The union Environment Ministry last week notified a ‘Graded Response Action Plan’ against air pollution for Delhi and the National Capital Region. The plan puts governments under the lens and holds out the promise of improvement in air quality, if followed properly. But it also faces huge challenges of implementation.
What does a ‘graded response’ to air pollution mean?
A graded response lays down stratified actions that are required to be taken as and when the concentration of pollutants, in this case particulate matter, reaches a certain level.
At the level of 100 microgrammes per cubic metre of PM 2.5, for example, mechanised sweeping and water-sprinkling along roads has to start. Traffic police personnel have to ensure smooth flow of traffic, and all pollution control measures that are already in place — such as stopping landfill fires, and enforcing Pollution Under Control (PUC) norms and a ban on firecrackers — have to be imposed strictly.
According to a Central Pollution Control Committee (CPCB) report, the average PM 2.5 level in Delhi between May 2015 and March 2016 was around 105 µg/m³.
The response will change as pollutant levels increase. In January 2016, the average PM 2.5 concentration was 211 µg/m³, with concentrations crossing 300 µg/m³ on a few days. If this level persists for more than 48 hours, an emergency will be declared, which means a return of the odd-even road rationing scheme, ban on construction activity, and no entry of trucks in Delhi unless they are carrying essential commodities.
It is in December and January that the measures will mostly be in place, as pollution levels are the highest then.
The actions under the graded response plan are cumulative in nature.
The plan was prepared by the Supreme Court-mandated Environment Pollution Control Authority (EPCA), which held meetings with stakeholders from all states over several months.
How will the system work practically?
The concentration of pollutants will be communicated to EPCA by a task force that will primarily comprise officials from the respective pollution control boards and India Meteorological Department. This will be an average for the entire city.
The job of ensuring implementation of the action plan will be EPCA’s, which will delegate the responsibility to the concerned departments. According to EPCA’s report, at least 16 agencies will have to work together to implement the various parts of the plan.
These include the municipal corporations of all NCR towns, the traffic police, police, transport departments, Delhi Metro Rail Corporation, Delhi Transport Corporation, Resident Welfare Associations, Public Works Departments and Central Public Works Department, Chief Controller of Explosives, and the Petroleum and Explosives Safety Organisation. Each body has been set a task that it will have to carry out when EPCA asks it to, based on the concentration of pollutants.
What are the challenges in implementing the plan?
A large number of agencies, from different states, will have to work together — this in itself is a huge challenge. That a coordination agency — EPCA — has been appointed is the silver lining.
Some agencies have already pointed out problems in implementing the plan. During an air quality emergency, for example, odd-even has to be imposed. The Delhi government has, however, stated that it will be very difficult to implement the scheme without a notice of at least a week, so that alternative arrangements for public transport can be made and an awareness drive launched.
The municipal corporations, which have to hike parking rates by 3-4 times if the air quality is very poor, have to hold an elaborate meeting each time they change these rates.
A system will have to be devised, experts say, to smooth out these problems. The next month is expected to see a flurry of meetings involving all concerned agencies, especially pollution control authorities and state governments.
But what was the need to devise such a complex system?
According to EPCA officials, the idea is to put in place graded response actions in a way that the emergency level is never reached. The plan focuses on taking progressively tougher actions as pollution crosses each level, without waiting to impose strict measures when the emergency situation has already been reached.
During the first week of November 2016 — post Diwali — pollution levels were so high that several actions were taken simultaneously, including stopping construction, restricting the entry of trucks into Delhi, and shutting the Badarpur power plant.
Experts say that such knee-jerk reactions will not be required if the graded plan is followed. There is also a lot of stress on the strict implementation of existing rules, such as controlling crop-burning, open burning and landfill fires, implementing PUC norms and traffic rules, stopping the spread of fly ash, and regulating brick kilns.
Has such a system been tried elsewhere?
Beijing and Paris, most notably, have implemented graded action plans over the past few years. Paris recently implemented the odd-even road rationing scheme when PM 2.5 levels crossed 95 µg/m³. It also made public transport free to encourage people to leave their vehicles at home.
Several Chinese cities have a road rationing scheme when pollution reaches severe levels. They also shut schools and industries when particulate matter levels stay higher than around 300 µg/m³ for more than two days in a row, and a Red Alert is triggered.