Environment Ministry's Cooling Action Plan Is a Good Start but Not Good Enough

The ICAP alludes vaguely to “targeted programmes to enable cooling" lower income groups without any substantive discussion on the issue, so placing the onus on municipalities and NGOs to lead initiatives.

As global temperatures climb steadily, the increased frequency and intensity of heatwaves is one of the biggest challenges that policymakers must look to address. The effect of heat stress is experienced in a number of different ways, ranging from reduced productivity to morbidity and mortality. Against this backdrop, the release of a draft India Cooling Action Plan (ICAP) by the Ministry of Environment, Forest and Climate Change (MoEFCC) last month is a significant and positive development.

This is an important document, the first of its kind, “to address the cooling requirements across sectors and ways and means to provide access to sustainable cooling for all.” The plan contemplates a 20-year scenario, from 2017 to 2037, and provides recommendations across sectors like air-conditioning, buildings and refrigeration. The section focusing on space cooling, or cooling energy use in buildings, is particularly notable because this constitutes a significant portion of the demand in the cooling sector.

The ICAP begins by discussing the importance of cooling in the context of health and economic growth in India. But by failing to define what exactly ‘cooling’ means, the focus and framework of the ICAP do not emerge very clearly. Additionally, the document aims to set standards for “adaptive thermal comfort” but does not as much as define this term. Specifically, as far as the cooling of buildings is concerned, the narrative in this policy document is centred predominantly around building standards and, particularly, the Energy Conservation Building Code (ECBC) and efficiency standards for air conditioning.

The need for cooling is universal but by no means homogenous, and for a document called the ‘India Cooling Action Plan’ to avoid addressing the connotations of cooling in the context of a large majority of India’s population is a significant gap.

Space cooling in buildings

The ICAP recommends a two-pronged approach to meet buildings’ cooling needs: first, by improving building and construction norms to reduce the need for active cooling, and second, by improving cooling technologies to reduce the cooling demand. In practical terms, this translates into buildings with improved insulation, resulting in reduced dependence on cooling appliances, and then improving the energy efficiency of the cooling appliances themselves.

This is certainly a sound trajectory, also supported by the latest report from the International Energy Agency. It finds that building codes and appliance standards have been key policy measures for inhibiting energy consumption. In 2017, mandatory energy efficiency policies covered 34% of the global building energy consumption. This is certainly a figure that governments should focus on improving.

But a significant drawback of the ICAP lies in its failure to discuss how best to provide affordable and sustainable cooling to India’s Economically Weaker Section (EWS) and Low Income Groups (LIG). For example, slum-dwellers lack access to housing in buildings, in the limited sense contemplated by the ECBC/ECBC-R, on which the ICAP heavily relies. Further, this section of society is most vulnerable to heat stress and lacks access to air-conditioning.

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The ICAP alludes rather vaguely to “targeted programmes to enable cooling for EWS and LIG”, and without any substantive discussion on the issue, so placing the onus on municipalities and NGOs to lead initiatives such as cool roof programmes. The cooling needs of this section of society have clearly not been prioritised by the policy, and a nuanced discussion on this topic is conspicuous by absence.

The value of behavioural interventions

The ICAP makes important contributions in the field of technology-based energy improvements in appliances for cooling buildings, including institutionalising these improvements, predominantly in the air-conditioning sector. However, one of the limitations of the ICAP is that the potential of demand-side measures to reduce energy consumption through a shift in habits and behaviour is almost completely absent.

The ICAP suggests cursorily that thermostat setting could be mandated in the 22-26° C range, as part of the adoption of the indeterminate “Adaptive Thermal Comfort”. However, there is no discussion on the implementation modalities of such a measure from the perspective of industry standards or state intervention.

The anticipated expansion of cooling through air-conditioning should not allow us to lose sight of the urgent need to address the lock-in effect of a technology with massive global warming potential. The need to disrupt the path-dependencies of air-conditioning must be addressed as urgently as the potential for supply-side technological gains in this sector. While the potential in energy savings from improved efficiency standards in fans and air-coolers has been briefly discussed in the ICAP, there is no discussion about harnessing this potential to diminish the lock-in effect of air-conditioning.

Also read: In Defence of Air-Conditioning

It is important for a comprehensive cooling policy to contemplate measures that can discourage consumers from relying excessively and superfluously on cooling devices. The policy should envisage collaboration with DISCOMs to evolve a cascading pricing structure to monetarily disincentivise excessive demand/overcooling (determined, for example, by the number of hours of usage or the number of devices per household). The mechanism for enforcing, disincentivising and penalising over-cooling should be rigorous.

Cooling as an urban planning goal

A national-level cooling policy must tackle in much greater detail the measures that should be taken to offset heat stress, including the heating effects generated by the cooling sector itself. For example, the emissions from the cooling sector in urban centres are particularly problematic, for leading to the urban heat island (UHI) effect.

The recent Special Report of the Intergovernmental Panel on Climate Change also highlighted the significance of heat stresses arising from the UHI effect, especially since some major urban centres are likely to experience devastating heatwaves in the future. The ICAP only mentions in passing that municipal bodies must develop “urban heat action plans”. A truly holistic cooling plan must necessarily address a clear methodology for offsetting the UHI effect. This could include, for example, mandatory afforestation and tree cover rules along with an increase in the number of parks and water bodies.

A goal as broad as cooling cuts across many sectors of the government machinery. The policy document acknowledges this, and notes that “the ICAP implementation will be best served by active collaboration among the relevant ministries as well as private sector entities”. This is crucial to the success of an all-India cooling policy.

While the MoEFCC has taken the lead in formulating the ICAP, the mitigation of heat stress cannot be the domain of this ministry alone. A corollary to the analysis above is that different actors, such as the Ministry of Power and the Ministry of Housing and Urban Affairs, must collectively meet the needs of a meaningful cooling action plan. These ministries must examine the ICAP and augment its efficacy with their own proposals and commitments.

The implementation of the ICAP should also be streamlined with existing government schemes, such as the Green Rating for Integrated Habitat Assessment (GRIHA) and the Pradhan Mantri Awas Yojana (PMAY), to further the goal of sustainable and affordable housing.

Additionally, since India’s federal structure has often proven to be a source of weak coordination and poor implementation, policymakers must reassess the domination of a top-down approach by the Centre. An effective cooling policy must envisage a clear framework with greater involvement of state agencies and municipalities, and improved centre-state synchronisation and accountability.

Parul Kumar is a Delhi-based lawyer and policy professional. She blogs at www.indiaenvironment.in.