MAKAAM’s CONCERNS FOR WOMENS FOREST RIGHTS IN THE DRAFT FOREST POLICY 2018

ITEM

TEXT

ANALYSIS

RECOMMENDATION

PREAMBLE

1.1

Recognizes only some forest produce —

Ignores forest dwellers as part of forest eco system  – need to include the human beings.

Communities have lived within and depended on forests. The policy does not acknowledge the human interface, focus on plant and micro organism in essentialized form

Forest is integrally part of the life and culture of  tribals and forest dwellers

1.1    Forests are a dynamic ecosystem consisting of plants, animals & microorganisms and human beings

Forests provide the carbon neutral timber, non timber products

food-tubers, flowers, fruits…

1.4 –

The increased concerns for biodiversity conservation and the need to enhance forest ecosystem services, through new technological advancements

Technologies cannot be viewed in isolation but  need to strengthen the relationship of people with nature rather  than treating communities as intruders

(Forest deptts make demands for resources in state forest policies to strengthen arms of forest guards to prevent human intervention- this approach is problematic (Eg Rajasthan)

……. through new technological advancements that promote livelihoods  and peoples participation in  the conservation of  forests and ecosystems 

1.2

 1.2 The forest policies of 1894 & 1952 have stressed on the production& revenue generation aspects of

the forests where as the principal aim of National Forest Policy, 1988

Recognizes forest policies but ignores the FRA altogether

FRA 2006 is  a landmark enactment which recognizes ‘historical injustice’ and needs to be taken into consideration in framing forest- people’s  relations in the forest policy.

1.5

Document acknowledges human co-existence at para stating “ cultural heritage of co-existence”

Strengthen this and use this coexistence as principle for community engagement

Cultural coexistence needs to be the primary principle for that guides the governance of forests and should  be integrated in the approach in the policy

2.1

Maintenance of environmental stability and conservation of biodiversity

Does not  reflect the symbiotic relationship and role of people with forests, or acknowledge their  role in its governance

2.1. Maintenance of environmental stability and conservation of biodiversity through preservation and conservation of natural forests and by recognizing, facilitating, and the preserving symbiotic relation between people and forest. In this manner, reinforcing the value of traditional knowledge, forest management systems and extant administrative mechanisms, such as the Tribal Advisory Councils, as a means for effective forest management

2.3

Improvement in livelihoods for people based on sustainable use of ecosystem services.

This  promotes an Exclusionary model of forest protection and conservation; colonial view of isolating environmental reserves; disregards human communities living in,

We should foreground the role of people and the sustainable use of resources with local communities

Improvement in livelihoods for people based on sustainable use of ecosystem ….services sustainable use of land, forest and water with the engagement of local communities in consonance with the provisions of the Scheduled tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006 (FRA), Panchayats (Extension to Scheduled Areas) Act, 1996 (PESA),

2.7

Safeguard forest land by exercising strict restraint on diversion for non-forestry purposes, and strict

oversight on compliance of the conditions.

Such safeguards must be in context of FRA and PESA, to ensure  interests of communities in forests are protected,  State should work to move out it’s loop holes and   strengthen communities.

2.8

2.8

Increasing substantially the forest/tree cover in the country through Afforestation & reforestation

programmes, especially on all denuded and degraded forest lands and area outside forests

Manage protected areas and other wildlife rich areas with the primary objective of biodiversity conservation and for enriching other ecosystem services.

Increasing substantially the forest/tree cover in the country through afforestation & reforestation programmes, and community-based forest management in consonance with Section 3 (1) (i), Rule 4 (1) (f) of FRA and Section 4 (d) of PESA especially on all denuded and degraded forest lands and area outside forests that are not under community use for livelihoods purposes   and ensuring that bio diversity of the area is maintained, and not replaced by commercially viable varieties, and activating the bodies entrusted with the task of forest management under FRA and PESA are strengthened to do the same. This should be done by  incentivizing  local  forestry and forest governance facilitating assured food basket and livelihoods for forest dwellers.

2.9

2.10

2.11

2.12

2.13

2.14

2.16

Manage protected areas and other wildlife rich areas with the primary objective of biodiversity

conservation and for enriching other ecosystem services.

Conserve and sustainably manage mountain forests to ensure continuous flow of ecosystem services, including biodiversity, cultural and spiritual services to both upstream and downstream population.

Factor green accounting, valuation of ecosystem services and climate change concerns adequately into the planning and management of all forests, protected areas and other ecosystems

Increase substantially the tree cover outside forests by incentivizing agro-forestry and farm forestry,

facilitating assured returns, with enabling regulations and by promoting use of wood products.

Integrate climate change mitigation and adaptation measures in forest management through the mechanism of REDD+(Reducing Emissions from Deforestation and Forest Degradation plus) so that the impacts of the climate change is minimised.

Incentivize sustainability in community managed, community owned private forests and creating a

sustained peoples’ movement for achieving these objectives

Ensure effective translation of this policy into action by establishing credible measuring, monitoring

and evaluation framework, ensuring good governance, providing commensurate financial support and developing an implementation framework with periodic review.

Biodiversity conservation needs to be viewed as an ecological activity rather than merely as ecosystem service

Such technical approaches do not consider community and its needs

Recompose to reflect community needs and  priorities for restoration of forests rather than viewing forests as a commercial product

These provision are against principles of ecological sustainability and community rights

Such measures cannot  be viewed in isolation of existing legal frameworks

Measuring, monitoring and evaluation framework cannot be  devoid of community roles as communities are responsible for their community rights to forests

Manage protected areas and other wildlife rich areas with the primary objective of biodiversity enrichment in consonance with the ecosystem needs of forest dwelling communities and  other  communities  in compliance with the provisions of FRA and PESA ……

This provision be deleted from the policy

To be implemented in the framework of FRA and PESA. In context of North East state should not meddle with community forest governance, and local institutions , instead strengthen womens participation in forest governance and in representation in decision making processes

Include “role of community its rights and governance and decisions”

Ensure community participation and knowledge in management and governance

Intensify agro forestry and farm forestry being mindful of the ecological diversity of such agro forestry to attend to community food and needs basket to address food  security

This point can be deleted

Effective translation of this policy into action by establishing credible measuring, monitoring

and evaluation framework, ensuring good governance, must be done based on community participation. Forest governance is a function of communities and should be strengthened based on a community centred approach, with reference to ecological diversity and enrichment that ensure community food and other interests and ensuring role of community its rights and governance and decisions

SECTION #3

ESSENTIAL PRINCIPLES

3.1

Essential Principles of Forest Management:

3.1

TEXT

Existing natural forests should be fully protected and their productivity improved. Adequate

measures will be taken to increase rapidly the forest cover on hill slopes, in catchment areas of rivers, lakes and reservoirs and ocean shores and, on semi-arid, and desert tracts.

ANALYSIS

Exclusionary model of forest protection and conservation; colonial view of isolating environmental reserves; disregards human communities living in, relying on, and protecting forests

SUGGESTIONS

Community and ecology interface approach to forest conservation is required

Existing natural forests should be fully protected and their productivity improved. Adequate measures will be taken to increase rapidly the forest cover on hill slopes, in catchment areas of rivers, lakes and reservoirs and ocean shores and, on semi-arid, and desert tracts with special focus on protecting and preserving indigenous plant variety and maintaining bio diversity. While promoting diversities the protection of community rights to resources will also be addressed

3.2

3.3

3.5

3.5

3.6

3.6 

3.7

Productivity of the

Forest plantations will be increased through scientific and technological interventions so as to encourage usage of more timber so that the dependency on other high carbon footprint wood substitutes is reduced.

3.3 Management of the natural biodiversity rich forests for maximising the ecosystem services for ecological security of the nation.

For conservation of flora, fauna and total biodiversity, the network of national parks, sanctuaries,

conservation reserves, community reserves, biosphere reserves and important wildlife corridors and

biodiversity heritage sites will be strengthened and extended adequately.

Afforestation with suitable species will be intensified so as to cater to the needs of the rural

population for fuel wood and small timber. Further alternative sources of energy like LPG etc will be

promoted in rural areas to reduce dependency on forests.

3.6 Non-Timber Forest Produce (NTFP) such as medicinal and aromatic plants, oil seeds, resins, wild

edibles, fibre, bamboo and grass etc. will be sustainably managed for improving the income of the

tribals & other forest dependent populations.

Promotion of trees outside forests urban greens will be taken up on a mission mode for attaining the national goal of bringing one third of the area under Forests & trees cover and also for achieving the Nationally Determined Contribution (NDC’s) targets of

the country

Contradictory to 3.1 and 2.13 and to the interests of forest bio diversity and community interests

Sequestring through national parks, sanctuaries etc. problematic, as the dense natural biodiverse forests of various kinds, landscapes and ecology are essential for overall ecological and livelihood services. Zoning in this way frees up forests for diversion and destruction.

No mention of livelihoods. Not in sync with earlier  principles

Experience of creation of protected areas: 2017- Amchang, Kaziranga (Assam), Barnaw-apara (CG): human rights violations; forced relocations; displacement. Forests are not ‘pristine’, but thriving ecosystems for life.

Ignores the role of communities in cconserving and managing biodiversity through sustainable practices, instead promotes a flawed approach to conservation devoid of people, threatening to lvielihoods and to community responsibility in management of conservation . As we are aware, conservation practives have been part of t he cultre of livelihoods practices  forest of forest based communities, and such a view needs to be integrated into forest management and biodiversity conservation approaches rather than distancing people  away from pfroests and denying them their resource rights.

3.5 “Afforestation with suitable species “ only taking  into consideration the fuel and small timber needs ignores the traditional knowledge and practices of healing and food and fodder that have sustained forests and forest dwellers Rural women spend much more labour time in collection of  fuelwood and fodder, food and herbs mainly  due the  denial of  access to forests and destruction of forests in their vicinity as it  does in the reliance of alternative energy resoruces.

The concept  of “ reduce dependency on forests” ignores the co eistance with forests in its multiple dimensinos and takes away from women and communities the right to govern forests and forest resources to meet their needs. 

This view presents NTFP only as an

Commercial product . Market-oriented view of ecological services; neglects local community-based forest economies; makes no mention of protecting traditional livelihoods dependent on forest resources; MSP for MFP for livelihood

“Afforestation with suitable species “ only taking  into consideration the fuel and small timber needs ignores the traditional knowledge and practices of healing and food and fodder that have sustained forests and forest dwellers while sustaining forests. Rural women spend much more labour time in collection of  fuelwood and fodder, food and herbs mainly  due the  denial of  access to forests and destruction of forests in their vicinity,

The concept  of “ reduce dependency on forests” ignores the co- existence with forests in its multiple dimensions and takes away from women and communities the right to govern forests and forest resources to meet their needs. 

This view presents NTFP only as an Income source and ignores the subsistence value of forest resources as a food resource for instance.

The sustainable management of NTFP including medicinal herbs and medicines needs to be located around communities that are traditional knowledge holders and have depended on these forest resources for their healing and health practices. The perspective that the policy respresents is one of  extractive exploitation rather than sustainable use.

3.7 which species , in which areas? Land divergence and selection of species that are not the basis  of  sustainable lvielihoods, only  source of  revenue  are likely  to impact local communities adversely

This view of forests as trees, as timber is flawed and extractive. Afforestation proposed as remedy, with target of one-third cover is inappropriate.

Plantations are not forests. The FSI myth whereby forest cover in India shown to be increasing on the basis of ‘ghost plantations’ needs to challenged and replaced.

In truth, large tracts of natural forests diverted for development projects, rapid destruction, degradation.  

This will be done by taking into account the voices from the community particularly ensuring the participation of women in collection, processing and sale of forest produce. 

Suggested that relying on, and protecting forests. Sequestring through national parks, sanctuaries it’s planning and implementation should be executed by FRCs with focus on women’s participation and empowerment

There is a contradiction between 3.2 and 3.3 given the impetus on increasing the productivity of forest plantations in 3.2 in direct contrast with the focus on management of natural biodiversity in the following section.

The term ecosystem services is not defined in the document

Suggested change: For conservation of flora, fauna and total biodiversity, the network of national parks, sanctuaries, conservation reserves, community reserves, biosphere reserves and important wildlife corridors and biodiversity heritage sites will be strengthened in accordance with the FRA, PESA, the Wildlife Protection Act, 1972, and Biological Diversity Act, 2002,

 the solution lies in the restoration of forest wealth based on local species knowledge and use systems

Instead women and their communities should be recognized as central to the management regimes and  the use and conservation of  these resources as an essential part of their  lives and livelihoods.

3.6    

Non-Timber Forest Produce (Non-Timber Forest Produce (NTFP) such as medicinal and aromatic plants, oil seeds, resins, wild edibles, fibre, bamboo and grass etc. will be sustainably managed in accordance with Section 3 (1) (c), Rule 2 (1) (d) and Rule 4 (1) (e) FRA and PESA in scheduled areas for improving the livelihood and food security of the tribals & other forest dependent populations.

Tthe solution lies as much in the restoration of forest wealth based on local species knowledge and use systems as it  does in the reliance of alternative energy resoruces like  LPG etc. when the latter exposes them to income based needs when their incomes are lmiited

Instead women and their communities should be recognized as central to the management regimes and  the use and conservation of  these resoruces as an essential part of their  lvies and livelihoods

 In a country that is reporting alarming degrees of malnutrition especially among forest dwelling tribal communities, it is important  to restore them the rights over traditional forest resources that provide the food and nutritional supplements of which they have an inherent knowledge than to deprive them of  such access and compel them to resort to income  based solutions

Women and men in Forest communities have sought  to improve incomes through sale of minor forest produce such as tendu leaves , but have received little protection of  the prices to be able to benefit  from such sales, while middle men and contractors have reaped the benefits. The NTFP polcies need to be oriented to enhancing control and access to returns from such resoruces to communities of collectors with an assurance of MSP rather than denial of access and restrictions to returns

Non-Timber Forest Produce (Non-Timber Forest Produce (NTFP) such as medicinal and aromatic plants, oil seeds, resins, wild edibles, fibre, bamboo and grass etc. will be sustainably managed in accordance with Section 3 (1) (c), Rule 2 (1) (d) and Rule 4 (1) (e) FRA and PESA in scheduled areas for improving the livelihood and food security of the tribals & other forest dependent populations.

NTFP- towards enhancing income of tribals. NTFP relevant for domestic/ household use and consumption- food, medicine, instruments etc. For enhancing incomes, MSP to be guaranteed. 

3.7 Add ….” It is further proposed that all interventions towards forest management should in principle and action, protect and promote the traditional knowledge of adivasi and forest dwellers. Women as bearers of this knowledge should be recognized and empowered to manage and control the forest management. “

4

4.1.1 (a)

4.1.1 (b)

4.1.1 c

4.1.1 d

4.1.1  Sustainable Management of Forests

 (a) Reducing Threats to Forests:

The various threats to Forests due to encroachments, illegal tree fellings, forests fires, invasive weeds, grazing, etc. will be addressed within the framework of the approved Working Plan/ Management Plan and also by ensuring community participation in forest management.

(b)              Forest fire prevention

With changes in climate and land use, fire is increasingly being viewed as a major threat to many forests and their biodiversity. Rising intensity and frequency of forest fires and their spread is resulting in substantial loss of forest functions and related ecosystem services every year. Adequate measures would be taken to safeguard ecosystems from forest fires, map the vulnerable areas and develop and strengthen early warning systems and methods to control fire, based on remote sensing technology and community participation. Also, awareness will be created about causes and impacts of fire on forests and local livelihoods.

(c)               Enhance Quality and Productivity of natural forests:

Many of our forest ecosystems have been significantly altered and degraded due to land conversion, pollution, over exploitation, deforestation and degradation etc. with adverse impacts on biological diversity and livelihoods of the local population. Protection and enrichment of dense forests will be a top priority.

d) Increase the productivity of forest plantations:

Productivity of the forest plantations are poor in most of the States. This will be addressed by intensive scientific management of forest plantations of commercially important species like teak, sal, sisham, poplar, gmelina, eucalyptus, casuarina, bamboo etc. The lands available with the forest corporations which are degraded & underutilized will be managed to produce quality timber with scientific interventions. Public private participation models will be developed for undertaking Afforestation and reforestation activities in degraded forest areas and forest areas available with Forest Development Corporations and outside forests.

(h)              Strengthen participatory forest management

India has rich and varied experience in participatory forest management. There is a need to further strengthen this participatory approach, for which a National Community Forest Management (CFM) Mission will be launched. This mission will have a legal basis and an enabling operational framework.. The national, state and local level development programmes shall be converged in these villages. All efforts to ensure synergy between Gram Sabha & JFMC will be taken for ensuring successful community participation in forest management.

·         These clauses in the policy represent a Colonial commercial orientation towards forests and resources, which is detrimental to forest ecosystem health as well as to community wellbeing of forest dweller species including men and women.

·         This clause adopts colonial orientation of forest management and use, now no longer valid after enactment of FRA, PESA. Adivasis and OTFDs are not ‘encroachers’ but rights holders and governors of traditional community forest resources under S.3(1)(i) and S.5, FRA.

·         Bundle of rights vested by FRA include rights to govern, manage and protect forests, to cultivate and inhabit, to collection and sale of MFP, to grazing etc. Essential for livelihood strategies.

Biggest threat to forests is accelerated diversion of forests for non-forest purposes, development projects. Statistics: Between 1980-2016, more than 1.5 million hectares of forest land have been diverted under the Forest Conservation Act, 60% of which is for infrastructure, irrigation, mining and other development projects. Since 1980,46% of forest diversion nationally has been carried out after the enactment of Forest Rights Act, 2006, mostly without ensuring recognition and vesting of rights and without taking consent of Gram Sabhas. Between June 2014 and April 2016, just prior to the enactment of CAF Act, the MoEFCC has granted Stage-I approval for diversion of 47,500 hectares of forests nationally. This is more than the forest land diverted in the decade between 2006-16 in the states of Chhattisgarh and Maharashtra combined! The mining sector accounts for the highest share of 29%.

NFP makes no comment on restricting forest diversion.

Enhance quality and productivity = market orientation. Preference for commercial species. Scientific interventions neglect traditional knowledge of communities of plants and species, regeneration. Women play a leading role in preserving, transmitting traditional knowledge.

Plantations: 60% monoculture commercial species under CAMPA, teak, eucalyptus. Set up after destroying natural biodiversity rich forests. Triggers nutritional and livelihood crises among adivasis. Eg, Kutia Kondh PVTH Kandhamal- plantation on traditional habitat under FRA. food basket of 75-80 millets reduced to 25. First time reporting distress migration on account of alienation from essential forest resources.

Change in cultural fabric.

Plantations: set up forcibly on recognized and vested CFR, IFR, CR lands. Agricultural lands destroyed, jhum/ podu cultivations. Curtails access to MFP for livelihood and income needs due to fencing etc.

Any new framework will be in contravention of the FRA . All the provisions for participatory approaches should be dovetailed with existing statutory provisions of FRA rather than diluting or obfuscating them.

Likewise imposing the JFMC in areas where community entitlements or potential for the same under FRA exists will be in contravention of the FRA and should be avoided

Restriction and protection is contrary to the provisions of FRA and must be viewed in the content of the role of community Forest rights, and the role  of FRC in managing the forest governance. 

We oppose the provision of forest plantations and planting commercial species. However if some plants need to be planted then it has be indigenous species of plants, trees and grasses. We oppose scientific management which is not based on the needs recognition of tribal and other forest dwellers such as pastoralists, fisherfolk etc

This provision need to be eliminated since it brands tribals and other forest dwellers criminal

Add in 4.1.b ….These measures will be approved, decided and addressed by the involvement of tribals and other forest dwellers whose lives and livelihoods are embedded within the forests

4.1.1 (c)

Degraded forests will be rehabilitated by promoting natural regeneration, by taking strict protection measures and also by planting locally suitable indigenous species for assisting the existing regeneration. They will be regenerated with the involvement of tribals and other forest dwelling communities

Reverse the degradation of forest by taking up rehabilitation without compromising its natural profile

We oppose the provision of forest plantations and planting commercial species. However if some plants need to be planted then it has be indigenous species of plants, trees and grasses. We oppose scientific management it needs recognition of tribal and other forest dwellers such as pastoralists, fisherfolk etc

Suggested changes…..

The provision of forest plantations is opposed to the wellbeing of forests as it promotes monocultural cropping  and commercial and intensive scientific management of forest plantations , often detrimental to ecological and claimatic and livelihoods wellbeing.

These practices need to be replaced by introducing practices that promote forest diversity, reduce ecological destruction and enhance community needs to be addressed for their multifarious uses such as food, housing grazing, fodder fuelwood et.

Lands available with the forest corporations which are degraded & underutilized will be managed to produce diverse forest produce to address subsistence needs of communities and timber and other local demands as a priority in order to enhance the redressal of ecological and community wellbeing.

Forest Management must be done by FRCs with the approval of the Gram Sabha in accordance with Section 3 (1) (i), Rule 4 (1) (f) of FRA and Section 4 (d) of PESA.

Forest Management will be done by FRCs with the approval of the Gram Sabha in accordance with Section 3 (1) (i), Rule 4 (1) (f) of FRA and Section 4 (d) of PESA. All efforts will be made to ensure that FRA provisions are strengthened

In areas not covered by FRA but where communities have customarily been mannaing  their forest resoruces such as in the North East Region, such community structures will be strengthened to be more gender inclusive and livelihoods oriented

4.1.1 (f)

4.1.1 (g)

4.1.1 (h)

Biodiversity conservation

Management through approved working plans

Strengthen participatory forest management

National Community Forest Management (CFM) Mission

will be launched.

Adivasis and OTFDs are rights holders and governors of traditional community forest resources under S.3(1)(i) and S.5, FRA. Working plans no longer operational over vested CFR lands. Gram Sabha can create CFR Management Committee under Rule 12. GS has rights to manage, protect, conserve wildlife, water resources, etc. Community participation throwback to JFM. No longer valid. Move to undermine FRA guarantees.

This structure would work in parallel of the MOTA and the provisions of the FRA . Instead such a mission should be placed within the MOTA to promote effective implementation of FRA to promote community based governance and management of FRA within framework of FRA

·         Globally, move to vest resources in the management and governance of communities as the best stewards/ guardians of resources.

·         Commercial exploitation, P3 models contrary to principles of democratic forest governance; have been widely opposed by forest rights groups, and are against the constitutional provisions for justice and rights of tribals in forest areas

·         Participatory management based on earlier flawed models of JFM, which marginalized communities from decision-making

Working plans will be formulated in keeping and in consonance with the Village FRMC plans, to address the priorities of communities in the management of forests and forest resoruces.

·         In India, several community-led forest protection initiatives, especially led and with active participation of women, which reflect modes of forest protection that is ecologically sound and meets livelihood needs. Efforts will be strengthened to ensure womens participation and leadership in the Forest Rights Management committees (FRMC) and to promote the formation  of community based FPOs to benefit them from the returns from resoruces from their forests such as gum, leisa, cinnamon, traditional herbs etc. Restrictinos on licences of these produce will be removed to entitle  and enable communities to control governance and management of such resoruces, with women as beneficiaries of  such incomes

4.1.1 (i)

(i)           Management of Non Timber Forest Produce

·         NTFP transferred to market use Destroys local sustainable livelihood base for market-oriented extraction.

·         Does not support local forest economy but compels men and women into low-wage labour, distress migration- whereas they are rightfully owners of these resources.

·         Not compliant with FRA- GS and CFRMC have rights to sell, issue transit permits etc. Revenue to be distributed within the village. Here, revenue diverted to private cos.

Management of NTFP to be oriented towards community-based forest economy: income needs secured not through FDC but through own co-operatives, sangathans. Efforts will be made towards MSP guarantee and in securing buyers as well as in strengthening value chains through a community based approach

4.1.2 (a)

4.2.1

4.1.2 Management of trees outside forests

a) Promote agro-forestry and farm forestry

Agro-forestry and farm forestry have taken deep roots in the country and Trees Outside Forests (TOF) are contributing to the increase in tree cover and enhancing ecosystem services, while meeting a bulk of the country’s wood demand and providing climate resilient incomes to the farmers.. Thus promotion of wood use obtained from sustainably managed forests and trees would play a significant role in mitigating climate

change and ensuring sustainable living. In view of this the following measures will be taken:

(i) Agro-forestry and farm forestry would be encouraged through commensurate incentives and

operational support systems..

(ii) Systems for certification of improved planting material would be put in place.

(iii) Price assurance to the farmers would be facilitated by putting in place pre-production agreements

between the farmers and the forest based industries.

(iv) Suitable location specific Public Private Partnership models will be developed involving Forest

Departments, Forest development Corporations, Communities, Public limited companies etc for

achieving the target of increased forest & tree cover in the country.

(v) Promotion of cultivation, harvesting, transportation and marketing of wood would be ensured by

relaxing the existing felling and transit regime in the country. Inclusion of agro forestry & farm

forestry in the Agricultural crop insurance scheme would be facilitated. Also, agro forestry and farm

forestry crop will also be included in National crop insurance scheme.

(vi) Massive awareness and extension services for promotion of agro forestry will also be launched.

·         Same critique as above.

·         Alienates lawfully vested forest rights, land rights. Insecurity of tenure.

Wood and forest management would need to prioritize community needs and species choices as well as management for the wellbeing of communities, who maty then generate the surplus based on a negotiation of demand and their own environmental and livelihoods needs

Promotion of wood cultivation  may often disrupt the ecological systems and result in denial and reduction of food crop and reduced access to commons which may be brought under such forests. These plantatinos are not ni interest of community livelihoods and food nutruitino needs especially for tribals and marginalized populatinos and should be avoided

Agro forestry needs to be viewed as a  means of  restoring resources and maintaining biodiversity for communities rather than as a commercial timber venture. In view of this the following measures will be taken:

Changes suggested……

i)                Agro-forestry and farm forestry would be encouraged through management of biodiversity and promotion of species selected and managed by women within communities, in order to manage the bio diversity and livelihoods needs of food, fuel , fodder and seeds within communities

ii)       operational support systems that adhere to community needs and priorities and control of resources within communities with a women centric approach.

(ii) Systems for certification of improved planting material would be put in place – this should be avoided 

(iii) Price assurance to the farmers would be facilitated by strengthening their capaciites to organize and manage their production systems and putting in place effective MSP regimes to assure forest workers and agro farmers their supportive prices, rather than being exposed to profitteering middle men and usurious market based industries

4.2

4.2.1 Production Forestry

4.2.2Economic valuation of the forests

4.2.3 Forest management for water recycling

4.2.4 Forest Certification

4.2.5 Integrate climate change concerns & REDD+ strategies in forest management:

4.2.6 Develop a national forest ecosystems management information system

These are all measures contrary to the interests of forest sustainability and the interests of ecological and social sustainability of forest regimes, oriented towards market and protitability

We do not accept these measures. Need to be formulated in context of the FRA and sustainable development priorities rather than imposing a market oriented footprint on forests and forest dwellers

4.3

Strengthen Wildlife Management Strengthen Wildlife Management

India has rich diversity of wild flora and fauna housed in varied ecosystems.,…

securing key habitats and re-establishing wildlife populations.

rising human animal conflicts, illegal

trade in wild species and climate change impacts. Hence, there is an urgent need to renew the efforts to safeguard wildlife and secure their habitats. Following actions will be undertaken in this regard:-

(a) Management of Protected Areas would be strengthened for preservation of habitats for

outside PA’s. The wildlife rich

areas and corridors outside PA’s would be identified and maintained for ensuring ecological and

genetic continuity. Such areas would be effectively secured by strengthening enforcement, restoring

habitats and managing ecological corridors.

(b) Assessment of species for survival and recovery measures based on population and habitat viability

parameters would form an integral and regular part of management planning and practices.

c)Human wildlife conflicts have escalated over the years .

D) and (e) Import and trade of exotic species, their uses and upkeep shall be subjected to strict regulations to

ensure that the native biodiversity does not face genetic contamination.

(f) Wildlife crime and illegal trade pose grave challenge to conservation efforts. The existing central monitoring, sharing of information and on line updating of data on forest/ wildlife crime would be institutionalised and further strengthened. The detection, investigation and prosecution capacity shall be augmented by technical support in form of network of forensic laboratories.

Focus on ‘flagship species, securing key habitats , with little consideration to traditional forest dwelling communities or to the systems of ecological management evolved by communities to live with other species are detrimental to wild life wellbeing in the lnog run

PA management without the involvement of communities and their needs being addressed is contrary to the principles of ecological development. Creates conflict, criminalizes communities, denies traditional rights to these regions, ignores communities own management systems .

Maintaining natural biodiversity profile cannot be viewed in isolation of communities

Viewing species only as a source of revenue is amyopic vision for ecology and forest sustainability and must be planned in the view of broader community wellbeing of traditional communities

Wildlife management does not require a special mechanism, but a mechanism that works to strengthen communities own systems and practices to manage thesi ecosystems.

Once the forest is restored to its natural condition and the autonomy of the forest is in the hands of tribals and other forest dwellers completely. The biodiversity of the forest will be restored with the management mechanism of tribals and other forest dwellers

4.5

4.5 Research and Education

Scientific research in forestry and wildlife is the back bone of forest management and contributes to

understanding of the forest dynamics leading to pragmatic conservation planning.

·         Current research and education does not give due consideration or take a holistic approach to community based forest and ecosystem management, not does it  attend  to the priorities that often women have highlighted as the reasons for community conflict in that their  survival and livelihoods are threatened

The curriculum of the FD and the WLM would be oriented to holistic and community centric approaches to promote a sustainable model of forest management. Only through such an approach will community needs and market demands for forest produce and species be ment in a sustainable and ecologically enriching process that will also help to mitigate climate distress and impacts

4.8

Legal and institutional frameworks

Measure to promote a National Board of Forestry headed by the central minister in-charge of forests and State Boards of Forestry headed by state minister in-charge of forests will only serve to build an authoritarian and state driven machinery for forest exploitation

It is hardly likely to promote the democratization of forest management nor strengthen the livelihoods of forect dwellers not the ecological wellbeing of forests. While  ensuring inter-sectoral convergence, simplification of procedures, conflict resolution and

periodic review, it is  likely only to strengthen extractive mechanisms to the detriment of communities and forests and the wellbeing of both

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Suggestion to Change this point  as below…..

This policy will ensure that it does not amend laws pertaining to forest land tenure rights and local self-governance laws, esp. FRA and PESA..

Further instead of formulating new institutional mechanism in the form of the National Forestry Board and State Forestry Board, existing mechanisms such as the  National Commission for Scheduled Castes and Scheduled Tribes, the Minority Commission, the Women and Child Department will be utllised and MOTA will be engaged to play a more cohesive role in forest management with the goals of ecological and livelihoods management in sight.

 Members of these bodies long with community leadership, ensuring womens participation and leadership in equal number at least, to form membership of the Board.

The Ministry of Tribal Affairs (MoTA) will be the Nodal Ministry

4.11

Harmonization with other laws and policies

Forests influence, and in-turn are influenced by activities and functions of different sectors such as Tribal affairs, mining, water, roads, tourism, agriculture, rural development, industry, irrigation and transmission lines etc. As far as community forest resources management under Forest rights Act is concerned, the new policy will address the same under participatory forest management and the same will be addressed through the proposed community forest management mission. It is also seen that the prescriptions under the farm forestry and urban greenings will ensure synergy with the existing agroforestry policy also. Necessary collaborative steps will also be undertaken to ensure that the policies, laws and programmes of various sectors, both at Centre and State level are in harmony with the objectives of this policy

Community forest resources management is highlighted under the  under Forest rights Act and PESA. The new policy must not contravene the same. Its efforts to address the same under participatory forest management and under the proposed community forest management mission are attempt to subvert the strengths and undermine the processes of community  based governance. Prescriptions under the farm forestry and urban greenings are likely to have adverse ecological and livelihoods impacts.

The objectives of this policy must be harmonized with the constitutional provisions as well as the provisions of laws to protect the interests of tribal and Dalit and OTFD communities particularly Schedule V and Schedule VI of the Constitution.

4.13

4.13     Good governance

The public service delivery system will be strengthened by optimizing human resource availability at all levels, ….

Institutional restructuring to enable effective implementation of this policy will be facilitated wherever needed. Human resource strategy for professional foresters and forest scientists will aim at attracting and retaining qualified and motivated personnel, keeping in view, particularly the arduous nature of duties often in remote and inhospitable places.

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Massive capacity building efforts, reinforcing transparency and accountability measures, prompt grievance redressal must be addressed to the needs of engaging and  strengthening  community roles, especially for women and youth in the management of forest resoruces and the institutinos to managem value and  supply chains to benefit from the same for their wellbeing and for the maintainance of ecological health fo forests.

Use of cutting edge technology must be used in the strengthening of community management syatems and in the participatory management of forest resources based no community leadership

Institutional restructuring is required to orient the processes and systems towards giving communities priority and leadership in the management of forests and forest resources raher than investing in PPP and other such measures that negate the rights of communities and threat to the ecological sustainability

Opportunities for professional growth and specialization will be provided and proper utilization of such specialization will be ensured. These measures of good governance should be located against the background of democratic principles of local governance.

 4.14

4.14 Implementation framework and way forward

This policy envisages that a national implementation framework be put in place to deliver on these policy ……

Implementation framework geared to current proposal will be focused on productivity and market based target. These are centralized structures envisaged which is  nither conducive for ecological sustainability  nor to monitor and strengthen community livelihoods processes

 Monitoring implementation of policy processes should be geared to strengthen community  engagement and community rights