New draft India Cooling Action Plan (ICAP), released recently by Union environment ministry, is grossly inadequate in its scope and ambition – says CSE

New Delhi, September 18, 2018: Responding to the draft India Cooling Action Plan (ICAP) released by the Union environment ministry to mark the 24th World Ozone Day on October 17, 2018, Centre for Science and Environment (CSE) has issued a statement dismissing the ICAP as “grossly inadequate and limited in its scope and ambition”. 

The ICAPprovides a 20-year perspective (2017-18 to 2037-38) to address the cooling requirements across sectors and ways and means to provide access to sustainable cooling for all. 

While the ICAP aims to provide sustainable cooling and thermal comfort for all, its actual intent is myopically focused on only the market for personal air conditioners, ignoring the fact that demand for cooling is driven by people and not by sale of air conditioners, say CSE analysts. “If we are planning to provide ‘Sustainable Cooling’ and ‘Thermal Comfort for All’, we cannot ignore 90 per cent of the Indian population’s need to have thermal comfort, "says Anumita Roychowdhury, executive director-research and advocacy, CSE. 

“This lack of planning can completely upset the energy budget of the country. At the same time,the ICAP has not indicated the benchmark for thermal comfort that needs to guide energy efficiency measures for all – users of active as well as passive cooling,” adds Roychowdhury.

CSE’s comments on the draft report of the national cooling action plan 

ICAP must capture equity issue, ensure thermal comfort for all without over dependence on active cooling: Cooling is an equity issue, and also a sustainability issue as large part of energy requirement is for cooling. ICAP must take note of the fact that about 60 per cent of current space cooling energy consumption is by top 10 per cent of the population.Over 96 per cent of transport cooling energy consumption is due to personal cars (13.5 per cent of population).This small minority skews electricity demand and locks in enormous carbon energy guzzling. In Delhi, 25-30 per cent of annual energy consumption is because of thermal stress; in peak summer, when energy demand soars, it is as much as 50 per cent of energy consumption. When temperature drops, energy consumption in the city drops dramatically – from 6,346 MW to 3,323 MW (10 degree C drop leads to 48 per cent demand drop in energy, irrespective of the time of day). This points to the importance of cooling and heating in energy management. 

While the ICAP will have to ensure significant improvement in energy efficiency measures, it will also have to ensure energy sufficiency by reducing dependence on air conditioners. At the same time, it will require to improve thermal comfort for the majority who are still not using active cooling but need other architectural design and material interventions to provide comfort to all. 

India needs thermal comfort defined to guide interventions for energy efficiency in buildings. While “Thermal Comfort for All”requires action to improve thermal comfort conditions of poor as well as reduce energy guzzling by the rich, all interventions need guidance on benchmark for thermal comfort in different climatic zones of India. This is influenced by ambient temperature, humidity, air flow etc. A predefined comfort range can help to guide action on both active and passive cooling of buildings. BIS has defined a temperature range of 26-30oC in which people are expected to feel comfortable.  At the same time different default temperature range is indicated by different agencies for active cooling or ACs -- it is 20oC for popular AC setting; 24oC proposed by the power ministry default thermostat setting advisory; 27oC is suggested by BIS standard indoor temperature for AC testing;and 30oC by NBC comfort limit for naturally ventilated building etc. This demands more policy clarity today to guide action on passive and active cooling operations with targeted comfort level. The ICAP will have to address that.  

Need to estimate cooling demand based on thermal comfort definition and not on sales of ACs. CSE’s Delhi study found the city doesn’t start using active cooling unless the outdoor thermal conditions donot cross 31-32oC heat index.Since cooling is energy intensive optimum balance between thermal comfort and energy efficiency need to be established. This report fails to do so. Based on CSE study and international examples (Japan, China, California and Australia) it is recommended to adopt a national thermal comfort goal. China and California have a policy that the settings for air conditioners in summer be no lower than 26°C and promotes a high-level of awareness with respect to the potential for reducing energy demand through measures that focus on lifestyle changes. Japan has set 28°C as indoor temperature set-point under its “Cool Biz” campaign. This is needed as there is enormous energy penalty associated with excessive cooling with ACs – in fact upto 6 per cent additional electricity use with one degree drop.  

National building codes should be amended to ensure all buildings are designed in a way that indoor conditions donot get hotter than the national goal for majority of hours in the year using passive design:Active refrigerant-based cooling should not be employed unless outdoor conditions make it impossible to keep indoor temperature below the comfort limit. This means housing of the poor needs to be improved to meet the national thermal comfort for all target, while housing of rich has to adapt to non-freezing temperatures. For example, if the Indoor temperature standard is set at 28+2 o C, it doesn’t mean indoor thermal conditions are 28+2 o C. Operational temperature can be lower with better air velocity and reduced radiant heat from walls and windows. As these parameters can’t be controlled as part of building regulation, building operators can play around with these to meet comfort expectations. There is a national need to curtain unhealthy and climate-insensitive addiction to “wow” temperatures that can only be provided using refrigerant-based cooling. 

Need more robust standards, labelling and testing methodology for ACs:This isneeded for ensuring a level playing field for other equally viable technologies – non-refrigerant based technologies. For instance, we find that current ISEER labelling is (inadvertently) pushing for 3 star over 5 star, because it making them look uneconomical and at the same showing that 3 star is not a high charge on your energy bill. There is no system to promote other technologies, including advanced air coolers and heat exchange systems. Need mandatory energy audit and monitoring of buildings. Institute mandatory disclosure of energy consumption of operational buildings to facilitate peer-comparison (EPI) and similar strategies to influence behaviour and curb guzzling. 

ICAP needs immediate overhaul. Summer is getting increasingly hotter in India. According to IMD Heat Index (averaged over the country) is increasing during summer (March-May) and monsoon (June-September) seasons at the rate of +0.56°C/decade and +0.32°C/decade respectively. This is made worse by the urban heat island phenomenon due to increased concretization of our cities and heat-rejects from anthropogenic activities (ACs in buildings, exhausts from vehicles, etc.). According to National Crime Records Bureau a total of 1,688 deaths due to causes attributable to forces of nature were reported in these 53 mega cities during 2015. Among specified causes of accidents due to forces of nature in 53 cities, maximum deaths were reported due to ‘Heat/Sun Stroke’, accounting for 12.8 per cent of total such accidental deaths during 2015. All deaths in Hyderabad, 88.5 per cent deaths in Vijayawada and 58.8 per cent deaths in Ahmedabad were due to ‘Heat/Sun Stroke’. At national level ‘Heat/Sun Stroke’ is the second biggest natural cause for accidental deaths after ‘lightning’, with 18.2 per cent of deaths. 

Also, very recently, the UN in its report “Chilling Prospects: Providing Sustainable Cooling for All” has recognisedthe existence of “Cooling Access Gap” in the world. It says that this gap is considered to comprise:i) those who simply do not have appropriate access to cooling now or in the near future and cannot reap the many socioeconomic, health, and environmental benefits of such access, as well as ii) those who are expected to gain access to cooling in the next decade(s), however are unlikely to have access to sustainable, efficient, and affordable cooling solutions under a business-as-usual development path.ICAP completely fails to address the first category and only partially addresses the second.


CSE strongly urges immediate revision of the ICAP document to address the serious gaps that if not rectified now can lock in irreversible energy guzzling. 

For more on this, please contact Parul Tewari, / 9891838367.