Experts feel that India’s action plan to tackle air pollution could lose wind before take off

The Indian government has acknowledged air pollution as an issue that requires a comprehensive national action programme. It recently unveiled a draft National Clean Air Programme (NCAP) outlining plans to tackle pollution across the nation, including upgrading the air quality monitoring network.

This is the first such action plan for all of India on an issue that has been constantly in the spotlight for its adverse impact on the health of citizens. With pressure from advocacy groups, global and national media and citizen groups, national-level action on air pollution was a long time in coming.   

However, according to experts, the draft programme plan lacks clear pollution reduction targets and city-wise or region-wise milestones, relies heavily on the state governments to lead the battle against air pollution and lacks the teeth to ensure compliance.

The programme plan was unveiled by the Ministry of Environment, Forest and Climate Change (MoEFCC) earlier this month. The ministry has sought views, comments and suggestions from all stakeholders by May 17.

The move comes close on the heels of MoEFCC and the country’s top pollution watchdog, the Central Pollution Control Board (CPCB), relaxing the December 2017 deadline for thermal power plants to meet emission standards till 2022.

“In India, there was never a national scale programme on air quality. The earlier focus was on cities but then there are so many polluted cities so unless we have a national scale programme to control pollution it is difficult to manage the problem,” said Sumit Sharma, associate director with The Energy and Resources Institute (TERI).

“Of course, the NCAP is not perfect but it is a good starting point. It has to evolve,” he added.

“Curbing air pollution at the national level requires action and coordinated efforts across state boundaries,”said Aishwarya Sudhir, researcher with Climate Trends. “We have multiple sources contributing to the problem requiring action at the grassroots as well as at the policy level and the NCAP is as close as we can get to understand the complex nature of the cleaning up that’s required. But the plan in itself has no time-bound targets to address the issue leaving it vague and unaccounted for.” 

Over the past few years, poor air quality in Indian cities has become a national issue. It started with international studies pointing out severe levels of air pollution in Indian cities resulting in premature deaths of millions in India. But what really jolted the Indian authorities were high levels of air pollution in Delhi and adjoining regions over past few winters.

In 2014, the World Health Organization (WHO) had ranked Delhi as the most polluted city in the world. In 2016, Delhi’s ranking improved. But four Indian cities, Gwalior (2), Allahabad (3), Patna (6) and Raipur (7), still figured in WHO’s list of top 10 most polluted cities of the world.

It was followed by strict orders by the Supreme Court of India and the National Green Tribunal to curb air pollution. The pressure from courts and intense public debate has pushed authorities to brainstorm over steps to tackle air pollution and acknowledge it as a national issue.

What is the NCAP proposing?

Noting that its goal will be to “meet the prescribed annual average ambient air quality standards at all locations in the country in a stipulated time frame,” the programme emphasises on augmenting an effective ambient air quality monitoring network across India including the rural areas, improving efficiency of monitoring, focusing on indoor air pollution, carrying out indigenous studies to understand health impact of air pollution on Indians and creating a national emission inventory.

In terms of numbers, it proposes to increase the manual air quality monitoring stations to 1,000 from 691 at present and add 50 more stations in rural areas. Currently, there are 691 stations in 303 of the 4,000 cities in India, and none in rural areas.

The document notes that rural areas maybe badly polluted, contrary to popular belief that rural areas are free from air pollution. Additionally, rural areas suffer from outdoor air pollution as well as indoor air pollution.

The NCAP also proposes to strengthen the number of stations monitoring particulate matter (PM) 2.5 to 1,000 from 67 stations at present. PM is one of the hazardous constituents of air pollution. Fine particles  can penetrate deep into the lungs and some may even get into the bloodstream resulting in serious diseases.

The plan also discusses the need for strengthening the network of real-time and continuous ambient air quality monitoring stations especially in cities in the heavily polluted Indo-Gangetic plains and for setting up a 10-city supernetwork to capture the overall air quality dynamics of the nation, the impact of interventions and trends.

NCAP also stresses on the need of scientific air quality management plans for 100 non-attainment cities. Non-attainment cities are those which were found to be the violating the prescribed National Ambient Air Quality Standards (NAAQS) consistently during the 2011-2015 period.

The plan also references international studies on air pollution in India, noting that these  studies use extrapolation techniques for air quality and health/disease related data which may not be realistic. The inclusion of this reference could perhaps be linked to the former environment minister Prakash Javadekar who had raised objections against international studies on air pollution and mortality in India.

“While there is no denial on serious health implications, attributing one to one correlation and number of deaths due to air pollution needs to be further investigated and supported by indigenous studies. More authentic Indian data and studies may further strengthen our efforts and public participation in improving air quality,” the programme document reads.

The total estimated cost of the series of actions listed in the NCAP over the next two years is Rs. 6.37 billion. But this estimate does not account for city-specific plans, which will entail  costs that are to be borne by individual state governments.

“In last decade the condition of pollution in cities, where air pollution is monitored, has moved from bad to worse. From that perspective, MoEFCC has come out with a plan, NCAP, for the first time. It also says that cities need to have a plan to meet the air quality standards,” said Anumita Roychowdhury, of the Centre for Science and Environment (CSE), a Delhi-based environment thinktank.

She said that the good part of the plan is that the ministry is going to put money into expanding the air quality monitoring across India which should help in assessing the problem in a better way.

Experts question implementation of the NCAP

In December 2017, while replying to a query in Rajya Sabha, India’s environment minister  Harsh Vardhan for the first time made public the fact that the government was working on the NCAP. But its details were not made public at the time.

Following that, in February 2018, Harsh Vardhan stated that under the NCAP, the government is  targeting to reduce air pollution levels of the non-attainment cities levels by 35 percent in the next three years and 50 percent in the next five years.     

Subsequently, a non-governmental organisation Greenpeace India obtained the NCAP concept note and related documents through Right To Information and made it public in March 2018. Those documents too contained details about the target of reducing air pollution by 35 percent in the next three years and by 50 percent in the next five years.

But the latest NCAP document released by the MoEFCC is silent on specific pollution reduction targets.

Experts also say that the plan is toothless and lacks clear targets. “It is still very advisory in nature. It doesn’t have strong teeth which will enable compliance. They have initiated a process but they need to come up with a more clear strategy for legal compliance with standards in a time-bound manner,” Roychowdhury explained.

She also stressed on having a “regional approach” while talking about high pollution in the Indo-Gangetic belt stating that “pollution doesn’t follow political boundaries”. Several cities in the Indo-Gangetic plains like Agra, Kanpur, Lucknow, Varanasi, and Patna suffer from high pollution.

Echoing similar sentiments, Nandikesh Sivalingam, who is a senior campaigner with Greenpeace India, said for the NCAP to have any impact it needs to have clear time-bound targets for reducing pollution.

“The national government needs to take ownership of the task of reducing emissions from large sources like industry and power sector which create a regional impact. Just city-specific plans alone will not be enough to reduce pollution at the regional level,” he added.

Environmental lawyer Ritwick Dutta emphasised that the NCAP “heavily relies on technology”.

“It only speaks high words. It neither has any clear strategy nor targets even when pollution is reaching toxic levels across Indian cities,” Dutta added.

Is the environment ministry indulging in doublespeak?

The environment ministry has come out with the NCAP to deal with pollution at the national scale. But it is not the first time that ministry has tried to take action on air pollution.

In December 2015, even as the U.N. Climate Change Conference in Paris was on, the MoEFCC notified strict norms to reduce air pollution and water usage by the thermal power plants (TPPs). The MoEFCC tightened emission standards for particulate matter (PM), sulphur dioxide, nitrogen oxides, mercury and reduced water usage limits by coal-fuelled thermal power plants. These standards were were to be achieved by December 2017 leading to significantly reduced air pollution from TPPs.

But the thermal power plant industry opposed the move citing technical difficulties and huge financial cost, especially in the older plants. The industry’s case was supported by the power ministry too.

Following this, the CPCB (which is administered by the environment ministry) wrote to TPPs in December 2017, informing them they have time till 2022 to adopt new technologies in a phased manner.

In an affidavit submitted by the MoEFCC to the Supreme Court on March 27, 2018, the MoEFCC has listed out arguments which have been put forward by the ministry of power to allow TPPs time upto 2022 to adopt stricter standards. Mongabay-India has access to this affidavit.

Additionally, the environment ministry revealed in the affidavit that the power ministry is seeking relaxation in rules regarding utilisation of fly ash from the TPPs. A MoEFCC notification on Jan. 25, 2016, had directed TPPs for 100 percent utilisation of fly ash generated from the plants by Dec. 31, 2017.

However, as per the MoEFCC’s affidavit, the power ministry informed them that it is not possible to achieve at present and thus has sought extension till 2022 for this as well. The MoEFCC told the Supreme Court that it was considering this request and a final decision is yet to be taken.

Experts are unhappy with this move as they feel TPPs are a major source of air pollution in India.

“The MoEFCC wasted two years without taking any meaningful step towards implementation of emission standards for coal power plants. What is more worrying is that CPCB illegally extending the deadline for implementation by five more years while it initially claimed that two years was more than enough,” said Sivalingam.

Ritwick Dutta said the industry was confident of getting an extension. “All the thermal power plants should have shifted to clean technology from 2017 but the industry took no action. That means they were confident that they will get the deadline extended and that’s what happened at last. Two years were wasted without any action and the result is for everyone to see,” said Dutta.