New Delhi/Bengaluru: Several citizen collectives in New Delhi have responded to the Commission for Air Quality Management (CAQM), after the authority called for the public’s recommendations on its recent report that identified various sources of air pollution in the capital city. Recommendations include increasing the focus to secondary pollutants along with primary ones such as fine particulate matter, more quantitative estimations of the contribution of different sources to air pollution in Delhi and the National Capital Region (Delhi-NCR), treating air pollution in the area as a public health emergency and focusing on not just short-term seasonal responses but implementing year-round and decisive action.What the CAQM report saidFollowing an order by the Supreme Court on January 6, the CAQM in Delhi-NCR and adjoining areas identified a panel of experts to put together the reasons for poor air quality in the national capital.The report of the air quality experts titled “Identification of the causes for worsening AQI in Delhi-NCR” published in mid January this year by the CAQM analysed – over a series of meetings with experts from NGOs, research institutes including IITs, etc. – the primary causes for the worsening AQI in Delhi-NCR, the major sources of pollution and their sectoral origins were.Also read: How Delhi’s Air Pollution Mirrors a Deepening Class DivideChiefly, it identified that in winter, the transport sector contributed to 23% of the observed concentration of fine particulate matter (or PM2.5, which is a major air pollutant) and secondary particulates from gas emissions from transport, industries and biomass burning contributed to 27%. Dust, biomass burning and other sources contributed to 15,20 and 6% respectively. In summer, this mix changed.Dust contributed most to PM2.5 levels during this time, at 27%. The transport sector contributed to 19%, industries contributed to 14% and biomass burning, secondary particulates and other sources contributed to 12%, 17% and 11%.On January 19, the CAQM called for recommendations from the public on the report.Recommendations rush inThe report discusses only PM2.5, noted the Delhi Swasth Saans Adhikar Nagrik Samiti (Delhi SSANS), a new forum of citizens who have united to raise concerns on pollution and climate change, in their letter to the CAQM.While the focus on PM2.5 will help frame “broad-brush pollution abatement measures”, it prevents discussion of other important primary pollutants such as NOx, SOx, CO etc. which produce dangerous secondary pollutants (as the report notes) and measures to specifically control these, the collective said.“We strongly urge efforts to study and interpret the available data, even if only through “meta analysis” as has been done now, to identify “average” annual levels of ALL primary pollutants for which standards have been set under the National Ambient Air Quality Standards (NAAQS) in India and also compare the same with WHO [World Health Organisation] norms,” SSANS said.The SSANS letter also identified methodological issues with the Report’s identification of contribution of sources to air pollution, calling it “misleading” and that it “detracts from the utility of the Report”. The collective recommended that the CAQM identify and quantify primary pollutants from which specific secondary pollutants are formed.More quantitative assessments required The figures for biomass burning are “somewhat surprising” because the report does not provide even approximate quantitative estimates of different sources – but still comes to “some problematic conclusions and recommendations”, the SSANS letter also noted. One is that the Report makes “sweeping remarks” such as that municipal solid waste and biomass are widely burned by low-income homeless and outdoor workers which “significantly worsens air quality” in Delhi-NCR; and that cooking (through the use of wood, for instance) by lower-income households in the NCR contributes substantially as a source of combustion.“Surely some quantitative estimation should have been made to support these claims against impoverished, marginalised people. Nor does the report discuss why the much vaunted LPG subsidy scheme does not seem to have reached such a large number of people,” it noted.The report calls for more Waste to Energy plants and this “comes as a shock”, the SSANS letter said, when science and residents’ experiences show that these plants emit a high amount of pollutants.Also read: Two-Thirds Of Delhi Does Not Have Reliable Air Quality DataTheir letter also recommended that the report include a section highlighting the ineffectiveness of certain measures that have been proposed or even implemented by authorities – such as anti-smog guns, truck-mounted water spray systems and artificial rain – to supposedly tackle pollution.“These false solutions only mislead the public and give them baseless hope, waste public resources and distract attention away from science-based solutions,” the letter, written by D. Raghunandan of the Delhi Science Forum on behalf of Delhi SSANS, read. It added that the public expects recommendations “towards an actionable set of measures to reduce air pollution in a time-bound manner”.The other signatories of the letter include Act Now For Harmony And Democracy (an organisation that works on issues related to democracy, secularism and justice), the All India Central Council of Trade Unions and independent journalist Saurav Das, among others.Enforcement over diagnosisAnother response to the CAQM’s Report came from Warrior Moms, a Delhi-based collective of mothers and caregivers who have been raising the issue of poor air quality for several years now.While they acknowledge “the scientific rigor of the report and its clear conclusion that air pollution in Delhi-NCR is a chronic, multi-source, airshed wide public health emergency driven by transport emissions, dust, biomass burning, industry and a substantial share of secondary particulate matter”, the most “critical gaps now lie not in diagnosis but in execution, transparency, health-centred governance and enforceable NCR-wide accountability” they said in their letter.Their letter, accessed by The Wire, highlighted how follow through on enforcement (including even court directions) “often fail to translate into timely, visible and consistent action on the ground”.“This persistent gap between intent and implementation directly affects our children’s health and erodes public confidence,” they noted.Other issues the letter addressed included issues surrounding data, transparency, monitoring coverage and staff shortages.Also read: As AQI Soars to 326, Delhi Govt Faces Heat from Citizens and Opposition Over Pollution Crisis“We are also concerned about the limited transparency and public accessibility of data and decision systems. While CAQM has invested in emission inventories, source apportionment, forecasting tools and decision support systems, these are not yet fully available in a manner that allows citizens, schools, doctors and independent experts to understand how forecasts translate into binding actions,” the letter noted.Like SSANS, Warrior Moms’ letter also noted how secondary particulate matter is a huge concern but is not addressed properly yet.‘Treat air pollution as a public health emergency’Among the 26 demands that the collective makes of the CAQM include formally recognising air pollution as a year-round public health emergency, with binding annual exposure-reduction targets instead of episodic, winter-only measures.Other demands include a moratorium in the NCR on tree-felling; treating non functional, manipulated, or bypassed Online Continuous Emission/Effluent Monitoring Systems as a serious offence, and ensuring immediate shutdowns and prosecution rather than advisory notices; and institutionalising a health-first governance framework, including child-specific exposure advisories, buffer zones around schools and hospitals and regular engagement with parents, doctors, students and health professionals.“As mothers, we experience the consequences of air pollution not as abstract data but as inhalers, chronic coughs, missed school days, anxiety and long-term health risks. Clean air is not a privilege or a seasonal concern; it is a basic right and a constitutional obligation. We urge the Commission to use this moment to move decisively from diagnosis to durable prevention through transparent, enforceable, and health-centred action,” the letter added.