Assess how far ex-situ crop residue management (biomass co-firing, straw procurement) can replace punitive measures in fighting stubble burning.

Ex-situ management takes paddy straw off the field and uses it as fuel, pellets or industrial feedstock. In November 2026 the Supreme Court suggested a procurement mechanism for crop residue, and farmer bodies used it to demand an end to penalties [1]. Ex-situ markets can replace punishment to a large extent, but not fully yet.

Where ex-situ can replace penalties

• Removes the motive: Farmers burn because it is the cheapest way to clear fields in the short paddy–wheat window. A price for straw changes that choice without punishing the farmer [1].
• Assured demand: The 2023 Crop Residue Rules require coal plants to co-fire a 5% biomass blend. CAQM imposed about ₹61.85 crore in compensation on six plants within 300 km of Delhi for falling short [2].
• Supply-side support: CPCB gives 40% capital support to set up paddy-straw pelletisation and torrefaction plants [3].
• Equity: Fines hit small and marginal farmers hardest, because they cannot afford balers. Buying their straw spreads the cost more fairly.

Why it cannot fully replace penalties yet

• Slow uptake: By March 2022, 4 of the 11 NCR thermal plants had not started mandated co-firing [4].
• Thin capacity: The 15 sanctioned pellet plants will use only about 2.70 lakh tonnes of straw a year [5]. That is a small fraction of the residue Punjab and Haryana produce.
• Logistics gap: Straw must be collected, baled and stored within weeks. Without collection at the farm gate, farmers still burn.
• Burning persists: Punjab recorded 3,729 fires between 1 April and 6 May 2026, in the wheat season alone [6]. NCR paddy burning fell by about 92% against 2021 [7], but that is a reduction, not elimination.

A calibrated mix

• Collection before penalty: Use CAQM's farm mapping and nodal officers [8] to link each farm cluster to an aggregator. Levy environmental compensation only where a collection option existed and the farmer still burnt.
• Symmetric enforcement: Penalise plants that miss co-firing targets as firmly as farmers who burn [2].
• Complement it: Pair ex-situ use with in-situ machinery and crop diversification, because markets alone cannot absorb all the straw.

Ex-situ management can become the main tool, with penalties kept as a last-resort backstop. How far it replaces them depends on how far the market reaches the farm gate. A "market first, penalty last" approach serves Article 48A's environmental mandate and SDG 3 (health) without making farmers the scapegoat.