Delhi Air Pollution: Are Harsher Penalties for Stubble Burning Missing the Mark?

A new CSE study found that stubble burning isn't the real culprit, contributing only 8% to Delhi's air pollution.

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Last week, the Central government updated its air quality management rules, increasing the penalties for stubble burning, effective immediately. The penalties now stand at Rs 10,000 for farmers who have two to five acres of land, and Rs 30,000 for farmers with more than five acres.

The notification came days after the Supreme Court pulled up the government over its inaction in combatting air pollution in Delhi, calling the Environmental Protection Act 'toothless'.

Around the same time, however, a new study by the Centre for Science and Environment (CSE), a Delhi-based environmental think tank, pointed out that stubble burning contributes only 8 percent to Delhi's air pollution.

If that's the case, is increasing penalties just another example of bike shedding, focused more on optics than substance?

What are the real polluters – and why are we failing to implement effective solutions where they matter most?

What's Polluting Delhi Air?

The data on stubble burning is complex, and its contribution to air pollution can vary depending on the day, the direction of winds, and the area of farmland being burned.

According to the CSE study, the average farm fire contributed 0.7 percent of Delhi's air pollution between 10 and 20 October. During the same period, the AQI in the city ranged between 155 and 240 ('very unhealthy').

This is not to say that stubble burning doesn't add to the toxic air. Daily data by the Indian Institute of Tropical Meteorology (IITM), Pune, shows that the contribution of stubble burning to the PM2.5 mass concentration in Delhi has steadily increased since 20 October. However, it's also been consistently less than 25 percent per day.

Over the past few years, the incidents of stubble burning too have reduced.

Data from the Environment Ministry indicate that stubble fires in Haryana, Punjab, Uttar Pradesh, Rajasthan and Delhi have reduced by 54.2 percent in 2022 compared to 2021, and by 44.3 percent in 2023 compared to 2022.

"This year we have seen that over the past week, there's been a change in the wind direction. We have been seeing winds coming from the south and south-east direction," says Sunil Dahiya, founder and lead analyst, Envirocatalysts.

This is an important detail because, according to experts, toxic emissions from stubble burning enter the city when winds blow from the northwest (Haryana and Punjab), where incidents of stubble burning are much higher than the other direction (Uttar Pradesh).

Local Sources to Blame: What Are They?

According to the study authors, local sources, particularly vehicular pollution (40-50 percent of the emissions) within the city, is the top polluter. Industrial pollution and waste burning are also major concerns.

"Local sources are the primary contributors to the elevated PM2.5 levels in Delhi, as concentrations remained high even when the impact of stubble burning was minimal."

CSE India

Prof P K Joshi from the School of Environmental Sciences, Jawaharlal Nehru University, New Delhi explains, "Chemical reactions between emissions from vehicles, industries, and other sources lead to the formation of secondary aerosols." He explains that these lead to a high concentration of SOx, NOx, and PM2.5 – fine particles notorious for being able to travel deep into your lungs and even bloodstream causing short-term and long-term health issues – in the air.

These are also sources that persist all year round.

According to the findings of the CSE study, Delhi needs to cut 60 percent of its current air pollution to meet the target of the National Ambient Air Quality Standards for PM2.5.

Why Are the Pollution Plans Failing?

A Graded Response Action Plan (GRAP) was implemented by the Commission for Air Quality Management (CAQM) in the Delhi-NCR and adjoining areas in August. Some of the measures included:

• Mechanical/vacuum sweeping

• Water sprinkling

• Using dust suppressants and proper dust disposal on heavy traffic corridors and designated sites

• 'Enhance vehicle parking fees to discourage private transport'

According to the experts, the failure of these measures to curb air pollution in the city is largely due to a narrow focus on these 'low hanging fruits' and 'quick fixes', rather than tackling the core issues – vehicular and industrial emissions.

• Short-sighted quick fixes

According to Dahiya, "There is no evidence that measures like using water sprinklers and antismog guns are effective in fixing air pollution in the long run."

He goes on to explain that while they can help in small locations for a short period of time, like at a construction site, these measures aren't effective in reducing air pollution across a whole city.

There is no government data available on the impact of these measures in bringing down pollution in the city over the years either.

"When Delhi is facing severe water shortage, you are using water for this (when there isn't enough evidence to suggest it works). It's absurd," adds Dr Bhargav Krishna, an environmental health researcher at Sustainable Futures Collaborative, an independent research organisation.

Prof Joshi adds,

"These measures focus primarily on Delhi and its immediate surroundings, with limited coordination at the regional level to address cross-border pollution sources."

The Quint reached out to Secretary, CAQM, and Chief Secretary of Delhi with a detailed questionnaire on the implementation and effectiveness of these measures, but we haven't received a response yet.

• A narrow focus

In 2019, the Ministry of Environment, Forest and Climate Change introduced the national clean air programme to encourage cities and states to look for long-term solutions to air pollution. However, over the years, the focus has been restricted to PM10. "This has narrowed this effort a lot," Natasha Chandy, head of programme, air quality network at Asar, tells The Quint.

"Right now, we have decided that dust (PM10) is the major pollutant, and as a result you have major investment going into equipment and measures to deal with this like water sprinklers and road sweepers."

Dr Bhargav Krishna

According to a press release by the Union Minister of State for Environment, Forest and Climate Change in December 2023, 90 cities out of 131 cities saw an improvement in air quality in FY2022-23.

"This assessment was solely based on PM10 levels. This doesn't make any sense. You're essentially saying that because PM10 levels are down, pollution is down," says another environment policy expert who didn't want to be named.

The expert added, "Clean air action plans, including the NACP, completely ignore long-term and insidious sources like industries, power plants, vehicles, waste burning, and MSMEs."

Beyond the Optics: What Need to Be Done?

These short-term measures under GRAP are steps to help reduce pollutants in the air after the damage is already done, experts opine.

"Most of the measures taken by the government are often reactionary rather than proactive. Measures are typically intensified only once pollution levels have already escalated to severe levels, which limits their effectiveness."

Prof PK Joshi, School of Environmental Sciences, Jawaharlal Nehru University, New Delhi

All this while the explosion of private vehicles and cabs on the roads remain unaddressed.

Dahiya says, "The Bharat Stage (BS) VI emission standards implemented in 2020 (it mandated that all private vehicles over 10 years of age must be taken off the roads) did help reduce vehicular pollution. But the number of new vehicles constantly added on the road is so high that it offsets the gains we made."

To counter this, not enough tangible action is being taken. What is the incentive for a car owner or someone who can afford a taxi cab to switch to public transportation?

"A move like this (higher parking charges) would only promote the use of public transportation if there is a robust infrastructure of public transportation in place as an alternative. Otherwise, someone who can afford a private vehicle would also rather pay the Rs 20-30 extra for parking than switch to public transportation."

Sunil Dahiya

Another major issue is the availability of road spaces for pedestrians.

As per the National Urban Transport Policy of 2006, which was reviewed in 2014, the first right to the road space should be given to a pedestrian, then to a cyclist, then to public transportation (buses), and then the remaining space should be for private transportation.

This policy has not been enforced in the 18 years since its inception.

So, the question stands – why the reluctance to act on measures that can truly make a difference?

According to Prof Joshi, the issue isn't a lack of laws and mandates, but their poor implementation.

There are laws in place to reduce emissions from construction, industrial activity and even waste disposal. But, he says,

"Enforcement agencies struggle to monitor and implement fines, and the adherence to the construction site and industrial emission standards are often ignored."

These policies are also often controlled by both local and central authorities, and coordination issues often lead to disjointed policy enforcement. For example, policies to restrict diesel use often conflict with policies to boost commercial activity that relies on diesel-based logistics.

Even with the willingness to act, there is a glaring absence of a strong, effective mechanism for action on the ground.

Dr Krishna explains, "We are currently dealing with an under capacitated state that is not equipped to deal with this issue because it lacks the technical expertise and the institutional leadership capable of dealing with these complex challenges."

"Dust is easier to manage than complicated, hard-to-regulate, decentralised sources of pollution like industrial emissions where a complex network of multiple stakeholders are involved."

Dr Bhargav Krishna

The bottomline is that for lasting improvements, Delhi’s approach to air quality needs a structural overhaul, moving away from seasonal, reactive measures to a year-round, multi-pronged strategy focused on prevention, enforcement, and coordination. 

And, "it will require us to consider the quality of air as an intrinsic part of the way we plan our cities," says Chandy.