Submission to the Draft National Clean Air Programme policy (NCAP)

Links below, last date of submission is 17th May, 2018. Email at [email protected]

• Acknowledging role of ‘development’– The fundamental point which remains unaddressed is that India‘s economy is copying a Western model advocating greater consumption. This is best evident through the recent news of Pune where there are now more vehicles than residents living in the city! While this surely would have contributed to higher GDP, the impact this would have on increasing air pollution can be easily understood. True development must be understood to be a reduction of wants and greed. Unless the crux of this is addressed, such policy documents as we have for the current policy would at best only bring about half-hearted measures.
• Local Language Translation for NCAP – NCAP must be made available in local languages, published in local newspapers/magazines, be communicated through government media and must actively reach the population which does not have access to internet through means of public consultation. Sadly more than 70 years after independence such documents only reach a small section of Indian citizens and does not take into account the views of most of the people at the ground.
• No Emission Reduction Targets– The draft concept note for NCAP released in March, listed targets to reduce 35 % pollution levels in the next 3 years and 50 % pollution levels in the next 5 years. Whilst it was expected that these targets would be elaborated more in the final document to include sector-specific emission reduction targets, even these overall targets have been removed from the final policy document. Not only overall emission reduction targets but sector specific reduction targets must be set and monitored too.
• Role of Agriculture –
  1. Measures to tackle stubble burningmust have a higher focus on promoting usage of stubble as cattle feed, mulch for soil and manure. The focus of the document is more of a punishment-driven (Annexure IV – Page 47) approach on stubble burning rather than bringing in awareness and promoting alternative measures to stubble burning as listed above. Such measures must be primarily implemented by involving farmers rather than forcing/penalizing them. A recent article also points delay in rice-sowing pattern from April to June as pushed by Haryana and Punjab government as additional reasons for the recent increase in pollution due to stubble burning as well. https://www.sundayguardianlive.com/news/12191-law-aiding-monsanto-reason-delhi-s-annual-smoke-season These must be looked in on holistically too.
  2. Whilst role of agriculture in air pollution in the document has primarily focused on stubble burning (See Section 5.4.2 – Page 5, 7.1.1 (iv) – Page 9), the role of increased atmospheric ammoniabecause of agriculture has not been addressed. Data from NASA research published in 2017 discovered increased ammonia concentrations from 2002 to 2016 over agricultural centres in India and other countries. Some of the key factors in increased atmospheric ammonia are fertilizer usage (and the subsidies provided for it), reduction of excess nitrogen in animal diets and recycle of manure in crop systems. An overall push towards organic farming would help in tackling these measures too.
  3. Role of pesticides in pollution (has only been very briefly touched on in 7.1.1 (iv) – Page 9) and death of people due to their inhalation has not been mentioned anywhere and needs to be tackled too. Recent cases in Maharashtra (2 detailed reports available http://indiaforsafefood.in/wp-content/uploads/2016/09/pesticidepoisoning-yavatmal-FFT-report-oct12-2017.pdfand http://www.pan-india.org/wp-content/uploads/2017/10/Yavatmal-Report_PAN-India_Oct-2017_web.pdf) and Tamil Nadu (full report available here http://www.kisanswaraj.in/wp-content/uploads/TN-fact-finding-report-pesticide-poisonings-for-print.pdf) where more than 50 people lost their lives must serve as a strong reminder for the same. Detailed suggestions and measures have been mentioned in these reports which must be incorporated as well.
• Economic Principles –
  1. Polluter Pays – Themes such as polluter pays which are amongst the most fundamental principles in tackling pollution around the world find no mention in the document. Without their being a clear and consistent articulation for the need for polluter to pay for the cost of cleaning up, a critical element of the policy will be left out. Infact, there are rising cases across the world of people holding their governments and corporations accountable (in courts and otherwise) for health damage caused due to polluted air by taking them to courts. Such mechanisms and frameworks must be built and strengthened in India too.
  2. Tackling fossil fuel subsidies– Research shows that India provided subsidies to the tune of Rs 1.24 lakh crore (http://www.iisd.org/sites/default/files/publications/india-energy-transition.pdf) was provided in just 2016 to oil & gas, coal and electricity transmission/distribution. This need to be reduced rapidly so as to ensure fossil usage of fuel based resources which contribute massively to air pollution is tackled. The draft report fails to address this critical issue.
  3. Internalizing externalized costs– Often the costs of polluted air are often left to be borne by those who have had no or very little role in pollution of the air itself. A lot of citizens pay for this with increased healthcare costs and bad health overall. There is a significant need to internalize these externalized costs borne by the wider society so that true cost of pollution is tackled holistically. This is missing in the policy document, once this is done – measures to internalize the externalized costs such as higher taxes on the polluting sources amongst others need to be implemented as well.
  4. Extended Producer Responsibility – In addition, the producer of the goods must have the responsibility of managing the goods which cause such pollution at the end of their lifecycle.
  5. Change in Transport Pricing –Transport pricing must fundamentally be changed to strongly incorporate pollution which has currently been externalised. For instance, railway transport in recent years has been getting more expensive whereas air transport has been getting more cheaper. However air transport results in a higher cost to air quality by means of carbon emission resulting in much higher air pollution per passenger whereas pollution caused in rail transport per passenger is much lower. Consequently the pricing of these means as an example must follow their comparative environmental footprint as well.
• Forests–
  7. Focus on conserving older trees, preventing deforestation –Whilst the document talks about tree plantation drive (Section 7.1.8-Page 12), it fails to mention that older trees have a much higher potential for cleaning air than planting new saplings which could take decades to come anywhere closer to have a similar impact on cleaning air as the older trees. Not only that but diverse forests have been found to have a much wider potential for cleaning polluted air than randomly planted trees.  The air policy must have a strong focus on preventing deforestation and diverting forests for ‘development’ related activities.
  8. Concretization– Urban trees and forests are much threatened by increasing concretization, which needs to be addressed and balanced so that they can continue to play their role in cleaning air too.
• Healthcare – Recourse to good-quality medical facilities for people suffering from air pollution related diseases must be made available for free especially for the economically weaker sections. The country’s health ministry must be involved in this to plan for means to ensure that the economically weaker sections do not have to pay for the polluted air by means of their health and expenses to treat it. This has again not been addressed in the document.
• Eco-friendly architecture – Underthe section ‘Indoor Air Pollution Monitoring & Management’ (Section 7.1.3 -Page 62) a stronger focus on environment friendly housing design must be kept as well. Materials used predominantly in the construction/housing industry today including cement, paints contribute hugely to indoor pollution. Research shows that houses made of eco-friendly materials including mud, bamboo etc which  are coincidentally also showing a rising demand in Western countries are much more eco-friendly. More awareness and promotion of such eco-friendly technologies must be done too. There is also a need to tackle synthetic paints which further cause greater indoor air pollution too.
• Vehicles –
  1. Reduction of private transport in cities– the document fails to even mention the need to tackle the massively increasing private transport in Indian cities. More than 3,500 vehicles are registered daily in Bengaluru. Unless the need for such measures is identified, addressing urban pollution cannot be addressed completely. Further, important mechanisms such as implementing congestion charge which have worked very well in reducing private transport and helping build public transport such as cities in London are missing in the document as well
  2. Building Public Transport –
     1. Reduced Ridership in Public Transport– While the report pats government on the back for measures to build public transport network (Section 1.5 – Page 2), it fails to even acknowledge the reduced ridership recently in Delhi for metro and bus because of the multiple increased fare hikes in the former and reduced services on the latter. If this is the condition of public transport in the capital of the country, the issues plaguing public transport in rest of the country can very well be imagined. Unless we can ensure that public transport is truly within the reach of the common man, it will not be fair to refer to it as ‘public’.
     2. Separate Lanes –While the results of the half-hearted experiments for dedicated bus lanes are still being witnessed in different parts of the country, there is a larger need for such separate lanes for buses, cyclists to be introduced throughout the country. At the least more such projects must be piloted throughout the country with lessons used to improve their implementation. This fails to find any mention in the document as well.

• Miscellaneous–
  1. Acid Rain, Eutrophication – Key impacts of polluted air such as acid rain, eutrophication (due to nitrogen pollution) are not even addressed in the document leave aside addressing it.

Cadmium Pollution – In addition to other pollutants, cadmium air pollution must be tracked and measured too. This is measured in Europe too but not mentioned in the NCAP document.