Pre-emptive only in name: Why GRAP in Delhi falls short despite updates

The latest round of changes, submitted by the Commission for Air Quality Management (CAQM) to the Supreme Court, is expected to be notified next week.

The Graded Response Action Plan (Grap) is set for its fourth overhaul in three years – the latest in a string of rapid-fire revisions since the major 2022 redesign that linked emergency measures to air quality index (AQI) forecasts and made them pre-emptive.

This mismatch between forecasts and ground reality has rendered the pre-emptive structure of Grap almost meaningless. (Ht photo)

Yet experts stress that despite the constant tinkering, Grap has repeatedly failed to achieve meaningful impact, largely because its changes arrive late, its implementation is weak, and its central premise – taking action before the air turns toxic – has never been followed.

The latest round of changes, submitted by the Commission for Air Quality Management (CAQM) to the Supreme Court, is expected to be notified next week. Several restrictions currently under Stage 4 may be shifted to Stage 3, and some Stage 3 measures pushed to Stage 2. Among the notable proposals: when Stage 3 is invoked, Delhi-NCR governments must decide whether offices should operate with 50% staff onsite, and staggered timings for all public offices would now begin at Stage 2 instead of Stage 3.

But experts said that repeated revisions mask the larger problem – Grap is implemented only after pollution spikes, not before.

“After the 2022 revamp, measures were supposed to be implemented in advance, but we don’t see that happening. This is also due to a faulty forecasting system which is not always accurate,” said IIT-Delhi professor Mukesh Khare, who served on the former Environment Pollution (Prevention and Control) Authority, which introduced Grap in 2017.

The 2022 redesign was meant to transform Grap from a reactive tool into a preventive framework. It introduced four AQI-based stages – Stage 1 (Poor), Stage 2 (Very Poor), Stage 3 (Severe) and Stage 4 (Severe Plus) – and required pre-emptive action. But this system depends entirely on accurate forecasts, and Delhi’s forecasting tools have repeatedly proven unreliable.

HT reported on November 14 that the Early Warning System (EWS), the forecasting model used by CAQM, failed multiple times this season. On November 10, it predicted “very poor” air for the next day, but the AQI plunged into the “severe” category – Delhi’s first severe air day of the season. Predictions for November 12 and 13 were also off the mark.

This mismatch between forecasts and ground reality has rendered the pre-emptive structure of Grap almost meaningless.

“We cannot wait too long to implement measures. Ideally, we need to have some fixed measures in place all through winter, instead of waiting to invoke different stages. As it is, by the time some measures or stages are invoked, it is often too late and the haze has settled in,” said Dipankar Saha, former head of CPCB’s air laboratory.

Adding to the problem is weak implementation. Over the past two years, both governments and enforcement agencies have struggled to impose restrictions with consistency. Experts point out that even when stages are invoked, compliance is patchy across sectors — especially for construction, waste burning, and vehicle movement. Residents often witness announcements on paper that do not translate into real-world checks.

In fact, several of the recent revisions have come under judicial pressure. In December 2024, following Supreme Court directions, CAQM moved several measures to earlier stages: interstate buses running on older diesel engines were barred at Stage 2 instead of Stage 3; resident welfare associations were ordered to provide electric heaters to all staff to prevent biomass burning; and bans on BS-4 diesel medium and light commercial vehicles were tightened.