This was announced with great élan and machismo in a public meeting recently -- The ministry of environment and forests will take charge of the controversial pollution inventory study that is being carried out in five cities and billed to four oil companies. The top brass in the ministry are still not willing to confirm this as their final decision. More meetings are planned to help them make up their mind.
The nature of the shift in the loci of power is still not clear. Official grapevine has it that retracting from the professed intention now may only add to the embarrassment already caused by the oil industry’s entry into such a sacred precinct of air quality management.
What might have ignited this after-thought over this study? Is this to stave off criticism of the inability of our air quality regulators and scientists to generate credible data, and assess and manage the air pollution problem? Or is it a reaction against the scalding public criticism of what seemed like an abdication of the regulators’ right to assess air pollution problem to the oil industry?
This particular pollution inventory study has high stakes. As far as the government is concerned, the results of this study will be the basis of the final decision on the deadline for enforcing Euro IV standards in the country. The government so far has rejected the proposal of the Auto Fuel Policy committee of enforcing Euro IV even in 2010 (see link, below). The involvement of the refineries in the study therefore fanned considerable suspicion, given their resistance to the rapid clean up of fuels.
If the government takes control, can we hope for a more unbiased and non-partisan approach to this study and decisions thereafter? Or hope for a more mature, science-based air quality management in the country? But what seemed like a very good idea suddenly troubled! Homing in on the regulators’ concerns and discussions of late confirmed that the environment bureaucracy at the centre is more concerned about losing control to the Judiciary than to the oil industry. On the face of it yet another good sign -- that after being driven by the Judiciary for over a decade now, the government finally wants to govern!
Yet why are we concerned? There is simmering tension -- air pollution scientists are getting reproachful of the action plans of the seven cities taking shape under the aegis of the Supreme Court to control particulate pollution. They have started complaining that these action plans lack balance due to excessive stress on vehicular pollution control -- downplaying the potential of other probable city-specific local sources. So we heard a strong plea for an integrated, multi-pronged approach for controlling air pollution. This murmur of discontent had a sharp ring recently at a meeting held jointly by the World Bank and the Central Pollution Control Board (CPCB) on the occasion of the release of the latest study of the Bank on air quality trend analysis in five cities of India.
This plea from our regulators to embrace an integrated framework to address the problems crowding their agenda and competing for resources and attention impressed but did not convince. Why? CPCB has taken the lead in issuing guidelines to 16 polluted cities listed in two court orders – April 5, 2002 and August 14, 2003, for preparing action plans. It has even laid stress on such progressive steps as setting air quality targets, improving air quality monitoring programmes, developing inventories of pollution sources, and charting a roadmap for controlling air pollution.
Yet in this seemingly balanced approach, the guidelines made it conditional that automobile pollution control measures to be included in the action plan, "may necessarily align to the auto fuel policy recommendations and directions." The diehard industry folklore persists -- that the transport sector does not merit measures more aggressive than the auto fuel policy roadmap. There are other, bigger, contributors to particulate pollution! Once again signalling the status quo in the transport sector – and expecting science to provide the rationale for it – instead of making other polluting sectors catch up fast.
Targeted action against vehicles is criticised in the name of comprehensiveness. Regulators are not disturbed by the evidence that vehicles already contribute more than 40 per cent of PM10, or the fact that diesel and petrol fuels together spew as much as a quarter to more than two-thirds of the PM2.5 in some cities. They also choose to ignore the fact that despite poor data, all the seven state governments that have submitted action plans to the court have covered all sectors – transport, industry, power plants and other sources. They have even provided plans for inventory and health studies. But all of them have indicated vehicles as among the most serious and rapidly growing sources of pollution.
Clearly, the problem lies elsewhere. Despite administering the most powerful environment laws in the country, the environment bureaucracy has failed to assess and control industrial and other sources of pollution. It has not been able to ensure the enforcement of air quality standards, accountability and compliance. This demands urgent intervention to enable science-based AQM. But using this argument to insist on maintaining the status quo in the mobile source sector truly defies reason.
For over a decade now, the judicial process has shown that it is possible to act based on the existing information in all sectors, in spite of on-going efforts to improve management capacities. To overcome the dismally poor state of air quality management in cities, the committee advising the court on air pollution matters has stated in its report of January 2004, "Though air quality planning is nascent in India and pollution source inventory inadequate, the precedence set by the Supreme Court in Delhi demonstrates that action can be started immediately. Priority actions can be drawn up based on science and evidence of harmful effects of air pollution and lessons from global good practices."
Our air quality regulators have not yet grasped the policy relevance of the existing scientific information. Not yet learn the skill of using diverse scientific information for decision-making, especially when their data is so chronically poor. Quantitative estimates are not supported with risk analysis to understand the health benefits of regulations. They are hoping that the results of the inventory studies will shift the problem, rather than solve it.
Surely, if emission inventories are the foundation upon which strategies are based and prioritised, building the skills of regulators to undertake such studies is critical. But a bigger challenge lies in communicating air pollution science, risk analysis and complexities to guide policy decisions. Regulatory agencies in India rarely organise their own research and are more dependent on external agencies for scientific information. But they also do not have capacities for rigorous internal scientific review to safeguard against biases that may even overwhelm science.
We are tired of pseudo-scientific arguments. If our scientists are still too inept to generate good data, and want to dawdle till more studies are conducted to be able to act -- let them. But then stop everything else – stop registering vehicles, bar new licenses to industry. Freeze growth!
-- Anumita Roychowdhury
Right To Clean Air Campaign