Council on Energy, Environment and Water Integrated | International | Independent

How Robust are Urban India’s Clean Air Plans?

An Assessment of 102 Cities

Tanushree Ganguly, L. S. Kurinji, Sarath Guttikunda
June 2020 | Risks & Adaptation

Suggested citation: Ganguly, Tanushree, L. S. Kurinji, Sarath Guttikunda. 2020. How Robust are Urban India’s Clean Air Plans? An Assessment of 102 Cities. New Delhi: Council on Energy, Environment and Water.


This report, in collaboration with Urban Emissions, evaluates the 102 city-specific clean air plans in India approved under the National Clean Air Programme (NCAP). Based on an extensive review of global literature on clean air planning, this report identifies key components of a clean air plan. It suggests ways in which these components can be integrated into the existing city action plans. Given that the current plans are preliminary, it provides recommendations to the State Pollution Control Boards (SPCBs) and municipal corporations on strengthening the plans.

The NCAP lists the preparation and implementation of air quality management plans by cities that do not meet the National Ambient Air Quality Standards - non-attainment cities - as a primary mitigation measure to reduce PM2.5 levels by 20 to 30 per cent with 2017 as the base year. The SPCBs were to submit the clean air plans which list down sector-specific interventions with predetermined timelines for implementation and the agency responsible for execution.

Key Findings

  • The SPCBs only had about two months to prepare the city action plans following a deadline set by the National Green Tribunal in 2018.
  • The city-level clean air plans stand as a collection of measures without specified goals and priorities.
  • Apart from Delhi’s clean air plan, which the Supreme Court partially notified for implementation in January 2018, no other clean air plan has a legal mandate for implementation.
  • The Central Pollution Control Board (CPCB) approved the plans and directed the SPCBs to implement them. However, without a timeline mandated for implementation, any failure or delay to enforce these plans cannot be questioned.
  • Over 40 per cent of the action points listed fall under the purview of multiple agencies, which can result in fragmented accountability.
  • About 24 per cent of the activities have been allotted to the pollution control boards.
  • Urban Local Bodies including Municipal Corporations and Urban Development Authorities are responsible for 37 per cent of the mitigation activities. This is problematic because of the country’s underdeveloped municipal finances.
  • Transport is the most discussed sector in most plans, accounting for 38 per cent of the total mitigation measures.
  • None of the plans proposes a regional coordination mechanism, although about 30 per cent of the pollution is from sources outside the city boundaries.
  • Only 25 cities’ clean air plans contain information on emission from different polluting sources. But this information does not translate into prioritising actions listed in the plan.
  • The absence of source information has led to the replication of plans across nine states with multiple non-attainment cities. Only 48 cities within eight states have made plans with distinct actions and interim targets.
  • The lack of a national emission inventory coupled with the absence of a standard protocol for air pollution emission reporting across states hinders the setting of emission reduction targets.
  • Only nine plans have listed budgetary requirements for executing the action points listed. The cost of execution ranges from INR 89 crore in Dimapur, which is the least densely populated city, to INR 16,780 crore in Mumbai - the most densely populated city.

Key Recommendations

  • Mandate preparation and periodic updating of plans under the Air (Prevention and Control of Pollution) Act (1981) once a city has been designated as non-attainment.
  • Integrate source information into the plans to prioritise concrete action. SPCBs should map out dispersed pollution sources in the cities and intensify inspection in these areas.
  • Budget the financial needs for each action point, identify potential revenue streams and raise funds to execute actions.
  • Identify key indicators that could be tracked to monitor the impact of the interventions.
  • Delineate responsibilities -- planning, implementing, enforcing, monitoring -- within the plans to participating agencies and avoid overlaps.
  • Set up a regional airshed management authority with significant enforcement powers under the Air Act for an efficient inter-state coordination mechanism.
Over 75% of the plans do not contain crucial information on emission from different polluting sources, leading to replication of action points and timelines across many highly polluted cities across the country.

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