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Plan to reduce air pollution by 20-30% by 2024 won’t lead to breathable air quality

Excerpts from Greenpeace India's report “Airpocalypse IV: National Air Monitoring Programme (NAMP) & Assessment of Air Pollution in Indian Cities” by Avinash Chanchal and Chetna Chauhan:
India was expected to have a total of 3000 stations established in Class I (population of one million or more) and II (population of 50,000 to 99,999) cities and towns by 2022. Although the data availability through the National Clean Air Programme (NCAP) which covered 342 operating stations in 127 cities/towns across the 26 states and 4 Union Territories of the country in 2016 has more than doubled in past three years and now (as on 17th December 2019) India has installed 793 stations in 344 cities/towns across 28 states and 7 Union Territories, but is still far from where it is expected to be and lags far behind, compared to other regions such as the United States, Europe and China etc.
In the year 2018, NAMP recorded data across 302 cities having 745 stations across 28 states and 7 union territories in India. Under the programme the monitoring of pollutants was carried out for 24 hours (4-hourly sampling for gaseous pollutants and 8-hourly sampling for particulate matter) with a frequency of twice a week, to have one hundred and four (104) observations in a year. In 2018 a total of:
1. 699 stations across 287 cities recorded data for 52 or more days in year 2018 (50% of the stipulated observations in a calendar year).
2. 631 stations across 264 cities recoded data for more than 78 days (75% of the stipulated observations in a calendar year).
3. 510 stations across 225 cities were able to record data for more than 93 days (90% of the stipulated observations in a calendar year).
4. 299 stations across 145 cities were able to record data for 104 or more days in 2018 (equal or more than the stipulated observations in a calendar year) compared to 224 stations across 109 cities/towns in 2017.
Stations with minimum 50% data recorded compared to the stipulated 104 observations in a year are considered in the analysis of prevailing pollution levels and ranking the cities for the current report. Out of 288 cities having one or more stations with more than 52 days of ambient air quality monitoring under NAMP for the year 2018:
1. More than 80% (231) cities/towns had PM10 levels exceeding the 60 µg/m3 limits for PM10 prescribed under National Ambient Air Quality Standards (NAAQS) by CPCB, implying that all these cities/towns belong to the non-attainment list.
2. Just one city/town (Lunglei, Mizoram) had PM10 levels under World Health Organization (WHO) prescribed level of 20 µg/m3 leaving all other cities with higher pollution levels than the WHO annual standard for PM10.
3. 140 cities/towns had PM10 levels beyond 90 µg/m3.
In January 2019, MoEF&CC, released the first ever National Clean Air Programme for India. Under the programme the cities are expected to reduce air pollution levels by 20-30% by 2024 from 2017 levels. The following table represents the number of non-attainment cities included as part of NCAP along with 20 more cities which have been identified as non-attainment by Central Pollution Control Board (CPCB) in August 2019 but have not been included under NCAP till now as per a recent question answered by Honorable Minister for Environment Forest and Climate Change in the last parliament session (December 2019). The figure also represents state-wise number of cities which are non-attainment as per 2018 annual average PM10 concentration (based on NAMP stations with more than 52 readings in 2018) but are not included in NCAP till now.


Government’s Initiative

NCAP in its current form and ambition is only a good first step on a long journey. For the first step to be meaningful it must be followed by other measures and several lacunae must be addressed. These include:
1. The NCAP is not notified under any Act (Environment Protection Act or Air Act) and is only being seen as a guiding document. To make the NCAP effective in achieving breathable air quality across the country, the air quality targets and specific measures identified in the document must be given a proper legal status. The experience of the GRAP (Graded Response Action Plan), CAP (Comprehensive Action Plan) for Delhi and Emission standards for coal based power plants show that implementation is a key challenge. The NCAP should be given stringent provisions making it legally binding on both authorities and polluters to cut down on pollution.
2. Crucially, the current ambition levels under NCAP (20-30% air pollution reduction by 2024) will not lead to breathable air quality in the country, as the pollution levels across much of the country are so high that even a 30% reduction will still leave levels above the NAAQS, not to mention the WHO standards.
3. The NCAP being a dynamic document must set specific city-wise pollution reduction targets rather than just providing a tentative window of 20-30% reduction across the board by 2024.
4. NCAP should also express the ambition to move to NAAQS in a time bound manner first and then should have a timeline to move towards the WHO guidelines. Tentative percent reduction targets over the next 5 years are insufficient without a longer term timeline to achieve breathable air quality and attain the health benefits of reducing pollution levels below NAAQS and WHO standards. Minor reductions from current hazardous levels might not be able us achieve great health benefits because concentrations even as low as 10 µg/m3 for PM10 and 6 µg/m3 for PM2.5 impacts human health .
5. There should be interim milestones/targets for half yearly and annual progress tracking so that we don’t just take stock of the progress in 2024 and will not be in a position to do anything if air pollution levels are not falling as required. Absence of interim targets/milestones has led to non-compliance of emission standards for coal based power plants where they have already missed two deadlines given to them over past four years, we should learn from those failures.
6. To achieve the air quality goals, much stronger sectoral policies and targets will be needed on the national and state level. Pollution across the country originates from the same key sectors – industry and power plants, household fuels, waste burning, crop burning and transport – with variance in proportions. Furthermore, much of the pollution levels in the identified non-attainment cities originates from outside the city limits. The obvious question which arises is, “What is the use of conducting 102 source apportionment studies for non-attainment cities if there are no sectoral targets and policies for emission reductions?”
7. With regard to sectoral targets, the NCAP has not incorporated any learning from the New Delhi experience: having conducted various recent source apportionment studies, Delhi had the basis to include sectoral pollution/emission reduction targets as well as very specific pollution reduction targets.
The Government must prioritise transparency, accountability and stringency in the actions proposed under NCAP while strengthening it over the next few months. Inclusion of legal provisions and sectoral targets is key to implementation and effectiveness of air pollution reduction plans. NCAP should be treated as a dynamic document that can be improved into a stronger instrument to achieve the dream of blue skies and clean air across India.

People’s Initiative

Public participation is critical in the fight against air pollution. Making our voices heard in the corridors of power, letting our leaders know that the status quo is unacceptable and that we as a nation want clean air as this is essential to achieving progress and healthy lives. The devastating toll that air pollution is taking on the quality of life of just about every section of society, but in particular children and the elderly ensures that inaction is not an option.
The right to clean air is in fact the right to life and political parties and governments must be queried on their plans to deliver clean air for India. In addition, our own choices for electricity and transportation and our advocacy for clean options on these fronts will play a major role in managing pollution levels in many parts of the country:
1. Supporting rooftop solar and other forms of decentralised renewable energy solutions that reduce the demand for coal-based electricity.
2. Increased usage of public transport, cycling and walking.
3. Using energy efficient appliances and reducing household energy usage.
4. Waste minimisation, segregation and recycling, which will reduce burning of waste in streets as well as at landfills, along with energy reductions and saving in transporting huge quantities of waste.
5. Most importantly, the citizens while making sure their lifestyle and activities move towards minimum pollution footprint, should make sure that they unite and demand their right to breathe clean air.
6. As most citizens live in areas where air pollution is a severe threat to personal health, using and promoting the use of personal protection measures – air purifiers and certified face masks (N95 or FFP2 standard) helps reduce damage to personal health, while increasing the visibility and recognition of the issue.

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