Abstract. Keywords: cost-benefit analysis, Sardar Sarovar dam, economic valuation, forestry, biodiversity, multi-criteria analysis

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1 Is Cost Benefit Analysis Alone a Good Tool to Evaluate Environmental Impacts? A Comparison of Submerged Forest and Compensatory Plantations from the Sardar Sarovar Dam Kaushali Dave Institute for Transport Studies, University of Leeds 38 University Road, University of Leeds, Leeds LS2 9JT, UK trakd@leeds.ac.uk Registration number: ISEE535 Abstract Cost benefit analysis (CBA) has been a major tool for the policy makers in deciding resource use and justifying chosen development projects. This paper aims to provide a critical analysis of the application of CBA in justifying development projects. The Sardar Sarovar dam is one of the large dams to be built on the river Narmada with several environmental, social and economic impacts across three Indian states. A part of the environmental impact of the dam includes the large submergence of tropical deciduous forest. In compensation to the area of forest submerged in Gujarat, some compensatory plantations have been carried out in the state. This study compares the economic return and ecological diversity of the submerged and the afforested areas. Using the Faustmann model, the economic value of the forests is found by calculating the revenue obtained from various forest products (timber as well as non-timber forest products) in the two systems. The net present value is calculated under the two aspects and this is then compared with the biodiversity in the two forest types. The economic and ecological costs and benefits from the submerged and afforested areas are compared, CBA critically assessed and the role of multi-criteria analysis evaluated. Keywords: cost-benefit analysis, Sardar Sarovar dam, economic valuation, forestry, biodiversity, multi-criteria analysis

2 Introduction In any kind of development project, it is important to incorporate the environmental impacts in policy appraisals. One way the governments around the globe do that is by the use of Cost-Benefit Analysis (CBA). CBA is a method of systematically arranging arguments of whether the project or the policy should go ahead or be stopped. This is because CBA framework clearly distinguishes between the different aspects of the project such as the cost stream, the benefit stream and the life expectancy of the project. However, there have been several criticisms of CBA on the grounds of equity. Moreover, ecosystem complexities make modelling economy and ecosystem interaction difficult (Hanley and Spash, 1993). This study aims to integrate the CBA framework with environmental impacts of constructing the Sardar Sarovar Dam (SS dam) on the river Narmada and with government decision making. Narmada is the largest west flowing river, rising at the Amarkantak range of mountains in the Shadol District of Madhya Pradesh. It is the fifth largest river in India and the largest in Gujarat. It traverses through the three Indian States of Maharashtra, Madhya Pradesh and Gujarat. The length of the river from the source to the sea is 1312 km while the length up to the dam site is 1163km (Sheth, 1994, Verghese, 1994). The current height of the dam is Full Reservoir Level (FRL) and is located 120 kms upstream of Bharuch, Gujarat, India. The full height of dam when the dam will be completed will be at meters FRL (see Appendix 1 for the location of the dam). The construction of the dam will result in the submergence of three complete forest villages and 16 partial forest villages in Gujarat alone which accounts for 4523 Ha of forest land. The reservoir will occupy a linear stretch of 214 km of water and width of 1.77 km. The submergence at the FRL is 37,690 Ha which comprises of 11,279 Ha of agricultural land, 13,542 Ha of forest and 12,869 Ha of river and wasteland. In all, 245 villages of three states are getting submerged out of which 193 are in Madhya Pradesh, 33 in Maharashtra and 19 in Gujarat (Ahmed, 1999, Morse and Berger, 1992 and Sheth, 1994). In mitigation to the forest getting submerged in Gujarat, the Government of Gujarat (GOG) has carried out compensatory afforestation of 4670 Ha in a non-forest area in Gujarat and 9300 Ha of Impact Area Plantations. This study focuses on comparing the old growth forest with the new compensatory plantations. The method used is by calculating a monetary value of the old growth forest and the new plantations by valuing its timber and non-timber forest products.

3 Methods The method used to compare the old growth forest and the new compensatory plantations is by the use of CBA. The economically relevant impacts of the dam are physically quantified and a monetary valuation of the relevant effects is made. This is then followed by discounting the future benefits and costs and applying the Net Present Value (NPV) test. Two approaches were taken while comparing the two forests. One is the economic value of the two forests and other is comparing the biodiversity of the two forests. However, only the financial value of the two forests will be incorporated into the CBA and not the biodiversity values. The value of the old growth forest was collected from the forest offices. The forest getting submerged by the SS dam falls under two forest divisions Rajpipla (E) and Chotaudepur. The forest officers at the two forest divisions had cut the trees before the forest wood gets submerged and therefore have a record of the monetary returns from the timber products of the forest. The forest products from the old growth forest include teak, non-teak timber, charcoal and minor forest products (MFPs also called Non Timber Forest Products NTFPs). The forest officers helped the tribals in collecting the NTFPs and thus had a record for monetary returns from the NTFPs. In the SS submergence area, the trees are felled for timber and other products before the submergence occurred. As the forests fall under two different Forest Divisions, the year of clear felling and the sale of the forest products differed in the two regions. Most of the clear felling was done in the 1980s. The value of the forest was found using the Faustmann model. The Faustmann rule in forestry states that the optimal time to harvest a stand is when the rate of change of its value with respect to time is equal to the interest on the value of the standing trees plus interest on the value of the forest land (Viitala and Tahvonen, 2004). As the old growth forest gives a continuous return with most of the species having a rotation cycle of 80 years, the Faustmann model was used to find the NPV of the timber stands with 80 years rotation time for timber and a one year rotation for the NTFPs of the forest. The discounting was done using a range of discount rates such as 4%, 6%, 8% and 12% to carry out a sensitivity analysis. The financial value of the new afforested area was found by estimating the revenue obtained after the first rotation period and then discounting it to the year 2000 using the discount rates given above. As per the forest officers at Kutch, the total area afforested cannot exceed 4000 Ha and so the financial returns of 4000 Ha of afforested land are found. The major products obtained from this forest are firewood and charcoal. There are various different species planted and these have different rotation periods. The future values of these species will be estimated using an interest rate of 8% and this will

4 then be multiplied to the estimated yield to provide the future revenue. This revenue is then discounted to the year 2000 using the discount rates of 4%, 6%, 8% and 12%. The financial returns from both the forests will then be compared to the year 2000 values. The biodiversity of the two forests is compared using the species richness measure but is not put into monetary value and is hence not included in the CBA. The biodiversity of the submerged forest was found by a study made by the Maharaja Sayajirao University (MSU) of Baroda. The study was done to find the status of the area as in 1992, the floristic elements, the rare and endangered species in the area and the methods to conserve them as well as the status of plants of economic importance was the aim of the study. As many as 70 field trips were undertaken by the MSU and were arranged around the year to cover all seasons for proper phenological observations (Sabnis and Amin, 1992). Results Biodiversity of forest going under submergence: A total of 600 plant species has been collected from the study area out of which 18 were fungi, six bryophytes, five pteridophytes and 571 angiosperms. The soil in this part of the project area is mainly deep black, shallow black, brown and alluvial soil. The annual rainfall is about mm per year (NWDA). The right bank of the study area consisted of 924 sq kms. between Vadgam and Hafeshwar. The main species found in the few patches of forest left in this area consists of Tectona grandis, Adina cordifolia, Lagerstroemia lanceolata, Anogeissus latifolia, Garuga pinnata, Butea monosperma, Morinda tomentosa, Holarrhena antidysenterica, Wrightii tinctoria and Lanena coromandelica. Some trees such as Hymenodictyon excelsum, Gmelina arborea, Emblica officinalis, Terminalia bellerica, Cordia gharaf, Ailanthus excelsa, Carya arborea and Azadirachta indica are also found. Most of the areas of right bank show well-established agriculture. The main crops are maize (Zea mays), rice (Oryza sativa), jowar (Sorghum bicolour), tur (Cajanus cajan) and cotton (Gossypium herbaceum). The monetary values of these farmlands were not estimated as they are used by the tribals only. However, it is important to note that agriculture in the forestry is completely ignored in the cost benefit analysis. The left bank area comprises of the Shoolpaneshwar Sanctuary which is spread over an area of 675 sq kms. This area is highly important because it forms the catchment area of the SSP. According to Champion and Seth s classification (Sabnis and Amin, 1992), the forests in this area are placed in to moist, mixed deciduous forest and dry, mixed deciduous forest. The moist deciduous forest includes trees like Terminalia crenulata, Adina cordifolia, Tectona grandis, Mitragyna parviflora, Hymeneodictyon excelsum, Lagerstroemia lanceolata, Anogeissus latifolia, Bridelia retusa and

5 Albizia lebbeck. The dry mixed deciduous forest is commonly found in areas with poor soil cover and heavy biotic pressures. Tree species such as Tectona grandis, Anogeissus latifolia, Garauga pinnata, Lanena coromandelica, Mitragyna parviflora, Pterocarpus marsupium and Madhuca indica are found in this region. Biodiversity in the compensatory plantations Under the compensatory plantations, the Government of Gujarat is raising 4670 ha in Kutch district of Gujarat. The soil in this part of Gujarat is mainly sandy/clay loams and the average rainfall is about 400mm per year. The major tree species planted under this compensatory afforestation are: Local Name Botanical Name Percentage planted Israel Bavad Acacia tortilis 39.06% Deshi Bavad Acacia nilotica 25.58% Gando Bavad Prosopis juliflora 18.60% Limda (Neem) Azadirachta indica 7.2% Pilu Salvadora persica 2.3% Gorad Acacia Senegal 1.76% Siras Albizia lebbeck 1.29% Other 25 or more species form the remaining 4%. As Acacia tortilis, Acacia nilotica and Prosopis juliflora along with Azadirachta indica form the majority of plantations, these will be mainly taken into consideration to calculate the benefits from the compensatory plantations. Economic Returns from the Two Forests: Taking into consideration that if the old growth forest is left intact, it would yield a steady income from timber with rotation cycle of 80 years and from NTFP with rotation of one year, the results of the old growth forest was found by finding the future value of timber and MFPs and then discounting it to the year 2000 using the various discount rates. Table 1 show the net income obtained from the various products from the Rajpipla (E) and Chotaudepur forest divisions. Table 2 shows the revenue obtained from the NTFPs from Rajpipla and Chotaudepur forests. The total net revenue obtained from timber, charcoal and MFPs from the Rajpipla and Chotaudepur forests is Rs. 50,283, Using the Faustmann model (Hartwick and Olewiler, 1998), the following formula is used to calculate the NPV of the timber stands and the NTFPs using the rotation cycles of 80 years and one year respectively.

6 Table 1 Revenue obtained from timber and charcoal from Rajpipla (E) and Chotaudepur forest divisions Forest Division Total Area in Ha Year of Cutting Products Net Income Rajpipla (E) Chotaudepur Obtained Timber 23,795, Charcoal 9,865,837 Timber 7,995, Charcoal 4,940,166.5 Table 2 Revenue obtained from the NTFP from Rajpipla (E) and Chotaudepur Forest Division Year of Collection Products Obtained Net Income Rajpipla (E) Tendu leaves 1,407, Mahuda flowers and seeds 65, Others 62, Chotaudepur Timru leaves 2,150,500 NPV = V / (1-e -rt ) where, V = net value of one cutting and t = rotation time. Thus, the NPV of the old growth forest using the discount rates of 4%, 6%, 8% and 12% can be summarized as in table 3. Table 3 The Net Present Value of timber and NTFP at various discount rates Product NPV at 4% 6% 8% 12% Timber 48,577, ,983, ,674, ,600, NTFP 94,015, ,301, ,947, ,599, Total 142,592, ,285, ,622, ,200, The net value of one cutting (V) was found to be Rs. 46,597, for timber and Rs. 3,686, for the NTFPs as shown in tables 1 and 2.

7 For the compensatory plantations, it was found that Acacia tortilis yield 54 metric tones (Mt) of firewood per hectare. Acacia nilotica 100 Mt per Ha, Prosopis juliflora 75 Mt per Ha and Azadirachta indica 30 Mt per Ha in approximately 15 year rotation times for each (National Academy of Sciences, 1980). Most of the plantations were finished in 1993 so the year of first rotation will be 2008 when the prices of firewood would be Rs /quintal (where 1Mt = 10 quintals) taking the base of Rs.100/quintal (as of year 2000) and an inflation rate of 8 per cent. The number of seedlings that survived in the area were converted to the amount in tones of firewood that they would yield considering that a hectare of plantation has 2500 seedlings and calculating the yield rates given above. It was found that the average survival rate through the various sites is 68 per cent. The data was obtained for 2238 Ha and was then extrapolated to 4000 Ha. The total survived trees in 4000 Ha was found using this survival rate. Table 4 shows the species planted and survived in the compensatory plantations. Table 4 Type of species planted in compensatory afforestation and the number survived Species No. planted in 2238 Ha No. survived at 68% rate in 2238 Ha No. survived in 4000 Ha at 68% rate Acacia tortilis 1,934,545 1,306,316 2,334,792 Acacia nilotica 1,434, ,947 1,763,980 Azadirachta indica 346, , ,669 Prosopis juliflora 836, , ,718 Using the productivity of the various species given in the table 4 and the fact that a hectare contains 2500 species, the survived seedling in 4000 Ha was converted to hectares and their productivity found using the productivity values of each species. Therefore, in an area of 4000 Ha, the following result was obtained for the main species which constitute 90 per cent of the total plantation. See table 5 for the results. Table 5 The productivity of species planted in 4000 Ha. Species Seedlings survived Productivity in quintals Acacia tortilis 2,334,792 5,043, Acacia nilotica 1,763,980 7,055,920 Azadirachta indica 980,718 2,942,154 Prosopis juliflora 429, ,602.8

8 Using the rates of Rs /quintal (which is equal to Rs.1,850.9/Mt), the gross revenue from the productivity is calculated to be Rs. 287,941, The collection cost is calculated using the current collection and other costs of Rs. 20,843,318 Table 6 NPV from compensatory plantations at different discount rates Species 4% 6% 8% 12% Acacia tortilis + A nilotica + Azadirachta indica + Prosopis juliflora 449,642, ,132, ,492, ,677,456.8 Discussion From the results obtained from the monetary value of the two forests as well as non-timber and timber benefits within the same old growth forest, it can be seen that the non-timber products have high economic value primarily due to its short rotation periods. The NTFPs include edible fruits, oils, latex, fibre and medicine. However, most financial appraisals of tropical forests focus exclusively on timber resources and have ignored market benefits from non-timber products. The newly afforested region in Kutch provides mainly firewood and charcoal. The species planted achieves maturity in 15 years whereas most of the trees in the old growth forest have a rotation period of 80 years. These differences in the rotation periods have a major impact in the valuation of the forests. As per the consolidated guidelines for the Diversion of Forest Land given in the Handbook of Environment, Forests and Wildlife Protection Laws in India, compensatory afforestation is one of the important conditions stipulated by the Central Government while approving proposals for the diversion of forest land for non-forest uses (for more information on the guidelines for compensatory afforestation, see Appendix 2). Compensatory afforestation has to be carried out in an equivalent area of a non-forest land and in the same district or as near as possible to the site of the diversion so as to minimise the effect on the micro-ecology of the area. However, this has not been done in the case of the Sardar Sarovar Project. Compensatory afforestation has been carried out in Kutch district which has a completely different climatic condition to that found in the areas getting submerged. Yet, the monetary returns from the new forest were found to be more than the old growth forest. This is due to the species planted. The old growth forest consists mainly of angiosperms and was very diverse in

9 species. While the forest provided fuel, fodder and fruits to the tribals, it was not yet of high economic value probably due to the low productivity of certain species. The newly afforested region in Kutch on the other hand, mainly consists of short rotation high firewood and charcoal yielding shrubs of Acacia nilotica, A. tortilis and Prosopis juliflora. These species may provide many benefits to the society and the locals due to the high calorific value of firewood and charcoal. Yet, the argument is that Gujarat selected the area because it was the only substantial area available and was badly in need of reforestation. A major factor bearing on the compensatory afforestation being carried out in Kutch is that the area there is cheap, being marginal for agriculture and in an area where the countryside has been recently depopulated. This approach adopted by Gujarat is at flaw. If the practice of replanting marginal forest land in compensation for better lands elsewhere continues, old growth, highly diverse forest will be replaced by new, less diverse habitats. Moreover, carrying out the compensatory afforestation in an entirely different ecozone ensures that the forest created will not have the same ecological composition as the one submerged. This is in violation to the principle that quality and not only the quantity of India s forest should not be allowed to reduce (Morse and Berger, 1992). This study has used cost benefit analysis (CBA) technique to compare the two forests in order to assess whether this is a justified tool to use when several ecosystem complexities are involved. CBA has been used as a major tool by policy makers in deciding resource use. However there are several shortcomings of CBA especially when applied to an ecological context. An important and critical point is the concept of discounting. The further into the future the benefit and cost streams occur; the lower is the net present value which results in the increased value of shrubland as compared to tropical forest land. CBA also fails to incorporate other important effects of environment in environmental decision-making. The inability to correctly price the environmental asset is a serious problem because an error in the prices can radically change the result of the CBA from positive to negative. As is common in most forests and other environmental assets, when property rights are illdefined, prices can be highly inaccurate (Chichilnisky, 1997). CBA also uses a monetary numeraire to make income and environmental impacts subject to a unified welfare evaluation. This means that environmental effects need to be valued in monetary terms and discounted (van Pelt, 1993). However, it is not always possible to put a value on environmental goods and services and the process of discounting is also a major concern. Moreover, one of the CBA s cornerstones is the principle of potential compensation. Costs are acceptable as long as the benefits are sufficiently large enough to compensate the losers, but whether actual compensation takes place is irrelevant. Hence expected environmental damage need not stop the approval of a project as long as its benefits outweigh the costs. Such an outcome is not compatible with ecological sustainability principle which implies that beyond a certain limit, environmental damage is undesirable or even unacceptable, and that disutility

10 increases with the size of the gap between expected and desirable resource use (van Pelt, 1993). The concept of complete compensability implies that good performance on the economic sector can justify poor performances on other sectors. This is against the concept of sustainability (Munda, 2005). Though the main aim of this study has been to compare the economic and ecological benefits from the two forests, there are several other derived issues resulting from these. One of the important functions carried out by the old growth forest was to provide home to the tribals. As per the Government of Gujarat (GOG) statistics, 4582 project affected families (composed of tribals) would be affected in Gujarat alone. Based on the resettlement package under the Tribunal Award, when a family loses more than 25% of their land, the major sons as well as their father will receive two hectares of land. This condition however requires that families claiming the compensatory land should have had a title or acquired to have a title on land in order to receive compensation. Thus people without entitlement to any previous land will be classified as landless outsee. This raises the question of intragenerational equity under the CBA framework. Economic valuation techniques have not been used to evaluate the biodiversity of the two forests. This is mainly due to the resource constraints faced during the study. Moreover, plant diversity in the two forests is compared on absolute scales rather than converting them to a monetary value. Though economic tools can be used to value most environmental commodities (Soma, 2006), when all environmental impacts cannot be quantified in monetary terms, multi criteria analysis (MCA) is an alternative approach which can help in making better choices between projects and policies (Dave, 2001). MCA techniques differ by the set of options and scales they can handle, the decision rules they apply and the method of scoring. Several methods are available to carry out a MCA based on the differences in techniques. These include pairwise comparisons, ranking, multi attribute utility theory, outranking methods and analytic hierarchy process. The advantages of MCA are that it allows several objectives to be considered, is relatively transparent (as the process of arriving to a score can be traced) and can be easily adopted in appraisals. However, there are several shortcomings of the technique. While the relative subjectivity of the scores is one of the problems, another is in determining which option is worthwhile (Phillips and Stock, 1993). This leads to the question on whose preferences count. Various interest groups will often assign different weights to different categories (Munasinghe, 1993). In case of development projects which have wide ranging economic, environment and social impacts, it is useful to be able to integrate quantitative and qualitative appraisal methods. While results from CBA can form one of the criteria in MCA, it is required that the decision maker is fairly objective and unbiased. In developing countries, projects have been largely driven by political ambitions with poor representation from other sectors of the society. In order to carry out a fair appraisal, it is required

11 that all affected sections have a representation in the appraisal as stakeholder participation is crucial. Using MCA techniques can be a way forward, however, complete coverage of the effects and total representation from all affected groups can be an expensive and time-consuming process. It is also important that policy makers are aware of the social and environmental impacts of projects. In case of the compensatory plantations from Sardar Sarovar dam, the GOG decided to ignore the stipulations provided for the compensatory plantations which resulted in a very different forest system created from that getting submerged. Based on the economic returns of the compensatory plantations from the CBA, it would be wrong to justify the compensatory plantations in exchange of the old growth forest. Conclusions: This project was aimed at comparing the benefits from the old growth forest with the benefits of the compensatory plantations from the construction of the Sardar Sarovar Dam. It was found that the NPV of the compensatory plantations is more than the submerged tropical forest. This implies that using the CBA approach to evaluate only the use-values of the forest, it is profitable and justified to replace tropical deciduous forest by semi-arid shrubland. However, the compensatory afforestation carried out by GOG is not in accordance with the rules stipulated for the diversion of forest land. The use of CBA as a decision-making tool though widely used and helpful is debatable and not completely reliable when it has immeasurable environmental impacts. A more correct approach towards these kinds of project appraisal is the use of multi criteria analysis or an integration of CBA and MCA techniques. It is not the technique of CBA that is flawed but its application on wider ecological, social and cultural services like the riverine and forest ecosystems which support vast ecological as well as cultural diversity. This project has been a pioneering work on the comparison of the old growth forest and compensatory afforestatation from the Sardar Sarovar dam. The decision to not evaluate the economic value of biodiversity in the two forests and include in the CBA might be regarded as a shortcoming. However, the argument of this paper is that biodiversity values should be taken and compared on their own without placing an economic value on them. This can be done by using MCA techniques available. It is also suggested that policy makers should take the wider environmental and social implications of projects in mind and maintain the quality and not only the quantity of India s forests.

12 References: Ahmed A. (1999), The Narmada Water Resource Project, India: Implementing Sustainable Development, Ambio 28: Chichilnisky G. (1997), The Costs and Benefits of Cost Benefit Analysis, Environment and Development Economics 2: Dave K. (2001), The Economic Value of Habitats: Methods and Alternatives, MSc Study Project Report, Brandenburg Technical University, Germany Hanley N. and Spash C., (1993), Cost Benefit Analysis and the Environment, Edward Elgar Publishers, UK Hartwick J. and Olewiler N. (1998), The Economics of Natural Resource Use, Addison-Wesley, USA Morse B. and Berger T. (1992), Sardar Sarovar: The Report of the Independent Review, Resource Future Inc., Canada Munda G. (2005), Measuring Sustainability : A Multi-Criterion Framework, Environment, Development and Sustainability 7: , Springer Munasinghe M. (1993), Environmental Issues and Economic Decisions in Developing Countries, World Development 21(11): National Academy of Sciences (1984), Firewood Crops: Shrub and Tree Species for Energy Production, Washington DC NWDA, Feasibility Report for Tapi Narmada Link, National Water Development Agency, India Phillips L. and Stock A. (2003), Use of Multi-Criteria Analysis in Air Quality Policy, Report prepared for Department for Environment, Good and Rural Affairs, Catalyze, UK Sabnis and Amin (1992), Eco-environmental Studies of the Sardar Sarovar Environs, MS University Press, Baroda

13 Sheth P. (1994), Narmada Project: The Politics of Eco-Development, Har-Anand Publications, New Delhi Soma K. (2006), Natura economica in Environmental Valuation, Environmental Values 15: 31-50, The White Horse Press, UK van Pelt M. (1993), Environment and Project Appraisal: Lessons from Two Cases, The Annals of Regional Science 28: 55-76, Springer Verlag, Netherlands Verghese B.G. (1994), Winning the Future from Bhakra to Narmada, Tehri, Rajasthan Canal, Konark Publishers, Delhi Viitala E. and Tahvonen O. (2004), Does Faustmann Roatation Apply to Fully Regulated Forest? Forest Science 52(1): 23-30

14 Appendix 1: Map showing the location of the Sardar Sarovar Dam (source: Morse and Berger, 1992)

15 Appendix 2: Consolidated Guidelines for the Diversion of Forest Land on Compensatory Afforestation Compensatory afforestation is one of the most important conditions stipulated by the Central Government while approving proposals for dereservation or diversion of forest land for non-forest uses. The detailed compensatory afforestation scheme along with details of non-forest/degraded forest area, map, etc., is required to be submitted in the prescribed form. Land for compensatory afforestation: i. Compensatory afforestation shall be carried out over equivalent area of non-forest land ii. As far as possible, the non-forest area should be identified contiguous to or in the proximity of the Reserved Forest or Protected Forest to enable the Forest Department to effectively manage the newly planted area iii. In the event that the non-forest land for compensatory afforestation is not available in the same district, non-forest land for compensatory afforestation may be identified anywhere else in the State as near as possible to the site of diversion, so as to minimise adverse impacts on the micro-ecology of the area iv. Where non-forest lands are not available or non-forest land is available to a lesser extent to the forest area diverted, compensatory afforestation may be carried out over degraded forest twice in the extent to the area being diverted or to the difference between forest land being diverted and available non-forest land, as the case may be v. The non-availability of non-forest land for compensatory afforestation would be accepted by the Central Government only on the certificate from the Chief Secretary to the State/Union Territory Government to that effect The scheme for compensatory afforestation should contain the following details: a) Details of equivalent non-forest or degraded forest land identified for raising compensatory afforestation b) Delineation of proposed area on suitable map c) Agency responsible for afforestation d) Details of work schedule proposed for compensatory afforestation e) Cost structure of plantation, provision of funds and the mechanism to ensure that the funds will be utilised for raising afforestation

16 f) Details of proposed monitoring mechanism (Handbook of Environment, Forest and Wildlife Protection Laws in India, 1998)