The Draft National Clean Air Programme Is Spirited but Lacks Action Points

With no time-bound activities to reduce pollution, the NCAP's proposed activities are nothing but new cells, committees, trainings and workshops.

In April 2018, the environment ministry released a draft of the National Clean Air Programme (NCAP). Its main goal is “to meet the prescribed annual average ambient air quality standards at all locations in the country in a stipulated timeframe.” Given the state of air quality in India, any initiative by the Government of India is a welcome one, especially given the lack of monitoring data in the research space and the lack of enforcement of existing laws to curb emissions.

The current NCAP draft is essentially a research programme designed to build institutional and technical capacity of central and the state pollution boards. The timeline of all proposals conclude in less than two years from the start. There is also no mention of a time-bound ambient air quality target to achieve or how.

If the NCAP is successful in meeting its research agenda over its intended lifetime, it would indeed result in a watershed of studies and information that can aid policymaking in India. Some proposed activities, and some missing links, are clubbed under five major heads below.

Ambient monitoring

The programme talks about increasing the number of manual stations to 1,000, reporting PM2.5, PM10, SO2 and NO2 levels, adding another 100 continuous monitoring stations in the Indo-Gangetic region, in addition to 210 operational and planned continuous stations. It also discusses

  1. Alternative methods for expanding the monitoring network
  2. Expanding the monitoring network to 50 rural areas with at least one station
  3. Revising the guidelines for ambient monitoring (last updated in 2003)
  4. Establishing a 10-city super monitoring network (definition pending)
  5. Certification system for new monitoring instruments
  6. Promoting programs on indoor air pollution monitoring with special focus on managing household fuel combustion, and
  7. Establishing an air information centre

All of this is expected to be completed in less than two years. This is a step in the right direction. Assuming it starts by late-2018, in simple terms, the amount of monitoring data that will be available for scrutiny and analysis will at least double by 2020.

We have a long way to go in expanding the ambient monitoring network in the country. It is estimated that we require at least 4,000 continuous monitoring stations (2,800 in urban areas and 1,200 in rural areas) to spatially and temporally represent air quality in the country. Besides ambient monitoring, an important aspect of knowing the sources of pollution is emissions monitoring and making that information available in real-time for further analysis. This task is missing in the programme.

Air quality management plans

In 2010, the Central Pollution Control Board (CPCB) and its partner institutions released an emissions inventory and source apportionment results for six cities. Under the NCAP programme, this will be extended to 94 non-attainment cities.

The programme emphasises sampling, chemical analysis and receptor modelling-based source apportionment and the emissions, dispersion and source modelling-based source apportionment. The six-city study took over five years to complete. The new 94-city study is scheduled to start and complete in two years, including putting together air quality management plans, with guidelines to implement the established strategy to control and manage air pollution in the city.

The NCAP also has a provision to build a national emissions inventory. It remains to be seen if the inventory will include real-time data from the emissions monitoring system installed at industrial stacks.

Air quality forecasting

It is obvious that pollution levels are bad in most Indian cities. Now, a provision in the NCAP to forecast these pollution levels based on modelling systems for at least 10 cities is a bold step forward. This will set up an official platform to alert the public about what the air quality will be like in the next two or three days, and allow those with opportunities to reduce their daily exposure rates. This is a global practice and is new only in India.

There are already a few programmes in place to this end. Urban Emissions (the research group with which the author is affiliated) has hosted a public information portal since 2016, with results from an operational air quality forecasting program for all of India, reporting pollution levels at the national, state and district levels for the next 72 hours.

Since the Commonwealth Games in 2010, the Indian Institute of Tropical Meteorology (IITM), Pune, has forecast and disseminated similar information for Delhi, Mumbai, Pune and Ahmedabad (under its SAFAR programme).

In March 2018, the World Bank and the Delhi Pollution Control Committee announced that they would jointly put together an international consortium to build an air quality forecasting system for Delhi. In April 2018, another modelling system was announced as part of a collaboration between the Ministry of Earth Sciences, the Finnish Meteorological Institute and the US National Oceanic and Atmospheric Administration. The goal: to increase the air quality forecasting capacity in India.

While the environment ministry is expecting to have its own air quality forecasting system, within two years, we will have more organisations to join this analytical race in parallel, providing us with a glut of information that can help make better sense of the short-term pollution variability in Indian cities.

Health impacts analysis

Most of the health impact analysis results reported in the media and referred in scientific studies come from the global burden of disease database. Two other studies were conducted in India, one from IIT Delhi and the other, from IITM Pune. The environment ministry said however that there was no clear link between health impacts and air pollution for India.

In the NCAP, there is a provision to publish health impacts analysis under the joint chairmanship of the Indian Council of Medical Research and the ministry. This is a welcome change in accepting that health impacts analysis is crucial. However, there are no details of the methods or processes of how this will be conducted; if there are any epidemiological studies planned or already under implementation from which these conclusions will be drawn; and how this can be concluded within a year, without referring to the studies already conducted in this space.

Institutional capacity building

A number of programmes are mentioned in the NCAP to increase the capacity of the pollution control boards:

  1. Air information cell to maintain and disseminate information generated at the pollution control boards
  2. Technology assessment cell to support bilateral and multilateral agreements undertaken by the pollution control boards
  3. Network of technical institutions to provide support for policies and programmes of the Government of India on air pollution
  4. Three-tier mechanism for review of monitoring, assessment and inspection for implementation of standards by the pollution control boards
  5. Awareness, training and capacity building drive at the pollution control boards
  6. A committee to review the ambient and emission standards
  7. Changes to the institutional framework for central and state pollution boards under the environment ministry and establishing international cooperation to share best practices on air pollution

There is a need to build the computational, technical and institutional capacities of the central and state boards to be able to digest and apply the information generated. But with no time-bound actions to reduce pollution, the proposed activities are nothing but new cells, committees, trainings and workshops, with little in the way of action.

The NCAP meeting its goals

The stated goal of the NCAP is to meet prescribed air quality standards. In a nutshell, the current NCAP draft is a long research program. A simple question remains: do we know enough now to act on where to invest and how to control some pollution in the next three years?

However, in the current NCAP draft, there is no mention of

  1. How much of the national ambient standards will be achieved, such as percentage reduction in ambient concentrations compared to, say, 2017 averages
  2. A timeline on when the targets will be achieved, like “we will reduce 50% of the pollution by 2020”
  3. Who will implement the air quality management plans for the cities in each time frame

This was also on the biggest drawback of the Graded Response Action Plan for Delhi. While the Environment Pollution Control Authority issues an alert based on air-quality trends in the last 48 hours, there is no nodal agency to implement or monitor any of the tasks listed under various alert categories.

Air pollution is a complex issue, and curbing emissions to meet standards is a simple but far from easy solution. More importantly, it is not solved by conducting studies alone. With multiple ministries and competing priorities, the responsibility of reducing emissions has been constantly shifting. Unless a common protocol involving all ministries is designed, the blame for poor air quality will keep shifting across jurisdictions, sectors and states.

While it is an ambitious research project, the NCAP will not lead to its stated goal of meeting prescribed air pollution standards within a stipulated timeframe by itself. Air pollution is the result of inadequate urban planning and needs multiple ministries and stakeholders to coordinate on finding a solution. Such coordination is not immediately apparent in the NCAP document.

As a statutory organisation under the Ministry of Environment, Forest and Climate Change, the CPCB is mandated to implement and enforce the Air Act 1981. The NCAP covers a narrow aspect of this and does not go far enough in specifying how exactly air pollution will improve. This is a pity.

There is no denying that research can direct policy and make it more effective. But one needs to guard against policy paralysis through actions not taken because of waiting for the perfect research to justify it. In an ideal world, real-time data and analysis should complement policy options so that we can evaluate the efficacy of different measures taken to reduce air pollution.

Currently, we are far from that scenario on both the policy and research fronts. The only policy measures we are taking are small pilots, such as the odd-even scheme or temporarily shutting down a power plant. On the research side, we do not have enough monitors and access to real-time data to study the impact of even these temporary measures.

Our only real option for improving air is waiting for meteorological events, such as rain and winds, to clear the air. For this, the current government finds it better to appease the gods.

Sarath Guttikunda is the director of Urban Emissions (India), an independent research group on air pollution, issuing three-day air quality forecasts for all Indian districts.