Kejriwal Has a New Winter Pollution Plan for Delhi. It Should Focus More on Cutting Emissions.

The Delhi government has started to prepare in advance this year, raising hopes that if it gets enforcement right, the air this winter may just be more breathable.

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First, the good news: In addition to announcing a ban on the storage, distribution, sale and bursting of firecrackers, the Delhi government has drafted a 10-point winter action plan to combat air pollution, based on data from the last five years to predict ‘hotspots’ two weeks in advance.

The draft plan is currently being circulated among air pollution experts and clean air advocates for feedback.

This is good news because the government has finally begun planning ahead of the annual winter pollution spike and because it will finally enlist predictive models and historical data and attempt to be more proactive, instead of reactive.

This has been the biggest complaint against the Graded Response Action Plan (GRAP). It was an emergency measure that banked on short-term control measures even as air pollution went off the charts.

Now for the bad news. The Delhi government’s environment department still depends on models like the GRAP, the same tired and inefficient civic agencies, and the under-staffed Central Pollution Control Board to help enforce existing pollution-control laws.

On September 14, the Delhi government conducted a review meeting with agencies that help run the city, including the Development Authority, Jal Board and the Public Works Department. The government is expected to unveil its final plan on September 30.

In this context, one saving grace is that the government intends to reach out to the newly minted Commission on Air Quality Management (CAQM). The CAQM has the ability to coordinate as well as catalyse bureaucratic decisions. It is itself headed by a bureaucrat – M.M. Kutty – who, as former chief secretary, is familiar with working with the aforementioned, and other, agencies.

Also read: Between Pollution and Lockdowns, Kashmir’s Beloved Houseboats Are Sinking into History

Delhi environment minister Gopal Rai has already said that he will call upon the CAQM this week to discuss stubble-burning. He also said he would talk about the Pusa bio-decomposer – a microbial solution to ferment stubble into manure. If the CAQM is able to avert the smoke from burning stubble in north India’s farmlands, it will more than justify its own existence, and also increase the health outcomes of nearly half a billion people that live on the Indo-Gangetic Plain. Recent data from the Energy Policy Institute, of the University of Chicago, suggested around 40% of Indians lose nine years of their lives by breathing North India’s foul air.

In case the Punjab and Haryana governments are reluctant to adopt the use of Pusa decomposer – since it has become associated with their political rival – clean air advocates have said they could adopt other similar solutions.

At the same time, as the farmers’ protests against the three infamous farm laws have intensified, no one expects those farmers who do burn paddy stubble will be fined heavily, more so since state elections in Punjab are around the corner. So the CAQM needs to quickly preempt stubble-burning with other (preferably inexpensive) solutions. Otherwise, North India will suffer more than it has in previous years.

Going by Gopal Rai’s statements, the stage already seems to be set. “There will be no need to register cases against farmers,” he said on September 10. “In Delhi, we took it upon ourselves to spray Pusa bio-decomposer in every non-basmati rice field. There will be no need to invoke provisions of law against farmers if the governments give them a solution.”

This is likely also why the Delhi government reiterated the ban on firecrackers on September 14. Smoke from burning stubble and firecrackers are the two largest sources of winter pollution peaks. And with less wiggle room vis-à-vis the stubble, the government has to turn the screw on fireworks.

The airshed level

To the Aam Aadmi Party’s (AAP’s) credit, it has been among the first political parties to publicly acknowledge the life-threatening effects of air pollution plaguing Delhi. It has also highlighted that pollution is a North India problem, not just a Delhi problem, and thus requires governments to work together. “Experts have ruled that this an airshed issue,” as Rai told reporters last week.

Rai then spelt out his government’s points of focus this winter:

  • Stubble and garbage burning
  • Vehicular and dust pollution
  • Identifying and tackling hotspots
  • Studying smog towers
  • Communicating with neighbouring states
  • Upgrading the pollution ‘war room’ and updating the ‘Green Delhi App’
  • Coordinating with the Centre and the CAQM

On the last count, the government is to set up a team of officers to talk to neighbouring states about fighting pollution together, Rai said. “Any activity against the environment in Haryana, Punjab, Uttar Pradesh affects Delhi, too,” in his words. This is another reason why involving the CAQM, and its centralised authority, will be crucial. No single state can independently solve the air pollution problem.

While the Delhi government’s winter action plan is a start, and the runway has been extended by being proactive, reducing exposure – versus reducing emissions – is a treacherous path. For example “studying smog towers”, one of the items on the government’s to-do list, means little. Smog towers do nothing to reduce emissions at the source, and are inefficient at human exposure to pollutants. As such, they are a waste of public money.

Several experts and activists have repeatedly slammed the 2019 Supreme Court order to install smog towers. Care for Air, the organisation I cofounded, penned a letter to the court and later filed a petition arguing against smog towers with scientific evidence, but the court dismissed it. Lawyer Veera Mauli wrote subsequently: “When judges decide to act as scientists, they can still demand compliance, but it spells disaster.”

But both the Aam Aadmi Party and the Bharatiya Janata Party have been quick to claim credit for even newly installed towers.

Similarly, upgrading a ‘war room’ and a ‘green app’ will only be as useful as their ability to address and resolve the people’s pollution complaints quickly and efficiently. The Delhi government has moved complaints about burning biomass to the app, with the relevant department promising a two-hour turnaround.

Also read: India’s Air Pollution Mitigation Strategy Needs More Direction

The government plan also has a “citizen engagement activities” part. It includes requesting citizens to reduce one trip per week, stop idling at red lights, prevent burning and to report fires they see. The city also hopes to involve neighbourhood watch groups, resident welfare associations, etc. through webinars and other nudges.

Unlike the erstwhile odd-even road-sharing scheme, which was mandatory, these activities are voluntary. (Rai has said the odd-even scheme will be used as a last resort.)

Using historical data and building on existing knowledge is a big improvement on last year’s “war on pollution”. But for this to be more than just rhetoric, the government needs to do more to reduce or capture emissions at the source.

Experts have also pointed out a challenge with using historical data to estimate pollution levels two weeks in advance. It’s that even a small meteorological change could precipitate sharp differences in estimated and actual pollution. Sudden winds or rain could easily skew data, blowing or washing away particulate matter – as could reduced industrial activity, as during the COVID-19 lockdowns.

EV and solar microgrids

Perhaps most importantly, until the Delhi government focuses on reducing emissions at source, its ‘war’ on pollution will be lost in advance.

The AAP has tried to have thermal power plants in neighbouring areas cut their emissions. It petitioned the Supreme Court to ask the Centre to not allow thermal power plants to continue operations without installing specific filters in their chimneys. But the court dismissed the petition in July. This means another big source of Delhi’s bad air will continue to remain unaddressed.

Thermal power plants have been lobbying the government since late 2017 to delay having to add these filters to their chimneys. Installing them will increase costs and thus reduce the plants’ profitability. But with the just-announced ban on firecrackers, at least one unproductive source of emissions is likely to be reduced – assuming the Delhi government can enforce it well.

Indeed, one area where the government can actually make a difference without the courts’ or the Centre’s help is in public transport. Until August 2021, Delhi had procured only 452 of the long-promised 1,000 additional buses. The total fleet strength is just under 6,800 – less than half of what experts have estimated the city needs. Improving public transport will lead to lesser congestion and, thus, lower vehicular emissions.

This said, the government has already made a difference in two areas. The first is its electric vehicles policy, notified last year. The other is the new solar microgrid in Malviya Nagar, which power minister Satyendra inaugurated last week. The pilot grid is expected to decongest the power network and stabilise the grid in times of high demand, by distributing the load efficiently and reducing dependence on coal. Jain said more such microgrids are likely to come up.

These are exactly the sort of longer-term policy measures that every city in India’s polluted plains needs, to clean the air its people breathe.


Stubble-burning has been pushed back this year thanks to incessant rains over North India. Delhi has received an unusual 383.4 mm of rainfall in September so far – the highest for the month in 77 years, according to India Meteorological Department data.

In addition to delaying the inevitable, the rains have also washed away a lot of the particulate matter that is most harmful to human lungs. The government’s SAFAR app, which tracks air quality, has stayed in the “good” to “satisfactory” range through most of August and September.

But those of us who follow the air-pollution narrative closely know this is just temporary respite. Data on NASA Worldview has started to show some fires in West Bengal, Jharkhand and Odisha, and across the border in Pakistan. After stubble-burning kicked off the high-pollution season, Diwali firecrackers were expected to add another layer of toxicity to our already foul air. But we now have reason to hope that if the Delhi government delivers on its promise, this winter could be somewhat better.

Note: This article was edited at 1:35 pm on September 16, 2021, to note that the author is cofounder, and no longer president of Care for Air.

Jyoti Pande Lavakare is an independent journalist, co-founder of the Care for Air non-profit and the author of Breathing Here is Injurious to Your Health: The Human Cost of Air Pollution, published by Hachette in November 2020.