New CSE survey and study debunks official numbers of trucks entering Delhi

Warns this can lead to gross underestimation of pollution load from trucks and weaken action

Welcomes Supreme Court intervention based on the findings of its report and the EPCA recommendations to ask for immediate measures to cut truck pollution before winter 

  • CSE launches its winter campaign against air pollution by releasing a new study that surveyed entry of trucks through nine entry points into Delhi

  • Study finds MCD estimation of trucks entering Delhi to be 70 per cent less than actual; difference in MCD estimation and CSE study is between 50 and 96 per cent at different points

  • Amicus curiae Harish Salve has filed an application in Supreme Court for taking immediate measures to cut pollution before winter sets in

  • Large numbers of trucks, running on outdated technology, spew smoke and make Delhi polluted

  • Study finds many of these trucks pass through Delhi to avoid higher toll charges on other routes

  • Pollution compensatory charge for trucks in addition to MCD charges have been recommended

  • Other recommendations include implementation of Bharat Stage IV standards by January 2016 and use of radio-frequency Identification for tracking trucks

New Delhi, October 6, 2015: Centre for Science and Environment (CSE) released here today its new report and survey on truck entry into Delhi that adds enormous pollution to Delhi’s air. This challenges the data reported by the Municipal Corporation of Delhi (MCD). 

Speaking to the media on this occasion, CSE director general Sunita Narain said: “Without the right numbers and more varied strategies, official action to control truck pollution has remained and will remain weak and ineffective.”

CSE has welcomed the Supreme Court intervention in response to the application filed by the Amicus Curiae Harish Salve who, based on the CSE findings and the recommendations of the Environment Pollution (Prevent and Control) Authority, has sought immediate measures to control truck pollution before winter pollution sets in.

Said Anumita Roychowdhury, CSE’s executive director and head of its air pollution control campaign: “This study has become necessary as it is clear that Delhi cannot fight its pollution battle without addressing the enormous pollution contributed by the trucks crossing its borders daily. The delay in building the two expressways has cost the city dear in terms of pollution. But given the coming winter and the increase in pollution, we need to find urgent options. While immediate steps are needed to complete the two expressways –western and eastern – directed by the Supreme Court over a decade ago, it is possible to take additional steps in the short term to reduce pollution load from trucks before this winter. Delhi has now got the dubious distinction of being the most polluted city in India and perhaps even the world. This is putting a huge health burden on its people.” 

What is this study about?

CSE commissioned a detailed survey to M/s V R Techniche Consultants Pvt Ltd to accurately estimate the number of commercial vehicles entering and leaving Delhi at all key toll points. This study was conducted to get an independent estimate and also to verify the MCD data. 

The traffic count survey was conducted by using 24 x 7 video recording method at fixed spots near selected entry points between June 29 and July 18, 2015. It has counted all categories of trucks and other commercial vehicles that feature in the MCD database. These include mini light goods vehicle, light goods vehicle, two-axle trucks, three-axle trucks, four-axle trucks, five-axle trucks, six-axle trucks, and trucks with more than six-axles. The survey was done continuously for 24 hours on the days of the surveys from 8 am to 8 am and counted trucks both entering and exiting Delhi.

This survey was conducted on nine representative entry points, which according to the MCD account for close to 75 per cent of the total commercial vehicle entry into Delhi. These selected entry points include: 1. Kundli border on NH 1 (KGT Main), 2. Tikri border on NH 10, 3. Rajokri border on NH 8, 4. Badarpur border on NH 2, 5. Kalindi Kunj, 6. Ghazipur Main on NH 24 7. Ghazipur Old, 8. Shahdara border on NH 19, 9. Shahdara Flyover.

The key highlights of the findings: 

Massive numbers of commercial vehicles entering and leaving Delhi: On a daily basis, some 38,588 commercial vehicles (excluding taxis) enter Delhi only from the nine locations. If this is extrapolated to the 127 entry points, then a total of 52,146 commercial vehicles (excluding taxis) enter Delhi. The survey had measured vehicles in both directions. And while it is difficult to know if the same vehicle has entered and then left Delhi on the same day, it is clear that the total number has an imprint on Delhi’s air as these vehicles will traverse through the city. The daily average numbers of light and heavy goods vehicles that enter and exit from the nine points are 85,799. The total number of commercial light and heavy duty trucks entering and leaving the city is 115,945 each day.

The MCD estimate of the number of trucks crossing Delhi borders is grossly underestimated and is unreliable for calculating pollution load from trucks: According to MCD data, on an average only 22,628 commercial vehicles, excluding taxis, enter Delhi each day from nine entry points, as against the 38,588 commercial vehicles counted by CSE survey – almost 16,000 vehicles less. This is an underestimate of about 70 per cent in the number of trucks entering from the nine entry points. 

Thus, according to the MCD, the total number of light and heavy trucks that enter Delhi everyday from all entry points is 30,373. This is even lower than what the CSE survey counted at nine entry points. Thus, MCD data on daily average truck entry is an underestimation by an astounding 70 per cent. The gap in different entry points varies in the range of 50-96 per cent. The survey establishes that the official numbers of truck entry into the city are a gross underestimation and they end up seriously under-estimating the health impact of these vehicles in the city. 

Enormous contribution to pollution load: Delhi’s own vehicles are responsible for 62 per cent of the particulate load from the transport sector and 68 per cent of the NOx load. The total number of light and heavy trucks that enter Delhi spew close to 30 per cent of the total particulate load and 22 per cent of the total nitrogen oxide load from the transport sector. 

“This is clearly a massive loading of toxic pollution. Without any restraint on the movement of these trucks, Delhi’s battle against toxic pollution cannot be won. Though light goods vehicles are 49 per cent of all commercial vehicles, the relative contribution of heavy trucks is much higher,” said Narain.

The ambient levels of PM2.5 and NOx vary and spike according to the hourly volume of truck traffic entering Delhi: The CSE survey includes information on the time of entry of all commercial vehicles. When this movement of vehicles is correlated with pollution data, a clear trend emerges. The pollution is highest in the city during the time when there is movement of heavy and light trucks.  While trends are more variable during summer night time pollution is sharper during winter.  

There is no reliable data on commercial traffic that is not destined for Delhi. Gross underestimation by MCD: The MCD data shows that the trucks turned back, in compliance with the order of the Supreme Court, is a mere 0.3 per cent of the total traffic. In other words, even taking the MCD estimate of the numbers of light and heavy vehicles, just 90 such vehicles were not destined for Delhi and the rest 29,000 needed to do business in the city. 

On the other hand, conducting a travel destination study has a huge drawback, as drivers do not provide accurate or correct information. A rapid diagnostic survey was done in 2014 only on the roads approaching NH 1 and NH 10 entry to Delhi. Truck drivers were randomly surveyed and asked about their origin and destination, about the trip and the commodity carried. This rapid and limited survey found that around 23 per cent of all commercial vehicles travelling on NH 1 were not destined for Delhi. In the same survey, it was found 40to 60 per cent of heavy trucks (three-axle and above) were not destined for Delhi. But it is also clear that it is not possible to distinguish between such vehicles and a strategy must be designed so that all light and heavy-duty trucks are covered. 

The most shocking expose was how trucks cross through Delhi not only because it is shorter but also because it is a lot cheaper as they avoid alternative toll roads around Delhi: It has come to light that while there are some viable options available to bypass commercial traffic, these roads are not favoured by transporters. There are alternative highways that exist on the western side of the city to transport goods between north India and west and south India. This is the most important commercial traffic route.  But trucks prefer to traverse through Delhi and not take these alternative highway roads in spite of the fact that there is no apparent and real difference in length.

The key reason is the fact that it is cheaper to travel through Delhi than to take these alternative roads. The reason for this choice of route is that these roads are toll roads and charge according to rates decided by the National Highway Authority of India (NHAI). The road that cuts through Delhi has a lower charge that is based on rates decided by the Municipal Corporation of Delhi.

For instance, NH 71 and NH 71A are toll roads that connect Rewari via Jhajjar and Rohtak to Panipat. This means that commercial traffic, which is travelling from north India to west via Jaipur and then to south India could take this route. It would not need to travel through Delhi. But the toll rate for the three-axle trucks to travel on this road is Rs 1,420. If the truck travels through Delhi, it is required to pay the MCD toll, which for a three-axle truck would be Rs 450.

The length of the trip is not much different – while travelling via NH71 and NH 71A is 172 km, travelling through Delhi is marginally shorter at 163 km. It is also clear that travelling to the east of India – from north to east via Agra, there are fewer ready highways that can obviate the need to traverse through Delhi. 

“Travel through Delhi needs to be charged so that there is a clear disincentive for the use of these roads, the cost of pollution is paid for and there is an incentive for viable options to be built that do not require going through the already congested and polluted airshed of Delhi,” said Roychowdhury.

“Imposing this charge will reduce the traffic that has options not to travel through Delhi immediately. It will also create conditions for traffic that is not destined for the city, to look for alternative routes”, she added. 

CSE recommends a number of urgent steps before winter
CSE welcomes the fact that key urgent measures that can make a difference in the short term have been taken on board and recommended to the Supreme Court by Harish Salve and the EPCA. 

Implementation of a pollution compensatory charge on all light and heavy-duty trucks entering Delhi as an additional charge to the MCD toll. This should be done as a way to equalize the difference between toll roads and travel through Delhi. Taxis are being exempted as they provide options for public travel. Similarly, in category two buses should also be exempted as there is need to make this travel cheaper and viable to take away from private car travel.

There is a need to implement Radio-Frequency Identification (RFID) on trucks: The RFID scheme will enable electronic payment and to track them electronically as they pass through the tollbooths. This will help to identify non-destined trucks with greater precision and make management easier.  NHAI has directed nationwide roll out of RFID for commercial vehicles, but implementation is slow. This can be easily implemented in Delhi, as technology is available and relatively cheap to install on every truck. The contract given by MCD to the private operator includes the provision to move towards RFID, but no deadline has been given. Clearly, there is no incentive for the operator to move towards RFID, which would reduce the dealings in cash considerably. 

There is a need to introduce Bharat Stage IV emissions standards nation-wide by April 2016: Emissions levels from trucks cannot be lowered effectively if trucks continue to run on outdated technology and highly polluting fuel. The current Bharat Stage III standards that apply to trucks across the country are 15 years behind Europe. As trucks have a 15-year life, any delay in bringing in better technology or fuel, means more polluting on-road vehicles. Cleaner fuel is also required nationwide as trucks travel long distances. The current draft standards issued by the Ministry of Surface Transport and Highways require inter-state (truck) traffic to move to Bharat Stage IV only in April 2017. This delay is unacceptable. 

• For further information or interviews, please contact Vrinda Nagar, CSE Media Resource Centre, at 9654106253/

• For the Fact Sheet on the CSE study and other related documents, please visit and