Revised GRAP from October 1: How the pollution-control plan evolved & what can improve

The new measures are an essential and significant reaction to the winter pollution situation in the capital but is still an emergency measure
A truck mounted with anti-smog gun being used to spray water to curb air pollution in Delhi.
A truck mounted with anti-smog gun being used to spray water to curb air pollution in Delhi. Photo: Vikas Choudhary / CSE
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As the winter months approach, toxic air threatens to envelop Delhi and the neighbouring towns again. For years, Delhi-National Capital Region (NCR) has been battling high air pollution that are spiking to alarming levels.

To prevent this deterioration of air quality, a Graded Response Action Plan (GRAP) was notified in January 2017 for Delhi-NCR and adjoining areas. This was regularly updated, the most recent being done on September 17, 2024 by the Commission for Air Quality Management (CAQM). 

The plan was designed similar to an emergency alert system, which directs the governments to take concrete and prompt actions depending on the severity of pollution and mitigate the peaking of pollution during winters. The plan has undergone several revisions since its inception and will mark GRAP's eighth iteration this year. 

Initially, focus of the GRAP implementation was majorly based on the PM2.5 and PM10 concentrations. With subsequent revisions, now it has been based on the city's air quality index (AQI) levels, which are calculated based on the eight pollutant concentrations. These are PM10, PM2.5, nitrogen dioxide, sulphur dioxide, carbon monoxide, ground-level ozone, ammonia and lead.

The severity of pollution for implementation of GRAP has been categorised into four stages, based on Delhi's AQI levels: Stage I — 'Poor' (AQI 201-300); Stage II — 'Very Poor' (AQI 301-400); Stage III — 'Severe' (AQI 401-450); and Stage IV — 'Severe+' (AQI > 450). Each stage outlines specific actions that must be implemented to curb pollution levels.

Although the updated GRAP represents advancement, concerns about its efficacy and preparedness for the successful implementation continues to be a challenge. 

Evolution: Reactive to proactive strategy

The GRAP has evolved over the years. Initially, it was more of a reactive system and now it follows a more proactive approach.

Earlier, the actions were implemented when the air quality was at a dangerous mark (Very Poor, Severe or Severe+) levels for three consecutive days. The new system developed by the Indian Institute of Tropical Meteorology and System of Air Quality and Weather Forecasting and Research forecasts the pollution levels for the following three days, which helps the government to take pre-emptive actions. 

This shift in implementing actions from reactive to proactive measures will help to enable rapid and targeted sectoral interventions before the air quality further worsens.  

The new additions to the GRAP are related to vehicular emissions, which is one of the main contributors to the local sources of pollution in Delhi. The Decision Support System (DSS) for Air Quality Management developed by IITM provides data on real-time source apportionment of PM2.5. 

The Centre for Science and Environment (CSE) has analysed the DSS data showing that among the local sources impacting Delhi's air quality, around half of Delhi's particulate pollution during winter months come from vehicles.

Since vehicles are a consistent source of pollution year-round, it puts immense pressure on the local authorities to regulate vehicular activity in the region during high pollution periods and otherwise. Also, more than half of pollution comes from the neighbouring cities to Delhi. 

Targeting diesel vehicle emissions

The government has introduced more stringent actions, particularly aimed at diesel-operated vehicles. Under Stage III of the revised GRAP, new measures have been added, restricting the movement of diesel vehicles. These include: 

  • Government to impose strict restrictions on plying of Delhi-registered diesel-operated medium goods vehicles (MGV) to BS-III standards or below, in Delhi, except those carrying essential commodities / providing essential services. 

  • Government of National Capital Territory of Delhi to not permit BS-III and below diesel operated light commercial vehicles (goods carriers) registered outside Delhi, to enter Delhi, except those carrying essential commodities / providing essential services.

  • Do not permit inter-state buses from NCR states other than EVs / CNG / BS-VI diesel, to enter Delhi (excluding buses / tempo travellers operated with All India Tourist Permit).

The revised plan has also addressed the issue of diesel generator (DG) sets (which vary in capacity from 62kV to 800kV) under Stage II of GRAP. As per revision, it has been made compulsory to run only those DG sets which have dual-fuel mode operations or are equipped with emission control equipment.

Further, more stringent regulations will be applied at higher AQI levels. DG sets that aren't operating in dual fuel mode due to a lack of gas infrastructure or supply are only allowed for designated emergency services. 

Challenges in implementing GRAP

Some additional stringent measures have been introduced in subsequent revisions of GRAP. The revised plan provides a list of several banned activities under construction and demolition activities; however, critical public projects and emergencies are exempted. Construction activities, a significant contributor to dust pollution, for instance, are banned under Stage III of GRAP.

However, there are concerns when it comes to the ability and readiness of the stakeholders' departments in NCR to coordinate the activities and enforce necessary measures effectively. In addition, some loopholes might make the restrictions less effective.  

Furthermore, in vehicle sector, to curb the emissions from on-road vehicles, enforcement of the pollution under-control certificate system has been long reprehended for its lack of effectiveness in catching the polluting vehicles.

The International Council on Clean Transportation and the Delhi government recently conducted research on the remote sensing device programme, which is a good development because it helps to identify those vehicles who are gross polluters.

For this to work well, a robust infrastructure is needed. Based on this study, nearly 89 per cent of vehicles in Delhi comply with BS-IV or BS-VI standards, and only 11 per cent were pre-BS-IV models.

More direct communication systems are required to alert residents to rising pollution levels and the associated health risks. This can be done through emergency alerts or SMS and public engagements are necessary to inform about the measures directly.

Although GRAP is enforced during periods of high pollution, the average citizen is frequently unaware of the steps that must be taken immediately.

Sustained actions, systemic reforms beyond GRAP

GRAP attempts to address the immediate issue of rising pollution levels, but it is not a long-term solution. For example, waste burning will impact local pollution, but this can be reduced by implementing a comprehensive waste management plan that will include 100 per cent waste collection and segregation. A complaint redressal system on emergency basis for waste burning will also help in dealing with the immediate pollution spike.  

Similarly, vehicle emissions, which is a leading source of pollution in Delhi's, requires year-round action. Policies such as odd-even can momentarily alleviate the soaring levels of pollution and congestion in the city; this must be complemented by a massive overhaul of public transport infrastructure and restraining private vehicles by implementing stringent parking policies to reduce the overall number of vehicles on the road. 

Another issue is with the unfit and end-of-life vehicles, which remain a significant concern. With effective monitoring systems, it will be easier to identify and remove unfit vehicles from the roads.

The VAHAN database still needs to be updated, showing that it needs to be adequate to identify such vehicles. Very few unfit vehicles have been identified on the VAHAN. As per mandate, all the Heavy Goods and Passenger Motor Vehicles were supposed to go to the Automated Testing centres from April 1, 2023 and medium and light motor vehicles by June 1, 2024. This deadline for mandatory testing has been extended to October 1, 2024.

A big achievement by Delhi has been in terms of procurement of electric buses. The city has around 2,000 e-buses on various routes at present. 

A plan has to be formulated to deal with the road dust as well. This should be done before implementing the GRAP rule to pave roads so that resuspension of road dust does not create a menace. 

Air pollution: A growing health crisis

The State of Global Air 2024 by the Health Effects Institute released alarming numbers on the deaths caused due to air pollution in 2021. Globally, in 2021, air pollution was found to be the second-leading risk factor for death, accounting for roughly 8.1 million deaths.

The high pollution levels and large population of India have led to 2.1 million of these deaths, out of which 237,000 were attributable to ozone exposure. 

A casual modelling study by the Lancet Planetary Health in 2024 also estimated mortality in 10 cities of India because of ambient air pollution. Ahmedabad, Bengaluru, Chennai, Delhi, Hyderabad, Kolkata, Mumbai, Pune, Shimla and Varanasi have reported on an average more than 33,000 deaths every year, according to the findings.

Delhi alone was found to have reported around 12,000 deaths which can be attributed to air pollution. These death figures highlight how urgently we need to take effective and sustained action.

The revised GRAP is an essential and significant reaction to the winter pollution situation in Delhi and NCR. It is still an emergency measure, though, since it deals with symptoms rather than causes. Only long-term structural improvements — from better waste management to year-round vehicle emissions reductions — will bring about true progress.

Meanwhile, the first priority is to ensure that the steps outlined in GRAP are implemented promptly and effectively to prevent air quality from deteriorating in the nation’s capital during another winter.

Additionally, GRAP should not be implemented in an ad-hoc manner and should be put in place in a coordinated fashion, aligned with the Policy to Curb pollution for Delhi-NCR. The latter was was formulated in 2022 by CAQM and outlined short-, medium- and long-term solutions for all the sectors.  

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