both in the quantity and quality of forest cover.
Flawed Reporting:
1. Unreliable, unscientific methodology
The methodology followed to evaluate forest cover is full of flaws. It continues as in previous years, to include orchards and gardens of one hectare or more with canopy cover of 10% which do not qualify as forests.
Coconut, oil palm and rubber plantations are also counted as forest cover. The reported increase in tree cover comes mainly from plantations, with mango and coconut plantations contributing 13.25% and coconut 4.37% respectively.
Ground truthing, which is an important element of assessment has not been done adequately to exclude these non-forest areas and publicly-available satellite imagery shows a drastic decline.
2. Disregard for Supreme Court Orders
Despite the Supreme Court order in the Godavarman 1996 case, directing State Expert Committees to identify all forests, irrespective of ownership as per the dictionary meaning of the term, states have failed to do so and the ISFR 2023 has consequently left out large chunks of forest without legal protection.
The Supreme Court’s 2011 order in the Lafarge case directed FSI to digitize maps of all forests that come under the purview of the Forest Conservation Act 1980.This has not been complied with and is not included in the IFSR 2023.
3. Loss of Forest Cover: Between 1996 and 2023 large tracts of forests have been diverted for various ‘development’ activities with more than 3,00,000 hectares of forest land being diverted for non-forestry use in the past 15 years. This is not reflected in the ISFR 2023.
4. Fluctuation of Data
No explanation has been given for the huge fluctuations in the data of States for unclassed forests from one cycle of reporting to the next. For instance in UP, the area of unclassed forests starts at a high of 14000 sq km in 1995 and drops to below 4000 in 2001 and continues thereabouts till 2023. This wildly fluctuating pattern is revealed in the data of other states also, clearly indicating that the data is unreliable.
5. Incorrect calculations:
Between ISFR 2021 and 2023, 1488 sq Kms of unclassed forests were lost as per the data of the ISFR 2023 which reveals a decrease in forest area and not an increase of 1445.81 sq kms as is being claimed in the ISFR.
6.Replacing natural ecosystems with plantations
The report estimates that 33.21% of forest area can be regenerated through plantations. Grassland, rocky areas, swamps, deserts, etc. are distinct ecological entities and are not meant to be turned into forests. This is a stereotype which has caused irrevocable damage to our varied ecosystems. ISFR 2023 continues to promote this damaging practice.
Decrease in quantity and quality of forest cover:
7. Unwelcome development in NE States
The ISFR reveals a decline in forest cover between 2013 and 2023 in the biological hotspot of the North Eastern states, to an extent of 3132.27 sq kms This is probably due to oil-palm plantations which are ecologically damaging and need to be discouraged.
8. Decrease in high altitude forests
The ISFR reports a massive decrease in forest cover in high altitudes – more than 1500 sq Kms above 1000 m altitude. This is of great concern since such decrease drastically lowers our safeguards against landslides, floods, mud slides, etc. Despite such reports, the government continues to divert forest lands in high altitudes for dams, roads etc.
9. Degradation of forests: One of the key findings of the ISFR 2023 is that 92,989 sq kms forests got degraded in the country in the last decade (2011 to 2021) While huge funds have been pumped into afforestation and eco-restoration schemes, forests across the country continue to steadily get degraded, as revealed in the ISFR.
10. Promotion of discredited Green Credit Program
The ISFR 2023 highlights and promotes the Green Credit Programme (GCP), for plantation in degraded areas. While degradation of 92,989 sq kms of forests is a disgraceful outcome, the ISFR is projecting its identification as positive, showing this area as available for enrichment planting!
The GCP is a flawed scheme allowing business houses to earn ‘green credits’ by paying for ‘dubious’ plantations which can then be used for diverting forests. The matter has been challenged in court and is awaiting a decision. We, in the CCG have also written a letter on 19/03/2024 pointing out the perils of the Green Credit Programme.
Considering that the degradation and destruction of forests has catastrophic impacts on climate change and on human lives, we request the government to take a serious note of erroneous and misleading reports such as the ISFR 2023. We request you to ensure that future reports are scientific and factual. False data feeds complacency, justifies further forest diversion and fails to provide stringent measures for forest conservation.
We also request the government to make protection of forests and biodiversity a priority area and not continue to divert forests for “development projects”. Such projects, more often than not, benefit business houses and user agencies while endangering the country’s climate resilience, leading us to a state of ecological dystopia.
Satyameva Jayate
Yours faithfully
Constitutional Conduct Group (60 signatories, as below)
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J.L. Bajaj | IAS (Retd.) | Former Chairman, Administrative Reforms and Decentralisation Commission, Govt. of Uttar Pradesh |
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G. Balachandhran | IAS (Retd.) | Former Additional Chief Secretary, Govt. of West Bengal |
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Gopalan Balagopal | IAS (Retd.) | Former Special Secretary, Govt. of West Bengal |
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Sharad Behar | IAS (Retd.) | Former Chief Secretary, Govt. of Madhya Pradesh |
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Aurobindo Behera | IAS (Retd.) | Former Member, Board of Revenue, Govt. of Odisha |
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Madhu Bhaduri | IFS (Retd.) | Former Ambassador to Portugal |
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Pradip Bhattacharya | IAS (Retd.) | Former Additional Chief Secretary, Development & Planning and Administrative Training Institute, Govt. of West Bengal |
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Nutan Guha Biswas | IAS (Retd.) | Former Member, Police Complaints Authority, Govt. of NCT of Delhi |
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R. Chandramohan | IAS (Retd.) | Former Principal Secretary, Transport and Urban Development, Govt. of NCT of Delhi |
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Purnima Chauhan | IAS (Retd) | Former Secretary, Government of Himachal Pradesh |
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Kalyani Chaudhuri | IAS (Retd.) | Former Additional Chief Secretary, Govt. of West Bengal |
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Gurjit Singh Cheema | IAS (Retd.) | Former Financial Commissioner (Revenue), Govt. of Punjab |
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F.T.R. Colaso | IPS (Retd.) | Former Director General of Police, Govt. of Karnataka & former Director General of Police, Govt. of Jammu & Kashmir |
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Anna Dani | IAS (Retd.) | Former Additional Chief Secretary, Govt. of Maharashtra |
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Vibha Puri Das
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IAS (Retd.) | Former Secretary, Ministry of Tribal Affairs, GoI |
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P.R Dasgupta | IAS (Retd.) | Former Chairman, Food Corporation of India, GoI |
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Kiran Dhingra | IAS | Former Secretary, Govt of India |
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Pradeep K. Deb | IAS (Retd.) | Former Secretary, Deptt. Of Sports, GoI |
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S.K. Guha | IAS (Retd.) | Former Joint Secretary, Department of Women & Child Development, GoI |
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H.S. Gujral | IFoS (Retd.) | Former Principal Chief Conservator of Forests, Govt. of Punjab |
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Meena Gupta | IAS (Retd.) | Former Secretary, Ministry of Environment & Forests, GoI |
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Ravi Vira Gupta | IAS (Retd.) | Former Deputy Governor, Reserve Bank of India |
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Siraj Hussain | IAS (Retd.) | Former Secretary, Department of Agriculture, GoI |
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Naini Jeyaseelan | IAS (Retd.) | Former Secretary, Inter-State Council, GoI |
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Gita Kripalani | IRS (Retd.) | Former Member, Settlement Commission, GoI |
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Subodh Lal | IPoS (Resigned) | Former Deputy Director General Ministry of Communications, Govt of India |
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Sudhir Kumar | IAS (Retd.) | Former Member, Central Administrative Tribunal |
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Sandeep
Madan |
IAS (Retd) | Former Secretary (Govt of Himachal Pradesh) |
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Dinesh Malhotra | IAS (Retd) | Former Secretary,
Govt of Himachal Pradesh |
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Aditi Mehta | IAS (Retd.) | Former Additional Chief Secretary, Govt. of Rajasthan |
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Avinash Mohananey | IPS (Retd.) | Former Director General of Police, Govt. of Sikkim |
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Sudhanshu Mohanty | IAS (Retd) | Former Chief Secretary, Govt of West Bengal |
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Anup Mukerji | IAS (Retd.) | Former Chief Secretary, Govt. of Bihar |
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Deb Mukharji | IFS (Retd.) | Former High Commissioner to Bangladesh and former Ambassador to Nepal |
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Shiv Shankar Mukherjee | IFS (Retd.) | Former High Commissioner to the United Kingdom |
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Nagalsamy | IA&AS (Retd.) | Former Principal Accountant General, Tamil Nadu & Kerala |
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Ramesh Narayanswami | IAS (Retd.) | Former Chief Secretary, Govt. of NCT of Delhi |
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Surendra Nath | IAS (Retd.) | Former Member, Finance Commission, Government of Madhya Pradesh |
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P. Joy Oommen | IAS (Retd.) | Former Chief Secretary Government of Chhattisgarh |
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Amitabha Pande | IAS (Retd.) | Former Secretary, Inter-State Council, GoI |
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Mira Pande | IAS (Retd.) | Former State Election Commissioner, West Bengal |
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Maxwell Pereira | IPS (Retd.) | Former Joint Commissioner of Police, Delhi |
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Alok Perti | IAS (Retd.) | Former Secretary, Ministry of Coal, GoI |
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G.K. Pillai | IAS (Retd.) | Former Home Secretary, GoI |
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V.P. Raja | IAS (Retd.) | Former Chairman, Maharashtra Electricity Regulatory Commission |
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M.Y. Rao | IAS (Retd.) | |
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A Madhukar Reddy | IRTS (Retd) | Ex Director, Railway Board |
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Satwant Reddy | IAS (Retd.) | Former Secretary, Chemicals and Petrochemicals, GoI |
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S. Satyabhama | IAS (Retd.) | Former Chairperson, National Seeds Corporation, GoI |
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N.C. Saxena | IAS (Retd.) | Former Secretary, Planning Commission, GoI |
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A. Selvaraj | IRS (Retd.) | Former Chief Commissioner, Income Tax, Chennai, GoI |
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Ardhendu Sen | IAS (Retd.) | Former Chief Secretary, Govt. of West Bengal |
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Ashok Kumar Sharma | IFS (Retd.) | Former Ambassador to Finland and Estonia |
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Navrekha Sharma | IFS (Retd.) | Former Ambassador to Indonesia |
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Raju Sharma | IAS (Retd.) | Former Member, Board of Revenue, Govt. of Uttar Pradesh |
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A.K. Srivastava | IAS (Retd.) | Former Administrative
Member, Madhya Pradesh Administrative Tribunal |
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Prakriti Srivastava | IFoS (Retd.) | Former Principal Chief Conservator of Forests & Special Officer, Rebuild Kerala Development Programme, Govt. of Kerala |
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Anup Thakur | IAS (Retd.) | Former Member, National Consumer Disputes Redressal Commission |
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P.S.S. Thomas | IAS (Retd.) | Former Secretary General, National Human Rights Commission |