New Government’s Agenda: Look beyond dust

Reinvent National Clean Air Programme to focus on fine particulate matter and trans-boundary pollution 

Only a year is left for the polluted cities of India to clean up their act. In January 2019, the Union environment ministry launched a comprehensive policy framework, the National Clean Air Programme (NCAP), to improve air quality in 131 cities and urban agglomerations that consistently reported high pollution levels. The aim was to lower the concentration of particulate matter in these cities by up to 40 per cent by 2025-26, from the 2019 level. To enable implementation, NCAP promised performance-linked funding—a first-of-its-kind strategy to curb air pollution. A massive Rs 19,711 crore was earmarked for the programme. By 2023, as stated in the ministry’s Annual Report 2023-24, all the 131 cities showed improvement in the levels of PM10 (particulate matter with a diameter of 10 microns or less). But have these cities managed to reduce air pollution effectively, which can cause a host of illnesses from lung cancer to cardiovascular diseases to low birth weight and lead to premature death? There are questions around this, and let me tell you why.

Of the Rs 19,711 crore earmarked under NCAP, Rs 16,539 crore is for 49 cities and urban agglomerations, each housing more than 1 million people; the remaining Rs 3,172 crore has been earmarked for 82 cities with smaller populations, as per the ministry’s Annual Report 2023-24. However, an analysis of this data shows poor utilisation of funds—an indicator of ineffective implementation. Till December 2023, the 49 million-plus cities received Rs 8,357.51 crore, but spent only 70 per cent— Rs 5,835.03 crore—of it. The 82 smaller cities received Rs 1,292.5 crore, and spent only 37.5 per cent, or Rs 480.92 crore, of it. This indicates the scale and speed of action to tackle air pollution are yet to catch up with the target.

The metrics used for judging progress in air pollution abatement are also questionable. For instance, NCAP was originally planned to reduce concentrations of both PM10 and PM2.5. But in practice, only PM10—the coarser dust particles—is considered as the basis for assessing air quality improvement. This has diverted attention and investments towards dust control, while PM2.5, the more harmful particles emitted largely from combustion sources, remains neglected. Analysis of the spending under NCAP shows that as much as 64 per cent of the funds have gone into activities such as paving and widening roads, repairing potholes, water sprinkling and buying mechanical sweepers. By comparison, funds allocated to reduce emissions from combustion sources, responsible for PM2.5, are a lot less—only 14.51 per cent of the total funding under NCAP has been spent on controlling biomass burning, 12.63 per cent on tackling vehicular pollution and a mere 0.61 per cent on industrial pollution control.


  • Fine particulate matter, PM2.5, is a more relevant health indicator to assess air quality than coarse particulate matter PM10. Use PM2.5 as benchmark in National Clean Air Programme
  • Identify key sources of PM2.5 and plan measures to mitigate the pollution
  • Cities that rank high under National Clean Air Programme for improved PM10 levels, do not necessarily rank high for policy action. Fix this

While cities under NCAP need to only demonstrate improvement in PM10 levels to access funds, under a parallel programme of the Union environment ministry called Swachh Vayu Sarvekshan (SVS), cities are ranked based on action taken in different sectors along with PM10 reduction. These include policy measures to reduce vehicular and industrial emissions, emissions from biomass and municipal solid waste, road dust and dust from construction and demolition waste, and also on public awareness about these policies. But performance based on PM10 reduction under NCAP and ranking based on action taken under SVS often do not match. While both the assessment strategies for NCAP and SVS are steps in the right direction, transformative changes are possible only if the method of tracking progress and compliance is stronger. So here are a few suggestions for the new government to achieve clean air.

Use PM2.5 as benchmark: PM2.5 is a more relevant health indicator to assess improvement in air quality. Besides, the impact of policy action on PM10 levels is difficult to establish, as it is highly impacted by wind-blown dust, loose sub-soil from farmlands, and is released by specific sources like mining and construction.

Choose the right metrics: Since under NCAP, PM10 is used as the indicator to measure progress in air pollution, focus is on dust control. Key combustion sources like transport and industry, which are the major sources of PM2.5, do not receive priority for developing mitigation pathways. Besides, most industrial sources and power plants are located outside municipal boundaries, and thus remain beyond the ambit of city action plans. Small- and medium-scale units that exist in the non-confirming areas of cities are often not considered.

Some information on industrial pollution control measures get reported only if a city is an industrial city or town. Even then, information on steps to accelerate transition to clean fuels and technologies is scanty. Similarly, often progress reports of cities are inadequate on the indicators set by the Central Pollution Control Board (CPCB) for improvement in on-road emissions management, old vehicle phase out, vehicle electrification, public transport improvement and non-motorised transport. These strategies are not well developed quantitatively and qualitatively for implementation, funding and reporting.

Link policy action with air quality improvement: Currently, there is no way to establish the link between policy action and improvement in pollution levels. Cities ranked high under NCAP for improved PM10 levels do not necessarily rank high under SVS for taking policy action. Similarly, cities that score high for good policy action under SVS can be the worst performing cities under NCAP for not improving PM10 level. An assessment by Centre for Science and Environment (CSE), Delhi, shows that in 2022-23, Guntur city of Andhra Pradesh and Angul town of Odisha were among the best in their respective city categories for taking good action under SVS, but were worst performers under NCAP for not improving PM10 levels. In 2022, Lucknow was among the top performers for good action under SVS but in 2023, it was among the worst performers under NCAP. This needs to be fixed.


  • Cities cannot meet their clean air benchmark unless a regional approach is taken to reduce trans-boundary pollution
  • Polluter pays principle must be followed while designing taxes, cesses, and pricing products for additional revenue, which can be used to create dedicated funds for targeted action
  • Sector-specific funding strategies need to converge efficiently to accelerate action

Go beyond cities: Experience shows that cities cannot meet their clean air benchmark unless a regional approach is taken to reduce trans-boundary pollution. Even though NCAP has taken on board the idea of airshed approach especially targeting the Indo-Gangetic Plain, an inter-state coordination framework is yet to develop. However, state action plans can be leveraged to minimise the influence of upwind pollution sources on downwind air quality within the state. Regional approach is also an opportunity for smaller towns, suburban and rural areas to curb air pollution collectively, as they do not have adequate resources and individual capacity to implement complex measures and infrastructure.

National policy for local action: Strategies for clean air action related to industry, power plants, public transport infrastructure, waste management and clean fuels need support from the Union government. For instance, although state governments are notifying the list of approved fuels, they cannot often scale up implementation as national policies on pricing and infrastructure for clean fuels are not adequately supportive. Similarly, cities aiming to improve transit infrastructure or to introduce remote sensing measurement need Central government rules and support. Even though national policies have suggested innovative financing strategies for sectoral resource mobilisation, it is not usually practised. Sector-specific funding strategies need to converge efficiently to accelerate sector-wise action on clean technologies, fuels, green infrastructure and urban design solutions.

Polluters must pay: Polluter pays principle must be followed while designing taxes and cesses, and pricing products for additional revenue, which can then be used to create dedicated funds for targeted action. Delhi has imposed an environmental compensation charge on truck entry daily, on each litre of diesel fuel sold and on big cars and SUVs (sports utility vehicles). Since municipalities are the primary driver of action, they can explore green municipal bonds.

Need sectoral targets: NCAP has rightly allowed sector-specific action and funding to align with clean air action. For example, performance-linked funding for garbage-free cities by 2025 under Swachh Bharat Mission 2.0 shows cities are taking action to control waste burning, and that is reported under NCAP. This also shows that sectoral schemes and programmes with stronger legislative and regulatory framework, and committed funding, have faster pace of progress. This needs to be scaled up.

This was first published in the 1-15 June, 2024 print edition of Down To Earth

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