Perspectives from ISB

Introduction

The fact that severe air pollution in India shortens average Indian life expectance by 6.3 years is no longer a surprise, but that this silent pandemic is still very much ill-managed, sure is. The persistence of air pollution in New Delhi and many cities in northern India is not a new phenomenon. The rapid industrialisation in late 90s, burgeoning middle class with high disposable incomes and rising vehicular population, increasing construction work, crop burning in winter months, and the Himalayan mountain range barrier are the many factors accentuating this problem. These ingredients have paved the path for an unsettling way of life – 99.3% of India’s population breathes air that exceeds the safe quality limits set by the WHO.

Assessing the Current Policy Landscape

The National Clean Air Programme (NCAP) was launched in 2019 by the Ministry of Environment, Forest and Climate Change with the intent to attain 20%-30% reduction in concentrations of PM10 (particulate matter of diameter between 10 and 2.5 micrometer) and PM2.5 (particulate matter of diameter 2.5 micrometer or less) by 2024.For all its good intentions, the programme has met with limited success. From under-utilisation of allocated funds to inconsistent performance metrics across the identified cities to poor enforcement by officials, NCAP continues to be a mere plan on paper – well laid out, but ineffective.  

Examples from Asian Neighbourhood

India may be doing a few things wrong but is there any scope to turn things around? The case of Beijing may offer a solution–one of China’s most polluted cities untill 2021, Beijing adopted an aggressive strategy to enforce the use of electric vehicles and public transport. It also introduced “Low Emission Zones” which limit access to polluting-vehicles and are open only to cleaner, emission-compliant transportation.In yet another move to incentivise private sector, China promotes commercial bank investments in clean energy in return for investment subsidies, enabling the government to meet its green financing targets.It is a smart concoction of Keynesian and Classical theories of economics to solve for an externality. Seoul is yet another case in point– it managed to reduce its PM2.5 concentration levels for three consecutive years from 2019 to 2022. The Korean government constantly revises its Clean Air Conservation Act (with the most recent revision in December 2022) to monitor emissions. Not only did it strengthen its legal framework for clean air but also drove on-ground implementation through renovating its coal-powered plants as natural-gas plants and mandating installation of eco-friendly boilers in households.Not surprisingly, the gains in health outcomes were significant as per a study published on Science Direct–an 8% decrease in cardiovascular mortality rates and 10% decrease in cerebrovascular mortality rates compared to the baseline period.

Lessons for India

For starters, India could begin with an obvious one–amend the Air (Prevention and Control of Pollution) Act introduced in 1981 and revised in 1987, it has not undergone any modifications in the last 38 years. This law should be amended to include modern sources of pollution such as vehicles, dust, stubble burning and landfills. A strong legal framework is one that is also updated regularly with a strong default detection mechanism in place. Heavy penalties make sense only if the probability of detection is high. While the Air (Prevention and Control of Pollution) Act gave sweeping powers to state and the central government, it has not been enforced effectively in several decades. For instance, the Central Pollution Control Board (CPCB), the organisation entrusted with the powers of the Air Pollution Act, has mandated the use of air quality sensors in construction and demolition sites. However, as per a Times of India report, ~50% of such sites in Delhi have not installed these sensors. This raises an important question–do legislative powers necessarily translate to enforceability? Implementers often cite limited resource availability as a factor. In the absence of enough manpower for the activities relating to enforcement, citizen participation is critical. The use of advocacy through schools, workplaces and social media can be effective in  instilling a personal motivation in citizens to seek clean air as a right. Such reinforcement creates a positive socio-cultural norm, a pro-climate attitude which in turn incentivises high accountability on part of the government.

Secondly, NCAP suffers from the problem of many–many sources of funding (albeit underutilised) and subsequently, many parameters of measuring performance. Standardising these metrics would make gaps easy to measure and implementation easier to track. The use of economic subsidies like a cap-and-trade system that would incentivise the use of cleaner energy does not figure prominently in India. This system would set a cap on emissions, allowing firms to buy and sell permits to stay below the threshold. Such a system (“Emissions Trading Scheme”) was implemented in Gujarat in 2019 – initial lessons estimate a reduction in PM emissions by 24%.The central government should consider expanding this model across other industrialised cities. As per the International Institute for Sustainable Development, India’s financial support for fossil fuels dwarfed that of renewables in 2021, with the former receiving nine times more subsidies than its cleaner counterparts. A re-evalution of this subsidy gap will be a definite ‘incentive’ push for firms looking to invest in cleaner energy.

The more complex issue of crop burning needs stakeholder involvement and operational investments to diagnose and solve for. Stubble burning is a practice adopted by farmers to remove excess crop residue from fields. This process releases harmful pollutants (methane, sulfur oxides, PM2.5, PM10 etc.) that are not just localised but also transcend state boundaries. Burning is deemed necessary by farmers because it is cost-effective, and works for the tight time window before the sowing season begins. The government’s ‘Happy Seeder’ initiative, a machinery which sows seeds while simultaneously removing residue does not seem to have generated enough interest. Farmers cite its complex nature, lack of adequate training and the rental model-led delays as key issues. If burning crop residue is a quick, cheap fix for farmers, the government can only tackle this by offering free access to machinery—an otherwise costly investment for them. This programme should be strengthened through training workshops, increased manufacturing of machinery and governmental subsidies to promote its usage.

On the face of it, many of these ideas may appear costly but now is a good time to remind ourselves that much of the clean air funds remain unutilised and poorly targeted. Thus, there is significant scope for appropriate re-direction.

Way Forward

For a menace that cost ~1.67M lives in 2017 and routinely devastates public health in India, the Ministry of Health and Family Welfare’s role in implementing NCAP is strikingly minimal. A number of research studies have been conducted to quantify the health impact of air pollution. These findings are very meaningful in creating a feedback loop for the design of NCAP. The Ministry of Health can play a big role in presenting these results for technical and non-technical audiences, i.e., scientists, doctors, public department officials, policymakers, and urban planners.

The authors Roberts et al., in ‘Getting Health Reform Right’, a landmark health reform manual, state – “…all policy reform is a profoundly political process”. There is no reason why this should not apply to India. Each year, from November through February, Indian citizens drown in toxic fumes across most cities. However, much like an undervalued public good, there is limited political will to invest in cleaner air because the public health benefits are not immediately ‘felt’ or ‘seen’. A reactive approach to air pollution means regressing into a climate-amnesia where the harmful effects fade into a mere footnote from March through October. Therefore, the need of the hour is a clear political agenda-setting at the start of each fiscal year, with policy packages (like some of the ones stated above), built-in accountability frameworks and consistent stakeholder participation round the year. If air pollution knows no borders, why should our solutions? It’s time for a full-scale, multi-sectoral response that is not just creative but also forward looking.

Author’s Bio: Smitha is pursuing Masters of Public Health at Harvard T.H. Chan School of Public Health, with a focus on health policy. She also holds an MBA from the Indian Institute of Management, Indore, and is trained in Economics. Smitha is passionate about policy design to strengthen health systems and programme implementation that can improve care outcomes in low- and middle-income countries.

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