We have been barking up the wrong tree on air pollution

On its 46th foundation day, the Central Pollution Control Board (CPCB) released two reports that should force us to re-examine our approach towards controlling air pollution.

The first report is the ‘National Ambient Air Quality Status & Trends 2019’, which contains air quality data for 344 cities/ towns from 28 states and 6 UTs. This is the only report that gives a snapshot of the status of air pollution in the country.

The second is a report on the ‘Impact of the Lockdown on Ambient Air Quality’. This report compares data for 12 cities from different parts of the country, including Delhi and NCR towns, during the lockdown phases with the corresponding periods in 2019. The report also estimates the various sources on air pollution in Delhi by chemically analysing PM2.5 (particles less than 2.5 microns in size or fine particles) in different phases of lockdown. Furthermore, it measured PM2.5 concentrations using satellite to estimate the air quality improvement over the entire country.

Read in isolation, these two reports do not give us much new information than which is known or expected. For instance, it is known that air quality is a pan-India problem. Similarly, we all experienced cleaner air during lockdowns, and therefore, a dip in the ambient air quality levels was expected. But once we put these two reports together, a completely new picture emerges that puts a question mark on our approach so far in controlling air pollution and the way National Clean Air Programme (NCAP) is being implemented. Here are the major findings of these two reports:

India has predominantly a PM10 problem: Most cities are exceeding the National Ambient Air Quality Standards (NAAQS) for PM10 (particles less than 10 microns in size or coarse particles). About 78% of the cities exceeded PM10 standards compared to 36% for PM2.5, 9% for NO2 and none for SO2.

We are not winning the air pollution battle: The data for the last few years show that while the SO2 concentration has decreased and NO2 concentration has remained stable, the PM2.5 levels have increased and PM10 levels have remained very high and are fluctuating. So, the two problem parameters – PM2.5 and PM10 – are not showing any sign of abating. In fact, PM2.5 levels have increased significantly in the last three years.

The CPCB report also lays to rest the controversy about air quality improvements in Delhi. PM2.5 levels in Delhi have consistently increased in the last 3 years and were 144 micrograms per cubic meters (μg/m3) in 2019 – more than three times the standard.

The baseline pollution level in India is high: During the peak lockdown (March 25-April 19), ground based monitoring stations in 12 cities recorded average PM2.5 levels of 25-50 μg/m3 and PM10 levels of 50-110 μg/m3. The satellite recorded PM2.5 levels in different parts of the country as 29-76 μg/m3, with an all-India average of 59 μg/m3. These levels are double the WHO standards and almost the same as NAAQS.

So, when transportation and industries were down by 80%, coal power plants were operating at 40% capacity, and people were largely indoors, even in relatively less polluting months of March-April, the country was barely meeting NAAQS. This indicates that pollution from cooking fuel, agriculture and natural sources are sufficient to breach air quality norms in large parts of the country.

An interesting fact the report captures is that during the lockdown in Delhi, the ratio of PM2.5 to PM10 was higher than in 2019. This is contrary to the general understanding; one would have expected lower ratio during the lockdown because factories and vehicles were not operating. The only plausible reason seems to be that we have been underestimating the contribution of PM2.5 from cooking fuel and natural sources.

If we join the dots, what emerges is that controlling PM10 emissions is key to solving the air pollution crisis. This would mean reducing the burning of solid fuels like biomass and coal and controlling emissions from land and agriculture. But by mainly focussing on cities and vehicles, we have lost the plot on air pollution. I will discuss this in detail in my next column.

Rebuilding a sustainable economy post Covid

The global economy is in recession, and it is predicted to be more destructive than the Great Depression of 1929 and the Global Financial Crisis (GFC) of 2007. India too has been hit hard – tens of millions have lost their jobs, and the economy is projected to shrink by 4-9% in 2020-21. The last time the Indian economy contracted by more than 5% was in 1979 when the entire country was devastated by a once in a century drought (and some regions with floods).

Both Morarji Desai’s and Charan Singh’s governments fell, and we had mid-term elections which brought Indira Gandhi back into power. The fallout of this political upheaval was the founding of the Bharatiya Janata Party in early 1980, which successfully challenged the Congress and came to power within two decades. I believe that the India in which we live in today was in many ways created in 1979. The question is: What kind of India will the 2020 economic recession create? And, can we steer the ‘new’ India towards a more just, equitable and sustainable society?

A defining feature of the current economic crisis is the unprecedented fiscal and monetary stimulus packages being rolled out by the governments to provide relief and revive the economy. According to the International Monetary Fund, the total stimulus package for G20 countries averaged 12.1% of GDP – many times more than GFC. India too has announced a stimulus package worth 10% of GDP (though there are opposing views on this number). A quick analysis of the stimulus packages shows that they are primarily targeted to revive the current economy; hardly any country has thought about the long-term transition.

In India too, the focus is on the existing ‘brown economy’ and shovel-ready projects. The attention on the immediate crisis has also relegated climate and environmental concerns to the background. This is evident in the increasing plastic pollution and investments in the fossil fuel industry. Regulatory changes in the environment and labour sectors have also been proposed for the ‘ease of doing business’. While there is nothing wrong in short-term stimulus packages to keep the current economy alive, they must not be environmentally destructive. On the other hand, we also have to ensure that the long-term economic recovery takes into account the social and environmental crisis the world is facing today.

In other words, we must differentiate between a short-term stimulus to jumpstart an economy and a longer-term strategy to transition to a sustainable society. While the former mostly requires fiscal and monetary support, the latter requires long-term investments and serious pricing and policy reforms. The current economic crisis offers us a once in a lifetime opportunity to roll out a long-term strategy along with stimulus packages in core sectors:

  • Make agriculture sustainable: Agriculture accounts for 50% land, 85% water, uses a massive amount of chemicals and provides low-income livelihood to 50% of the population. Agriculture is central to building a sustainable society.
  • Transform the energy sector: We are at a cusp of change in the energy sector. With stimulus and R&D, we can build a new energy architecture based on renewable electricity, battery storage, smart grids and hydrogen fuel for industries.
  • Build resilient infrastructure: Massive amount of money will be spent by the government to build roads, airports, buildings etc as part of the stimulus package. We must make them ‘green’. Instead of roads, we should prioritise railways; instead of concrete jungles, we must build sustainable cities.
  • Invest in nature: Reversing deforestation and desertification and enhancing soil, wetlands and forests will build resilience against climate change and also provide massive livelihood opportunities.
  • Support local and small businesses: For jobs, sustainability and resilience of the supply chain, local small businesses are going to be the key. Government policies must support the development of efficient and green small businesses.
  • Invest in social capital and governance: None of the above would be possible without an educated and healthy society and good governance.

If we consider the experience of the past, then the economic recovery is going to be a long haul. The New Deal enacted by Franklin Roosevelt to respond to the Great Depression lasted for seven years (1933-39). Rebuilding in India will also need time and money. We must spend these rethinking about the type of economy and social system we need and want in the future.

India needs a new EIA law

The Draft Environment Impact Assessment (EIA) notification 2020 has become a hot potato for the ministry of environment, forest & climate change (MoEF&CC). First, the Delhi high court overruled the ministry’s decision on the time limit for public comments and increased it till August 11. Then, in response to a formal complaint of the environment minister for spamming his email account, the cybercrime unit of the Delhi police invoked a terrorism-related law to shut down the website of young environmental campaigners, who were running an online campaign against the draft notification.

Though the police have now withdrawn the notice, the public uproar against the draft notification continues. Reportedly, lakhs of people have written to MoEF&CC to scrap the draft. So why is there such a hullabaloo around this subordinate legislation?

Chad Crowe

The draft EIA notification 2020 seeks to replace the existing law – the EIA notification 2006 – which grants Environment Clearance (EC) to projects. The major criticisms against the new draft are that it dilutes scope of public participation, legalises post-facto EC, removes the requirements of EIA study for several categories of projects, and weakens the provisions of reporting by companies. To understand the significance of these changes, let’s look at the 2006 law.

The EIA notification 2006 is possibly the most amended piece of environmental law. It has been amended 43 times, and at least 50 office memorandums (worth 350 pages) have been issued to tweak this law. Many of these changes have diluted the original version for some or other industry. The 2020 draft, in large part, brings together several of these revisions.

Therefore, effectively the 2020 version is a little worse than the existing one. So, while I appreciate the criticism of the proposed draft, keeping the 2006 version or even improving it is not going to solve the environmental problems in the country either. Let me explain why.

First, the approach of conducting EIA of individual projects is bad science. The environment is affected by the cumulative impacts of all activities, which project-specific EIAs fail to capture. Even if individual projects meet all benchmarks, their cumulative effects may still destroy the environment. This is evident in most mining and industrial areas of the country – from Singrauli to Korba and from Vapi to Patancheru.

Second, the EIA report, which forms the basis for EC decisions, is prepared by a consultant paid by the project proponent. This creates an apparent conflict of interest, and therefore most EIA reports are not worth the paper they are written on. I am yet to come across an EIA report that says that a project is likely to have significant ecological impacts.

Third, the process of the public hearing, which is mandated to take into account the concerns of the project-affected people, is a sham. Public hearing as practised in India is neither an informed consultation nor an informed consent. Most times, it is organised in the presence of police force, and physical violence is not uncommon.

Worse still, concerns of the community are most often dealt with in a cursory way by the expert appraisal committees (EACs). EACs typically ask companies to make some investments like building schools or providing drinking water to appease the community. MoEF&CC has even formalised this by calling these expenditures as ‘corporate environment responsibility’ (CER) and directing companies to earmark 0.125-2% of the capital investment on CER.

Finally, the environmental conditions imposed on the companies are rarely monitored by authorities. Monitoring is based on self-certified half-yearly reports submitted by companies; this has been reduced to yearly report in the 2020 draft.

The fact is that the current EIA and EC process in India is defunct. While it involves a lot of paperwork, there is little improvement on the ground. 99.9% of the projects are cleared, and non-compliance of the safeguards is rampant. The paperwork and transaction costs, on the other hand, gives legitimacy to industries to argue for watering down the process further.

It is, therefore, time that we demand a new EIA law based on sound science, and robust and transparent decision making processes to safeguard environment and community rights as well as to reduce investment risks of industries. This can be achieved by integrating three environmental concepts.

The first is the strategic environmental assessment (SEA). SEA will help to evaluate the ecological ramification of policies and plans and address concerns at the earliest stage of the decision making process. Many countries have adopted SEA to integrate environmental concerns in policy making.

The second is the regional planning approach. This involves conducting carrying capacity studies and developing regional plans based on them. This will allow us to take into account cumulative impacts and also provide information to project proponents to decide the location of the projects beforehand.

The third is project specific EIAs. In this, EIAs should be done for major projects and not for all. The focus here should be to improve environmental management plans and post-clearance monitoring. To ensure quality EIA reports, an environment information centre should be established to provide independent data to consultants and the EACs. In all the three processes, public participation should be ensured to improve assessment and scrutiny.

The EIA process is the most important piece of environmental law as it has the scope to decide the development trajectory of the country. But this powerful piece of legislation has never been discussed or legislated by the Parliament. Time to take the EIA discourse to the Parliament floor and develop a new law suitable for the 21st century.

Over regulation will not solve plastic waste problems

An oft-repeated saying in India is that our environmental laws are good, but their implementation is poor. I have always disagreed with this simply because the primary reason for a law’s poor implementation lies in its flawed design. Most environmental laws in India are designed using a top-down approach, with an inadequate understanding of ground realities, leading to failed implementation. The recent draft guidelines published by the Ministry of Environment, Forest & Climate Change (MoEF&CC) on Extended Producers Responsibility (EPR) for plastic wastes is a classic example of this approach.

EPR is a ‘polluter pays’ principle under which producers and users of plastics, especially plastic packaging, have to take back plastic waste and recycle or dispose of them in an environmentally sound manner. The first regulation on EPR was enacted almost a decade back in the Plastic Waste (Management & Handling) Rules, 2011. The rules directed municipal authorities to set up plastic waste collection centres with financial support from the producers. The problem was that EPR was vaguely defined and the municipalities were not capacitated to implement the rules. This law was repealed within five years.

The Plastic Waste Management Rules, 2016 replaced the 2011 law. It introduced a slew of provisions for everyone in the plastics supply chain. Under EPR provisions, companies were directed to work out their own arrangements for collecting plastic waste and achieve 100% collection within two and a half years of enactment of the rules. Four years later, we are in 2020, and no company has fulfilled its EPR obligations. The new draft guidelines intend to amend this very situation.

It’s crucial to understand why companies have failed to meet their EPR obligations time and again. The main reason seems to be a combination of ambiguous laws, high regulatory burden, and inadequate time for implementation. For instance, under the 2016 rules, companies were asked to develop their modalities without any proper guidance. Some companies hired third party organisations called Producers Responsibility Organisations (PROs) to collect and dispose of wastes on their behalf. But, this was a colossal failure due to lack of formal coordination between PROs and municipalities.

Likewise, the regulatory burden was very high. Companies selling their products in multiple states had to register themselves in each state and meet state-wise EPR obligations. This became a logistic and accounting nightmare as companies now had to account for every kilogramme of plastic packaging sold through dealers/ sub-dealers in different states and collect back the same amount. Alongside this, the timeframe of two and a half years was just too short a window for companies to enact an EPR-compliant system.

It seems that MoEF&CC hasn’t learned from past failures – the 2020 draft guideline is prescriptive, top-down, and onerous. It proposes to register every producer/ brand owner/ importer, even those using a small amount of plastic for packaging their products. Similarly, it hopes to trace and account for every kilogramme of waste, through a system of multiple certifications and third party audits, using blockchain technology.

To compensate for the vagueness in 2011 and 2016 rules, the draft guidelines have allowed all possible EPR models without deciding which one is best suited for Indian conditions. Additionally, it has proposed a maze of licensing procedures, authorities, and committees at the Centre and in states to implement the law. In a nutshell, the draft EPR guidelines, if enacted, will likely again fail in implementation because it has ignored ground realities and put a high regulatory burden on companies.

If 20 years of plastic waste legislation has taught us anything – the first law was enacted in 1999 to ban (the still widely available) thin polythene bags – it’s that regulations and penalties are not sufficient to manage plastic waste; we need to transform the market and municipal services to solve this problem. Without strengthening and improving city waste management, we cannot hope to manage plastics. Moreover, the best way to reduce plastic waste is to find an alternative to plastics. An EPR policy that doesn’t recognise the need to decrease the use of plastics or create a straightforward, accessible model to support municipalities is bound to fail.

India is too poor to afford coal

As part of the stimulus package to revive the economy, the Union government has announced a slew of measures to boost production and reduce imports of coal. It has liberalised the sector, curtailed the monopoly of Coal India Limited (CIL), and has announced an investment of Rs 50,000 crore for coal transportation infrastructure. All this has been done to double coal production in the next four years – from 730 million tonnes in 2019-20 to 1.5 billion tonnes in 2023-24. The question is: Can India afford such a massive increase in coal consumption?

Till three years back, coal was the cheapest source of electricity. Then in May 2017, the solar power tariff nosedived to Rs 2.62/kWh – 20% lower than the coal based power tariff of NTPC – and changed the energy market forever. Since then the coal power prices have kept increasing because of the increase in coal mining and transportation costs, while the costs of renewable and energy storage systems have continued reducing on the back of global and local innovations.

Just three weeks back, the Solar Energy Corporation of India awarded a project to ReNew Power to supply 400 MW of renewable energy, round the clock, at a tariff of Rs 2.90/kWh. Very few, if any, new coal power plants can compete with this tariff. In fact, the business case to install a new coal power plant is fast vanishing with such steep reduction in the prices of renewables with storage.

The business case entirely erodes if one includes health and environmental costs. Coal is the single largest source of air pollution and CO2 emissions in India. About half of all the CO2 emissions come from burning coal, and coal power plants account for 60% of particulate and 50% of sulphur dioxide emissions of the entire industrial sector. Deaths and diseases due to air pollution cost India a GDP loss of more than 5% and coal-related pollution constitutes a significant proportion of this. If we add carbon price and pollution cost to coal, then we should be shutting down even the existing power plants.

The private sector understands these risks and has practically stopped investing in coal power. According to a report published jointly by Global Energy Monitor, Sierra Club and others, a staggering 47,400 MW worth of coal power projects, mainly of the private sector, was scrapped in India in 2019. The private sector, instead, is now investing in renewable energy. In 2019, more than two-thirds of all the new power plants constructed in India were based on renewables, with the bulk of investments coming from the private sector and FDIs. The question, therefore, is why in the face of an overwhelming case against coal, the government is still promoting it?

The reason seems to be twofold: One, coal is viewed as the foundation of energy security and self-reliance (Atmanirbhar Bharat); and two, it is considered as a shovel-ready venture to revive the economy in parts of central and eastern India (about 25 districts) that are primarily dependent on coal for growth and employment. While these reasons can be justified as short-term expediency, they would become a liability very soon.

We need to understand that the investments made today will lock our economy to expensive coal for the next 20-30 years. This will limit our scope of innovation and reduce the pace of transition to clean and cheap renewable energy. We will, therefore, be paying a high cost of energy even when much more affordable options would be available. Can India, which already has one of the highest costs of energy in the world, afford this?

As far as coal mining areas are concerned, they have been suffering from ‘resource curse’ for decades. Most coal districts are polluted and poor with some of the worst human development indicators.

More coal mining will perpetuate the status quo. The need, therefore, is of economic diversification and a ‘just transition’ plan for these districts to reduce their dependence on coal.

If Covid-19 pandemic has taught us anything, it is that our current economic system is akin to ‘sawing-off the branch on which we are sitting’. By investing in coal, we will exacerbate climate change, increase air pollution and make energy more expensive in the future. We need an Atmanirbhar Bharat, but atmanirbharta (self-reliance) must also be affordable and sustainable.

The truth about air pollution in Delhi

Contrary to the claims made by the Delhi government, air pollution in the city has deteriorated significantly since 2012.

To understand the exact situation of pollution in the city, one has to understand the status of air pollution monitoring.

There is an irony being played out in Delhi. While the national capital is reeling under one of its worst spells of air pollution, the Delhi government is bringing out a series of advertisements claiming that the pollution levels are down by 25%.

The advertisements mention that the levels of PM 2.5—particulate matter of size less than 2.5 microns—have reduced from 154 microgrammes per cubic meter (µg/m3) during 2012-2014 to 115 µg/m3 during 2016-2018. If this claim is valid, then we are on the right path, and we should continue with the current action plan to control air pollution. If it is not, then we should seriously change track and develop a new blueprint.

To understand the exact situation of pollution in the city, one has to understand the status of air pollution monitoring. Delhi has the largest number of air quality monitors in the country—47 monitoring stations, to be precise. Out of these, 10 are manual monitors, and 37 are continuous monitors. Four agencies own these monitors—the Central Pollution Control Board (CPCB) has 13 monitors, Delhi Pollution Control Committee (DPCC) has 24, India Meteorological Department (IMD) has 7 monitors, and the National Environmental Engineering Research Institute (NEERI) has 3.

Continuous monitors give pollution readings every 15 minutes, and these are used for calculating the Air Quality Index (AQI). CPCB has developed data validation criteria for these monitors. For example, continuous monitors must be operational for 16 hours in a day for estimating daily pollution levels. Similarly, they must be operational for 80% of the time in a year for determining the annual pollution levels.

In manual monitors, the monitoring is carried out for 24 hours, with a frequency of twice a week. There must be a minimum of 104 readings in a year for estimating annual pollution levels. In India, data from manual monitors are still used to make country-wide comparisons on the status of air pollution. The reason is simple: we have 573 manual stations in 240 cities/towns compared to just 202 continuous monitors in 112 cities/towns. Manual monitors, therefore, are sentinel monitors as they have comparable data for the longest time-frame.

As one can see in the accompanying graphic, continuous monitoring is a recent phenomenon in Delhi. Twenty continuous monitors were installed in 2018, and seven were introduced in 2017. We have data from only four monitors for 2012 onwards. But, there are significant data gaps from these four monitors. For instance, the Dilshad Garden monitoring station had correct data for only 32 days for 2013; the ITO station has data for less than 50% of the time for 2012, 2014, and 2016; and RK Puram has no data for 2013, and 2014. Most researchers have concluded that using data from the continuous monitors to estimate annual pollution levels for the years 2012 to 2016 is statistically wrong. Therefore, one has to rely on manual monitors to establish whether the pollution status has improved or deteriorated since 2012.

The data from manual monitors, published by CPCB, shows that the amount of PM 2.5 has almost doubled between 2012 and 2018—from 63 µg/m3 in 2012 to 121 µg/m3 in 2018. The average PM 2.5 level during 2012-2014 was 72 µg/m3, and during 2016-18, it was 115 µg/m3—an increase of 59%. So, air pollution levels in Delhi have increased significantly, and not reduced. From where, then, has the Delhi government put together data to show a reduction of 25%? Interestingly, there is another set of data put out by DPCC, which is less publicised. This DPCC data shows that the average level of PM 2.5 was 154 µg/m3 during 2012-14, which reduced to 131 µg/m3 during 2016-2018—a reduction of 15%. DPCC data, however, comes with a disclaimer. It clearly states that for the period 2012-2017, the data is based on four continuous monitors, and the 2018 information is based on 26 monitors. As explained above, the data from the four continuous monitors are incomplete. They cannot be the basis for estimating pollution levels during the 2012-2017 period. Even if we had complete data from the four continuous monitors, comparing data of four monitors with that from 26 monitors is highly spurious. It will not stand even the basic statistical scrutiny.

Nevertheless, let’s take the DPCC data with a pinch of salt, and put it together with the CPCB data. We can see, in the accompanying graphic, where the mistake has happened. The Delhi government has taken continuous monitoring data of DPCC for the period 2012-2014 and manual monitoring data of CPCB for the period 2016-2018 to claim that air pollution reduced by 25%. This is cherry-picking, and completely wrong. These types of analyses cannot be the basis for decision-making.

Let me end by saying that I support CM Arvind Kejriwal on stubble burning. He is absolutely right that the spike in pollution post-Diwali is because of stubble burning. One can smell biomass burning in the air, and we need to do something about this urgently. But, he is wrong to claim that his actions have led to a 25% reduction in pollution levels. Instead of putting out wrong information, it is important that his government goes back to the drawing board and develops a new blueprint for saving this historical city from Airpocalypse.

Environment needs technology and innovation

Chandra Bhushan: ‘We will be very engaged in the climate change debate’

This article originally appeared on Civil Society.

It is not common to find a hard-nosed environmentalist with a fan following in the boardrooms of corporations. Chandra Bhushan is one such.

As the leader of the Green Rating Project at the Centre for Science and Environment (CSE), Bhushan held an unwavering mirror to the standards of industries such as paper, cement, automobiles and mining.

Company after company was persuaded to improve technologies and processes. A space was created for engagement with senior management, which learnt to abandon stealth for a willingness to talk openly about where their factories were falling short.

Bhushan has now set up iFOREST or the International Forum for Environment Sustainability and Technology. An engineer by training, he believes modern technologies and innovation can bring quantum improvements in the environment. Dr R.A. Mashelkar heads the iFOREST board.

Bhushan was with CSE for 22 years. He was handpicked by the late Anil Agarwal and was a disciple who learnt from him how to be combative and collaborative at the same time. After Agarwal died, Bhushan worked closely with Sunita Narain on several impactful campaigns. He led many of CSE’s research programmes. 

We spoke to Bhushan on his plans for iFOREST and how he sees the path ahead through the maze of India’s environmental problems.

You are leaving CSE after 22 years. After having worked closely on so many frontline issues what will you be doing now?

I had a wonderful journey at CSE. As an institution we achieved many milestones especially at a time when environmentalism in India was at a very nascent stage and people didn’t have information. That’s when Anil (Agarwal) came in with the State of India’s Environment report, Down to Earth began as an environmental magazine and research teams were set up at CSE. Some basic environment laws and regulations were put in place. CSE was at the right place at the right time, poised to become one of the leaders of the environment movement in India.

Today the language of environment has been mainstreamed. Everyone talks of environmentalism and every government has a paper on the environment. The challenge is how do you scale up implementation.

I have been thinking about this for quite some time. The era of top-down policy is over. The question is, how do you convert policy into a scaled-up model for implementation?

That is the real challenge the country faces today and that is what motivated me to embark on my next journey where I could look at policy design and, more importantly, at innovation. I think we are in an era where technology is available for large-scale innovation and scaled-up work in the field of environment.

So, policy design, innovation and scaled-up implementation — these are the three core pillars we will be building on.

You have worked closely and fruitfully with industry. Based on this kind of experience what are the areas you would focus on?

Absolutely. I was fortunate perhaps to lead the only programme in the environmental movement in India which engaged fruitfully with industry on the same platform, at the same level. When I was releasing the Green Rating report on the cement industry I was speaking to industry leaders and Anupam Mishraji was sitting in the front. Post the report’s release he came up to me, took my hand and said, ‘This is Gandhism at its best’. 

At that time I didn’t understand what he meant. Later, I realised he was essentially saying that speaking truth to power is what Gandhi did. The Green Rating project did exactly that.

We spoke truth to the most powerful industrialists in India. Initially, they were resistant. But once they understood the unbiased nature of the rating and the foundation of goodwill it had for industry and the environment, they all came out to support us — from Gautam Thapar to Harsh Pati Singhania to Yogi Deveshwar…

In fact, Deveshwar was a big fan of the Green Rating project. Recently, after his passing away, I met some of his colleagues from ITC. They narrated a story which really warmed my heart.

In our first paper industry rating we had given the worst rating to ITC. Deveshwar called a board meeting in which he said, Who the hell is this Chandra Bhushan who says we are the worst paper plant in India. The next time he rates us, make sure we are the best. And that is exactly what happened. Four years later, when I rated ITC again, the company had the best paper plant in India.

This tells me that without engagement with industry and businesses you cannot improve environment in India. Environment cannot be solved by government alone. In fact, I always say environment is too important to be left to the government. We need industry engagement, financial sector engagement and public participation. Only then will we be able to resolve environmental issues.

One of the pillars of our work will be green economics. How do we green, not only industry, but the financial sector so that there is market support for the environmentalism that we want.

To take it to spaces where strife happens?

I would say to take it to uncomfortable spaces for environmentalists like me.

Like?

See, one of the problems in the environment movement is that we do not know how to engage with businesses. It’s very easy for other environmentalists to accuse you of being on the side of business even if you are engaging at the same level, even if there is no financial transaction. So it’s a very uncomfortable space to be in.

But the Green Rating project taught me that the way to navigate that uncomfortable space is to be open and transparent. So for the Green Rating project, every letter I wrote to industry or received from industry, every report that we published, I would get put up on the website. Then there was no scope for any kind of negative publicity to happen.

When you talk of NGOs and activists being adversarial for a long time, actually industry, even now to some extent, is adversarial in its own way. Despite that, in 22 years you have seen a change.

Absolutely. I have seen change. I have seen a time when no industry had an environment policy, when in the corporate boardroom, environment was not discussed. Today, every industry I go to has a subcommittee on environment and sustainability.

That’s a big change.

It is. People are discussing environment in their boardrooms which is a tremendous change. That discussion has to also become more real and more implementable. I am quite hopeful in an era of climate change, industry is realising that their businesses are at stake. One episode of extreme weather can wipe out a plant. Think about what happened in Pune, Patna and other cities. There were plants that were wiped out. So I think industry is realising that climate change and other environment issues are a threat to business.

Will climate change be one of the key areas you will be taking up?

Yes. We will be very engaged in the climate change movement because the solutions to climate change are going to be extremely challenging. We have to change the energy system.

But that’s a big issue.

Actually, changing the energy system is the easy part. We have the technology. We have wind and solar and we already live in a battery world. I mean, can you live without your mobile and laptop? So we are living in a battery world except that it has to be enlarged. The question is: how do you produce steel and cement? How do you produce food? How do you transform the transportation sector and the aviation sector? These are the big challenges we face and these are also core industries.

So what will you be working on, initially?

We have decided to work on four pillars in an integrated way. The first is livable and sustainable cities. Globally, more people live in cities already. I’m quite sure that when the 2020 census results come in 2022, you will find 40 to 50 percent of India’s population living in cities. So cities are going to define the sustainability of the nation. Not rural areas. 

The second pillar, which I am very excited about, is an integrated programme on agriculture, land, forests and water. See, most environmental problems focus only on land management. Everything is about land. We will discuss climate change adaptation and other issues.

The third is energy and climate change. We will be discussing transition. It is an irony that climate change will lead to huge transfer of wealth. The poorest part of India is where the coal is and the richest part of India is where renewable energy is located. If you close down coal mines, what happens to the Jharkhands and Jharias? They are polluted, it is true, but there is economic activity happening there. How do you make the transition from coal to renewables without disrupting livelihoods in poor regions?  

What do we do about coal?

I think we have 30 years to close down coal. Whenever someone says close down coal I give them a perspective. I tell them to think about 30 years ago. We had floppy discs, then. Today, we have more computing power than Apollo 11 in our hands. Thirty years is a long time for the world to change. There is also pressure for change to happen.

My sense is you have to build an alternative economy and industries in those areas. Coal will not end because we have renewable technology. Coal will end if there is political support and grassroots support to say, yes, we are now ready to transition from coal.

The fourth area is green economics where we will work very closely with the financial sector and industry.

In terms of coal, and this is so important to the nation, what do we do in the interim? Obviously, it makes sense to use our coal but at the same time you live in a warming world.

It isn’t just about India closing coal. It’s about the world moving away from coal. What should be the principle on which this should happen? And the principle I have arrived at is based on depreciation. If a plant has depreciated — covered its capital, interest, benefits… then it should be closed down.

If you draw a map of the world and place all the coal plants according to depreciation, you will find the oldest plants, whose average age is 40 years, are in the US. So it is immediately possible to start closing down US plants. There is Europe which also has old plants. If we use this principle then India should perhaps start closing its plants from 2030 and complete this process by 2050.

But during this interim period what should we do?

I think we should promote clean coal, high-efficiency utilisation of coal, reduce our T&D losses — we lose 30 percent of our electricity — and improve energy efficiency so for every unit of coal we get more economic and social output. This is what the roadmap should be and we have 30 years for this transition to take place.

Who do you think will fund iFOREST?

It will remain a publicly funded organisation. I do not see the colour of money.  I see its quality. So even if it is less money it should allow you to do good work. We need money with patience. Right now the money that comes to the NGO sector doesn’t have patience. The funders want a report the very next month. In this field, if you want to do good work you need money with quality and patience. My board is very keen that we raise as much Indian money as possible. 

पर्यावरण को बर्बाद कर रही भारत की पर्यटन संस्कृति

भारतीय पर्यटन उद्योग से हर साल लगभग 250 मिलियन टन से अधिक कार्बन डाई ऑक्साइड का उत्सर्जन होता है, जो कि भारत के कुल CO2 उत्सर्जन का लगभग 10% है। चिंताजनक बात यह है कि यह आंकड़ा साल दर साल तेजी से बढ़ता जा रहा है।

क्या होगा यदि मैं आपसे कहूं कि हमें अमरनाथ और वैष्णो देवी जैसे धार्मिक स्थलों पर तीर्थयात्रियों की संख्या को सीमित करने की आवश्यकता है? क्या होगा अगर मैं आपको बताऊं कि शिमला, महाबलेश्वर और गंगटोक जैसे हिल स्टेशनों पर उनकी क्षमता से अधिक मात्रा में पर्यटक आ रहे हैं और उन्हें रोकने की जरुरत है? कई लोग इसे संविधान में उल्लिखित स्वतंत्रता के अधिकार और धार्मिक स्वतंत्रता के अधिकारों के उल्लंघन के रुप में देखने लगेंगे। लेकिन सच्चाई यही है कि ऐसी जगहें अपने अस्तित्व को बचाने की लड़ाई लड़ रही हैं और इसके लिए हमें पर्यटकों की संख्या को सीमित करने की जरुरत है।

इस साल जून में, मनाली में पर्यटकों की संख्या इतनी अधिक हो गई थी कि हजारों वाहनों ने इस हिल स्टेशन के सभी छोटे और बड़े रास्तों को जाम कर दिया था। इस जाम की वजह से कुल्लू से रोहतांग पास जाने वाले रास्ते पर हजारों पर्यटक पूरी रात फंसे रहे। लोग खुले में शौच करने को मजबूर हो गए थे और वायु प्रदूषण का स्तर भी काफी बढ़ गया था।

इस तरह की स्थिति सभी प्रमुख पर्यटन केंद्रों पर होने की संभावना है। कारण बहुत साफ है- जैसे-जैसे भारत का निम्न-मध्यम वर्ग अमीर हो रहा है और लोगों के पास खर्च करने के लिए अतिरिक्त पैसे भी बढ़ रहे हैं। पर्यटन उनको आकर्षित कर रहा है। यही कारण है कि भारत में यात्रा और पर्यटन से जुड़ा क्षेत्र सबसे तेजी से विकसित होने वाले उद्योगों में से एक है। 2018 की जीडीपी में इसका योगदान लगभग 9% यानी लगभग 17.5 लाख करोड़ रुपये था।

लेकिन यह विकास पर्यावरण और पारिस्थितिकी से समझौते के बदले हो रहा है। दुनिया भर में तेजी से हो रहे पर्यावरण परिवर्तन में पर्यटन क्षेत्र पर बढ़ रहे दबाव का भी अहम योगदान है। भारतीय पर्यटन उद्योग से हर साल लगभग 250 मिलियन टन से अधिक कार्बन डाई ऑक्साइड का उत्सर्जन होता है, जो कि भारत के कुल CO2 उत्सर्जन का लगभग 10% है। चिंताजनक बात यह है कि यह आंकड़ा साल दर साल तेजी से बढ़ता जा रहा है।

हालांकि कई पर्यटक स्थल ऐसे भी हैं जो कि अपने आप को प्रदूषण से बचाए रखे हैं, लेकिन अधिकतर पर्यटक स्थलों की हालत बहुत खराब है और वे लगातार प्रदूषित हो रहे हैं। खासकर भारत का हिमालयी क्षेत्र ऐसे पर्यटन का केंद्र बन चुका है।

अगर हम लद्दाख का ही उदाहरण लें। ठंडा रेगिस्तान कहे जाने वाले इस इलाके में जल संसाधनों की सीमित उपस्थिति है। यहां के स्थानीय लोग इस बात को समझते भी हैं और प्रतिदिन 25 लीटर से कम पानी का ही उपयोग करते हैं। लेकिन यहां आने वाले पर्यटक दिन भर में करीब 75 से 100 लीटर पानी का उपभोग करते हैं।

लद्दाख में लगभग 700 होटल हैं। हर साल यहां लगभग 2.5 लाख पर्यटक आते हैं, जो कि क्षेत्र की आबादी के बराबर है। इससे क्षेत्र के जल संसाधनों पर दबाव पड़ता है। लद्दाख के प्रमुख शहर लेह में पानी का प्रमुख स्त्रोत सिंधु नदी है। सिंधु नदी की वजह से यहां का जलस्तर ठीक-ठाक है और लोग बोरवेल की मदद से जमीन से पानी निकालते हैं।

लेकिन लेह में बोरवेल की संख्या दिन प्रतिदिन बढ़ती जा रही है, जिसका प्रभाव लेह के गिरते जलस्तर पर दिख रहा है। इसका सीधा प्रभाव लेह के स्थानीय लोगों पर पड़ेगा जो पेयजल और कृषि उपयोग के लिए इस पानी का प्रयोग करते हैं। लद्दाख लंबे समय तक ऐसे पर्यटन दबाव को सह नहीं पाएगा।

लद्दाख की तरह ही कई और पर्यटन केंद्र भी कुछ इसी तरह के पर्यावरणीय दबाव से गुजर रहे हैं। उदाहरण के तौर पर, तमिलनाडु के पर्यटन पर्वतीय क्षेत्र कोडाइकनाल में पर्यटकों की संख्या पिछले दस वर्षों में चार गुना बढ़ गई है। पर्यटकों की इस बढ़ती संख्या कारण इस इलाके को पानी की कमी का सामना करना पड़ रहा है। इसके अलावा यहां का सीवेज सिस्टम प्रभावित हुआ है, वायु प्रदूषण में वृद्धि हुई है और अधिक सड़कें बनाने के लिए जंगलों का कटान भी हुआ है।

पर्यटकों द्वारा प्लेट, चम्मच, स्ट्रॉ और बोतलों के अतिशय उपयोग के कारण इस क्षेत्र के प्लास्टिक प्रदूषण में भी वृद्धि हुई है। पर्यावरण विज्ञान के अनुसार हर क्षेत्र की अपनी एक वहन क्षमता होती है, जो संसाधनों की उपलब्धता और उनके उपयोग पर निर्भर करती है।

एक बार भी हम उस क्षमता को पार करते हैं, उसी वक्त पर्यावरण और पारिस्थितिकी को नुकसान पहुंचने लगता है। भारत में कई ऐसे पर्यटन स्थल, विशेष रूप से हिल स्टेशन, तीर्थ स्थल और वन्यजीव अभयारण्य हैं, जो अपनी वहन क्षमता को पार कर गए हैं। कई जगहों पर यह वहन करने की क्षमता क्षेत्र की भौतिक सीमाओं के कारण नहीं बल्कि संसाधनों के कुप्रबंधन की वजह से अधिक सीमित हो गई है।

कश्मीर विश्वविद्यालय में भूगोल विकास विभाग के प्रमुख मोहम्मद सुल्तान भट द्वारा किए गए एक अध्य्यन के अनुसार लिद्दर घाटी, जहां पर अमरनाथ मंदिर स्थित है, की वहन क्षमता महज 4,300 तीर्थयात्री प्रतिदिन की है। लेकिन अमरनाथ यात्रा के दिनों में यहां हर दिन औसतन 12,000 से अधिक तीर्थयात्री गुफा में जाते हैं।

ग्लोबल वार्मिंग की वजह से पहले से ही मंदिर के आसपास के ग्लेशियरों प्रभावित हो रहे हैं और मानवीय दबाव इस दुष्प्रभाव को और बढ़ा रहा है। इसका परिणाम यह है कि अमरनाथ गुफा में स्थित प्राकृतिक शिवलिंग हर साल आकार में लगातार कम होता जा रहा है और कई बार तो यात्रा समाप्त होने से पहले ही पूरी तरह से पिघल जा रहा है।

अगर स्थिति ऐसी ही बनी रही तो कुछ दशकों में ही ऐसा मौका आएगा जब श्रद्धालुओं के पास जाने और प्रार्थना करने के लिए शिवलिंग नहीं होगा। इसलिए, ऐसी जगहों पर पर्यटकों की संख्या को सीमित करने और स्थानीय प्रशासन में सुधार करने की तत्काल जरुरत है।

हम अपने पड़ोसी देश भूटान से इस मामले में सबक सीख सकते हैं। भूटान ने पर्यटन शुल्क को बढ़ाकर पर्यटकों की संख्या को नियंत्रित किया है। भूटान में प्रत्येक पर्यटक को हर दिन एक न्यूनतम पर्यटन शुल्क का भुगतान करना पड़ता है, जो कि सीजन के अनुसार प्रति दिन 14,000 से 17,500 रुपये तक होता है। इस शुल्क का एक हिस्सा हम भूटान से भी बेहतर कर सकते हैं। धार्मिक स्वतंत्रता और समानता को सुनिश्चित करने के लिए हम आर्थिक रूप से कमजोर वर्ग के लोगों की एक निश्चित संख्या को धार्मिक पर्यटन के लिए आरक्षण दे सकते हैं। बाकी के लोगों के लिए किसी भी पर्यटक स्थल की यात्रा करने के लिए एक निश्चित शुल्क लगना चाहिए।

कहने का लब्बोलुआब यह है कि भारत की वर्तमान पर्यटन संस्कृति से कार्बन का उत्पादन बढ़ रहा है और यह पर्यावरण के लिए बिल्कुल भी उचित नहीं है। यदि हमें इन स्थानों को लंबे समय तक बनाए रखना है, तो पर्यटकों की संख्या को सीमित करने के साथ-साथ कई कठोर कदम उठाने होंगे।

पर्यटन महत्वपूर्ण है और लोगों को अपने धार्मिक और पसंदीदा स्थानों पर जाने का विकल्प होना चाहिए। लेकिन हम इससे होने वाले पर्यावरण परिवर्तन के प्रति आंख नहीं मूंद सकते। इसके अलावा पर्यटन उद्योग, पर्यटकों को आकर्षित करने के लिए एक सुखद वातावरण देने पर निर्भर करता है। कोई भी गंदी और प्रदूषित जगह पर नहीं जाना चाहता।

लेकिन भारत की वर्तमान पर्यटन संस्कृति पर्यावरण को बर्बाद करने वाली है। अगर हमें पर्यटन का आनंद लेना है तो हम सभी को और अधिक जिम्मेदार बनना होगा। इसके लिए हमें ‘वास्तविक टिकाऊ पर्यटन’ को बढ़ावा देने की जरुरत है।

Single-use plastics: A roadmap to eliminate this menace

Even after enacting four major legislations in the last 20 years, we have not been able to eliminate even one single-use plastic product.

Regulations, and penalties are not sufficient to eliminate the use of single-use plastics. We need a transformation in the market and the municipal services

I am glad that the Union government didn’t announce any ban on single-use plastic products on the October 2, 2019. It is not that I don’t want these environmentally harmful products to be banned; it is just that I don’t think we have done the groundwork to implement a successful ban.

The history of plastic waste management in India is replete with hastiness; we have brought in regulations, but never prepared the market or the local government for the transition.

The first major regulation came 20 years back, in 1999. The Plastics Manufacture, Sale and Usage Rules, 1999, essentially tried to eliminate single-use polythene bags by specifying the size, and thickness of bags that could be sold in the market. It mandated that no carry-bags made of virgin, or recycled, plastic that are less than 8 x 12 inches in size, and less than 20 microns in thickness can be sold in the market.

The 1999 rules were amended, and the Recycled Plastics Manufacture and Usage (Amendment) Rules, 2003, was enacted to exempt export-oriented industry, and to improve enforcement. Alas, nothing much changed on the ground, and thin polythene bags continued to be sold widely in the market. During this period, no effort was made to promote an alternative to these carry-bags.

Then came the Plastic Waste (Management & Handling) Rules, 2011. In this, the minimum thickness of plastic carry-bags was increased to 40 microns, and municipal authorities were given the responsibility to set up systems for plastic waste management. Municipalities were also supposed to set up plastic waste collection centres, with financial support from the manufacturers, in line with the principle of Extended Producer’s Responsibility (EPR). But, EPR was vaguely defined, and never got implemented. The ban on less than 40-micron thickness carry-bags was also executed poorly, and municipalities were not capacitated to implement the rules.

The most comprehensive (and somewhat complicated) law came in 2016. The Plastic Waste Management Rules, 2016, came with a slew of provisions for everyone in the plastic supply chain. The rules:

  • Increase the minimum thickness of plastic carry-bags from 40 to 50 microns;
  • Expanded the jurisdiction of applicability from the municipal area to rural areas, and made gram panchayats responsible;
  • Defined a very complicated system of EPR for producers/brand owners that needed multiple registrations, and multiple payments;
  • Introduced plastic waste management fee through pre-registration of producers, importers and vendors. For example, the shopkeepers and street vendors willing to provide plastic carry-bags were asked to pay a hefty plastic waste management fee of a minimum of Rs. 48,000 per year.

Three years hence, hardly any of the above provisions have been implemented satisfactorily.

Then, in June 2018, on the occasion of World Environment Day, the prime minister vowed to phase-out single-use plastics by 2022. Before that, in March 2018, Maharashtra became the first state to implement a ban on single-use plastics. Telangana followed suit in June, and Himachal Pradesh and Uttar Pradesh in July 2018. Tamil Nadu, on January 1, 2019, became the fifth state, and Odisha, on October 2, 2019, the latest to implement a ban on single-use plastics. Today, at least 18 States and UTs have imposed a ban on plastic carry-bags, and some sort of ban on single-use plastic products. But, report after report indicates that after a spurt in enforcement at the beginning of the ban period, things are back to normal. Take the case of Uttar Pradesh, which has implemented the bans in phases.

On July 15, 2018, Uttar Pradesh banned single-use polythene bags, glasses, cups, and cutlery. From August 15, 2018, it imposed a blanket ban on the manufacture, stocking, sale, and transport of all disposable plastic and thermocol items. In the last phase, from October 2, 2018, disposal of all types of non-biodegradable polythene was banned to make Uttar Pradesh a plastic-free state. One year down the line, the bans have not been very successful in reducing single-use plastic despite penalty conditions like imprisonment of one year, or fine of up to Rs. 1 lakh.

Maharashtra paints a similar picture. Because it hastily enacted the law, it had to grant multiple relaxations. The enforcement challenge is so great that despite Brihanmumbai Municipal Corporation collecting about Rs. 4 crore in fines, and seizing more than 75 tonnes of banned plastic items in the last year, reports show that plastic plates, spoons, cups, and polythene bags are back in the market.

Please, don’t get me wrong. It is not that these rules and regulations have not made a dent in our fight against plastic pollution. They have; people are more aware, civil society is taking autonomous actions, producers are more cautious, and the industry has been forced to think about the alternative. But, because we enacted these regulations in haste, we failed to prepare the market, or the municipal authorities for the transition. The result has been that we have not been successful in eliminating even one single-use plastic product (not even the single-use polythene bag of less than 20 microns thickness) in 20 years of trying.

If there is one thing to learn from the experience of the past 20 years, it is that regulations, and penalties are not sufficient to eliminate the use of single-use plastics. We need a transformation in the market and the municipal services to achieve this. What this transformation should look like, I will discuss in the next column.

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