Is India’s National Clean Air Programme (NCAP) achieving its objectives? A new CSE assessment says there are concerns, presents an agenda for reform

NCAP must not get reduced to being just a dust control programme: CSE 

• 64 per cent of funds under NCAP and 15^th Finance Commission spent on road dust mitigation; much less allocated for controlling emissions from combustion sources such as industries, vehicles and biomass burning
• Benchmark for assessing performance of cities focused on PM10 – CSE calls for changing the focus to the more harmful PM2.5
• Mismatch between systems of assessing performance of cities – cities recording high scores for improving PM10 levels under NCAP assessment are often at the bottom rank for taking action under Swach Bharat Survekshan and vice versa
• NCAP an important national framework for air quality management and protection of public health. Has to enable massive energy transition across industry, transport and households, mobility transition to scale up integrated transport, walking and cycling, and circular economy to reduce emissions from waste  

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New Delhi, July 19, 2024: Has India’s much vaunted National Clean Air Programme (NCAP) helped our cities meet clean air standards to reduce the public health risk that air pollution poses? A new assessment report by Centre for Science and Environment (CSE) says there are serious concerns with the way the Programme has been run through the five years of its operation. 

The report by CSE – titled National Clean Air Programme: An agenda for reform – was released here today. 

NCAP was launched by the Union Ministry of Environment, Forest & Climate Change (MoEF&CC) in January 2019. This is the first ever national effort to set clean air targets for 131 designated polluted cities,with the aim of reducing particulate pollution by upto 40 per cent by 2025-26 from the base year of 2019-20. This is also the first ever instance in India of performance-linked funding for improving air quality. 

Speaking on the occasion, CSE director general Sunita Narain said: “While NCAP’s objectives and aims have always been commendable, we are finding that attention and investments under it are largely focused on dust control, and not on emission-spewing combustion sources such as industries or vehicles. As much as 64 per cent of the funds utilised under NCAP and the 15^th Finance Commission have been spent on road dust mitigation. Much less has gone towards controlling emissions from combustion sources --- with industrial pollution getting 0.61 per cent, vehicular pollution 12.63 per cent, and biomass burning 14.51 per cent. A balanced approach to funding is critical for effective impact.” 

The money flow

A lot of money has flowed in to fund the clean air action plans in Indian cities. Under the overall Programme (NCAP) which covers 131 cities, 49 cities with million-plus populations have received money from the 15^th Finance Commission; the remaining 82 cities have been funded directly by NCAP.

• Funds released to 131 cities: Rs 10,566 crore
• Amount utilised overall: Rs 6,806.15 crore (64 per cent of the released funds), as of May 3, 2024
• 64 per cent of the overall utilisation has been in road dust mitigation
• Funds released for 82 NCAP cities is significantly lower than that given to the 4915^th Finance Commissioncities. Utilisation of funds follows the same trend.
• 82 NCAP cities: Rs1,616.47 crore released; Rs 831.42 crore (51 per cent) utilised
• 49 cities under 15^th FC grant: Rs 8,951 crore released; Rs 5,974.73 crore (67 per cent) utilised 

Anumita Roychowdhury, executive director, CSE says: “Cities are judged based on different metrics. There are serious questions about these metrics being used to benchmark progress and its implications for real improvement.” The CSE report points out that while under NCAP cities need to demonstrate improvement in PM10 levels to access the funds, under the parallel programme of Swachh Vayu Sarvekshan (SVS) these cities are ranked based on policy measures implemented in managing sectors such as biomass, municipal solid waste, road dust, public awareness, besides improvement in PM10 concentrations.   

Adds Roychowdhury: “The new agenda for clearing the air has to gear up for scale and speed of changefor transformative reform. This needs massive energy transition in all sectors, mobility transition to reduce automobile dependence and shift long range transport from polluting roadways to railways and waterways, and circularity to close the loop around all waste streams. That is possible only if the method of tracking progress and compliance gets stronger.”  

Key highlights of the CSE report and action to be taken 

• Dust control has become the focus; PM2.5 should be the benchmark

Taking PM10 as the basis for assessing air quality improvement has diverted attention and investments towards dust control. Even though NCAP was originally planned to tackle both PM10 and PM2.5 concentrations in non-attainment cities, in practice only PM10 concentration has been considered for performance assessment. PM2.5, the more harmful fraction and emitted largely from combustion sources, has been neglected.

Says Roychowdhury: “Annual changes in PM10 levels can be significantly influenced by meteorological factors, dust storms and heatwaves, rather than just policy actions. This may not adequately mirror the impact of action across all key sectors.PM10 monitoring needs to be source specific.” 

Make PM2.5 improvement the benchmark to drive action. PM2.5 is a more relevant health indicator to assess improvement in air quality. 

• Mismatched aims and objectives; real on-ground action must be incentivised

Currently, cities ranked high for improving PM10 levels may not necessarily rank high for taking policy action. Cities that score high for good action under SVS can paradoxically be the worst performing cities for not improving PM10 concentration under NCAP. There is no way to establish the link between action and improvement in PM10 levels. 

CSE’s assessment shows that in 2022-2023:

• No clear correlation is apparent between policy implementation and PM10 improvement. Cities like Agra, Delhi, Ghaziabad, Meerut and Jabalpur (>10 lakh population category) performed well under SVS but performed poorly under NCAP for reducing PM10. Delhi ranked 9th under SVS for implementing policy measures but is at the bottom, scoring zero, under NCAP. In the 3-10 lakh population category, Amravati, Guntur and Rajahmundry were the best performers for taking action under SVS but were at the bottomunder NCAP. Among cities with population of below 3 lakh, Kala Amb, Angul and Talcher ranked at the top under SVS and at the bottom under NCAP.
• Several cities performed well under both SVS and NCAP. Indore, Srinagar, Bhopal and Trichy (over 10 lakh population) ranked best under both assessments. Similarly, Moradabad, Firozabad, Ujjain and Bareilly (in the 3-10 lakh population category) and Parwanoo and Rae Bareli (population less than 3 lakh) were at the top under both SVS and NCAP. 

• Key combustion sources neglected; improve the metrics to prioritise sources of toxic emissions –focus on industry, transport, solid fuels

With the current focus on dust control, the key combustion sources including transport and industry do not receive priority to build ambitious pathways. Due to city-specific action and a ‘hardline’ drawn around municipal boundaries, most industrial sources and power plants remain outside the orbit of city action plans. The small and medium scale units that exist in the non-conforming areas of cities are often not considered. 

Industrial pollution control remains business-as-usual.Only if a non-attainment city is an industrial townshipdo some additional steps on industrial pollution control get reported. There is minimal reporting on stack emissions inspection, challans and closure notices or notification of approved fuel list. There is very little information in the city progress reports on upscaled action to accelerate clean fuels and technology transition. 

Progress reports of cities are also minimal on the indicators developed by the Central Pollution Control Board (CPCB) for transport sector interventions requiring improvement in on-road emissions management, old vehicle phase-out, vehicle electrification, public transport improvement, non-motorised transport and parking policy as a demand management measure. These strategies are not well developed quantitatively and qualitatively for implementation, funding and reporting. 

For on-road emission management, information is largely confined to PUC challans and is limited on old vehicles phase-out; it not been translated into renewal and scrappage policies in line with the scrappage and fleet renewal notifications of the Ministry of Road Transport and Highways. Remote sensing cannot proceed as there are no central rules. Some states are using NCAP funds for expanding charging infrastructure. 

With respect to public transport, states have not yet adequately adopted state- and city-level guidelines and service-level benchmarks for planning of public transport infrastructure and multi-modal integration to enable modal shift and increase ridership. There is intermittent reporting on small corridors of walking and cycling. CPCB indicators related to parking policy as a demand management measure are not well understood. Cities often take this as a supply side management – read multi-level parking. The CPCB needs to develop adequate guidance and align the transport indicators more explicitly with the relevant Central government policies that have defined the targets, and design principles of these measures. 

• Non-transparent/unavailable data; need transparency in reporting of action in cities to deepen the understanding of solutions implemented in cities

Annual ranking and improvement in air quality is not publicly available city-wise as part of the formal reporting system of NCAP. It is not possible to determine the level, scale and quality of action in each sector or understand how top-performing cities achieved 80-100 per cent of their targets.Evidence of detailed action is sometime available outside the NCAP reporting system. For example, the MoEFCC’s Annual Report of 2023-24 gives details of interventions of the Air Commission in Delhi-NCR.Says Roychowdhury:Delhi-NCR's multi-sector actions have improved air quality, but pollution remains a significant challenge that NCAP must address. The programme needs to assess the level of action required for different cities and towns, considering their unique challenges and circumstances, to meetclean air benchmarks.” 

• Go beyond cities to take a regional approach

The experience so far has shown that cities cannot meet their clean air benchmark alone and need a regional approach to reduce the influence of transboundary pollution. Though the NCAP programme has taken this on board to target the Indo-Gangetic Plainswith an airshed approach, inter-state coordination framework is yet to develop. State Action Plans have to be leveraged to minimise the influence of upwind pollution sources on downwind air quality within the state. 

Regional approach is also an opportunity for addressing pollution in smaller towns, suburban and rural areas as these need a cluster mechanism for solutions and common infrastructure. These towns do not have adequate resources or capacity to implement complex measures and infrastructure. 

• National policies have to enable local action in cities and states

Multi-sector clean air action is both federal and national in nature. Several strategies related to industry, power plants, public transport infrastructure, waste management, and clean fuels need Central government support. Take for example, the approved fuel list that all state governments are issuing now – often, they cannot scale up implementation as national policies on pricing and infrastructure for clean fuels are not adequately supportive. Natural gas needs to be under GST to avoid the cascading effect of state taxes. Similarly, cities aiming to improve transit infrastructure or introduce remote sensing measurement need Central government rules and support. 

• NCAP needs long term policy visibility and funding strategy for sustained and scalable action

In the next leg of the Programme, sectoral funding strategies need to converge more efficiently to accelerate sector-wise action on clean technologies, fuels, green infrastructure and urban design solutions. Even though national policies have suggested innovative financing strategies for sectoral resource mobilisation, it is not usually practiced. The state governments also need to do budget forecasting for advanced planning, build supportive strategies and repurpose funds according to the clean air indicators to free up resources from ineffective strategies and infrastructure. 

Polluters-pay principleshould be applied to design taxes and cess, and pricing of products initiated for additional revenues to create dedicated funds for targeted action. Delhi, for instance, has imposed an environmental compensation charge on each truck entry daily, on each litre of diesel fuel sold and on the big cars and SUVs. Currently, city governments are underwriting the potential of generating revenues from parking by not enforcing variable parking pricing and eliminating free parking. As municipalities are the primary drivers of action, explore the opportunity of green municipal bonds. 

• Need sectoral targets and mandate

NCAP has allowed reporting on the relevant sectoral actions and funding to align with clean air action. This shows that parallel sectoral schemes and programmes with stronger legislative and regulatory framework, mandate and committed funding have a faster pace of progress. For example, performance-linked funding for garbage-free cities by 2025 under Swachh Bharat Mission 2.0 shows more advancement that gets widely reported by cities as action taken to control waste burning. Clean air action has to get deeply sectoral with time-bound targets for development of infrastructure, systems and compliance for scalable impact and prevent deaths and illness. 

• Need protocol for data recording and reporting on indicators

ULBs and SPCBs struggle to collect and upload data on the PRANA portal due to lack of understanding on tracking and maintaining datasets, despite having the relevant information. Departments need a protocol for inter-departmental information flow and reporting. They should be supported to develop an automated digital system for e-recording and reporting data in a standardised format, with capacity building and potential surveys or assessments to ensure effectiveprogramme implementation. 

• Need stronger institutional mechanism and capacity for planning and implementation in cities

Several indicators have asked for strengthening of the capacity of the departments for the purpose of monitoring, tracking and providing laboratory support air quality monitoring and assessment. Most cities have set up high-level task forces under the chief secretary of the state with representation of heads of departments. This system has to work more effectively in planning the scope of multi-sector and multi-departmental action and for efficient fund allocation. 

• Performance-linked assessment needs to capture and promote best practices to build the learning curve for other cities

The system of ranking and scoring cities is an opportunity to capture the details of sectoral good practices in different cities. If captured well, this can present a learning curve for others on the quality and scale of action. 

• Need sustainable funding strategy at Central and state levels for sustained and scalable action

Current funding system under the 15^th FC grant will come to an end in 2025-26. A more structured approach is needed to mobilise and align resources for clean air action until 2030. Sectoral funding strategies need to converge more efficiently to accelerate sector-wise action on clean technologies, fuels, green infrastructure and urban design solutions. There is no state-level strategy to mobilise additional resources through innovative financing. 

Application of polluters-pay principles is needed for designing taxes, pricing policy and cess for additional revenue to create dedicated funds for targeted action. As the municipalities are the primary drivers of action, the opportunity of green municipal bonds can be explored. Mainstreaming resources and repurposing of funds for clean air action is the imperative. Central schemes must converge and integrate clean air and low carbon objectives with targeted subsidies and market-based mechanisms to promote scaling up of clean technologies and address affordability and equity 

• Next phase of reforms need to prioritise action in key sectors to implement at a scale across the regions

The upcoming challenge is the need to shift the focus towards implementation of priority action in key sectors of pollution at a scale and link the performance-linked funding with targeted milestones. 

For more details, please contact Sukanya Nair of The CSE Media Resource Centre, 8816818864, sukanya.nair@cseindia.org