Expert Speak Terra Nova
Published on Dec 06, 2019
Industrial air pollution – What’s there to hide

Winter 2019-20 saw many protests and campaigns in and around Delhi as air pollution was much worse than the previous year. Much of the focus was on the farm fires which on some days accounted for almost half of Delhi’s air pollution. However, a significant part of emissions, industrial pollution, are not just throughout the year beyond winter but are often overlooked in mass campaigns. There are two parts to this - emissions from industries and, what the government has designated, Critically Polluted Areas. How are these sources of air pollution being brought under control and is there enough accountability?

Industrial Air Pollution – What’s There to Hide

Perhaps never before has so much time been devoted in the Supreme Court and Parliament to air pollution as there has been since the start of the great smog of Delhi in October-November, 2019. Outside the two institutions, there have been headlines, protests, and campaigns.

News reporting<1>, which shows the daily percentage share of farm fires in Delhi’s pollution<2>, has focused a lot of the attention to Punjab, Haryana and western Uttar Pradesh north of the capital. This percentage has fluctuated daily from 2-3% to a peak of almost 50%. But this in-your-face pollution obscures a larger problem, that it’s not only farm fires, it’s not only Delhi, and it’s not only in winter.

Satellite pictures repeatedly show smog hanging over the sub-continent, coast-to-coast, north to south. The haze over the landmass is similar to the haze over India’s pollution policies. There are two main aspects to be covered in this paper. The first concerns the Critically Polluted Areas or CPA<3>. The second is a vast network of emission monitors in polluting industries whose data the public cannot access. Both these are spread across India.

India’s Critically Poor Areas

Way back in 2009, before air pollution became a ‘thing’ in public discourse, the government identified 43 Critically Polluted Areas. These were rated on a new index, the Comprehensive Environmental Pollution Index (CEPI)<4> to cut pollution on priority. Apart from air pollution it factored in water and land pollutants and the effect on humans and eco-geological features. In almost ten years since then there’s been little improvement, in fact as far as air pollution is concerned there’s been a sharp deterioration.

The CEPI scorecard has been put out in public only four times since 2009. The most recent one was out as part of an order<5> of the National Green Tribunal. This was the 2018 data released after a gap of five years<6>. A comparison of the last two pollution scorecards with an emphasis on air pollution has perhaps one upside. The number of Critically Polluted Areas, those with a score of above 70, have come down from 43 to 38 in these nine years.

The rest of the pollution index data paints a dismal picture of deteriorating air quality.

  • The overall number of Polluted Industrial Areas, of which CPAs are one part, has gone up from 88 to 100.
  • All the top 15 CPAs in 2018, barring Manali in Tamil Nadu and Panipat in Haryana, were not in the top 15 in 2013.
  • As many as seven in the 2018 list, including Mathura, Vadodara and Gurgaon, were not even listed as critically polluted five years earlier.

The scorecards label the status of pollution in the air, water and land as critical, severe and normal. This is calculated on the factors such as whether the number of people potentially affected within a 2 km boundary of the pollution source is above 100,000 or less.

  • The number of the total Polluted Industrial Areas which had the status of ‘critical’ air pollution jumped fourfold from 8 to 32 in these five years, and those with ‘severe’ air pollution went from 17 to 28.
  • Of the top 15 in 2013, only five places had ‘critical’ air, but this increased to thirteen places by 2018.

Table 1: Top 15 Critically Polluted Areas, 2018. Source: CPCB

Sl. No. Name of Polluted Industrial Areas (PIAs) Air CEPI 2018 Score # Status of Environment
1. Tarapur(Maharashtra) 72.00 93.69 Ac*_Wc_Ls
2. Najafgarh-Drain basin including Anand Parbat, Naraina, Okhla, Wazirpur (Delhi) 85.25 92.65 Ac_Wc_Ls
3. Mathura (Uttar Pradesh) 86.00 91.10 Ac_Wc_Ln
4. Kanpur (Uttar Pradesh) 66.00 89.46 Ac_Wc_Ln
5. Vadodara (Gujarat) 82.00 89.09 Ac_Wc_Ln
6. Moradabad (Uttar Pradesh) 76.00 87.80 Ac_Wc_Lc
7. Varanasi-Mirzapur (Uttar Pradesh) 67.50 85.35 Ac_Wc_Ln
8. Bulandsahar-Khurza (Uttar Pradesh) 79.50 85.23 Ac_Wc_Ln
9. Gurgaon(Haryana) 70.00 85.15 Ac_Wc_Ln
10. Manali (Tamil Nadu) 59.75 84.15 As**_Wc_Lc
11. Panipat (Haryana) 66.00 83.54 Ac_Wc_Lc
12. Firozabad (Uttar Pradesh) 76.00 81.62 Ac_Wc_Ln
13. Udham Singh Nagar (Uttarakhand) 33.00 81.26 An_Wc_Ln
14. Jodhpur (Rajasthan) 67.00 81.16 Ac_Wc_Lc
15. Pali (Rajasthan) 66.00 80.48 Ac_Wc_Lc

*Ac: Air-Critical

**As: Air-Severe

Table 2: Top 15 Critically Polluted Areas, 2018. Source: CPCB

2013 rank Industrial Cluster / Area State Air CEPI 2013 score Status of Environment
1 Vapi Gujarat 51.75 85.31 As-Wc-Ls
2 Ghaziabad Uttar Pradesh 69.5 84.13 Ac-Wc-Ln
3 Vatva Gujarat 43 83.44 An-Wc-Ln
4 Singrauli Uttar Pradesh 68 83.24 Ac-Wc-Lc
5 Pali Rajasthan 54 82.71 As-Wc-Lc
6 Chandrapur Maharashtra 51.75 81.9 As-Ws-Lc
7 Panipat Haryana 48.25 81.27 An-Wc-Ln
8 Ankaleshwar Gujarat 67.5 80.93 Ac-Wc-Ls
9 Vellore -North Arcot Tamil Nadu 59.75 79.67 As-Wc-Ln
10 Indore Madhya Pradesh 65 78.75 Ac-Wc-Ln
11 Noida Uttar Pradesh 50 78.69 As-Wc-Ln
12 Jodhpur Rajasthan 57.5 78 As-Ws-Lc
13 Mandi Gobindgarh Punjab 55 77.98 As-Wc-Lc
14 Manali Tamil Nadu 55.5 77.26 As-Wc-Ln
15 Patancheru Bollaram Andhra Pradesh 62.5 76.05 Ac-Wc-Ln

Hidden in plain view: Nothing transparent about air pollution data?

In 2016, CEPI was revised<7> essentially to ease the moratorium on environmental clearances to allow for changes to capacity, manufacturing processes and so on as long as there was no increase in the pollution load or any adverse impact on the environment. It also called for polluting sources to be identified in the public domain and published by state governments periodically.

Trawling through pages and pages of websites, there is clearly a need for clear, simple reporting of how pollution is being monitored and controlled and if polluters are indeed paying up.

Take for example the case of thermal power plants in Haryana. As per Haryana’s rules till very recently mandated inspections once every three years<8>. But the Bahadurgarh one was last inspected in July, 2013, the Ballabhgarh one in November 2014, and the Panipat one in December 2015<9>. This pace of inspections of these thermal power plants is obviously not enough, a fact recognized by the NGT and given these are ‘red’ category industries, that is, highly polluting.

A letter by the chairman of the Haryana State Pollution Control Board from 10th Oct, 2019, says the NGT found that the board’s inspection policy hardly matched the mandate of precautionary sustainable development principles of environmental law. Also, its auto-renewal policy results in pollution remaining unchecked. On being ordered to revise its inspection schedule, the board has now announced inspection once a year for power plants. But on its website, there’s been no update of whether these have been inspected. This, when all these power plants are in the pollution air shed of Delhi and its neighbours and contribute in making it the region with the world’s worst levels of air pollution.

But contribute exactly how much? This is data that is kept out of the public domain. All polluting industries are required to have, since 2016, Online Continuous Emissions Monitoring Systems (OCEMS). As of 2019, there are over 2700 OCEMS installed in a little over 3500 “highly polluting” industries<10>; the remaining faced closure-directions according to the National Clean Air Programme. The OCEMS data goes directly to CPCB. But the CPCB does not release this publicly. Its officials have the power to take immediate corrective action against industries in order to control pollution<11>. India’s environment minister told the Rajya Sabha that they are “controlling every minute<12>” of the OCEMS.

But there appears to be a contradiction between what officials say. This system of minute-to-minute monitoring of pollution on which officials can take immediate action against businesses cannot be used for regulatory purposes. As the CPCB chairman, SPS Parihar, said at a press conference on the 18th of November, 2019, the online data is yet to be recognized under the law and that’s work in progress. While there is an online and continuous monitoring system, the law mandates only manual data, which is slow to process, be used for regulatory purposes and field visits are made on this basis.

There is a case study worth looking at briefly about Panipat’s Indian Oil refinery. It’s about how a polluter, as recognized by the NGT, put up a fight despite the work of HSPCB and CPCB officials which was praised by the tribunal.

The Panipat refinery is in the ‘red’ category of the 17 most polluting types of industry (the others being cement, thermal power plants and so on), and it was inspected by Haryana pollution control officials in June, 2018. It found the level of PM 10 pollutant far higher than the permissible limit of 100 micrograms per cubic meter. The officials reported irritation to eyes and an odour in the vicinity of the unit<13>.

IOC in its defence before the NGT submitted that ambient air quality is an issue all over northern India and cannot be attributable to its refinery, something it claimed that the pollution control officials could also not prove. Nevertheless, IOC promised the Haryana State Pollution Control Board that it would reduce its carbon footprint by 18% by 2020. However, the tribunal ruled<14> that the refinery must pay an interim compensation of Rs 17.31 crores. The NGT’s reasoning was that there was a violation of environmental norms for air and water pollution, that liability was unavoidable and as a public sector unit the refinery should be a model for compliance with environmental laws.

Much of this points to a need for a clearer, more transparent data and regulatory regime. And perhaps also an overhaul in mindset – to recognize a problem and address it openly with no half-measures, which is what India’s air pollution crisis demands.

‘How many children die of air pollution, minister?’

Consider, for instance, environment minister Prakash Javadekar’s speech on the 21st of November, 2019 where he spoke of the need to try out air purifiers in open spaces, something that some air quality experts have shown is a waste of taxpayers’ money. Referring to one such pilot project in Delhi, he said it was a “mix result.<15><16>

However, the answer tabled<17> in the Rajya Sabha says there was “minimal improvement”

in ambient air quality. ‘Mixed’ could mean 50-50, ‘minimal’ categorically doesn’t.

There is also a lack of clarity, or even confusion, in the ruling establishment whether or not to accept data from outside itself.

Is the Government aware that around one lakh children are dying every year because of air pollution in the country? This was asked in the Lok Sabha soon after NDA 2.0 took office. Minister of state for environment, Babul Supriyo responded, “These estimates are based on models, simulations and extrapolations. Though air pollution is one of the triggering factors for respiratory ailments and associated diseases, there are no conclusive data available in the country to establish direct correlation of death/disease exclusively due to air pollution. Health effects of air pollution are synergistic manifestation of factors which include food habits, occupational habits, socio-economic status, medical history, immunity, heredity, etc., of the individuals.”

Yet the minister’s fellow BJP MP, Gautam Gambhir, stated in the middle of the great smog of Delhi, on the 19th of November,  that in India a child dies every three minutes because of air pollution<18>, a figure which works out to 175,000 deaths a year. The father of two young children added that we need to think of long-term solutions otherwise our children will be paying the price.

The CPCB says the pollution index, CEPI should be a warning tool for governments and others concerned to understand the severity of pollution<19>. But data, rules, policies need to be more easily accessible to public scrutiny and accountability so that every voter can be aware of what exactly is causing pollution in her or his area. Should not the millions of people living within a radius of 300 km of Delhi know exactly how much air pollution is emitted every day from the dozen or so coal-fired power plants in area?

How many apart from those deeply into air pollution analysis would, for instance, know that Najafgarh drain basin in Delhi is the second-highest Critically Polluted Area in the country? That doesn’t sound terribly exciting until a look at a map shows that this drain basin covers most of India’s Capital.


<1> SAFAR’s daily bulletin issued by the Indian Institute of Tropical Meteorology, Pune. This is a division of the Minister of Earth Science, Government of India.

<2> Percentage share of stubble fires in PM 2.5 levels in Delhi

<3> CPAs or Critically Polluted Areas, first announced in 2009 by the Central Pollution Control Board: https://cpcb.nic.in/displaypdf.php?id=Q1BBL05ld0l0ZW1fMTUyX0ZpbmFsLUJvb2tfMi5wZGY=

<4> https://cpcb.nic.in/displaypdf.php?id=Q1BBL05ld0l0ZW1fMTUyX0ZpbmFsLUJvb2tfMi5wZGY=

<5> http://www.greentribunal.gov.in/Writereaddata/Downloads/1038-2018(PB-I)_10-7-19.pdf

<6> 2009, 2011, 2013 CEPI data:  https://data.gov.in/catalog/details-comprehensive-environmental-pollution-index-cepi-scores-and-status-moratorium?filters%5Bfield_catalog_reference%5D=87024&format=json&offset=0&limit=6&sort%5Bcreated%5D=desc

<7> http://cpcbenvis.nic.in/industrial_pollution.html#

<8> https://hspcb.gov.in/content/Consent_Policy_Procedure/InspectionPolicy_30_10_2019.pdf

<9> https://hspcb.gov.in/content/17_type/2018first.pdf

<10> http://cerca.iitd.ac.in/files/reports/NCAP%20Report%20Full.pdf

<11> https://cpcb.nic.in/openpdffile.php?id=TGF0ZXN0RmlsZS9fMTU1ODAwMTY3Nl9tZWRpYXBob3RvMTM2NzYucGRm

<12> http://164.100.47.7/newdebate/250/21112019/14.00pmTo15.00pm.pdf

<13> http://www.indiaenvironmentportal.org.in/files/file/Panipat-refinery-NGT-Order.pdf

<14> http://www.greentribunal.gov.in/Writereaddata/Downloads/738-2018(PB-I)OA10-5-19.pdf

<15> http://164.100.47.7/newdebate/250/21112019/14.00pmTo15.00pm.pdf

<16> https://www.youtube.com/watch?v=jgkF8z98nhE

<17> https://pqars.nic.in/annex/250/AS78.pdf

<18> http://164.100.47.194/LOKSABHA/QUESTIONS/QResult15.aspx?qref=1306&lsno=17

<19> https://india.mongabay.com/2019/11/develop-time-bound-action-plans-for-critically-polluted-areas-moefcc-tells-state-governments/

SAFAR Air Quality Forecast, 8.11.2019

https://twitter.com/ashimmitra/status/1191763346661339137?s=20

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