NHAI Mandates Plantation Compliance Before PCC/PCOD and During O&M Period

The National Highways Authority of India (NHAI), vide Policy Circular bearing reference no. 7.4.20/2026 dated August 26, 2026 (the “Circular”), has issued guidelines to ensure strict compliance with contractual plantation obligations along the median and avenues of National Highway projects. The Circular notes that plantation and landscaping, being mandatory contractual obligations, are often not accorded due importance while recommending and issuing the Provisional Certificate of Completion (PCC)/Provisional Commercial Operation Date (PCOD).

The Circular requires plantation works to be undertaken in accordance with the applicable Contract/Concession Agreement, IRC:SP:21-2009, the Green Highways Policy, 2015, and other applicable NHAI/Ministry of Road Transport and Highways (MoRTH) circulars, including NHAI Policy Circular No. 7.4.16/2024 dated December 19, 2024, prescribing standards for saplings.

The Circular prescribes minimum threshold for issuance of PCC/PCOD. Plantation shall be considered compliant only where plantation has been carried out over at least 80% of the available Right of Way (ROW) earmarked for plantation and the planted saplings demonstrate a Minimum Survival Rate of 90% at the time of inspection. The Independent Engineer/Authority’s Engineer (IE/AE) is required to specifically certify compliance with these requirements while recommending issuance of the PCC/PCOD.

To ensure proper assessment of plantation works and survival rates, Regional Officers (ROs) are required to take the assistance and advice of the Joint Advisor (Environment & Plantation) during final inspections and assessments preceding issuance of the PCC/PCOD.

The Circular further provides that any plantation shortfall beyond the prescribed 80% threshold shall be included in the Punch List, together with specific timelines for completion. Further, financial withholdings provided under the relevant Contract/Concession Agreement shall continue until the balance plantation is completed and the prescribed plantation target is fully achieved.

The Circular further provides that the plantation obligations shall continue during the Operations and Maintenance (O&M) Period. The release of O&M/Annuity payments in Engineering Procurement and Construction (EPC), Hybrid Annuity Model (HAM) and Build-Operate-Transfer (BOT)-Annuity projects, and assessment of maintenance compliance in BOT-Toll projects, shall be strictly contingent upon maintaining a Minimum Survival Rate of 90% across all years. Further:

• casualty replacements shall be undertaken using plants of commensurate age and growth to preserve uniformity of plantation; and
• prior to processing payments or certifying maintenance compliance, the ROs shall consult and obtain technical assistance from the Joint Advisor (Environment & Plantation) to verify field compliance.

The Circular strengthens the enforcement of plantation obligations by making compliance with prescribed plantation and survival thresholds a prerequisite for issuance of the PCC/PCOD and continued release of O&M/Annuity payments. This is expected to ensure that plantation and landscaping requirements are treated as integral components of highway development and maintained throughout the project lifecycle.