CSE says India needs to adapt a regional air quality management framework

Cities alone cannot meet their clean air targets if the regional influence of the airshed cannot be tamed and minimised 

CSE releases its new global review of regulatory approaches to implement regional action 

New Delhi, September 7, 2022: On the occasion of the UN International Day of Clean Air for Blue Sky, Centre for Science and Environment (CSE) warns that air has no boundaries – because of this, clean air action plans that draw hard boundaries around cities for the clean-up job are failing to address the major pollution sources in the larger orbit.They are fighting a losing battle, even as pollution from the larger airshed continues to invade and undermine local efforts. 

This has emerged from a recent global review done by CSE, titled Managing Regional Air Quality: Need for a framework. 

Find the full review document click here

Says AnumitaRoychowdhury, executive director, research and advocacy, CSE: “The science of regional influence of pollution has begun to take shape in India. The National Clean Air Programme (NCAP) has taken on board the principle of regional air quality management. But there is no regulatory framework to enable multi-jurisdiction management for aligned action and to establish the upwind and downwind responsibilities of state governments to improve regional air quality. The deadly winter smog that wraps the entire Indo-Gangetic Plain every year is a lasting reminder of this regulatory gap.” 

India’s NCAP has recognised the idea of a regional approach and inter-state coordination. It mentions that a comprehensive regional plan needs to be formulated incorporating the inputs from the regional source apportionment studies. It has listed series of measures that will cut across multiple jurisdictions and are regional in nature. These include implementation of policies related to transport like stringent norms for fuel and vehicles, shift from road to rail/waterways, fleet modernisation, electric vehicle policies, clean fuels, bye-passes, taxation policies, etc. 

Industrial sector measures include stringent industrial standards, clean fuels, clean technology, and enforcement, and continuous monitoring. All these measures need enhanced LPG penetration and control of agricultural burning, and a regional level inter-state coordination, specifically for the Indo-GangeticPlains. But while the idea has been taken on board, the framework for a formal adoption of integrated management of airshed is not yet in place. 

Such an approach has a legal underpinning. This framework requires delineation of the region for aligned and coordinated action. This in itself is challenging, as the scientifically delineated airshed may have several administrative and political overlaps in the real world and may be an impediment to establishing a legal framework to align regional action and responsibilities within a delineated zone. 

This will require an operative framework. Says Roychowdhury: “Technically, identification of critically polluted areas is permitted within the existing provision of the Air (Prevention and Control of Pollution) Act, 1981, that can be leveraged for the purpose of air shed management. But this is currently applied with a very narrow scope to only the industrial areas/clusters. This can be expanded to cover a larger region based on the principle of airshed-based action.” 

Such a precedent has not been set at an executive level in India yet. Only the public movement, judicial intervention and the subsequent setting up of the Air Commission for the Delhi-NCR and beyond has established the principle of regional approach and integrated planning by encompassing Delhi and sub-regions of three other states in the NCR region. This is an experiment that needs to be leveraged to create a framework. 

Roychowdhury says: “This is needed to establish upwind and downwind movement of pollution and its effect and how this science can inform regional action and planning. This will also require strong science to assess and model air quality transport within a region, identify region-wide pollution sources, impact of atmospheric conditions and factors on local build-up of pollution and regional transport to understand the down-wind and up-wind character of the pollution movement among others. This science is in a very nascent stage in India though some valuable evidences have begun to emerge.” 

What are other countries doing?

CSE’s global review shows that globally, national governments have begun to develop such a framework for management of transboundary pollution within the country and between countries. India also needs its template for regional action. 

The US

• Delineation of Air Quality Control Regions under the Clean Air Act (CAA)
• The “Good Neighbour” Provision: Interstate transport provisions of the Act -- also called the “good neighbour” policy – have a provision to address interstate transport of pollutants to downwind states.
• Setting regional pollution budget
• Cross-State Air Pollution Rule (CSAPR) programme: The USEPA uses a contribution screening threshold of 1 per cent of the NAAQS to identify upwind states that may significantly contribute to downwind non-attainment and maintenance problems. States have to make an extra effort to reduce pollution from their sources.
• Regional approach to air quality monitoring network design
• Air quality management in California is a joint effort including local, state, and federal bodies. In many circumstances, meeting federal and state air quality criteria in the downwind area is a joint effort.

Europe

• Convention on Long-range Transboundary Air Pollution (LRTAP or Air Convention): The signatory parties agree to reduce emissions to the levels set based on their current exposure, available technologies, cost of implementation and economic constraints. The Gothenburg Protocol (in its 2012 amended version) established national emission ceilings for ozone precursors and fine particulate matter (PM2.5)for each country in the EMEP (European Monitoring Evaluation Programme) region.
• The Air Conventionlaid down a complex framework involving scientific, policy and compliance coordination amongst the signatory parties to mitigate transboundary air pollution.
• Transboundary air pollution monitoring: The Convention’s scientific infrastructure for unified monitoring and modelling programmes plays an important role in a scientific assessment.
• EU Air Quality Policy: Recently, the European Green Deal called for the development of a zero-pollution action plan, with one of its primary goals being to improve air quality across the EU. Legal regulation is a significant policy instrument used by the EU and its member states to achieve the operational objectives.

China

• Adopted a regional approach by delineating clusters like Jing-jin-ji (Beijing-Tianjin-Hebei region (BTH) with 28 towns including Beijing), Yangtze River Delta (south Shanghai) and the Pearl River Delta (south Guangzhou and Shenzhen) – adopting the Jing-jin-ji air pollution management framework.
• The government has identified Beijing, Tianjin, and another 26 cities in Hebei, Shanxi, Shandong, and Henan provinces (collectively referred to as “2+26” cities) as key cities along the air pollution transport channels in Beijing-Tianjin-Hebei and surrounding areas in 2017 and prioritised these cities for the purpose of air pollution control.
• Adopted regional cooperation mechanism in Beijing-Tianjin-Hebei region: In 2013, the State Council released the Jing-jin-ji and surrounding area Air Pollution Action Plan and Enforcement Regulation that mandated the Beijing-Tianjin-Hebei region to reduce its 2012 levels of PM2.5by 25 per cent by 2017. 

India needs to operationalise regional action

This review has established that the scope of India’s NCAP needs to be expanded to go beyond the city to a larger region for an airshed approach and include strategy and framework for regional air quality management. The most recent effort is the preparation of state action plans that has created an opportunity for more harmonised action across districts. 

More steps are needed to develop regional monitoring strategy, legal frameworks, operative mechanism for integrated action and alignment of responsibilities of different authorities and compliance system within the region and the federal system. This strategy is needed to meet the clean air standards. As the science has established clearly that it is not possible for any local administrative unit to meet the clean air benchmark without minimising the regional influence, airshed level control strategies become necessary to meet the clean air targets. 

KEY ACTIONS NEEDED

• Set up interstate councils to operationalise this regional framework.
• Adopt regional scale air quality monitoring strategy and assessment of regional contribution to pollution.
• Adopt method for delineation of airsheds.
• Adopt a legal framework for regional air quality managementof air quality control regions.
• Expand the scope of “critically polluted area” under the Air Act, to define the airshed zones for comprehensive action.
• Establish responsibility in state/regional plans to account for contribution to air quality in downwind regions.
• Create regulatory and institutional framework for regional air quality management.
• Establish oversight for multi-jurisdiction action in the targeted regions.
• Operationaliseshared responsibility.
• Emulate the US’s “Good Neighbour” provision in its Clean Air Act – for clean air action plans to account for upwind and downwind pollution.  

See CSE’s pre-Blue Sky day press release click here: 

For more details and interviews etc, contact Sukanya Nair of The CSE Media Resource Centre: 8816818864, sukanya.nair@cseindia.org