Why the Supreme Court’s Direction on Delhi’s Airpocalypse Will Likely Fail

In 2013-2014, the CPCB spent a mere Rs 8.14 crore on air-quality monitoring for the entire country and this amount was further reduced to Rs 5.45 crore in 2014-2015.

In the absence of structural changes, ‘Clean Air for All’ will remain a distant dream. Credit: vijay_chennupati/Flickr, CC BY 2.0

In the absence of structural changes, ‘Clean Air for All’ will remain a distant dream. Credit: vijay_chennupati/Flickr, CC BY 2.0

Is there a panacea to India’s air quality woes? Earlier this month, the Supreme Court of India attempted to address the curious case of Delhi’s ‘air-pocalypse’ by approving the Graded Response Action Plan (GRAP). Proposed by the Central Pollution Control Board (CPCB), the GRAP classifies air quality into four categories: poor, very poor, severe and emergency, based on the concentration of particulate matter measuring 2.5 micrometers (PM2.5) and 10 micrometers across (PM10). Each category will trigger interventions ranging from ban on waste burning, better pollution control technology for coal power plants/brick kilns to the closure of power plants, ban on the entry of diesel trucks and construction activities across Delhi.

As a policy, interventions like GRAP can at the most promise to mitigate exposure. They shy away from addressing the root causes behind deteriorating air quality. For starters, even with GRAP in place, Delhi cannot breathe safe if Punjab and Haryana continue to pollute. In that sense, the scheme overlooks a fundamental issue with regard to air pollution – that it transcends physical borders. A joint study published by the Netherlands Organisation for Scientific Research, California Institute of Technology and NASA found that industrial emissions from China were making their way to the western US via wind currents. Does that make GRAP ineffective? Not at all – but applying such measures to a wider geography would certainly yield better results.  

The success of initiatives like GRAP relies on three fundamentals: monitoring infrastructure, reliable data and effective communication. Our research shows that the Indian regulatory mechanism has a lot of catching up to do on all these fronts.

Monitoring infrastructure

A good public policy is one where planning, monitoring and evaluation are built within the implementation process. Pollution mitigation policies primarily depend on an efficient monitoring infrastructure. A cursory investigation into the current monitoring infrastructure of the CPCB and a few state pollution control boards has thrown up some concerning facts.

The CPCB operates and maintains 60 continuous monitoring stations in 12 states across India. The data from these stations is pivotal to the successful implementation of GRAP or any other pollution mitigation program. An analysis of the data from CPCBs’ real-time air quality portal shows that, of the 60 stations, only 47 test for PM2.5 and only 29 for PM10 (among other parameters). Ironically, the station located at CPCB’s headquarters in East Arjun Nagar tests neither PM10 nor PM2.5.

Further, the distribution of the monitoring stations across India is skewed in favour of the big cities even when other regions around them are far more polluted. For instance, the three stations allocated to Tamil Nadu are all located in Chennai, despite Cuddalore, the 16th most polluted industrial region in the country, being just 200kms away.

The situation is more grim in states like Chhattisgarh, Jharkhand and Odisha, where highly polluting mineral-based industries are located. There are no real-time monitoring stations in these states. The state agencies are also severely under-resourced. An RTI filed by community members revealed that the Chhattisgarh Environment Conservation Board has only one PM10 monitoring machine and no PM2.5 machines. To put this in perspective, Chhattisgarh has 157 minerals-based industries known to emit particulate matter. In 2009-2010, the environment ministry had declared Korba in Chhattisgarh as the fifth critically polluted region where the environment had severely degraded due to industrial activities.

Reliability of data

The Environment Protection Act (EPA) 1986 makes it mandatory for all states to have at least one or more recognised labs to carry out sampling and environmental monitoring exercises. In order to be recognised under the Act, the labs have to earn a certificate from the National Accreditation Board for Testing and Calibration Laboratories (NABL) and the Occupational Health and Safety Management System (OHSAS).

As of August 30, 2016, only 12 labs in nine states have been recognised by the CPCB under the EPA 1986. This raises serious questions about the capabilities of State Pollution Control Boards in testing and generating data to take legal action.

In addition to this, the quality of data available in the public domain is highly unreliable. The real-time air quality portal of CPCB often displays contradictory and inconsistent data. For instance, air quality data of Varanasi and Ahmedabad between December 1 and 26, 2016, confirms the case. While both the cities had ‘bad to emergency’-like air quality days (Ahmedabad 24 and Varanasi 21), the final analysis for Ahmedabad states “there is NO instance when data has exceeded Prescribed Standard of PM2.5 [sic]”.


Communication often remains the biggest challenge for regulators dealing with public health emergencies. Current systems to inform citizens on air pollution are rudimentary experiments with mobile technology at best. For instance, the System for Air quality-weather Forecasting and Research (SAFAR) application launched in 2015 by the Ministry of Earth Sciences merely provides a colour-coded advisory to citizens and is available only in Pune, Delhi and Mumbai. SAFAR has also had only 50,000 Android downloads since its launch. On the other hand, there is no mechanism to issue alerts to users who don’t have smartphones.

Moreover, numerous private air quality-indexing apps have flooded the market causing further confusion among average citizens. While most of them provide readings, a few advice purchasing masks that are known to be ineffective.

Investing in clean air and health

The story so far gives scant hope for achieving cleaner cities. Logic should drive more financial resources towards improving the state of our labs in particular and regulatory agencies in general. Here again the current trend is very disheartening. According to financial reports of the CPCB, the total grants received by then from the Government of India were slashed by 12.7% from Rs 68.9 crore in 2013-2014 to Rs 60.1 crore in 2014-2015. In 2013-2014, the CPCB spent a mere Rs 8.14 crore on air-quality monitoring for the entire country and this amount was further reduced to Rs 5.45 crore in 2014-2015.

Needless to say, it is imperative to invest more in research and development and data collection that will help enhance the understanding of pollution science and shape sector-specific responses.

Ideally, episodes of poor or severe air quality should go beyond advisories and trigger appropriate medical interventions. The notorious ‘haze’ caused by burning of agricultural waste in southern Indonesia is an annual phenomenon – and Singapore and Philippines expect the inevitable haze to hit every year. In addition to issuing advisories, the ministries of health in both the countries work with hospitals to build capacity to cater to increased inflow of patients and for suitably responding to specific health issues linked to haze exposure.

It is clear that air pollution mitigation strategies cannot be isolated in nature. It calls for a systems approach where synergies will have to be built between several agencies. An effective policy would have to integrate the efforts of urban planning, transport, public health, agriculture, industries and urban local bodies, among other agencies. It would also require massive public awareness and citizen participation. In absence of these structural changes, ‘Clean Air for All’ will remain a distant dream.

Dharmesh Shah is a public policy expert working on issues of environmental health and pollution. Shweta Narayan is the coordinator of Healthy Energy Initiative, India, investigating the links between energy choices and their health impacts.

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