Delhi’s pollution action plan stuck in fine print and protocol, needs relook
Experts said these protocols need a relook to make pollution control measures pre-emptive and not reactive as they are now.
Delhi’s ordeal in the grip of severe-plus air pollution extended over 30 consecutive hours Saturday morning, when the Supreme Court stepped in, suggesting a two-day lockdown for the choking city.
While a call on lockdown is yet to be taken, curbs such as physically shutting schools (however, online classes will continue) and stopping construction activities that were announced by the Delhi government later on Saturday are already mandated in the Supreme Court-approved Graded Response Action Plan (Grap). But the administrative intervention remained stuck in protocols and the fine print.
Delhi has been experiencing another seasonal chokehold since Diwali, and under the Grap protocol, authorities can declare an air emergency and impose these curbs mandated under the severe-plus band of air quality only when PM2.5 levels cross 300 µg/m3 or PM10 levels cross 500 µg/m3 (which is fivefold above the standard) and stay there for at least 48 hours.
Experts said these protocols need a relook to make pollution control measures pre-emptive and not reactive as they are now. The mechanism for implementation as well as enforcement needs rapid capacity-building, not just in Delhi but also across the National Capital Region, backed equally by strong administrative and political will.
Late intervention
Officials involved in the enforcement of pollution-control measures said they have been on track with the implementation of Grap. However, they agreed that the Commission for Air Quality Management (CAQM), which is tasked with implementing Grap, and other agencies calling the shots could be more sensitive to the gravity of the pollution crisis in the national capital, rather than being stuck in the technicalities of the plan.
“On November 6, the PM 2.5 levels and PM 10 levels slipped into the severe-plus levels. However, the very next day, it briefly came below that threshold. So, technically, the CAQM and CPCB were not liable to introduce the severe-plus measures, even though the pollution continued to be at hazardous levels and was forecast to get worse. How is PM 2.5 exposure of 299ug/m3 any better than 300ug/m3? But we are stuck in technicalities,” said an official who asked not to be named.
Anumita Roychowdhury, executive director (research and advocacy), Centre for Science and Environment (CSE), said Grap is only a guiding document and the agencies responsible to implement it are allowed to take additional measures to control the rising pollution.
“Since after Diwali, apart from two days, Delhi has been recording severe days. What are the authorities waiting for? Grap is a guiding document and it also explicitly mentions under the severe-plus measures that the administration can call in any steps other than that mentioned in the action plan to control the dangerous pollution levels. The administration needs to use its discretion and not use Grap as an excuse to not do anything. Grap measures should be automatically enforced,” Roychowdhury said.
Forecast-based response
Experts said that under Grap, the agencies need to respond to forecasted levels of air pollution as opposed to observing what happens over the course of two days and then taking a call.
Delhi currently has two forecasting systems, the Decision Support System developed by Indian Institute of Tropical Meteorology and Union ministry of earth science’ Early Warning System, both of which provide air quality forecasts, which could be used to make advance decisions.
“There are multiple sources of air pollution forecasts, including from the Indian Institute of Tropical Meteorology, available now. There is a clear case for Grap to rely on these forecasts to proactively initiate short-term emergency responses, instead of the current reactive approach,” said Santosh Harish, fellow at Centre for Policy Research.
Beijing’s colour-coded emergency response system, for instance, is an air quality index (AQI) forecast-based action plan rather than a reactive action plan such as Delhi’s.
The “particulate matter approach” taken by Grap itself needs a relook, said environmental lawyer Ritwick Dutta. An an analysis of Grap by the Legal Initiative for Forest and Environment (LIFE), an outfit founded by Dutta, states that Grap does not consider all air pollutants, but only particulate matters such as PM2.5 and PM10. Even if the level of pollutants such as SO2 or NOX increases – which are a part of AQI index monitoring -- Grap does not come into effect.
“Even if Grap is implemented in full, it only looks at levels of PM 2.5 and PM 10, but does not look into quality of air as such. So you can have very high levels of other pollutants (in the air) and still have very good grap implementation. Therefore, by nature, Grap is faulty,” Dutta said.
Weak, haphazard enforcement
The post-Diwali smog over northern India is a well-established phenomenon. Yet, each season, pollution mitigation is conducted haphazardly even as Grap marks out each step of enforcement and responsibilities of the agencies involved.
But compliance cannot be ensured without capacity building and administrative will. A case in point is the recent directions to municipal agencies to increase the parking fee, and to transport agencies to implement differential rates in public transport to encourage off-peak travel. Both directions have not been enforced.
“Grap says deploy extra buses when pollution levels peak. But where are the extra buses? Where are the extra drivers? It is not like a fire service where we have vehicles waiting on standby. Similarly, parking rates have to go up four times when pollution peaks to very poor levels. But where is the mechanism to charge more? Traffic congestion has to be reduced, but are instructions given to Delhi Police that they are not supposed to put barricades during peak pollution times?” asked Dutta.
Need year-round approach
Delhi’s baseline pollution -- from vehicle emissions, construction activities, waste burning -- is high all through the year. During the non-winter months, Delhi sees some relatively cleaner days due to the favourable weather conditions, although freak build-ups such as the dust storm in summer lead to pollution spikes. After monsoon withdrawal, when the wind patterns change and the temperature starts to dip, stubble burning in Punjab and Haryana, coupled with local emissions, lead to a massive pollution spike. On Diwali, blatant violation of government’s ban on burning of firecrackers pushed air quality into severe zone a day after the festival.
Recognising this, Grap was designed to be a year-long exercise to check polluting activities even when the air is moderately clean. For instance, for ‘moderate to poor’ days, Grap directs municipal and road-owning agencies to stop garbage burning, impose heavy fines for non-compliance, conduct mechanised sweeping on busy streets, sprinkle water on unpaved roads every two days and stringently enforce rules for dust control at construction sites.
Unfortunately, much of this exercise has been reduced to a calendar event to be observed when winter pollution peaks. Making efforts to control particulate matter during the onset of winter serves no effective purpose, said Dutta.
Santosh Harish said, “Ultimately, emergency responses are only a last-ditch effort to reduce exposures to a small extent. Several of these wintertime local actions on waste burning and construction dust need to be implemented year-round to be well understood and complied with, instead of being episodic actions.”
Time to upgrade Grap
Notified in 2017, Grap was to end the problem of multiplicity of agencies in Delhi and NCR towns so that they could be made answerable to an overarching body— then, the Environment Pollution (Prevention and Control) Authority that was assigned the task of implementing the Grap and submit action-taken reports to the Supreme Court. Through a Union government ordinance last year, the Epca was dissolved and replaced by the 20-member Commission for Air Quality Management in Delhi-NCR and adjoining areas, which is now in charge of Grap.
“What we knew back then about Delhi’s pollution sources is not what we know now. After 2017, we had a detailed source apportionment study by TERI, which gave us clarity on local and external sources. So, we cannot brace this document blindly and say that we are only going to enforce what is written in black and white because the scenario has changed and we must also revise the document accordingly,” said a senior government official who was formerly deputed with the Delhi Pollution Control Committee.
Dutta stresses the need to take pollution action plans beyond cities. “We blame stubble burning in Punjab and Haryana for pollution peaks in Delhi. The reason for that is that the focus is on cities, not states. Today, only 122 cities have been counted as non-attainment cities and their pollution action plans are limited to them. The National Clean Air Programme very clearly requires each state to prepare its own state action plan by 2020. Not a single state has done that,” he said.
“The non-attainment cities have been identified based on a study of 370 cities, not 4,000 cities that we have in India. According to us, the data should be of 4,000 cities, plus rural areas. Only then you will come to know the extent of pollution levels and what needs to be done,” he added.
