Take the recommendations of experts and citizens into consideration for a robust NCAP

In December 2017, the Ministry of Environment, Forests and Climate Change (MOEFCC) announced the National Clean Air Programme (NCAP) in the Rajya Sabha. A broad national level strategy, the aim of the NCAP is to tackle rising air pollution levels across the country. In March, the ministry told the Supreme Court that the initiatives proposed in the NCAP would be finalised within four weeks.

After the deadline passed, the ministry released the NCAP draft concept note on their website, which lists the various governmental initiatives planned. You can find the note here - http://www.moef.gov.in/sites/default/files/NCAP%20with%20annex-ilovepdf-compressed.pdf

However, the concept note has some glaring gaps -- there's no clarity sectoral targets, no interim deadlines for implementation of the objectives and no mention of community-based monitoring initiatives.

We have until May 17 to tell the union environment ministry to come up with an inclusive, robust NCAP. Sign this petition to send your recommendations.

Sources:
http://www.moef.gov.in/sites/default/files/NCAP%20with%20annex-ilovepdf-compressed.pdf
http://www.business-standard.com/article/pti-stories/national-clean-air-programme-to-be-finalised-within-four-weeks-govt-to-sc-118030801000_1.html
https://timesofindia.indiatimes.com/home/environment/concept-note-on-national-clean-air-plan-lacks-source-wise-emission-reduction-strategy-say-activists/articleshow/63280693.cms

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Email 

Subject : Stakeholder comments on National Clean Air Programme

Dear Dr Shruti Rai,

The Ministry of Environment, Forest and Climate change (MOEF&CC) released a draft policy on the National Clean Air Programme (NCAP) on Tuesday, April 17. (http://www.moef.gov.in/sites/default/files/NCAP%20with%20annex-ilovepdf-compressed.pdf) 

Kindly find below the comments from various stakeholders like CSOs, farmers representatives, citizen groups and academics on draft NCAP below. 

We hope the government would take these into consideration and strengthen NCAP to ensure that the air pollution problem is addressed in a time bound manner.  

Here are the comments: 

1. The draft NCAP  clearly misses the discussions held within the ministry about making the programme time bound and having specific targets, i.e., in October 2017 page 31 of the file notings on NCAP has the following “....Kindly refer note pre-page 5-9/N regarding approval of Concept Note and outline for National Clean Air Programme (NCAP) targeting to reduce 35% pollution within next 3 years and 50% of pollution level in next 5 years. Hon’ble MOEF&CC has noted at 9/N that Ministry may initiate everything aggressively after the parliament session is over..” 

The same was also mentioned by the honorable minister Dr Dr. Harsh Vardhan in a public forum back in february - https://economictimes.indiatimes.com/news/politics-and-nation/hope-to-cut-air-pollution-in-100-cities-by-50-in-next-5-yrs-harsh-vardhan/articleshow/62904958.cms

NCAP without such targets is a meaningless document which cannot result in affective absolute pollution levels reductions. Hence we recommend that MOEF&CC should incorporate the 35% reduction in three years and 50%  reduction in five years as targets to make NCAP effective. 

2. The draft NCAP is only in one language (English) does not allow the impacted population to be part of the process for even commenting on the draft, it should have been made available in other regional languages as well at-least in those languages which are widely spoken by the community mostly impacted by hazardous pollution levels. Hence we recommend that MoEFCC translate NCAP into regional languages and extend the deadline for public consultation by at least one more month.  

3. Draft NCAP has ignored polluting sectors like industry and coal thermal power plants, which are regulated by the central government. Given the regional nature of the problem and the fact that pollution is not restricted only within cities. Highly polluting industries and industrial clusters should be regulated under NCAP with clear timelines and targets for implementation. 

4. NCAP needs to have clear interim milestones for all the activities it's proposing even under section 7.2 giving budgets and timelines. Milestones are crucial for evaluating the success of NCAP and the same interim milestones should also be extended to sectors like industry and power plants.

5. NCAP seems to be outsourcing all implementation and budgetary responsibility to the states. This could lead to in-action because of the lack of capacities of state PCB. To ensure uniformity among states on quality action plans and to ensure that inter state issues are addressed to tackle issues regionally. The central government should play  a more involved role in capacity building states and significantly increase budgetary allocations to states for implementation 

6. Draft NCAP misses out on including high polluted cities like Patna, Gaya and Muzaffarpur in the list of polluted cities even though they made to the list of top most 20 polluted cities in world according to recent WHO report. Hence there needs to be a relook at the process of selection of cities

7. The programme lacks sector specific plans for emission caps (Coal Consumption for Power Generation and Industries; Vehicular emission load and registration etc.) and emission reduction targets similar to what European Union uses to ensure progress in all Member States, and what China had when they started cleaning the air in 2012 through Emission standards for power plants and Action Plan in 2013 for reducing Air pollution levels by 2017. To ensure that air pollution levels come down and remain low in the long term cumulative carrying capacity of regions should be assessed before expanding internal combustion vehicles, industries and power plants in the future

8. The number of cities covered under NCAP is limited to 100 nonattainment cities based on data available from NAMP stations between 2011-2015, but 2015/2016 data published by Greenpeace India in their latest report “Airpocalypse-II” in January 2018, suggests that at-least 228 cities out of 280 (for which they were able to collect data out of total approximately 300 cities covered under NAMP now ) were above the Indian annual PM10 standard of 60 µg/m3 and should be classified as non-attainment. Furthermore, satellite-based estimates convey on even more worrying picture, with almost the entire country under hazardous pollution levels. So the coverage of NCAP should not just be limited to the list of 100 cities as mentioned in the concept note and should be extended to other polluted geographies as well.

9. “Road Widening and supporting development of such infrastructure (flyovers) within cities” as suggested under the letters issued to SPCBs/PCCs in 2015 and 2016 are likely to result in an increase in emissions, as they promote private ownership and use of vehicles. To decongest the traffic more emphasis must be given on promoting/strengthening the Non-Motorised Transport (NMT) and public transportation, which are long term sustainable solutions.

10. NCAP fails to highlight the need for controlling the unsustainably increasing private transport in Indian cities. Important mechanisms such as implementing congestion charge which have worked very well in reducing private transport and helping build public transport in cities such as London are missing from NCAP. Many countries across the world are moving on banning diesel vehicles due to pollution and health impacts arising from them, India should learn from them and adopt similar approaches.

11. NCAP should have more emphasis on Electric vehicles/Buses etc. Along with parallel infrastructure development to make sure that these electric vehicles are charged with electricity from renewable sources to bring reduction in emissions and air pollution.

12. It is not clear how NCAP overlaps with other laws and plans that govern the cities and sectors. It has no mention of the emission norms set for power sectors and industries, likewise does not talk about integrating with city levels plans like the master plan and municipal solid waste rules etc. hence there should be better integration at all levels.

13. As expansion of industrial capacity and thermal power plant capacity are one of the key drivers of India’s air pollutant emissions growth, approvals of new industrial capacity should take into account the current air pollutant levels and cumulative impacts from already approved and planned new sources in polluted regions and specifically across the entire Indo-Gangetic plain.

14. NCAP must have holistic approach to tackle the issue of stubble management Currently the approach is isolated. Clear infrastructure management for “in-situ crop residue management” should be incorporated in NCAP.

15. A comprehensive waste minimization and segregation policy should be integrated with NCAP to control air pollution.

16. For participatory approach under NCAP we must have a comprehensive structure for people to participate in planning, execution, implementation and monitoring of the progress under NCAP.

17. Emergency response action plans such as GRAP should be strengthened to be more effective by covering all sources of pollution comprehensively and systematically, precautionary rather than being reactionary (in current version) by being based on forecast. Along with implementing it across all polluted cities and regions in the country not not just keeping it limited to Delhi-NCR, So that advisories to industries and public can be issued in emergency situations.

Comments on the issues directly addressed in the Concept Note on National Clean Air Programme:

7.1.1 Augmenting Air Quality Monitoring Network:

A.    While adding approximately 300 more manual air quality monitoring stations in cities and 50  in rural areas along with PM2.5 monitoring facilities is a good step but the specificities on how that data will be shared with minimum time delay, systematically and in an easily accessible way with public and at-least state wise allocation of these stations to be introduced needs to be specified.

B.    Increasing the number of CAAQMS from 101 to 310 (210+100) in next two years is a good initiative but the number of CAAQMS should be much more (beyond just 310) even beyond city boundaries, just having 1 monitoring station in a city or only having 100 cities having 2 or more CAAQMS is not going to help build a proper advisory network (out of which Delhi alone has more than 35 CAAQMS).

C. One station each city in the 10 city Super Network would not be able to give the representative air quality of the area, So a more comprehensive and systematic approach is required to set-up such networks which are envisaged to represent national air quality dynamics.

D. The mention of identification and development of alternative cost effective technology for sources and ambient air quality monitoring is a good step but special emphasis on community air quality monitoring and role of low cost air quality monitoring devices should be added so that the reach of data on air quality can penetrate to larger sections of the society.

E. Data from Continuous Emission Monitoring System (CEMS) and ambient air quality monitoring stations installed in vicinity of the industrial plants and facilities is not available in public domain (specifically for 17 red category industries). Making already generated data on emissions and air quality available is of essence for effective air quality management. The NCAP needs to strengthen monitoring of major industrial emissions sources. Emissions and air quality data from these sources should be integrated with manual and real time data sharing portals, websites and apps, so that common people can have access and understanding of the pollution sources around in larger geographies and localities around them (industrial clusters, including in rural areas).

F. Mobile air quality monitoring units such as Mobile vans and drones should also be used to have a wider coverage of air quality data monitoring.

7.1.2 Air Quality Management Plan for 100 Non-Attainment Cities and 7.1.17 Extending the source apportionment studies to all non-attainment cities:

A. The formulation of Air Quality Management Plan for 100 cities is a great step but there seems to be confusion in terms of timelines and process through which they would be prepared. Ideally such plans are either generic based on large polluting sectors for regions or are based on specific source-apportionment studies. The timeline for making the plans is 1 year and for source apportionment studies to be completed is 2 years, which causes confusion without mentioning how do we intend to use source apportionment once we already have the management plans.

B. Also, the schedule of initiation and completion of all 100 source apportionment studies within 2 years should be provided along with interim timelines.

C. In order for the source apportionment studies to be useful, it is crucial to create unified guidelines for the sampling, analysis, emission inventory and atmospheric modeling methodologies to be used, as well as unified source categories.

7.1.4 Air Pollution Health Impact Studies:

A. The already conducted studies by CPCB on Air Pollution and Health Impacts in collaboration with Chitranjan National Cancer Institute, Kolkata clearly establishes the linkages along with Report of the Steering Committee on Air Pollution and Health Related Issues which highlights direct linkages between Air Pollution and Human Health, We should learn from those studies and should not discard them saying that there are no such studies done in past.

B. Health Impact study should not be restricted to questionnaire services, real and scientific health assessment based on clinical data must be in incorporated in NCAP

C. Health Impacts other than lung function need attention such as mental health, increase in cases of parkinson and alzheimer, behavioural problems such as ADHD, could be manifestation of air pollution.

D. NCAP should incorporate Data on Chronic Obstructive Pulmonary Disorder (COPD) and ensure underlying mechanism/causative effects on such disease

E. More details should be available in public domain on proposal to Study on Air Pollution (Indoor/Ambient) and health impacts in terms of funds, resources, etc.

7.1.5 Setting up Air Information Centre:

A.    Representation of Civil Society Organisations should be ensured in such centres which will be responsible for data analysis, interpretation, dissemination, issuing builtins, keeping track of international developments and bringing out policy updates.

7.1.6 Certification system for monitoring instruments:

A.    Accreditation body should also provide accreditation for low cost air quality monitoring devices.

B.    Accreditation body should ensure the regular calibration of the air quality monitoring devices and the data quality for data generated by them in collaboration with the Air Information Centre.

7.1.6 Air Quality Forecasting system:

A.    Interim milestones (timelines) with number and names of areas covered under the system should be highlighted clearly for proper accountability and monitoring the progress.

7.1.7 Extensive Plantation Drive:

A.    Apart from plantation drives NAPC should have plan to protect forest and other vegetation across the country and within the cities.

7.1.9 Issuance of Notification on Dust Management (Road dust and C&D):

A.    Strict compliance to rules under Construction and Demolition Rules, 2016

7.1.18 Review of ambient air quality standards and emission standards-

A.    While coming up with new and modified standards international best practices and emission standards for other countries/geographies should be compared and the best and most stringent standards should be adopted keep the futuristic approach and public health at priority rather than just the short term industrial interest.

B.    Formulated emission standards should also be implemented and there should be clear timelines and plans to be formulated while coming up with the standards in a transparent manner with publicly available progress and data.

7.1.19 Institutional Framework-

C.    The framework should have more division of powers and accountabilities for CPCB; SPCBs; PCCs; State Governments and District Authorities (Collectors, Magistrates or Municipal Commissioners etc.), So that people can hold them accountable for their actions and inactions and personal.

Last note in the NCAP Concept note mentions, “It is to be noted that cost for city specific action plan implementation which will entail major cost is not reflected as part of this NCAP and will have to be majorly born by the States”- therin the NCAP should provide provisions of fund availability by MOEF&CC/Central Government to the states and SPCBs so that actual actions can be taken and the actions are not left in proposed states due to absence of funds and clarity from states. A more clear outline and fund availability/help from Central Government to states for NCAP implementations should be included in final version of the NCAP.

We hope you take these into consideration. Thank you.