On the Air Pollution Action Plan for the National Capital Region of Delhi

On the Air Pollution Action Plan for the National Capital Region of Delhi

By Dr. Yashpal Singh

 The Government of India is in the process of drawing up an action plan for the control of Air Pollution in the National Capital Region of Delhi. The draft Action plan has been posted by the Ministry of Environment, Forests and Climate Change on its official website for comments.  I have had an opportunity to have seen the draft action plan and have a few suggestions to offer. These have been separately communicated to the Ministry also.

 Most importantly, I would tend to feel that a considerable contribution to aggravated levels of Pollution in the winters is due to inversion triggered increased fumigation hours and a consequent build up of pollutants. Sodar based studies have indicated that Delhi witnesses a poor ventilation characterized by stable inversion for about 12 hours (1800 to 0600 Hrs) and a  good atmospheric ventilation period of about 7 hours (1000 to 1700 Hrs) during the day. If high emission peaks of the  fuel burning and combustion cycles (firings, shut downs etc) are conducted during periods of good ventilation, build up  is  avoided but the same processes of burning fuel during the periods of thermal fumigation (winter evenings) will add to polluting the ambient air quality by trapping the emissions  within. Fumigation lasts for upto 2 hours during the summers (April to August), it may extend to about 4 hours during the post monsoons (September to October)  and may extend upto 8 hours in winters. The poorest ventilation in Delhi has been reported from 0100 to 0400 hrs. Information of good ventilation and fumigation periods could, therefore be utilised to regulate the operating hours of emission sources.

Studies carried out by the IIT, Kanpur have also suggested that even with the best of control options it is unlikely that a standard of 100 microgram/m3 of PM10 and a standard of 60 microgram/m3 of PM 2.5 could be met.  Under such circumstances, I would feel that it could be advisable to reconsider the standards, based on the contribution of area sources and meteorological conditions, or consider seriously the freezing of all further development which is likely to result in population and traffic movements beyond the holding capacities of different sectors,   as envisaged in the master plan.

With reference to the action plan being drawn up by the Government, I may have the following suggestions to offer.

Crop Stubble Burning, monitoring and interstate coordination

  1. The enhanced concentration of pollution in October and November has been already established as being largely due to crop residue burning (contribution to PM 10 estimated to  being as high as 140 microgram/m3 and PM 2.5 being as high as 120 microgram/m3). There is an immediate need to regulate this.
  2. If stubble burning is inevitable, allow it by permit only.
  3. The action plan envisages monitoring of agreed enforcement measures to reduce crop stubble burning. If a reduction in crop stubble burning is the immediate alternative, the impacts during the months associated with thermal inversion could be reduced by ensuring that no stubble is burnt between 1400 Hrs and 1000 Hrs during the months of September to February. This could be examined as an agreed enforcement measure.
  4. To offset the high incidence of costs on farmers, sustainable stubble harvesting and disposal practices could be included as a recognised C.S.R. activity and the Corporate Sector motivated to participate by investing in capital expenditures towards setting up of scaled up sustainable stubble management centres.
  5. Post monsoon crop burning should be minimized. Residual crops can be harvested and utilised in energy production, biogas generation, commercial feed stock for cattle, composting, conversion in bio-char or as raw material.

Pollution Monitoring and source attribution

  1. Ensure that all policy frameworks and action plans for future development are based on source apportionment studies (diurnal and seasonal) and plans drawn up for future development on carrying capacity assessments.
  2. Sub rule 3 (B) of the Environmental Protection Rules 1986 specifically provides that, “The combined effect of emission or discharge of environmental pollutants in an area, from industries, operation, process, automobiles and domestic sources shall not be permitted to exceed the relevant concentration in ambient air as specified against each pollutant in columns (3) to (5) of schedule VII.”
  3. The prohibition of further establishment of /expansion of air polluting industries in the NCR region could, therefore, be examined since the ambient air quality standards have already been exceeded.

State and Municipal Actions required to reduce air pollution

  1. Ensure that all future development proposals are evaluated in terms of adequacy of existing/proposed infrastructure to support the development and allowed only after the participating agencies have certified for adequacy as per the existing infrastructure or the integrated adequacy plan. This would include, power, water, roads, sewage treatment, MSW and other wastes and the ambient air quality.
  2. Ensure that all Master and Area Development plans and or activities (including conversion of residential to commercial or increase in FAR) likely to influence the carrying capacity and environmental quality of the area have a due environmental
  3. Open burning of MSW should be banned completely.
  4. Set up facilities for organic waste composting/refuse derived fuel.
  5. Segregation of Municipal Solid Wastes at the Household level should be strictly ensured and biodegradable wastes sent to waste converters and waste to energy plants otherwise biodegradable wastes may reach land fill sites and be allowed to burn and smolder as a matter of convenience.
  6. Wood, crop residue, cow dung and coal are widely used in slums and are the single largest contributors to PM 10 and PM 2.5 emission from area sources. A plan for slum redevelopment and rehabilitation needs to be drawn up along with promoting use of clean fuels.
  7. Labour at construction sites should be prohibited from burning wood, crop residue, cow dung or coal for cooking. Instead they should be provided clean fuels by builders as a compliance to their environmental responsibilities.
  8. Particulate matter emission from the use of coal in hotels, restaurants and road side eateries in the NCR is large and contributes to air pollution. Hotels, Restaurants and road side eateries should be restricted from using coal and shift to electric or gas based appliances.
  9. P.G./Piped gas supply could be made available to all households.
  10. Prohibit storage of desilted sludge from drains on roads or embankments.
  11. Emissions from soil and road dust can be controlled through sweeping, watering of roads and dusty walk ways (Treated effluents could be used) and growing grass on berms in order to prevent re-suspension of dust.
  12. Develop infringement free walk ways and cycle paths to facilitate free flow of traffic. Provide wall to wall pervious paving for all roads.
  13. Staggered business timings particularly restricting business hours during winter nights may reduce the emission build up during fumigation periods.
  14. Synchronise traffic lights to facilitate free flows of traffic.
  15. Construction and demolition wastes handling rules should be strictly enforced.
  16. Small diesel generating sets (Less than 2 KVA) at the ground level should not be permitted to operate.
  17. Solar power generation and inverter should be promoted.

Reducing Pollution from power plants and other polluting industries.

  1. Evolve an agreed enforcement plan with the States and evolve guidelines to prescribe that from September 15 to February 15 every year, start ups and shut down in furnaces/boilers/ kilns etc. are undertaken only between 10 am to 4 pm.
  2. Prescribe Air Quality index as a standard for ambient air quality.
  3. Flyash storage ponds/disposals sites should be constantly monitored by the Pollution Control Boards under dedicated programs.
  4. Industries be advised to use cleaner fuels.
  5. NOx and SO2 have a tendency to form secondary pollutants. Both these gases are increasing at alarming proportions. A road map and action plan needs to be drawn up especially for thermal power plants. NOx and SOx were expected to increase by about 45% over the 2007 figures in 2017. PM on the other hand was only expected to increase by about 7%.
  6. NCR and the surrounding areas could be evaluated in terms of the ambient air quality standards and CEPI and declared so if covered. A moratorium could then be introduced.
  7. An integrated zoning atlas for siting of industry needs to be developed and implemented for the NCR. Till such time all new industries/expansion of industries leading to additional air pollution should not be allowed.

Reducing Pollution from Vehicles

  1. Implementation of BS VI, electric and hybrid vehicles, traffic planning and decongestion of roads and improvement of public transport can be implemented for vehicle emissions control.
  2. Synchronization of traffic signals will reduce idling emissions.
  3. Registration of new vehicles could be regulated based on carrying capacity estimations. This may need immediate attention.
  4. New vehicles could be registered only if adequate parking is available with the owners.
  5. Odd even approach could be considered to be implemented from 4 PM to 10 AM on winter nights to avoid the thermal fumigation hours.
  6. Strictly review and enforce the PUC system and consider empowering the company owned authorized service centers to issue certificates.
Filed in: Biodiversity & Nature Conservation, Consultants, Dr. Yashpal SIngh, Laws and Procedures

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