Clean air plans ready for 102 cities, but no budget

90% of the cities that have made plans under the National Clean Air Programme have no budgetary support. None, except Delhi, have a legal mandate to implement those either.

The National Clean Air Programme (NCAP) was announced in 2018 and the draft was accepted in 2019. The programme is designed to build institutional capacity and initiate studies to better understand the pollution load in cities. 

122 cities from 20 states and 3 union territories were declared “non-attainment” cities, based on the observed particulate matter pollution trends from the national ambient monitoring program (NAMP). 

These cities were required to submit action plans outlining how to achieve 20-30% reduction in the ambient PM 2.5 levels by 2024, when compared to 2017. As of May 2020, there are 102 approved action plans.

A review of these action plans was conducted jointly by Urban Emissions (UEinfo) and Council of Energy Environment and Water (CEEW). UEinfo is an independent research institution that was founded with the vision to be a repository of air pollution related information, research, and analysis. CEEW is one of South Asia’s leading not-for-profit policy research institutions, uses data, integrated analysis, and strategic outreach to explain – and change – the use, reuse, and misuse of resources.

The utility of clean air plans  

A clean air plan (CAP) aims to improve air quality and public health by identifying cost-effective measures to reduce emissions from all the known sectors. CAP is also a collection of regulations, policies and programmes for cleaner air, planned and/or implemented by the respective states.

The first known CAP in India is a white paper on Delhi’s air pollution in 1997. The 102 approved NCAP action plans are consistent with what we have observed in the past submissions, in terms of interventions necessary and the agencies which need to play a critical role in advancing the agenda of clean air. 

Key interventions that all the cities want to implement
(a) Augment public transport 
(b) Eradicate road and construction dust 
(c) Abolish open waste burning 
(d) Promote clean cooking 
(e) Implement industrial emission standards 
(f) Increase ambient monitoring capacity
(g) Raise public awareness.

As it stands, the cities passed one stage of the NCAP process by submitting a wish list of actions for blue skies. But the big question remains, with no legal binding associated with these action plans, can the cities achieve the NCAP targets by 2024? 

Current challenges

  • The city-specific action plans stand as a collection of measures without specified goals and priorities.
  • Apart from Delhi’s clean air plan, no other city-specific plan has a legal mandate for implementation.
  • 90% of India’s 102 city clean air plans have no budgetary allocation.
  • 75% of city CAPs do not contain information on the share of pollution originating from sources in the city and outside the city airshed
  • Over 70% of the control measures listed in the plans involve overseeing, planning, proposing, preparing, investigating, identifying, ensuring, strengthening, training, studying, and engaging. Less than 30% call for on-ground pollution control.
  • None of the plans propose a regional coordination mechanism, although the 30% of the pollution is from sources outside the city boundaries

Salient features in a few states


Maharashtra has 18 non-attainment cities, maximum of all states in India. 

38% of actions are specific to the transport sector and 16% of all actions focus on the industrial sector.

The state pollution control board oversees only 20% of the mitigation activities, while 41% comes under the ambit of municipal corporations and urban local bodies and 22% under the department of transport.

Despite 18 non-attainment cities in Maharashtra, the clean air plans in the state are distinct unlike many other states across India. But, the absence of sectoral emission reduction targets, city-specific priorities, and a standard protocol for air pollution reporting progress on actions across sectors, could derail implementation of the plans in the state.

Uttar Pradesh

14 of Uttar Pradesh’s 15 non-attainment cities have identical plans.

All 15 action plans listed 56 measures across 17 different agencies. Of these, 30% of actions fall under multiple agencies and this could fragment the accountability. Hence, for each action point, it is crucial to delineate specific tasks among participating agencies.

29% of actions are specific to the transport sector and 16% of actions planned are to control road dust.


53% of actions are specific to the transport sector. 

Only 26% of the activities fall under the scope of the pollution control board. Urban local bodies and the transport department are responsible for 60% of activities.

Key learnings from CAPs in Himalayan cities

Unlike the cities in Central and South India, cities on the Indo-Gangetic plain are adversely affected by winter weather patterns. This happens in two ways: 

(i) An invisible blanket of air compresses the air to the ground and diminishes its ability to mix, thereby enhancing pollution levels near the ground 

(2) Increased need for space heating in places that witness lower temperatures.  

This phenomenon is more pronounced in Himalayan cities like Dehradun, Shimla and Srinagar, to the extent where domestic space heating and its emissions from local and regional burning of biomass and coal is the largest contributor to annual PM 2.5 levels. 

Here we need more customized and seasonal interventions to bring down the overall pollution levels.

Role of municipal bodies

Across all action plans, pollution control boards oversee only 24%, municipal corporations and urban local bodies oversee 37% and multiple agencies (including local bodies) oversee 40% of the mitigation activities. This underlines the fact that municipal bodies are crucial for final implementation of the activities and their accountability is key to the success of the NCAP.

Recommendations for the road ahead

We need to consider a long-term view for effective air quality management. Preparation of action plans is only the beginning of the process and this is not a one-time job.

Once a city has been designated as a non-attainment city, preparation, periodic update, and review of plans should be mandated by law

Every city needs to assess and integrate source information to prioritise actions

Every action plan must account for its financial requirements

Plans should clearly delineate the responsibilities of participating agencies for better implementation of the actions and effective management of overall air quality

Cities need to establish an inter-state and inter-city coordination mechanism, to account for managing pollution from long-range transport.

Cities need to enhance their ambient monitoring capacity, in order to track changes (benefits or fallouts) in the air quality, which is the key ingredient of effective air quality management.

Plans also need to report interim milestones and sectoral emission reduction targets. The responsible agencies should identify key indicators that can be tracked to monitor the impact of their interventions.

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