New Delhi: Provide the public with regular information about polluters and fine industries for emissions that exceed legal limits.

These are two of five “evidence-based” recommendations to tackle air pollution across India, according to a 2018 policy brief prepared by researchers of the Energy Policy Institute of the University of Chicago (EPIC) and Evidence for Policy Design (EPoD) programme at the Harvard Kennedy School in Boston.

The other three: Stop industries from paying supposedly independent laboratories to audit their smokestacks, provide regulators with real-time emissions data and allow industries to trade their emissions, said the brief, released on August 16, 2018.

More than 660 million Indians live in areas that exceed the country’s standard (40 µg/m3 annual and 60 µg/m3 for 24 hours) for particulate matter (PM) 2.5, airborne particles 30 times finer than a human hair that can sicken or kill people by entering the lungs.

Indians would live a year longer if India were to achieve its national air quality standards; life expectancy would increase by four years if India could meet pollution standards--10 µg/m3, or three times tighter--set by the World Health Organization (WHO), said the brief.

“Some of the greatest gains would be seen in the country’s largest cities such as Delhi,” said the policy brief adding that similar gains are expected across the Indo-Gangetic plain, including in the rural areas. “There, people would live six years longer if air quality met the national standards.”

In 2015, only one in 1,000 Indians lived in areas where particulate pollution did not exceed WHO annual safe levels for PM 2.5 of 10 µg/m3 , IndiaSpend reported on January 18, 2018.

In 2015, as many as 1.09 million deaths in India were attributed to PM 2.5 pollution, our report said.

“Air pollution is causing hundreds of millions of people in India to lead shorter and sicker lives,” said Michael Greenstone, co-author of the policy brief, in a university release. He is the Milton Friedman professor in economics and the director of EPIC and the Tata Centre for Development at the University of Chicago.

The crux of the recommendations relates to improving air quality by regulating emissions from major polluting industries without harming India’s industrial economy.

“However, we are at the dawn of a new era where the combination of advances in computing power and big data are creating radical new opportunities for environmental regulations to reduce air pollution, without undermining the urgent goal of robust economic growth in India,” said Greenstone.

Here’s an analysis of the recommendations:

Improve emission monitoring by making audits independent

To check if industries are complying with air pollution standards, regulators, such as the Central Pollution Control Board (CPCB) or various State Pollution Control Boards (SPCBs), rely on manual inspections of the industry stacks (chimneys). In many cases, industries are allowed to hire accredited laboratories (labs) to check their own pollution.

This practice produce “biased” results, said the policy brief.

In Gujarat, “monitoring reports carried out by accredited third-party labs were found to be heavily biased”, the policy brief said. About “29% of industries were falsely reported to be in compliance” by these labs and reason behind the bias was found to be “the conflict of interest”, since the industries were paying environmental labs for these tests.

Auditors should be randomly allocated to industries to check pollution, and they should be paid from a fund independent of the industries involved. Independent back checks of their sample results should be performed, and they should be penalised if their results show a bias, the brief recommended.

In one such exercise taken up in collaboration with the Gujarat Pollution Control Board, false reports of industry compliance were reduced by 80%, said the brief.

Provide regulators with real-time data on emissions

The lack of quality data on the smokestack pollution of industries has hindered regulation of polluting industries.

In 2014, the CPCB ordered the installation of “continuous emissions monitoring systems (CEMS)”--meant for real-time monitoring of stack emissions--across 17 categories of “highly polluting” industries.

Many SPCBs, however, require “substantial capacity-building efforts” to scrutinise data, oversee calibration and use data for enforcement, the brief said.

“For example, CEMS still require manual calibration,” the brief said, referring to the process of evaluating and adjusting the precision and accuracy of measurement equipment used in real-time monitoring. “SPCBs must ensure that conflicts of interest are eliminated, and data quality protocols are followed to detect and take action against data corruption.”

Provide the public with information about polluters

People should have access to emissions records and results of inspections of industries, generally limited to regulators, suggested the policy brief.

“Public disclosure of this information can lead to public pressure from civil society groups, as well as pressure from investors and peer industrial plants, and nudge polluters towards better behavior,” the brief said.

However, emissions data could be hard to comprehend for the lay public. But a ratings programme piloted by Maharashtra Pollution Control Board (MPCB), in collaboration with the researchers from EPIC India and EPoD, shows a way.

Maharashtra Star Rating Program, as it is called, rates hundreds of large industrial plants on a 1- to 5-star scale, IndiaSpend reported on June 26, 2017.

The best-performing industries receive five stars. Those with the highest density of emissions receive only one star. Industry, government and the public can then log onto the MPCB website to access the report cards for plants in their area.

“The potential to earn a 5-star rating provides an incentive for polluters to maintain low levels of emissions,” said the brief.

A “good part” of the work in our star-rating project in Maharashtra is taking data that is hard to understand and making it comprehensible, Rohini Pande, professor of International Political Economy and co-director of EPoD at Harvard Kennedy School, told IndiaSpend.

Beyond ratings, the website of MPCB makes the pollution information appealing to the public, with colorful graphics to convey the type of industry, the location on a map and a feedback button that connects the public to industries.

“All of this is costly and beyond the scope of what pollution control boards are required to do,” said Pande, adding that if future transparency initiatives are to work without a research budget, civil society and the media would need to translate open data for the public.

“Still, the point remains that all of this depends on the government making data public in the first place,” she said.

After Maharashtra, the Odisha State Pollution Control Board (OSPCB) will launch its own star-rating programme. OSPCB’s ratings will be based on CEMS data and will be updated every month.

“The adoption of similar transparency and public disclosure initiatives across India would lead to a radical change in efforts to control industrial pollution,” the brief said.

Use fines for excess emissions

India should use monetary penalties against polluting industries. “[This] would increase the flexibility that regulators have in responding to environmental offences, widening the number of polluters facing regulatory action,” said the brief.

Indian environmental laws rely on criminal penalties, such as plant closures and investment hold-ups, to keep industries in compliance. These “inflexible regulation” tools lead to action against a fraction of major violators, while many others are let off, the brief said.

So, the question: Would industries be getting away easily by paying fines?

When you add positive as well as negative incentives, you are more likely to turn industries away from “undesirable actions”, but, “this is entirely absent from India's policy landscape”, said Pande.

More detailed pollution data can lead to steeper fines for greater violations, and “small transgressions” can be "affordable", Pande said. “The same readings can allow us to reward industries that are emitting below the standard,” she said.

Allow industries to trade emissions

Industries should be allowed to trade their emissions, with caps, and trading markets should be established in industrial clusters.

Under a cap-and-trade system, aggregate emissions from regulated industries are capped; industries need permits for each unit of emissions; the number of permits is equal to the cap; and industries are allowed to trade permits, said the brief.

“The cap-and-trade system allows industries to strike a balance between reducing their own emissions through various abatement measures and purchasing permits,” it said.

Under traditional command-and-control regulations, polluters may be willing to trade off the risk of being detected and penalised with the “avoided costs” of compliance, particularly if “abatement costs” are high and enforcement capacity is limited, said the brief.

(Tripathi is a principal correspondent with IndiaSpend.)

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