It is not possible for local administrative units to meet the clean air benchmark without minimising regional influence; airshed level control strategies are thus necessary to meet clean air targets

The theme chosen for the International Day of Clean Air and Blue Skies this year is “Together for clean air”. The idea is to seek stronger partnerships, increased investments and shared responsibility to mitigate air pollution and public health risks. Regional cooperation becomes critical as air has no boundaries and action cannot be siloed.

Science has made it increasingly clear that pollution from the larger airshed continues to influence and undermine local efforts to mitigate air pollution. Action therefore requires a regional scale. This local-to-regional connect requires cross sector and multi-jurisdictional strategy.

India’s National Clean Air Programme (NCAP) of the Government of India has taken on board the principle of regional air quality management. But there is no regulatory framework yet to enable multi-jurisdiction management for aligned action and investment to establish the upwind and downwind responsibilities of state governments to improve regional air quality. The deadly winter smog that wraps the entire Indo-Gangetic Plain (IGP) every year is a lasting reminder of this regulatory gap.

India’s NCAP has recognised the idea of regional approach and inter-state coordination. It mentions that a comprehensive regional plan needs to be formulated, incorporating the inputs from the regional source apportionment studies. It has listed series of measures that cut across multiple jurisdictions and are regional in nature.

There is now a growing interest to scale up action and inter-state coordination specifically for the IGP due to its unique meteorology, landlocked ecosystem and high pollution and population.

In fact, the National Green Tribunal in its directive dated September 9, 2021, had taken cognisance of the high particulate pollution in IGP compared to other regions and had sought advanced air pollution abatement measures to enable sustainability while maintaining regional balance in development and industrial activities.

Following this directive, an integrated assessment of the IGP and a regional emissions inventory by the expert committee under the Central Pollution Control Board had highlighted that Uttar Pradesh is the highest PM2.5 emitter in the region followed by West Bengal, Bihar, Punjab and Haryana.

The industry sector alone accounts for 48.5 per cent of the total emissions in the region. Solid fuels for household cooking contributes as much as 19 per cent with highest contribution from UP, Bihar and West Bengal. Affordable cooking energy sources remain a challenge. The main contributors to transport pollution are the metropolitan cities like Delhi, Kolkata, Lucknow and the industrial areas.

It is challenging for any city or town in IGP to meet the clean air targets if the regional clean-up is not achieved. The framework for a formal adoption of integrated management of airshed is not yet in place.

Such an approach has a legal underpinning. This framework requires delineation of the region for aligned and coordinated action. This itself is challenging as the scientifically delineated airshed may have several administrative and political overlaps in the real world and may be an impediment to establishing a legal framework to align regional action and responsibilities within a delineated zone.

This will require an operative framework and state council. Technically, identification of critically polluted areas is permitted within the existing provision of the Air (Prevention and Control of Pollution) Act, 1981, that can be leveraged for the purpose of air shed management. But this is currently applied with a very narrow scope to only the industrial areas/clusters. But this can be expanded to cover a larger region based on the principle of airshed based action.

Such a precedent has now been set in Delhi and the National Capital Region (Delhi-NCR). Public movement, Judicial intervention and the subsequent setting up of the Air Commission for the Delhi-National Capital Region and beyond has established the principle of regional integrated planning for four states in the NCR region. This needs to be leveraged to create a framework for all other regions.

This is needed to establish upwind and downwind movement of pollution and its effect and how this science can inform regional action and planning. This will also require strong science to assess and model air quality transport within a region, identify region-wide pollution sources, impact of atmospheric conditions and factors on local build-up of pollution and regional transport to understand the down-wind and up-wind character of the pollution movement among others. This science is at a very nascent stage in India though some valuable evidences have begun to emerge.

Regional cooperation is also the most efficient way to leverage and maximise outcome of funding that is available for clean air action as well as for all other sectoral action. For the award period 2021-22 to 2025-26, the 15th Finance Commission has recommended Rs 38,196 crore in the form of the Million-Plus cities Challenge Fund of which Rs 12,139 crore is for ambient air quality. Already, Rs 8,000 crore is available. Capture full scope of multi-sector action in this spending and set targets for convergence and aligned action across states.

What other countries do

A global review carried out by the Centre for Science  and Environment shows that globally, national governments have begun to develop such a framework for management of transboundary pollution within the country and between countries. India also needs its template for regional action.

In the United States, Air Quality Control Regions are delineated under their Clean Air Act (CAA). The “Good Neighbor” Provision in the Act addresses interstate transport of pollutants to the downwind states. Clean air action plans need to build in the downwind impacts. It sets the regional pollution budget.

The Cross-State Air Pollution Rule program of the Environmental Protection Agency uses a contribution screening threshold of one per cent of the NAAQS to identify upwind states that may significantly contribute to downwind nonattainment and maintenance problems.

States have to make extra effort to reduce pollution from their sources. They take a regional approach to air quality monitoring network design. Air quality management in California is a joint effort including local, state, and federal bodies. In many circumstances, meeting federal and state air quality criteria in the downwind area is a joint effort.

In Europe, the Convention on Long-range Transboundary Air Pollution (LRTAP or Air Convention) allows signatory parties to agree to reduce emissions to the levels set based on their current exposure, available technologies, cost of implementation, and economic constraints. The Gothenburg Protocol (in its 2012 amended version) established national emission ceilings for ozone precursors and fine particulate matter (PM2.5)for each country in the EMEP (European Monitoring Evaluation Programme) region.

The Air Convention has laid down a complex framework involving scientific, policy and compliance coordination among the signatory parties to mitigate transboundary air pollution. Transboundary Air Pollution Monitoring is in place for unified monitoring and modelling programmes. The European Air Quality Policy and European Green Deal have called for the development of a zero-pollution action plan to improve air quality across the EU.

Operationalise regional action

The most recent effort under NCAP to prepare state action plans has created an opportunity for more harmonised action across districts of the state and also work towards inter-state cooperation.

More steps are needed to develop regional monitoring strategy, legal framework, operative mechanism for integrated action and alignment of responsibilities of different authorities and compliance system within the region and the federal system. This strategy is needed to meet the clean air standards.

This requires an interstate council to operationalise this regional framework and a legal framework for regional air quality management of air quality control regions. Responsibility must be established in state / regional plans to account for contribution to air quality in downwind regions.

As science has established clearly that it is not possible for any local administrative unit to meet the clean air benchmark without minimising the regional influence, airshed level control strategies become necessary to meet clean air targets.

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