From days of smoke-fileld ‘90s with no plan in place to the GRAP is quite some thing though there's still more to be done
Air Pollution in Delhi and the National Capital Region (NCR) has been in the public eye since the mid 2010s. It was in 2015-16 that the various stakeholders — media, civil society and citizen’s groups — started taking serious note of the poor air quality in the region. This was spurred by the increase in the particulate matter (PM) concentration.
But it was in the 1990s that Indian cities started turning into a toxic hell. This deterioration took place despite a spate of strong legislation on pollution control during the 1980s. These include the Air (Prevention and Control of Pollution) Act, 1981 and the Environment (Protection) Act, 1986.
Apex institutions like the Central Pollution Control Board (CPCB) and state pollution control boards came into existence. In 1996, the Supreme Court, upon the release of Slow Murder, a report by Delhi-based non-profit Centre for Science and Environment on air pollution in Delhi, issued a suo moto notice to the Delhi government to submit an action plan to control air pollution in the city.
The report was triggered by a series of high air pollution episodes in the city, accompanied by the visibly dirty, soot-laden emissions belched by vehicles. This was then merged with an ongoing public interest litigation against air pollution, filed by Mahesh Chandra Mehta, an environmental public interest attorney and an activist.
In December 1996, the Delhi government submitted to the court its first action plan to combat air pollution. But civil society groups soon realised that the state action and implementation of this plan would not take place without public pressure.
In recognition of the need for technical support to guide the decision-making process and to ensure implementation, the Supreme Court directed the Union Ministry of Environment and Forest, or MOEF (now the Ministry of Environment, Forest and Climate Change, or MOEFCC) to set up an authority to advise the courts on pollution and to monitor implementation of its orders.
In January 1998, MOEF constituted the Environment Pollution (Prevention and Control) Authority (EPCA) for NCR. The government launched the National Air Quality Monitoring Programme (NAMP), a network of monitoring stations across the country to constantly monitor key pollutants round the year. This was tied with the Air Quality Standards for the ambient air quality to provide a uniform yardstick for assessment of air quality at the national level.
In June 1998, after taking stock of the key actions needed to reduce air pollution, EPCA submitted Report on monitoring and priority measures proposed by the authority for air pollution control to the Supreme Court. The report framed an action plan with a target of reducing air pollution over the next two years.
Subsequently, in July 1998, on the basis of this report, the Supreme Court issued directions to all authorities to comply with the timeframe given by EPCA to implement action points. The government plan included the conversion of vehicles (including the entire city bus fleet, replacement of pre-1990 auto rickshaws and taxis with new vehicles on clean fuels) to run on compressed natural gas (CNG) as an important measure to contain pollution.
EPCA took this action point, among other, and established a schedule for implementation. The pressure from such reports brought about a serious of policy action in Delhi-NCR.
Since these first-generation actions, the sources of pollution in Delhi-NCR have been significantly growing. For instance, in spite of tightening the emission norms, the total number of vehicles increased from 4.24 million in 2004 to more than 10.8 million in March 2018. It must be noted that this is the vehicle registration data for Delhi alone, not including the various cities and urban areas of NCR.
At the same time, the growth in public transport fleet in Delhi-NCR did not keep pace. Another reason for increased emissions was industrial sources. Although through its citation policy for industries, Delhi moved the worst category of industries out of Delhi, these units relocated to towns and industrial areas just outside the borders of Delhi, within NCR.
Additionally, at a regional level in north India, seasonal sources such as crop residue burning also intensified during the years between the first-generation actions and now. Multiple new settlements developed in the region and construction activities boomed. The population of NCR also increased from 16.6 million in 2001 to 46.1 million in 2011 — an annual growth rate of 10.75 per cent.
As a result, the gains in the first wave of action were lost. The momentum too was lost. The state machinery became reticent to the cause of improving the air quality. However, the situation would have been much worse if Supreme Court orders had not been implemented.
Second wave of (in)action
The second wave of action can be categorised as a period of inaction. From 2010 to 2015-16, the various governments — central and state — took few concrete measures. At the same time, the growth in pollution sources continued at record levels, both inside Delhi (vehicles and municipal solid waste) as well as in NCR (construction and industry).
The government implemented BSIV standards for vehicular technology and fuel, in Delhi and other metropolitan cities of India in 2010. However, after this, there was considerable delay to extend it to the rest of India. Only in April 2017 the entire country switched to BSIV. Neither was any movement made on rapidly moving to higher standards (BSV, VI).
Although there was some movement to create a fuel policy to move to more stringent standards and cleaner fuel, the targets set for bsVI were for as far away as 2025. Also, there was little effort to control the demand aspect of mobility, either in terms of replacing personal vehicles through public transport, nor in terms of regulating the form of urbanisation prevalent in many of our cities to promote smaller, more compact cities.
Notable efforts in this period to control air pollution were related to monitoring and transparency. In 2009, MOEFCC revised the previous standards (which were different for residential and industrial areas) and notified the National Ambient Air Quality Standards for 12 pollutants, revising the existing standards for clean air.
These standards created a uniform baseline for acceptable ambient concentrations of 12 pollutants, and introduced regulatory monitoring of PM2.5. Along with the creation of standards, several hundred monitoring stations were established across India in this period. These were still inadequate in number and were mostly manual monitoring stations, as opposed to real-time automatic stations.
In 2014, MOEFCC, along with inputs from experts and civil society as well as the Union the Ministry of Health and Family Welfare, created the National Air Quality Index (NAQI). It was a tool that would create transparency and accessibility in the availability of air quality data. It would convert complex numbers relating to air pollutant concentrations to a simple index, which would indicate the state of air quality in terms of an adjective — Good/Satisfactory/Moderate/Poor/Very Poor/Severe — and an associated colour and health advisory for people.
Third (current) wave of action
In 2015, the Supreme Court delivered a number of significant orders on air pollution in Delhi. These included orders on public transport, clean fuels, vehicular emissions and infrastructure in NCR. These orders indicated the seriousness that the judiciary treated the issue of air pollution with. However, this judicial intervention, in addition to the resistance faced from the central and state governments, was indicative of the manner in which the government was dragging its feet on key actions to control air pollution.
In October 2016, Delhi faced one of its worst smog episodes. From November 8, the PM2.5 levels rose to over 750 microgramme per cubic metre (µg/m3), over 12.5 times the permissible limit. The thick, inescapable smog that descended onto Delhi’s streets had one major consequence — it woke up all the stakeholders out of their slumber.
In response to the 2016 smog incident, the Delhi government took steps curb the number of private vehicles operating in the city. The ‘Odd-Even’ measure, as it was popularly known, was intended to reduce vehicular emissions and traffic congestion, thereby improving the air quality. It was rolled out in two fortnight-long phases in January and April 2017.
While it certainly reduced peak pollution loads, its implementation left much to desire, neither fulfilling its role effectively as a tool for emergency action nor creating much impact in the long term. But it did lead to a city-wide discussion on air pollution and its sources. It also spurred discussion among the middle class which had so far been unconcerned. Other stakeholders, including the media and civil society, plunged headfirst into mainstreaming air pollution and discussed its sources and solutions.
The smog episode also led to a flurry of action, mostly in the realm of advocacy and litigation. The Supreme Court, in November 2016, asked the key authorities and governments in NCR to formulate a plan to deal with such pollution episodes and on January 12, 2017, MOEFCC notified the Graded Response Action Plan (GRAP).
GRAP, for the first time, sought to create a coordinated response to pollution episodes that involved action from various regulatory bodies across NCR, with the different measures being linked to the prevalent Air Quality Index (AQI). GRAP contains measures to reduce addition of fresh emission load during high pollution episodes, such as those that have been observed in Delhi in November every year since 2016. It is a graded plan, where the severity of action increases on the basis of aqi levels.
GRAP has been in effect in Delhi-NCR since February 2017 and contains actions categorised under four categories — Moderate to Poor, Very Poor, Severe and Severe+ or Emergency. Of these, the actions under the ‘Moderate to Poor’ category are enforced round the year, or permanently. The higher categories, ‘Very Poor’ and ‘Severe’, have been put into effect for the winter months — October to March, which usually see very high pollution days. The highest category of pollution actions, ‘Severe+ or Emergency’, come into effect on the basis of air pollution levels.
For implementation of GRAP, it was important to understand the key problem areas for air pollution control in Delhi-NCR. For this, a focus on enhancing the monitoring capability of the region was imperative. In 2015-16, the monitoring network of Delhi was disaggregated and data was hard to come by.
Although there were 12 automatic monitoring stations, these were owned and operated by different organizations — Delhi Pollution Control Committee under the Delhi government; System of Air Quality, Weather Forecasting and Research under the Ministry of Earth Sciences; and, CPCB under MOEFCC. Although these stations were selectively putting out data into the public domain, it was hard to access and rarely consolidated.
Tasked with the implementation of GRAP, EPCA worked on the expansion of the monitoring network, as well as on forecasting and weather-tracking for air quality management. To monitor real time ambient concentrations of PM2.5 and PM10 — the primary pollutants in Delhi-NCR — CPCB set up a centralised open access portal that provides data from 52 monitoring stations in NCR.
This real-time data allows for reliable inputs for policy decisions as well as to make executive decisions on the control of air pollution sources. The portal is also designed to allow individuals and citizen groups to identify the state of air quality in their immediate surroundings.
This portal has lead to the identification of pollution hot spots — sub-regions within Delhi-NCR — which consistently have elevated PM levels. For example, EPCA identified Anand Vihar as a hot spot for pollution in the winter of 2016-17.The next step was the formulation of a local action plan, which identified the local sources of particulate pollution, as well as the actions needed to control these sources.
Based on this intervention by EPCA, the local stakeholders — the East Delhi Municipal Corporation, Delhi Pollution Control Committee, Uttar Pradesh Pollution Control Board, Uttar Pradesh State Road Travel Corporation and Delhi Transport Corporation — as well as local municipal bodies were asked to work on measures to reduce particulate emissions in the region.
Similarly, in October 2018, EPCA identified nine pollution hotspots, including Mundka, Bhiwadi, Dwarka, Faridabad, Delhi Technological University, Bhalaswa, Ghazipur, Sahibabad and Punjabi Bagh. The regulatory agencies as well as the stakeholder executive bodies in this region were then asked to prepare local action plans to counter PM sources.
In November 2017, there was another smog episode. Through the winter of 2017-18, the pollution spiked to alarming levels, which were highlighted by the media and civil society. This sustained winter pollution episode, renewed the focus on air pollution. GRAP was under implementation, for the first time in winters, leading to several measures.
EPCA put into effect ‘Very Poor’ and ‘Severe’ categories of actions for the winter months, until March 15, 2018. This include a ban on the use of diesel generator sets in Delhi; the closure of brick kilns, hot mix plants and stone crushers across NCR; and the shutdown of the Badarpur Power Plant for the winter months.
In 2018, the CAP for Delhi-NCR was also notified. This plan contains medium to long-term measures for pollution control, including detailed timelines for implementation. The plan will have major effects on controlling air pollution in Delhi-NCR.
What India can learn from Delhi
A lesson from 2018 is that GRAP delivers results when there is a cohesive action from key stakeholders. As seen during the November 2017 smog episode, the timely communication of AQI and weather patterns from CPCB and the met department, and prompt deliberation by EPCA and other regulatory authorities, have ensured that measures under grap were effective to reduce pollution levels.
However even emergency action frameworks like GRAP have limitations. The city first needs systemic reforms to effectively implement plans like GRAP. For instance, during the 2017 smog episode, all municipal corporations of Delhi, under orders from EPCA, tried to increase parking fee as a vehicle-restraint measure to reduce pollution in Delhi. But the move did not work because the city did not have a parking policy — it only had ill-placed parking facilities with no process to levy a fee.
Similarly, another action point of restricting use of diesel generator sets, identified as major polluting source in a January 2016 India Institute of Kanpur (IIT)-Kanpur study for Delhi-NCR, was not possible due to the region’s dependence on them for power. Gurugram and certain other towns in Haryana have no continuous supply of power and rely on generators. Thus, this initiative to ban diesel generators could be only implemented in Delhi.
In 2017-18, the steps taken in Delhi-NCR to check air pollution, due to judicial activism and public pressure, have pushed cities across India to strategise their own cohesive plans. This macro approach has to be supplemented by sustainable and conscious development policies at the Centre. Efforts like a cohesive parking policy and augmenting the air monitoring network have to be replicated in cities now.
A key observation from the Delhi experience is the necessity of an authority to bring all the stakeholders together for policy deliberation and to lead enforcement and implementation of the action plan. Delhi-NCR has the enviable advantage of having an authority like EPCA to take the lead in policy action and also in pulling up agencies when found lax.
This is not to say that the way forward is through creation of more committees and task-forces. The merit of having such committees becomes questionable when no one takes ownership of the issue and the accountability of such participating agencies remains obscure.
For instance Delhi-NCR had a series of task-force committees on air pollution, comprising key stakeholders who manage or provide service utilities or monitor air pollution. What NCR needed was an agency or authority to lead the action and to monitor the implementation which came out of such deliberations. This role to a large extent has been fulfilled by EPCA for Delhi-NCR.
Judicial intervention in this issue has been the only medium so far to whip the states into action. Despite various court orders, the states have been slow on even formulating air pollution action plans for their cities. Authorities refuse to take ownership and remain in denial of their role to the pollution load in the city.
As witnessed in Delhi-NCR, the states so far have only focused on the short-term actions limited for the duration of severity of pollution. The long-term actions points that the Comprehensive Action Plans emphasise on remain largely ignored. Augmenting transport infrastructure, non-motorised transport infrastructure, bringing systemic reforms in parking and Mass Rapid Transit systems are all capital-intensive projects.
Any policy in this direction has to be informed by the scientific suitability and overall requirement of the cities to result in a behavioural or consumption / lifestyle change in the city dwellers. Policies evolving and framed today need effective strategies. This has to be done for each action point. Under the current action plan, the cities need to aim for a general air pollution reduction target of 35 per cent.
States, UTs to be held accountable
In an order passed on October 8, 2018, the National Green Tribunal (NGT) took cognizance of the delay by states in formulating action plans and the intensity of public health risk from air pollution. NGT also issued an ultimatum to all states and Union Territories asking “non-attainment cities” to prepare action plans within two months and to bring air quality within the prescribed norms within six months from date of finalisation of their action plans.
This NGT order is momentous because it creates, for the first time, a mechanism of accountability of the regulators for enforcement. It holds the chief secretaries of states and the administrators of Union Territories personally liable for failure to formulate action plans. This was absent till now and allowed for procedural lapses to delay implementation of crucial policy plans.
It directed the states to form the Air Quality Monitoring Committee (AQMC) to draft the plan, which would be further supervised by the chief secretaries to ensure intra-sectoral co-ordination. The court further constituted a committee comprising of CPCB, IIT-Delhi and IIT-Kanpur to examine and review the action plans of all the states, which would then be approved by the chairperson of CPCB.
With these policy interventions, air quality has shown minor improvement in some big cities in recent time. But it is not sufficient and more focused, time-bound initiatives at both city and national levels are required to address the issue. The need for a National Clean Air Programme (NCAP)-India for reduction in air pollution levels at both regional and urban scales is both urgent and necessary.
This was first published in the State of Environment 2019.
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