Slow murder continues: Some suffer more

Right to clean air is about inter-generational equity. Traditionally, the health impacts of air pollution have been understood in terms of the relation between dose and response at an undifferentiated population scale. But over the years, more nuanced approaches have evolved to investigate the modifiers and specific impacts on groups differentiated by age, gender, socio-economic and nutritional status, and a range of other factors that define the vulnerabilities and underpin marginalisation.

Evidence is stark on infant deaths during the first month of life due to lower respiratory infections; low birth weight and preterm births affected by air pollution (refer to preceding chapters). Foetal exposure to pollutants is on the rise, as many harmful substances can easily pass through the placenta. Children are especially at risk because their respiratory systems are still developing. Furthermore, their immature immune systems hinder their ability to cope with these exposures.

There is mounting evidence from several studies in different regions indicating disproportionate impacts of air pollution on vulnerable groups. There is no absolute definition of a vulnerable population. Several attributes are considered to define vulnerability and susceptibility to air-pollution-related risks. These include age, gender, socio-economic inequalities, nutritional status, occupational exposures and geographical location that determine proximity of the communities to pollution sources. It is now quite widely understood that children, the elderly and women, especially pregnant women across all socio-economic groups, and socially disadvantaged communities are disproportionately impacted by air pollution. It is necessary to understand the nature of these widely different risks.

Several epidemiological studies are available in India that bear out special vulnerability of poor and marginalised women to household air pollution. This is one of the direct manifestations of poverty and lack of access to clean cooking energy. India also has a considerable gender-based air pollution exposure disparity. Due to unequal access to basic social goods, mortality is worsened when women have a lower socio-economic status. Moreover, women from the lower income class use traditional indoor stoves for cooking and heating with very poor ventilation, especially in urban areas. These are fuelled by biomass and produce carbon monoxide, hydrocarbons and particulate matter and account for nearly 24 per cent of ambient air pollution from PM2.5. These women are disproportionately exposed to indoor air pollution and due to their pre-existing poor nourishment, face greater threat to their respiratory, cardiovascular and reproductive health.

It is now widely understood that older people are more susceptible to environmental risk factors because with age they have more underlying health conditions, including hypertension, diabetes, heart disease and slower metabolic rates. In fact, with age, air pollution can further aggravate heart disease, stroke and lung diseases, including chronic obstructive pulmonary disease and asthma and diabetes. The elderly are also more vulnerable to weakened immunity, neurological disorders including Parkinson’s disease and Alzheimer’s, and a range of compromised mental health problems. These require increased healthcare, emergency hospital admission, and increased cost of medication. Ageing also means long-term and lifetime exposures to air pollution, with a range of health outcomes. Global evidence indicates that countries with large and ageing populations have higher levels of deaths and illness due to air pollution. India is moving in that direction of demographic transition. The combination of a very large population, ageing population and socio-economic disadvantages make the risk even more daunting.

The disproportionate impact of health burden on the poor is significantly more pronounced due to their weak health status, nutritional deficiency, weak coping capacity and high exposure levels. Even though evidence on health impact on low-income groups has begun to emerge, this has not been well investigated or integrated in policies. There is a sprinkling of studies in India and these definitely point towards the special vulnerability of the low-income groups and the associated health inequity. A 2021 Yale University study found that the mortality risk from indirect sources falls disproportionately on lower-income households in India. This suggests that industry-wide pollution controls can reduce inequity in the impacts of ambient air pollution. However, as low-income households face an order of magnitude higher mortality risks from indoor air pollution, clean cooking fuels remain the most effective way to reduce the number of premature deaths from air pollution in India. A 2023 global study, “Global Air Pollution Exposure and Poverty”, published in Nature Sustainability found that about 716 million of the world’s lowest income people (living on less than US $1.90 per day) live in areas with unsafe levels of air pollution. Air pollution levels are particularly high in lower-middle-income countries, where polluting industries and technologies dominate. This study shows that high-income Indian households contribute maximum to the outdoor air pollution due to emissions from manufacturing, transport and products they consume. But low-income households are nine times more vulnerable to premature deaths than the high income counterparts. A 2022 World Bank study reiterates that about one in 10 people exposed to unsafe levels of air pollution live in extreme poverty. For the extreme poor, the air pollution level means increased severe health risks compared to higher income households. The effect of air pollution is aggravated by poverty and inadequate access to health care.

A very serious concern that has been indicated in a few studies is the cancer risk among the marginalised. The end point of all toxic risk is cancer. A very early survey conducted by the Department of Preventive Oncology, Tata Memorial Centre, Mumbai about two decades ago had found high incidence of cancer in the slum areas and air pollution was envisaged as one the probable contributory factors. The implication of this for the poor is ominous. In fact, in the early years the Harvard Centre for Cancer Prevention, USA, found a larger occurrence of lung cancer among the poor. The American Cancer Society had issued a report to the nation that highlighted the key issues related to the cancer risk among the poor, including the magnitude of suffering, high healthcare cost, access to healthcare and health insurance, and lack of awareness.

With a very large urban population and dominance of urban poor, this can emerge as a serious public health agenda. The urban landscape in India is dominated by the informal settlements where the marginalised communities and poor live. As per one cse estimate, at least one in every six urban Indians resides in informal settlements. Moreover, six in 10 persons in informal settlements live in close proximity to unsanitary drains and every sixth person lacks access to treated water as per the assessment based on Census 2011. These bring out the compromised coping capacity during illness.

Further review has found close proximity of informal settlements to pollution hotspots prone to waste dumpsites, open burning, traffic choke points, small scale construction sites and informal industrial units. In fact, some indicative vulnerability mapping by an ongoing cse study in a few cities such as Jaipur and Kolkata found that the overlaps between pollution hotspots, heat hotspots, flood hotspots and location of the informal settlements. This is a serious matter, given the burgeoning population in informal settlements with growing urbanisation. It is estimated that while urban population increased by 32 per cent, population in informal settlements increased by 131 per cent during 2001–11. About 11 out of 47 cities with more than million populations have on an average as much as 30 per cent of the population living in informal settlements. This population may double in the coming years. The enormity of this problem also emerges from the fact that most of the informal settlements are located and are growing in marginalized areas around the urban periphery that are least serviced and remain mostly outside the orbit of municipal services, transport connectivity and healthcare services. For a long time, even the housing policies focussed on relocation and resettlement of the informal settlements from the city centre, which has further compounded the disadvantages. Recent policies on public housing schemes are now also focusing on in-situ development with amenities inside the cities. The World Health Organization (WHO) observes that although all populations are affected by air pollution, the distribution of burden of consequent ill-health is inequitable. The poor and disempowered and those living near roads or industrial sites are often exposed to high levels of air pollution and this is worsening in cities.

Most exposed are those who have to work outdoors or in close proximity to specific pollution-generating activities and industrial processes. This is yet another dimension of vulnerability. Evidence has emerged on the vulnerability of informal workers to outdoor air pollution and extreme weather events. The International Labour Organisation has always highlighted the risk of occupationally exposed groups to a range of environmental risk factors. This matter has become the focus of new investigations in India as well. A 2022 study by the Delhi-based non-profit Chintan Environmental Research and Action Group assessed the relationship between the respiratory illness of low-income, outdoor workers, including waste pickers, municipal sweepers and security guards. They investigated the socio-demographic characteristics, lifestyle, knowledge on air pollution and health issues experienced by workers. They also examined respiratory health in terms of pulmonary function and assessed the relationship between the incidence of respiratory illness and socio-demographic and working environment factors.

This study was conducted at selected locations in Delhi. Waste pickers in Bhalaswa landfill, Ghazipur landfill, Mahipalpur and Vivekanand Camp and municipal sweepers of South Delhi Municipal Corporation (SDMC), New Delhi Municipal Council (NDMC) and East Delhi Municipal Corporation (EDMC), New Delhi Municipal Corporation (NDMC) and Khan Market were studied. The study specifically reviewed security guards in Safdarjang Hospital, CAG building, ITO, Reliance Building, Chandni Chowk etc. For comparison, it considered a control group in several neighbourhoods of central Delhi, and carried out pulmonary function or respiratory function and spirometer tests among these groups. The study showed that among waste pickers, air-pollution-related illness dominated at 86 per cent. The lung function among waste pickers was significantly lower compared to other groups. The severity of obstruction and restriction impairments for waste pickers can be as high as 57 per cent. Female waste pickers are 3.9 times more likely to have respiratory illness.

Among the municipal sweepers, 97 per cent of the participants were exposed to air pollution during their jobs while 37 per cent did not have enough protection from the cold during winter. Approximately 23 per cent reported major illnesses such as fever, headache and blood pressure in the preceding one year. Only 11 per cent, however, visited hospitals for treatment. Female sweepers were approximately six times more likely to have respiratory illnesses. Among the security guards, about 45 per cent faced health issues such as cough, sore throat, burning sensation in eyes, headache etc. About 86 per cent had abnormal lung function.

Another study published in Environmental Science and Pollution Research Journal in 2022, which focussed on auto-rickshaw drivers, street vendors and sweepers, found that most of those surveyed complained of headaches/giddiness, nausea, and muscular cramps. Auto-rickshaw drivers reported the highest prevalence of ophthalmic symptoms, including eye redness and eye irritation due to exposure to vehicular pollution. Vendors reported a higher prevalence of headaches and eye redness due to increased exposure to vehicular emissions. The majority of auto rickshaw drivers, vendors and sweepers believed that air quality was impacting their health. Most of them had restricted lung function.

Construction sites in cities can be a significant source of exposures. A review by CSE showed that key sources of dust in construction sites include sand, grit, conveyor system, truck movement, soil excavation, site clearance, material handling and storage, bulldozers, crane, crushers, piling, building demolition, and concrete batching. Every stage of construction can be a source of toxic dust. This can exist as silica dust from sand, stone, rock, sandstone, brick, concrete and mortar that contains crystalline silica. Dust from masonry work, tunnelling, road milling and mixing of cement and concrete can affect workers. Mining dust from cutting and drilling can have adverse impacts. Other sources include stone crushing dust while making aggregates, stone polishing dust and wood dust. Demolition of old buildings has more lead and asbestos that are highly toxic. Serious health risks are associated with construction-waste-related particles, which cause lung cancer, silicosis, chronic obstructive pulmonary disease and asthma. In fact, a 2023 global study on exposures of construction workers in construction sites brings out the pattern of exposures in different phases of construction. For example, workers engaged in pit-bottom operations in building foundations; steel bar processing in the main structure; and plastering, masonry, and putty workers engaged in installation and decoration are at the highest risk in construction sites. A survey carried out by the Help Delhi Breathe and Mahila Housing Trust in Delhi found that informal workers, especially those who live close to the landfill sites, face very high exposure. Unfavourable working conditions, harsh climatic conditions like extreme cold winters or heatwaves, unsafe work sites and inequity compound the problem. Informal workers who work in polluting industries or in construction sites face the challenge of job loss if clean air action is directed at the polluting activities and industries. These snapshots of evidence help to establish a range of risks from outdoor air pollution, and location disadvantage of where these communities live.

The emerging evidence points towards inequity due to economic backwardness that is inherent social structure making it difficult for the vulnerable groups to negotiate solutions for themselves. This inequity can be associated with social caste structures. There is a study that has mapped the air pollution exposure disparity in rural parts of India and found a strong correlation between the exposure distribution and socio-economic status. Integrating some of these indicators may help to improve investment patterns to maximize welfare and health gains by targeting the most vulnerable and targeted communities. As already seen, there are evidences on location of polluting industries and power plants that are more heavily concentrated in poor, socially disadvantaged villages.

One of the studies — “High-Resolution PM2.5 Emissions and Associated Health Impact Inequalities in an Indian District” published in the journal Environmental Science and Technology — conducted in Saharanpur district of Uttar Pradesh with an urban and rural context, showed that there are greater contribution-exposure gaps between socio-economic classes. Rural areas account for 68 per cent of annual premature deaths. Low-socioeconomic-status groups suffer 6 per cent, 7 per cent, 7 per cent and 26 per cent higher premature mortality from PM2.5 exposure due to industries, domestic cooking fuel burning, open waste burning and transportation, respectively, compared to their contribution to air pollution. Most disability-adjusted life years (DALYS) in the research domain are found in worker groups with lower socio-economic status.

Even though there aren’t specific environmental justice laws in India, there are various legal provisions, policies and judicial decisions that have underscored the environmental justice principles and protection of environmental rights. In public interest litigation (PIL) cases on air pollution, the judiciary has upheld the Constitutional provisions aimed at ensuring environmental protection and the right to life. These include Article 48A, Article 21 and Article 51A(g) of the Indian Constitution. Article 21 guarantees the right to life and personal liberty, which has been interpreted by courts to include the right to a clean and healthy environment. The judiciary has interpreted this article expansively to include the right to a clean and healthy environment as an integral part of the right to life. This interpretation has led to numerous landmark judgments where courts have intervened to protect the environment and ensure environmental justice. Through Article 21, citizens have the right to approach the courts to seek relief against environmental degradation or violations that threaten their right to a healthy environment.

Additionally, Article 48A mandates the protection and improvement of the environment. This article is a directive principle of state policy, which mandates that the State shall endeavour to protect and improve the environment and to safeguard forests and wildlife. It emphasises the duty of the state to ensure environmental protection as part of its governance responsibilities. While directive principles are not enforceable by courts, they serve as guiding principles for the State in policy making and legislation. Article 48A underscores the importance of environmental conservation and sustainable development in the national agenda.

While Articles 21 and 48A protect the environmental rights of the citizen, Article 51A(g) of the Indian Constitution outlines the fundamental duties of the citizen towards the environment. It states that every citizen of India must protect and improve the natural environment, including forests, lakes, rivers, and wildlife, and to have compassion for living creatures. Article 51A(g) emphasises the role of citizens in environmental conservation and sustainable development and places a responsibility on every citizen to contribute to the protection and enhancement of the environment, thereby promoting environmental justice at the grassroots level.

Together, these constitutional provisions create a framework for environmental governance in India. While Article 48A guides the state in formulating policies and laws related to environmental protection, Article 21 ensures that individuals have the right to a clean and healthy environment and can seek legal recourse in case of violations. Article 51A(g) reinforces the notion that environmental protection is not only the responsibility of the state but also the duty of every citizen. This combined approach helps in achieving environmental justice by balancing environmental conservation with developmental needs while safeguarding the rights of citizens.

Apart from the constitutional provisions mentioned above, environmental legislations like the Environment (Protection) Act, 1986, and the Air (Prevention and Control of Pollution) Act, 1981 also have a few provisions within their framework to reduce air pollution exposure of the inequitably impacted population. The Air (Prevention and Control of Pollution) Act, 1981, through its regulatory framework, pollution-control measures, public-participation provisions, compliance monitoring and legal remedies contributes to ensuring environmental justice indirectly by aiding pollution exposure assessment and participation of the vulnerable population and further enforcing the penalties on the violators.

The Air Act has measures that can aid public participation in the formulation and implementation of pollution control measures. Section 21 of the Air Act, which empowers the Central Pollution Control Board (CPCB) and State Pollution Control Boards (SPCBs) to take measures for the prevention, control, and abatement of air pollution, indirectly provides avenues for public involvement. These boards often conduct public hearings, seek public comments on proposed regulations, and may involve the public in the monitoring and reporting of air quality data.

While the Air Act of 1981 does not have explicit provisions akin to modern environmental legislation that mandates public participation, the establishment of the boards (that typically include representatives from various stakeholders, including government agencies, industry, environmental organizations, and sometimes members of the public) and their functions create mechanisms through which public involvement can occur in matters related to air pollution control and management.

Along with having provisions for public participation, the Air Act also provides for legal remedies and penalties for non-compliance with pollution-control measures. It allows affected individuals and communities to seek recourse through courts in case of environmental violations. By providing avenues for legal redress, the Act empowers citizens to protect their right to a clean and healthy environment. Hence, even though the Air Act does not have any explicit environmental justice mandate, it has some provisions within its framework that follow the principles of environmental justice and can act as a policy lever to further the environmental justice legalese.

However, due to a lack of proper guidelines and mandates, the application of these provisions, concerning justice principles, is left to the discretion of the enforcer and the polluters. Under the polluter pays principle, the offending industry might just find paying the fine levied more economically reasonable than mitigating the emissions. Such loopholes potentially add to the burden of the pollution exposure of the socioeconomically marginalized community due to their lack of either awareness or political clout to contest effectively.

Another similar Act that entails ensuring a clean environment for the people by empowering the central government to take measures to protect and improve the environment is the Environment (Protection) Act, 1986. Even though most of the provisions within the ambit of the Environment Act that resemble the principle of environmental justice are similar to that of the Air Act, the mandate for Environment Impact Assessment (EIA) is noteworthy. India’s Environmental Impact Assessment (EIA) process for industries does not explicitly include provisions labelled as ‘environmental justice’. However, the EIA notification issued by MoEFCC outlines several mechanisms that indirectly contribute to promoting environmental justice. These mechanisms aim to ensure that environmental concerns and the interests of affected communities are adequately addressed in the process of granting environmental clearance to industrial projects.

If used and amended correctly, EIA can become a lever for promoting environmental justice as it mandates assessing the impact of all the pollution generating development projects like thermal power plants, mining etc. on the neighbouring environment and population as a part of the environment clearance procedure. The state governments assess the environmental effects before project approval, often involving public consultation. Public hearings and consultations are conducted to provide affected communities with an opportunity to express their concerns, opinions and grievances regarding the proposed project. Along with a role in the overall decision-making process, EIA equips the stakeholders with comprehensive information on the environmental, social and economic impacts of proposed projects. This provision to include communities and stakeholders in decision-making gives them a medium to voice their concerns regarding potential project impacts, both environmental and socio-economic.

The environment impact checklist of EIA sometimes includes, socio-economic aspects, along with environmental aspects. In certain cases, the EIA notification requires the preparation of a Social Impact Assessment (SIA) report to assess the potential social implications of industrial projects on local communities. It requires collecting data on whether and how a proposed project will change the neighbourhood demographic structure, the current social infrastructure around the project and the potential impacts on the local communities.

The SIA evaluates the socio-economic characteristics of affected communities, identifies potential impacts on livelihoods, access to resources and social infrastructure, and proposes measures to mitigate adverse effects to aid in addressing socio-economic inequalities caused or aggravated by proposed projects. If collected correctly and diligently, this information will help the vulnerable stakeholders make informed choices that weigh the long-term implications of development on both the environment and communities. Moreover, with a wider view, the EIA legislation of 2006 has the potential to address environmental injustices by ensuring fair distribution of project burdens and benefits across society. It prompts decision-makers to consider potential disproportionate impacts on vulnerable or marginalised communities, thereby promoting equity in decision-making processes.

There have been ongoing debates and critiques regarding the effectiveness of the EIA process in ensuring genuine participation and protecting the rights of marginalized communities. While the flexibility of the 2006 legislature was a provision to integrate the new sciences and requirements, it seems to have been exploited to undermine the entire purpose of EIA. The EIA 2006 Notification defined the sectors and projects that require going through the process of public hearing or public consultation to acquire project approval and appraisal. It had outlined the entire procedure of both public hearing and public consultation. Public consultation is a broader process of engagement with stakeholders throughout the EIA process, aiming to gather input and feedback on the proposed project. Public hearings, on the other hand, are specific events within the public consultation process where stakeholders have the opportunity to provide oral testimony and express their views on the project before a designated authority.

There were certain sectors, like the ones pertaining to ‘national defence’ that were exempt from public consultation. However, over the years the list of exempt sectors and industries has only increased. In July 2023, the Ministry issued a notification exempting all the standalone re-rolling units or cold rolling units with valid Consent to Establish and Consent to Operate from the requirement of public consultation during its Terms of Reference (TOR) application provided the application is made within a year of the notification. In October 2021, the ministry issued an office memorandum permitting a 20 per cent increase in production for mining operations of minor minerals such as iron, manganese, bauxite and limestone, based solely on public consultation. Furthermore, the public hearing process for legacy mining projects granted environmental clearance under the 1994 EIA notification was further relaxed. These projects are now only required to undergo public consultation rather than following the entire public hearing process outlined in the 2006 EIA notification. Relaxation on public consultation and data accessibility will not only further undermine the potential of EIA to enable environmental justice but also obfuscate the basic principle behind EIA —protection of people and environment and a participatory justice that gives voice to the voiceless.

The Ministry of Environment, Forest and Climate Change launched the National Clean Air Programme (NCAP) in January 2019. Its aim is to ‘improve air quality in 131 cities (non-attainment cities and Million Plus Cities) in 24 States/UTs by engaging all stakeholders… to achieve reductions up to 40% or achievement of National Ambient Air Quality Standards for Particulate Matter10 (PM 10) concentrations by 2025-26.’ NCAP includes provisions aimed at addressing air pollution and its adverse impacts. It is broadly designed to improve the ambient air quality. However, as stated earlier, one of the requirements of the NCAP programme is the identification of pollution hotspots and prioritisation of actions in areas with high levels of air pollution. Though this provision does not directly hint at environmental justice, this provision created the opportunity to alleviate the disproportionate exposure faced by communities in the pollution hotspots.

NCAP emphasises the importance of inclusive stakeholder engagement, including participation from affected communities, civil society organisations and local authorities. This participatory approach can be leveraged to integrate the concerns and perspectives of marginalised communities in the planning and implementation of air quality improvement measures. The ncap programme also includes initiatives aimed at building the capacity of local authorities and communities to address air pollution effectively. This includes raising awareness about the health impacts of air pollution, providing training on air quality monitoring and management and empowering communities to take action to improve local air quality. NCAP includes provisions for conducting health impact assessments to evaluate the adverse health effects of air pollution on vulnerable populations, including children, the elderly, and individuals with pre-existing health conditions. Moreover, NCAP seeks robust air-quality monitoring and reporting systems to track progress towards air quality improvement goals by providing transparent and accessible air quality data.

The NCAP programme needs further reform to make more explicit provisions on integration of tools and indicators that align with vulnerability assessment of communities that are disproportionately exposed to air pollution and live in close proximity to polluting sources. It must also provide for integration of indicators of impact assessment of infrastructure and industrial projects on communities and seek adequate safeguards and protection, calibrate all mitigation measures to minimise livelihood disruption. Already NCAP has provided sector-wise indicators to cities to report progress across key sectors of pollution. These needs to include equity indicators as well.

Currently, the air-quality monitoring network is limited, and there are large data shadow areas in regions and cities of India. As of October 2023, there are 931 manual stations under the National Ambient Air Quality Monitoring Programme; 516 are real-time Continuous Ambient Air Quality Monitoring (CAAQM) stations. Of these, 512 manual stations and 344 CAAQM stations are in National Clean Air Programme (NCAP) cities. But there are large tracts of land and population that are not covered by the monitoring network. While this is not a constraint to scale up clean air action across the regions, there is still inadequate understanding of the spatial profile of air quality impacts on vulnerable communities. This could be widely dispersed as polluted industrial zones and areas of power generation; congestion hotspots; highway traffic; waste dumpsites and waste-to-energy plants; slums and squatter settlements; unauthorised colonies outside the municipal governance; and sensitive areas, including schools, hospitals and old age homes, among others.

It is not cost effective to expand regulatory monitoring to cover all data-shadow areas and where most vulnerable communities live. It is necessary to adopt alternative monitoring methods including satellite- based monitoring and sensor based monitoring for a multi-dimensional approach. The Central Pollution Control Board has permitted sensor-based monitoring for monitoring of pollution hotspots but not for regulatory compliance. Similarly, it is possible to do granular mapping of areas with the help of satellite data. It is necessary to provide air quality data to communities to understand the risks and action. Under the NCAP programme, the cities designated as non-attainment have been mandated to identify and implement hotspot action plan to address local pollution. These are currently defined based on dispersed pollution sources like waste burning, road dust, construction etc. But there is no policy to combine the pattern of exposures of the local communities as criteria to define hotspot action. This approach needs to be redefined for local action and for protection of targeted communities close to the pollution sources. To illustrate the point, about 13 hotspots—which subsequently increased to 18— were originally identified in Delhi. These include industrial areas like Okhla Phase 2, Dwarka, Ashok Vihar, Bawana, Narela, Mundka, Punjabi Bagh, Wazirpur, Rohini, Vivek Vihar, Jehangirpuri and Mayapuri; high-traffic nodes like Anand Vihar (including Mandoli), Shadipur, ito; and residential and recreational areas including R.K. Puram, Mandir Marg, Nehru Nagar, Patparganj, Sonia Vihar, Dhyan Chand Stadium, and Moti Bagh.

The hotspot plans of these areas show mapping of sources like road dust, construction sites, traffic congestion and open burning of waste. But these plans have not indicated the nature of exposure of the local communities, nature of their vulnerability and coping capacity, or the expected local benefits from clean air action. In fact, due to data gaps, communities who live near highly toxic landfills do not usually get included in these plans. There is considerable scope of reframing the hotspot action to make it more community oriented. However, some of the action taken in terms of controlling open burning of plastic waste in Mundka area in 2018 has the potential to reduce toxic exposure of the local workers and communities. It is also important to note that some exposures related to traffic congestion and waste burning may not be possible to address locally and may require city-wide systemic intervention.

The current limitation of the air quality management approach is the singular focus on ambient air quality in the Air Act, 1981. There is no legal recognition of ‘exposure’ that determines the health risk that communities face due to close and direct exposures to pollution sources. The only policy mandate has come from the ‘2015 Report of the Steering Committee on Air Pollution and Health Related Issues of the Union Ministry of Health and Family Welfare.’ This has stated that it is more important to know how close people are to the pollution source, what they are inhaling, how much time they are spending close to the pollution source than what occurs generally in the air that is influenced by climate and weather. It is necessary to shift from concentration management to exposure management. Ambient concentrations do not always well represent human exposures and are not a good surrogate for total air pollution risk as this cannot indicate exposure and health outcome. This principle will have to be integrated in the framework of NCAP and clean air action plans of the cities, states and regions, and needs to be leveraged to make local action more community oriented.

Multi-sector clean air action requires infrastructure development to enable sustainable choices for the larger population. But the planning and design of the new infrastructure or urban renewal may not have adequate safeguards to protect vulnerable communities. This is evident in the infrastructure plans in the transport sector. Currently, all clean air action plans have included affordable zero-emission travel modes, including walking and cycling. These are the modes of the urban poor, which are also part of the solution to air pollution. But this needs to be mainstreamed as a mode of choice for higher-income groups. But the infrastructure projects to enable mass-scale walking and cycling are often neglected in the planning and execution of clean air action plans.

Similarly, several steps are being taken to scale up formal and modern public transport systems like metro and modern bus systems to clean air and climate action. But public transport services are not being planned and deployed equitably and affordably. A 2018 study by CSE found that globally, spending more than 10-15 per cent of household income on transportation is considered unaffordable. The lowest 20 per cent of households typically spend no more than 10 per cent of their income on transport. Nearly one-third, or 34 per cent of Delhi’s population was excluded from basic non-AC bus services, highlighting a significant gap in access to affordable public transportation. Higher spending on transport leads to lower spending on housing, health and education and hampers inclusive growth.

Several state governments, however, do come up with policies to keep bus fares free for targeted groups like women. But there is no strategy to develop sustainable financing model—funding strategy for viability gas funding, tax reforms, revenue generation from other sources, etc. at the state level. Innovative strategies for the long term are needed for affordability and sustainability of the public transport system. On the other hand, development and modernization of public transport infrastructure— metro, bus rapid transit systems etc.—can also push the poor out of the city and disrupt their livelihood, increase travel distances and costs of living. A study by the TRIPP found that the Delhi Metro had displaced slums. For the majority of the relocated households, cycling and bus distances had increased by several kilometres as had the journey time. Similarly, average distances to services and number of trips had also increased. This had led to the decline in the share of walking and cycling for the community. Yet another study by CEPT shows that the share of transport cost in the household budget increased significantly for the bottom 50 per cent of the population, and that education and health had stagnated due to the BRT metro project. Along with this, the BRT Ahmedabad had also displaced nearly 2,000 vendors. This further aggravated the structural inequity that weakens the coping capacity of communities. Pro-poor mobility and housing needs to be aligned with air pollution-control measures to allow diverse livelihood choices and make the labour market efficient.

Several transportation policies have taken shape, which if implemented properly, can address inclusive planning. For instance, the Transit Oriented Development Policy requires compact urban form near transit nodes that include mixed-use and mixed-income development with improved accessibility. Institutional measures for efficient delivery are needed. National and state-level policies for pro-poor planning need to be sensitised.

This was first published as part of Slow Murder Continues: India’s suffocating journey of knowing and forgetting the deadly air pollution (2025), by the Centre for Science and Environment. It documents 40 years of reportage on air pollution and the fight against it in India. Download it here