- Nitai Hinduja*
1. Introduction and Structure
Introducing Carbon Credits and the Structure of the Article
A carbon credit refers to a one-tonne equivalent of carbon dioxide (or other equivalent Green House Gas or GHG) emissions that have been sequestered (i.e. removed), avoided or reduced from the atmosphere. This carbon credit can be used by a company/individual to offset a responsibility placed on it to sequester, avoid, or reduce a particular amount of carbon emissions. Simply put, a carbon credit can be thought of as a tradeable right to emit carbon.
Depending on the country in question, carbon credits may be obtained in the following ways. They are either directly issued by the government or allocated by accreditation and verification agencies for activities that lead to sequestered, avoided, or reduced carbon emissions. These credits, so accumulated or generated, may be traded, or sold between companies. These trades occur in either State Mandated Compliance Markets or Voluntary Carbon Markets, which comprise individuals looking to offset their carbon emissions, companies meeting sustainability targets etc.
Carbon credits and markets may have significant implications for Adivasis in India, and Indigenous Communities in general. These vary according to the particular formulation of carbon credits and markets in a given jurisdiction. However, broadly, impacts would be centred on questions of land rights and tenure, consent mechanisms, state control of forests and resources, and the possibility of abuse of asymmetric power. These possible impacts may have subsequent implications on the constitutional rights guaranteed to Adivasis in India, and subsequently, the constitutionality of carbon credits and markets in India.
To understand how these harms are enabled by the Carbon Credit Trading Scheme, 2023 (the Scheme), this article will first look into the legislative developments and history of carbon credits and markets in India. It would then explore the institutional structure that has been established under the scheme, alongside its possible implications. Then, drawing on literature from other jurisdictions, it would look into the implications of carbon credits and markets on Adivasis in India. Particular attention will be given to the literature on the interaction between REDD+ and indigenous rights.
2. Legislative Developments and Structure
In 2022, the Energy Conservation Act, 2001 (the Act) was amended (through the Energy Conservation (Amendment) Act, 2022) to insert Section 14 (w), which introduced the legislative possibility for the central government to notify/specify a carbon credit trading scheme. By inserting Section 14AA, the power to issue carbon credit certificates under the trading scheme to registered entities has been given to the central government or any agency authorised by the central government. Notably, these sections, while laying down the basic framework for carbon markets in India, are extremely limited in what they tell us of the actual structure of these markets and must be seen as simply enabling/regulatory provisions.
The Draft Green Credit Rules, 2023 were notified by the Ministry of Power for public comments on 26/6/2023. Shortly thereafter, the Ministry of Power on 28/6/2023 notified the Carbon Credit Trading Scheme, 2023 (the Scheme). The Scheme, notified under Section 14 (w) of the Act, lays down the regulatory framework for both setting up a Carbon Market in India and its functioning. The latter includes operations such as determining obligated and non-obligated entities, formulation of rules and procedures, determining emission reduction targets, issuing certificates, regulating the carbon market etc. To do this, the Scheme has set up regulatory bodies (such as the National Steering Committee for Indian Carbon Market) and has also delegated functions to already existing bodies (such as the Bureau of Energy Efficiency, Grid Controller of India Limited, Central Electricity Regulatory Commission, etc.).
Energy Markets Before the Scheme
Before the above notification, the Bureau of Energy Efficiency (BEE), which as we will see, is one of the primary functionaries under the scheme, released a Draft Blueprint on “National Carbon Market” in 2021. It suggests that India should look toward modifying existing market-based programs, such as the Perform Achieve and Trade (PAT) Mechanism and the Renewable Energy Certificate (REC) scheme. These programs attempt to incentivise the meeting of regulatory energy consumption requirements of particular industries. Going over and above these requirements leads to the generation of tradable Energy Saving Certificates (ESCerts).
While this current system is fairly limited in its scope and method of application, it is envisioned as the base over which a Voluntary Carbon Market will be developed. This would include increasing demand for ESCerts by increased coverage, fungibility, alignment with international verification standards etc. This would be followed by attempts to increase supply in the Voluntary Carbon Market, and then finally moving to a Cap and Trade system, which would entail statutory obligations on industries to limit their emissions.
Two observations are to be made here. First, significant questions lie on the relationship between the above Scheme, and the legislative mechanisms set forth to develop a carbon market in India. This leads to significant ambiguity and calls for clarification. The Draft Blueprint appears to be the precursor to the Scheme and specifically mentions that it is meant for stakeholder consultation.
The Draft Blueprint however omits to mention who these stakeholders are in the context of the Voluntary Carbon Market. It makes brief reference to affected industries and engagement with local stakeholders by project developers in the process of developing the project idea to generate carbon credits.
However, we may infer from the stakeholders involved in the PAT Mechanism that the stakeholders primarily concerned with the Blueprint include regulatory, implementing, administrative, verification bodies etc.
For our purposes then, it must be noted that the Blueprint does not make any reference to possible harms that may come from a carbon market. It does not recognise Adivasi communities as legitimate stakeholders in processes that appropriate their land, let alone engage with the possible implications for Adivasi communities. This absence, while expected, clearly points to the interests that are being served by introducing such a market-based mechanism as a solution to mitigate climate harm, which has an asymmetrical impact on Adivasi and other minority communities.
Second, and more pointedly, the proposal for an increase in supply in the Voluntary Carbon Market places a significant role on private entities. This is exacerbated by the fact that the BEE itself while being a statutory body under the Ministry of Power established under provisions of the Energy Conservation Act 2001, is premised on principles of self-regulation and the free market. In this, we can note a disjunct with the state’s constitutionally envisioned role vis a vis its citizens. Particularly, this method of envisioning the generation of carbon credits with increased private involvement, and the larger market-based approach to mitigating climate harm, puts Adivasis and other smaller communities involved in this process in a position that opens them to exploitation.
This is done by implementing a policy that is by design structurally inaccessible to Adivasi communities. This is in derogation of constitutionally and legislatively mandated agency and consent provisions. These protections are secured by a joint reading of Section 4(i) of the Panchayats Extension to Scheduled Areas Act, Section 4(2)(e) of the Forests Rights Act, and the judgment in Orissa Mining Corporation v. Ministry of Environment & Forest. In imagining nature as a tradable commodity accessible to private enterprise and market forces to exploit, it also violates the grant of community forest rights under Sections 3(1)(c), 3(1)(d), 3(1)(e), and 3(1)(i), guaranteed under Sections 4(1)(a) and 4(1)(b) of the Forest Rights Act.
Therefore, recognising this background of the BEE, the form of mechanism it seeks to build upon and develop, and the particular implications of such market-based mechanism, we can better analyse the provisions of the Scheme, and their corresponding implications.
Institutional structure established under the Scheme
In analysing the Scheme, it would be first helpful to lay out the different regulatory structures that have been put in place. Doing this will allow us to navigate the different functions, as well as differing natures of roles/involvement, of the various bodies under the scheme.
The National Steering Committee
The National Steering Committee for Indian Carbon Market has been constituted to manage the governance and for direct oversight over the carbon market.1 The Secretary, Ministry of Power is its Chairperson, and its members consist of representatives from the Ministry of Environment, Finance, New and Renewable Energy, Steel, Coal, Chemicals and Fertilisers, Petroleum, Agriculture etc. It also allows space for expert members, the Director of the BEE etc.2 In this regard, two observations must be made.
First, the Ministry of Power has been given the presiding role over the National Steering Committee, and not the Ministry of Environment, Forest and Climate Change (MoEFCC). This relegation of the MoEFCC to a secondary role is inexplicable, given that carbon markets are a direct response to climate change. The fact that the designated ministry for climate change plays a secondary role should be noted. It indicates a non-prioritisation of effective redressal of climate harm and reflects a lack of commitment to adequately addressing the asymmetric effects of climate change by relegating to the background the ministry with specific subject matter competence on the issue. This hierarchy and particularity in interest groups being served pervades most of the Scheme, as we will see later on.
Second, the Ministry of Tribal Affairs (MoTA) is conspicuously absent from the representatives that constitute the National Steering Committee. This again points to the systematic invisibilization of the interests of the Adivasi communities that are at stake. This invisibilization negates the struggle for representation of Adivasi interests that were foundational to the development of the PESA and the FRA. It also points questions to the applicability of PESA provisions such as the requirement of Gram Sabha consent under Section 4(e) of the PESA to the projects envisioned under the Scheme. There have been numerous reported instances of derogation of such overt protections, as well as a reading down of consent provisions under the Forest Conservation Rules 2022. Hence, the fact that there is an absence of explicit recognition of the role played by the Gram Sabhas in such projects renders the disregard of PESA protections much more likely.
Looking at the list of ministries involved in the National Steering Committee can provide us with some indication of the possible industries that are going to be covered by the carbon market. It also reflects that the primary stakeholders are seen by the government to be industries, and the impact of the carbon market on individual livelihoods has not been considered.
Moving on to the functions of the National Steering Committee, we must note that a majority of their functions are recommendatory in nature.3 These recommendations are made to the BEE, on issues such as regulations, emissions targets, issuance and trading of carbon credits, etc. Importantly, the Scheme is ambiguous on the nature of these recommendations. This ambiguity leaves scope for multiple possible interpretations that may lead to undue concentration of powers in the hands of one body. It also allows for a negation of responsibility and accountability, for an accurate determination of where decisions are coming from and the corresponding powers to take such decisions would end up being a post facto enquiry. This structure provides significant breadth for the exercise of discretion in the absence of adequate regulatory oversight.
The presence of this uncertainty has specific implications for Adivasi resistance against such legal frameworks, given that significant legal changes that benefit Adivasi communities (for example the PESA) are driven primarily by political struggle and movement. Hence, uncertainty on where authority and responsibility lie mystifies the identification of legal and policy spaces where struggle and protest may be located.
The Bureau of Energy Efficiency
The Bureau of Energy Efficiency (BEE) has been designated as the Administrator of the carbon market.4 Aside from the ambiguity behind the nature of the National Steering Committee’s recommendations, note that a significant amount of powers on the carbon market and its functioning vest with the BEE. This includes identification of sectors and targets for emission reductions, developing procedures for issuing certificates, guidelines for accreditation of verification authorities, compliance mechanisms etc.5 This again points to a concentration of competence with the Ministry of Power, given that the BEE is constituted under the Ministry of Power.
The above arrangement therefore leads to a situation where the National Steering Committee, chaired by the Ministry of Power, is the entity that provides recommendations to the BEE that is a functionary of the same ministry. There is also a larger case to be made here on legislative competence and delegation of legislative powers, given that under Section 3(2) of the Energy Conservation Act, the BEE is a Body Corporate, and most of its powers under Section 13(2) of the Energy Conservation Act are recommendatory in nature. The Scheme effectively allows the BEE to play a role that effectively amounts to law-making beyond the vires of the Energy Conservation Act. It can therefore be constructed as an instrument facilitating excessive delegation. In assigning this role to the Bureau, the Scheme effectively does not have a controlling mechanism on the Bureau, which points to a clear excessive delegation of state power to a body corporate. As pointed out earlier, this can have significant implications for locating responsibility and making space for local resistance to decision-making. Further, even though provisions in the scheme mandate for approval of the Central Government, what constitutes the Central Government for the purposes of the Scheme has not been clarified.
The Grid Controller of India and The Central Electricity Regulatory Commission
The Grid Controller of India has been designated as the Registry for the carbon market and plays the role of maintaining records and a database of transactions.6 Notably the Central Electricity Regulatory Commission (CERC), a quasi-judicial body established under the Electricity Act for dispute resolution arising under that legislation, has been designated as the Regulator for trading activities in the carbon market. While the CERC has regulatory expertise under the Central Electricity Regulatory Commission (Power Market) Regulations, 2021), it is unclear whether such sweeping regulatory authority is mandated. This is considering the fact that regulating carbon markets requires distinct capacities, and serve a very separate teleological purpose.
Also, it is important to note that the degree of regulation/intervention by the state in the market through these bodies is limited. This is reflected in the fact that under Section 7(2)(d), interventions have been specified only in cases of fraud or mistrust.7 As demonstrated in subsequent parts, there exist significant vested private interests and power relations between parties covered by the Scheme. Hence, the conscious absence of state intervention and protection may result in vulnerable stakeholders, particularly Adivasis, more open to private exploitation.
Accredited Carbon Verification Agencies
This trend of ambiguous and convoluted legislative framing, along with the concentration of power, under the Scheme continues when the Scheme speaks of Accredited Carbon Verification Agencies. Across the world, Carbon Verification Agencies are private bodies/companies that issue carbon credits to projects/industries that reduce emissions and ensure/verify compliance with emission reductions as per issued credits.
The definition in the Scheme, however, is contrary to this traditional understanding.8 It limits its functioning to verification activities. What exactly constitutes these verification activities has not been defined. The Scheme essentially creates an odd structure where the Bureau, at the recommendation of the National Steering Committee, would issue carbon credits and notify guidelines for accreditation of verification agencies. Notably, the role or nature of the Accredited Carbon Verification Agencies has not been precisely defined, and has been left open-ended.9 The arrangement further reifies the arguments on the unwarranted concentration of state power with the BEE and the corresponding harms to Adivasi communities, as highlighted in the earlier parts of this article.
Compliance Mechanism – Obligated and Non-Obligated Entities
Lastly, the compliance mechanism under the Scheme must be highlighted. As pointed out earlier, the vision for carbon markets in India seems to be the development of the Voluntary Carbon Market in the near future. Recent literature on the subject, particularly CSE’s Report titled ‘Discredited: The Voluntary Carbon Market in India’ has posed significant questions to the functioning and efficacy of Voluntary Carbon Markets.
However, the Scheme distinguishes between Obligated and Non-obligated entities under Sections 2(1)(k) and 2(1)(l), whose determination would be based on notification under the compliance mechanism. Simply put, the difference between the two is the voluntariness of their participation in the carbon market. It is through this procedure in the compliance mechanism that obligated entities can be made statutorily obligated to reduce carbon emissions, while the reduction of carbon emissions for non-obligated entities would continue to be on a voluntary basis.
The Scheme requires a Notification for this purpose, issued by the Ministry of Energy, Forests and Climate Change (MoEFCC) under the Environment Protection Act, 1986. However, much like the rest of the Scheme, the role played by the MoEFCC is largely minimal, given that such notification by the MoEFCC will be based on the recommendations of the Ministry of Power.10 Given the concentrating and centralising tendency of authority under the Scheme to the Ministry of Power, it does appear likely that the MoEFCC will have little role in the actual content and approach of such notification. The complete absence of the Ministry of Tribal Affairs (MoTA) from the Scheme is further pointed out, given the demonstrated impacts of the Scheme on Adivasi communities.
It is important to locate the significance of this choice in ministries to adequately understand the implications. There has been historical tension between the MoTA and the MoEFCC regarding the power to govern forests, which has traditionally been vested in the MoTA. Traditionally such power, particularly with respect to the implementation of the FRA has vested in the MoTA. Notably, recent steps have been taken toward ensuring better coordination between the two ministries for more effective implementation on such matters. The Scheme’s ignorance of such departmental expertise in delegating power, when read along with the silencing of Adivasi interests throughout the Scheme, helps us understand the clear alignment of the Scheme toward certain private interests rather than adequately addressing climate harm to the most vulnerable communities.
The Scheme provides no indication as to the rationale for determining what industries/companies would be treated as obligated and non-obligated entities. This, again being left to a combination of the Ministry of Power, the BEE, the National Steering Committee and the ‘Central Government’ (whoever that may be) results in an extremely convoluted decision-making framework, with no clarity on where the actual responsibility and corresponding accountability lies.11 Furthermore, given how important the distinction between obligated and non-obligated entities is, the abdication of this power by the legislature to the executive poses significant questions. In line with the law laid down in In Re The Delhi Laws Act, 1912, such forms of delegation of power would constitute a clear violation of the legislature’s essential legislative function, and the constitutional principle of separation of powers.
It is to be noted that much like the Draft Green Credit Programme Implementation Rules (Draft Rules), the Carbon Credit Trading Scheme puts in place a complex and convoluted regulatory framework through numerous constituted institutions playing different and at times conflicting roles in the governance of the carbon credit trading system. Further, there is no clarity on the interaction between the Draft Rules and the Scheme, given that at numerous places the roles of the institutions constituted do overlap.
Importantly, both the Draft Rules and the Scheme, tell us very little of the actual substantial framework of carbon credits and the carbon trading system that is going to be implemented in India. The actual functioning of the system and the rights/duties that flow from it have been left to the discretion of the constituted bodies, whose positions would have significant implications on its impact on Adivasi communities in India.
This uncertainty, however, does not prevent us from drawing possible implications of the above legislative framework in its current form on Adivasi communities in India, particularly given the primary structures instituted, referenced schemes (such as Accredited Compensatory Afforestation), trends in other jurisdictions, and the contrasting state attitudes toward private companies and Adivasi communities.
3. Implications for Adivasi Communities
Carbon Credits, and subsequently carbon trading systems, as technocratic solutions to climate change, have a long history of ignoring the agency of indigenous peoples, and structurally causing harm to indigenous communities. In the first instance itself, technocratic discourse on things like geoengineering, and carbon credits, are made unavailable to indigenous communities due to structures put in place by capitalism, colonialism, and state violence. This itself reduces the value of questions of consent etc. Most of such discourse, when ignorant of these roots of domination, only adds to the harm caused to indigenous communities.12
The question of responsibility must also be highlighted. The legislative structure effectively envisions a situation which legitimises the emitting activities of private companies if they have sufficient financial resources while placing the burden of mitigating such climate harm on Adivasi and indigenous communities. This dichotomy is even more stark given that such communities are asymmetrically susceptible to climate change.
Further, the very idea of commodification of nature through assigning a numerical value of carbon can negatively affect indigenous practices. Such may occur in the form of the state enforcing land management policies and requiring the production of industrial tree plantations on indigenous lands to generate carbon credits.13
As seen in the statement of the Minister of State for Environment, Forest and Climate Change, Ashwini Kumar Choubey in the Rajya Sabha, farmers and Gram Panchayats have been seen as avenues to generate and sell carbon credits. While at the first instance, one may be inclined to believe that such an approach could become an avenue for Adivasi communities to generate additional revenue, it is important to look at this further. When the history of such schemes is looked at in other countries, one arrives at the conclusion that they may render Adivasi communities vulnerable to domination by the state and private companies.
A lot can be learned in this regard from the implementation of REDD+. REDD+ incentivises forest growth and management to sequester carbon which would generate carbon credits, traded in exchange for compensation from international funds, through mediating private organisations or private companies. Notably, the implementation of REDD+ has been pervaded with instances of dispossession and appropriation of indigenous lands, and consequently exertion of control over forests by state and large corporate entities.
Drawing on Histories of Oppression
As seen in Tanzania, to protect Mangroves in line with REDD+ agreements, forest guards were trained and posted in target areas to enforce bans on cutting Mangrove trees after designating these areas as protected forests. Activities of subsistence were forcibly replaced by the growing of mangroves, leaving the affected communities vulnerable to poverty and food insecurity.14
The silence of the regulatory framework on the nature of the right to carbon, with whom such right lies, and the fact that such may possibly be claimed by the state as separate from designated individual and community forest rights under the Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006 (FRA) must be noted. Constitutional protections such as the Fifth and Sixth Schedules that purport for democratic engagement, and constitutionally mandated local self-governance mechanisms under the Panchayats (Extension to Scheduled Areas) Act, 1996 (PESA) are also ignored. The fact that questions such as these, which have direct implications for Adivasi lives and livelihoods have been left to the discretion of instituted bodies must be questioned in the strongest possible terms.
In Uganda, lands that were considered degraded and designated for reforestation in line with carbon offsetting commitments by a private company were cleared of ‘encroachers’ through widespread violent evictions by paramilitary forces, without any prior warning.15 This was a result of a drive to commodify and naturalise so-called ‘degraded’ lands, which is akin to rhetoric seen in schemes such as Accredited Compensatory Afforestation in India which seek to utilise designated wastelands. The centrality of dispossession and expansion of state control over forests in these situations cannot be ignored.
Middlemen and other private actors, when allowed to be involved in the process of identification of lands that are suitable for generating carbon credits, have also been documented to abuse their positions of power to vitiate laid down processes of consent. As seen in Colombia, indigenous leaders were compelled to sign agreements with such private actors under coercive conditions that allowed for access to their forestlands.16 The lack of clarity of the Indian legislative framework on the possible role of private actors as third parties in these transactions must therefore be viewed with significant apprehension, given the enormous dichotomy in negotiating powers. This approach opens Adivasi communities to similar forms of abuse, in a context where they have historically been subject to systematic abuses of power by private actors. It may also render forests open to increased private control, which would be contrary to the National Forest Policy, 1988.
The fact that the exact Standards of Verification by Accredited Verification Agencies are undecided and subject to undue discretion of the executive also poses a problem. It indirectly allows the state to dictate the economic/carbon value of certain forms of activities, thereby influencing and having control over the kind of forest activities undertaken by Adivasi communities. The determination of where carbon value lies is an imprecise science at the best of times. To enable the state to determine such values, without a robust system of checks, balances, and accountability which is transparent, opens the door for rent-seeking behaviour and nepotism, and will adversely impact Adivasi interests. This monetisation of the forest may lead to situations where market and private forces coerce Adivasi communities to give up activities part of their traditional cultures, leading to an erasure of Adivasi identity.
Hence, it is imperative that the system of carbon credits and trading must be scrutinised keeping in mind the interests of Adivasi communities, particularly given the current structural and functional ambiguities. This also raises significant questions about the constitutionality of such a system, given the interaction between the constitutional rights of Adivasi and tribal communities over their traditional homelands and resources, especially when read with beneficial legislation such as the PESA 1996 and the FRA 2006.
This degree of scrutiny is further mandated by the current trends of environment regulation in India which seek to broaden state control of forest lands through criminal sanction on forest dwellers, while simultaneously abrogating state responsibility to penalise environmental violations by private corporations. The amendments to the Wild Life (Protection) Act, of 1972 (WLPA) in December 2022 have a significant role in expanding the already vast state control over the areas where the WLPA is applicable. This has been done by expanding the list of animals protected under the WLPA, as well as increasing manifold the penalties levied for wildlife offences. Such an increase in criminalisation allows the state to exercise more effective control over forest-dwelling communities by necessitating alienation. It is important to read this with the recent amendments that water down compliance mechanisms in allocating forest lands for non-forest purposes, such as the Amendments to the Forest Conservation Act, 1980 . These have all but erased the requirement for prior Gram Sabha consent. Notably, this reflects a very clear state agenda that caters to private and corporate interests in commodifying forests.
Keeping this in mind, the inevitable question to be addressed is what ‘just’ policy looks like to mitigate climate harm. It is imperative that such takes the form of identifying the areas where climate harm is felt the most. This identification would require a recognition of the political nature of the distribution of risk and harm and would require policy interventions to pose direct questions toward and work outside of prevailing economic systems that are founded in dispossession. It would require centring Adivasi and other marginalised interests in the discourse on possible climate solutions. A failure to make this recognition explicit in policy interventions not only fails to adequately address climate harm but also amplifies structural deprivation.
Endnotes
1. Section 3(2), Carbon Credit Trading Scheme, 2023.
2. Section 3(3), Carbon Credit Trading Scheme, 2023.
3. Section 4, Carbon Credit Trading Scheme, 2023.
4. Section 5(1), Carbon Credit Trading Scheme, 2023.
5. Section 5(2), Carbon Credit Trading Scheme, 2023.
6. Section 6(1), Carbon Credit Trading Scheme, 2023.
7. Section 7(2)(d), Carbon Credit Trading Scheme, 2023.
8. Section 2(1)(b), Carbon Credit Trading Scheme, 2023.
9. Section 9, Carbon Credit Trading Scheme, 2023.
10. Section 11(3), Carbon Credit Trading Scheme, 2023.
11. Section 11(1), Carbon Credit Trading Scheme, 2023.
12. Kyle Powys Whyte, ‘Indigeneity in Geoengineering Discourses: Some Considerations’ (2018) 21 Ethics, Policy & Environment 289 <https://www.tandfonline.com/doi/full/10.1080/21550085.2018.1562529> accessed 7 July 2023.
13. Osensang Pongen, ‘Reconceptualizing Carbon Datafication through Indigeneity’ (2023) 4 Digital Geography and Society 100053 <https://linkinghub.elsevier.com/retrieve/pii/S2666378323000053> accessed 7 July 2023.
14. Betsy A Beymer-Farris and Thomas J Bassett, ‘The REDD Menace: Resurgent Protectionism in Tanzania’s Mangrove Forests’ (2012) 22 Global Environmental Change 332 <https://linkinghub.elsevier.com/retrieve/pii/S0959378011001932> accessed 7 July 2023.
15. Connor Cavanagh and Tor A Benjaminsen, ‘Virtual Nature, Violent Accumulation: The “Spectacular Failure” of Carbon Offsetting at a Ugandan National Park’ (2014) 56 Geoforum 55 <https://linkinghub.elsevier.com/retrieve/pii/S001671851400147X> accessed 7 July 2023.
16. Mariel Aguilar-Støen, ‘Better Safe than Sorry? Indigenous Peoples, Carbon Cowboys and the Governance of REDD in the Amazon’ (2017) 44 Forum for Development Studies 91 <https://www.tandfonline.com/doi/full/10.1080/08039410.2016.1276098> accessed 7 July 2023.
* The author wishes to acknowledge the insights provided by Shomona Khanna and Puja towards this piece.
