Air pollution is not just a winter problem, or just restricted to New Delhi. The Narendra Modi government will need to take up the air Indians breathe as a top priority in the next five years.
The big challenge
Air pollution levels are unsafe across India, all-year round.
While pollution spikes to dangerously high levels during the winter in north India, air quality in several parts of the country is poor or worse for large parts of the year.
There are several kinds of pollutants in the air: particulate matter, carbon monoxide, ozone, oxides of nitrogen and sulphur. Fine particulates (PM2.5) form a useful proxy indicator for air pollution. The population-weighted annual average concentration of PM2.5 across the country, estimated using satellite data, was 91 microgram/m3 in 2017 – more than twice the national standards.
Air pollution is a public health emergency.
The health impacts of poor air quality are staggering, and growing. Air pollution is estimated to reduce the average life expectancy in India by at least 1.5 years. In 2017, one in eight deaths in India was attributable to air pollution. There is growing evidence of the adverse impacts of pollution on cognitive abilities in children.
Multiple sources contribute at different regional scales.
Industries, power plants, vehicles, waste burning, road and construction dust, and household sources are significant sources. At a national level, household burning of polluting fuels for cooking and heating purposes form the single largest contributor to average PM2.5 exposure. Industries and power plants that burn coal are the second and third largest sources of exposure at the national level.
Because of different geographical scales of influence, pollution control measures need to target different sources at appropriate levels – which makes the central government’s role critical.
The existing policy framework
The National Clean Air Programme (NCAP), launched by the Ministry of Environment, Forest and Climate Change in January 2019, looms large over the newly elected Narendra Modi government’s policy landscape.
In its approach, the NCAP is a status quo-ist document, which adheres to city-specific templates from the past, and wholly misses addressing governance gaps. It reinforces India’s policy response to air pollution, which has largely been reactive, and overly reliant on administrative solutions.
Air pollution reduction needs greater commitment from the executive.
So far, pollution control has largely been driven by the judiciary. The new Modi government should assume leadership in crafting and implementing an effective national air pollution reduction strategy. Greater autonomy should be given to pollution control boards (PCBs) to act against polluters and the boards must have domain experts.
A new policy agenda
Strengthening National Clean Air Programme (NCAP)
To strengthen the NCAP, there is a need to focus efforts on a prioritised shortlist of solutions in the short term and begin extensive consultations about governance reforms needed in the longer term.
Prioritising concrete actions
With dispersed sources of pollution, such as transportation, households, waste burning and construction, administrative solutions that expect monitoring and enforcement are likely to fail. Instead, enforcement could work better for policy changes targeted at a higher, more centralised levels, where possible.
For instance, for vehicles, policy changes aimed higher up in the manufacturing process, like the requirement to comply with Bharat Stage VI norms, will work better than periodic inspections.
Keeping these factors in mind, NCAP must prioritise these three key areas:
Power plant emission norms
India’s formal regulatory infrastructure has traditionally focused on “point sources”, with good reason. Industries and power plants burning coal are the second and third largest sources in India, in terms of contributions to average national exposure to air pollution and resultant burden of disease.
The MoEFCC introduced new emissions standards for power plants in 2015, which required the installation of pollution control equipment. Ensuring that these standards are complied with, and the requisite control equipment installed by this revised timeline, if not at an accelerated rate, is critical.
Revamp Ujjwala to increase LPG use
The Pradhan Mantri Ujjwala Yojana was an important initiative. While primarily an energy access programme, it also tackled household solid fuel use, which is the largest contributor to pollution exposure in India.
To ensure continued usage of LPG, a clean fuel, the government needs to make prices affordable, and run campaigns to change behaviour and attitudes. This is unlikely to be a rapid transition, but some important first steps have been taken.
Invest in public transportation
Reducing transportation emissions would require a combination of ensuring easy access to affordable public and non-motorised transport, while simultaneously working on reducing emissions from the vehicles on the road. Ensuring that the public transit strategy is planned for the long term, and remains technology agnostic in the era of electric vehicles is key.
Strengthening regulatory capacity
The formal air pollution regulatory architecture in India is built around the Air (Prevention and Control of Pollution) Act 1981, the Environment (Protection) Act 1986, and rules and notifications issued under these.
As per existing law, the state pollution control boards have very limited flexibility to take action proportional to the polluting activity. Currently, they can send show cause notices, shut down industries through a closure notice or by shutting access to utilities, cancel regulatory consents or initiate criminal prosecution against the industries in court.
Strengthening the ability of pollution control boards to tackle point sources could provide a pathway to a broader reform process.
In the short term, pollution control boards must be resourced better, and be made more accountable through disclosure efforts.
- Increased resources of pollution control boards: Existing vacancies need to be filled with qualified people in the CPCB and SPCB. Increased staff resources should translate to increased inspections and monitoring.
- Increased accountability through public disclosure of regulatory data: Ensuring that PCBs release regulatory information (details of consents granted, inspections, online monitoring data, enforcement actions, etc.) into the public domain would make the industries and SPCBs more accountable to civil society and the media.
Longer-term reforms will require extensive dialogue, and, therefore it is important for the government to start deliberations early. We propose three broad elements for change:
- Remove legal barriers for effective enforcement: Amending the law to allow for a more diverse regulatory toolbox, that includes both existing powers and additional ones such as levying financial penalties, would increase the flexibility that the pollution control boards have.
- Institutionalised airshed-level management: Tackling air pollution effectively requires looking beyond administrative boundaries, and focusing on reducing emissions across the ‘airshed’ over which pollutants disperse.
- Development of a sector–airshed approach: The long-term strategy will need a careful application of sectoral approaches at the airshed level or a national or state level, and utilising an appropriate combination of administrative, technical, economic, and behavioural solutions.
Air pollution is a complex problem and requires a variety of mitigation measures. We need to unambiguously acknowledge the terrible impacts of air pollution on our health, move beyond the urban-centric approach, and tackle each of the big sources with a sense of urgency. Policy for tackling air pollution needs to shift from the reactive approach we have taken so far to one that is more systematic.
Santosh Harish is a Fellow at the Centre for Policy Research, New Delhi. Shibani Ghosh is a public interest lawyer and a fellow at CPR. Navroz K Dubash is a professor at CPR and coordinator of the Initiative on Climate, Energy, and Environment.
This is the ninth in a series of articles titled “Policy Challenges 2019-2024” under ThePrint-Centre for Policy Research (CPR) collaboration. A longer version of this piece is available on the CPR website at www.cprindia.org. The full policy document on a range of issues addressed in this series is available on CPR’s website.