Can India’s National Clean Air Programme ensure good air and environmental justice?

The conventional citizenship discourse in India is confined among the socio-cultural elites. Paradoxically, these elites often act as compliant participants, as per Hardin’s “tragedy of the commons”, prioritising individual gain over collective responsibility for shared resources. Their pursuit of short-term gains and self-interest has eclipsed the prioritisation of collective environmental well-being. A minuscule urban elite nowadays demands ‘clean water’, ‘clean air’, and ‘clean energy’ advocating people’s participation in the environmental decision-making process. Yet, the attitudes and incidents that foster people’s participation, or environmental citizenship, are rarely visible in cities. 

Within environmental citizenship and in the context of India’s ambitious National Clean Air Programme (NCAP) launched in 2019, I propose the concept of ‘atmospheric citizenship’. This refers to the active and democratic participation of citizens in improving air quality and shaping related policies – and goes beyond building awareness by disseminating data-driven air quality facts. ‘Atmospheric citizenship’ rejects the reductionist and technocratic ideas of air quality improvements (Negi and Srigyan, 2022)^[1]Scope 3 emissions further illustrate the multifaceted nature of air pollution. Focusing solely on technological solutions, such as improving thermal power plant efficiency or vehicle engines, represents a reductionist approach. In India, air quality improvement strategies often reflect this narrow perspective. such as improving thermal power plant efficiency and vehicle engines, or technocratic ‘solutions’ like air purifiers.

The NCAP is a time bound, sectoral, and performance-based fiscal transfer initiative to reduce 20-30 percent of Particulate Matter (PM10 and PM2.5) concentration by 2024 across non-attainments cities in India. Cities that consistently fail to meet the National Ambient Air Quality Standards (NAAQS) for five or more years are tagged as non-attainment cities, according to the Central Pollution Control Board (CPCB). The NCAP, in its framework and practice of air quality governance, missed the idea of people’s participation or ‘atmospheric citizenship’. 

Will mere technocratic dissemination of air quality data build awareness and bring forth active participation? Why is Swachh Vayu (clean air) not a part of the dominant discourse in urban policy-making on par with bijli (energy), pani (water), and sadak (road)? It is noteworthy that while people’s awareness and lived experience of air pollution have grown through print and digital media, their democratic participation in addressing the issue remains minimal. The highly polluted air and mitigation efforts are not even a part of our electoral democracy process.

The NCAP’s ambition is to make air breathable in urban India. Before it was rolled out, the National Action Plan for Climate Change introduced several initiatives, since 2008, many of which have failed due to inadequate financial allocations, mismanagement, and unmet commitments. One of its eight missions has been Sustainable Habitat – to create sustainable cities which includes clean air.

The NCAP has some major drawbacks:

• The development of clean air action plans in Indian cities has primarily been driven by directives from the National Green Tribunal, raising concerns that these initiatives may remain isolated, one-time exercises rather than forming part of a sustained and iterative process of air quality management as in the NCAP (Guttikunda et al., 2023). 
• Urban air quality is shaped by sources of pollution both within and beyond municipal boundaries, necessitating the establishment of inter-city and cross-state coordination mechanisms to address regional contributors effectively. Superficial measures, such as broad pollutant mapping or generalised land-use planning, are insufficient to tackle the complex issue. Instead, the emphasis must shift toward fostering community engagement to address pollution—such as promoting behavioral shifts away from waste burning and encouraging sustainable transportation choices; however, these must be complemented by robust government incentives, policies and infrastructure to ensure sustainable and equitable solutions. Urban local bodies should also prioritise targeted interventions to mitigate emissions from existing sources within and around city limits. 
• Most of the city air pollution plans are simple textbook-level recommendations; there is no proper thematic or integrated design plan. For instance, the Agra Clean Air Plan predominantly focuses on monitoring, regulation, and enforcement mechanisms. The fundamental question is, if the urban local body knows these check and control games, then what is stopping them from improving the air quality in the city? 
• The judicial and regulatory authority has shifted the conversation towards centralisation rather than democratisation. The NCAP missed detailed discussion on judicial aspects, environmental clearance and statutory law. In practice, the support for public interest litigation to strengthen government action to reduce air pollution is absent. 
• One of the fundamental dialectics in the NCAP is how can cities have clean air without compromising the rights of people to live, work, play and aspire to a better future. This is, to paraphrase Malini Ranganathan, moving towards how class and caste structures make for ‘environmental unfreedoms’.^[2] (Negi and Srigyan, 2022). City-level air pollution action plans fail to incorporate strategies that address caste- and class-based inequities in pollution mitigation. The deterioration of air quality is directly correlated with the urban rich’s right to consume more^[3]Tooltip content while the eternal struggle of the urban poor for a dignified life is measured and affected by pollution hazards. But the NCAP failed to address this. The per capita difference between rich and poor in India is quite sharp – the highest 20 percent of high-expenditure households in India produce roughly seven-fold more emissions than low-expenditure (BPL) households. (Lee et al., 2021). t is not about balancing rich and poor’s per capita emissions.
• A core challenge with the NCAP lies in financial allocation, particularly in how Urban Local Bodies use their funds and mechanisms to integrate these expenditures with broader environmental actions. A 2022 report by the Centre for Policy Research (CPR) highlighted that ten State Pollution Control Boards (SPCBs) in the Indo-Gangetic Plains— a region grappling with severe pollution challenges—are consistently reporting annual financial surpluses and skewed sectoral expenditure. These surpluses, along with accumulated cash reserves amounting to nearly Rs 2,893 crore, remain largely unutilised and predominantly locked in fixed deposits. 
• This questions the rationale for seeking additional financial support under NCAP when existing funds are not being optimally utilised (Mahajan et al., 2023). Notably, the NCAP’s expenditure data indicates that only two percent of these funds are allocated to research and development, and a mere 11 percent is directed toward infrastructure development. Such patterns suggest a lack of focus on fostering innovation or adopting advanced technologies to address the challenges, including infrastructure improvements. 

The local level
The challenges of achieving operational efficiency and timely expenditure underscore the broader inefficiencies within regulatory frameworks. For India to make meaningful progress in combating air pollution, regulatory agencies must prioritise effective and timely fund utilisation while addressing the issue of under-performance of ULBs – with a median utilisation rate of 49 percent – despite clear guidelines for expenditure under the programme.

Under the NCAP, the Swachh Vayu Survekshan initiative was launched to assess performance and build awareness among citizens by ranking cities in different categories (PRANA Portal, 2024). This index-based ranking metric is inspired by the 42 action points issued by the CPCB under Section 18(1)(b) of the Air (Prevention and Control of Pollution) Act, 1986. These action points include mitigating emissions from vehicles, road dust, and fugitive sources; controlling the burning of biomass and solid waste; addressing industrial pollution; managing construction and demolition activities; and implementing other measures. 

A quick survey of the variables used in the Swachh Vayu Survekshan reveals that it has once again overlooked people’s participation as a factor in ranking cities on clean air initiatives. The metric is limited to activities like awareness-building and public grievance redressal systems rather than encouraging direct or indirect involvement of the public. This is a significant gap as it fails to explicitly include and institutionalise people’s participation. 

Although air pollution hotspots have been identified in some cities, emission-reducing measures lack the active involvement of local communities. Several internationally recognised and community-driven air quality improvement initiatives, such as Air-Break, Breathe London, and the Los Angeles Library Air Sensor Loan Program, could be piloted in Indian cities for citizen engagement.

Regardless of the significant shortcomings in the NCAP and its implementation, it is noteworthy that all non-attainment cities, in compliance with its regulations, have developed their respective action plans. However, these plans remain ineffective and largely emblematic, compared to “paper tigers” and lacking substantive impact. A case in point is the Clean Air Action Plan of Kolkata Metropolitan Area-2022 which this essay will critically examine. 

How Kolkata fares
Despite being Asia’s second-highest polluted city in terms of PM2.5, the discourse on air quality degradation and policy initiatives in Kolkata remains limited and ignored. The city’s air quality monitoring infrastructure is inadequate, with only four stations measuring the key pollutants PM2.5, ozone (O3), and carbon monoxide (CO). Diesel vehicles and inadequate waste management have been identified as primary contributors to the deteriorating air quality. During Diwali, the air quality in Kolkata consistently remained in the “hazardous” or “unhealthy” categories. 

Reports estimated approximately 99 deaths per 1,00,000 people attributable to PM2.5 exposure (State of Global Air : Air Pollution and Health in Cities, 2022). The source apportionment study of Greater Kolkata revealed significant industrial contributions to the PM emissions, with annual loads of 12,480.4 MT for PM10 and 4,054.2 MT for PM2.5. Table 2 highlights that besides gas and coal plants, small-scale industries such as jute processing and bakeries are contributors too, underscoring the need to transition to cleaner energy sources. These industries need sector-wise action plans. 

Table 2: PM10 and PM2.5 emissions (MT/y) from select categories of Industries in KMC area

Source: CSIR-NEERI, 2019.

The Kolkata Clean Air Action Plan 2022 missed some imperative points to improve air quality by not addressing essential air pollution sources such as overall waste collection and segregation and road dust mitigation. It also failed to develop clean air consciousness among people. Telangana Chief Minister Revanth Reddy recently called Kolkata a ‘garbage dump’ because of its waste management failure.^[4] An average of 17 of 41 areas in the KMC are still doing partial door-to-door waste collection. Studies have found that Kolkata’s vehicle load on the road is the highest in the country and because the road infrastructure has surpassed its vehicle-carrying capacity, road dust and emissions from unregulated old buses are making the city’s air unbearable (Table:1)^[5]. The Plan failed to show concrete solutions for these issues. 

Table 1: Different sources of PM10 and PM2.5 and their rank 

Source: CSIR-NEERI, 2019. 

Moreover, the Plan reveals the municipal corporation’s largely top-down approach, with limited evidence of direct involvement of vulnerable populations or community organisations in decision-making processes. While stakeholders are invited to provide suggestions, there are no clear mechanisms to integrate public feedback into the iterative development of the Plan. This weakens the participatory framework in general and ‘atmospheric justice’ in specific. Also, there is no explicit mention of partnerships with civil society organisations and academic institutions, or grassroots initiatives that could empower local voices and foster community ownership of the plan. This lack of structured engagement with the public in the Plan diminishes opportunities for their participation in Kolkata’s air quality governance​. 

Ways to improve NCAP
Specifically, in the context of Kolkata, but also in general, the following suggestions are made to improve the NCAP:

• Given the gaps in performance and the programme’s centralised approach, future iterations of the NCAP could include encouraging community engagement through a bottom-up approach in planning, such as participatory GIS-based mapping of the hotspots (potholes and open waste burning mapping), local adaptive measures (carpooling and rooftop greening), and incentivisation of environmental-friendly behaviour.
• To address the local disparity of pollution monitoring, the ULBs can distribute technological equipment to track specific pollutants and their health impacts through people’s engagement and financial support. Establishing cadres like Clean Air Guides (CAGs) through collective ownership and responsibility, trained to monitor air quality using low-cost sensors and engage communities, could be a way forward (Damodar, et al., 2022).

Finally, I would argue that clean air is a necessity as much as food, clothing, shelter, electricity, water, and roads. Addressing air pollution effectively requires both political will and sustained public discourse.

References: 

1. CSIR-NEERI. (2019). PM10 and PM2.5 Source Apportionment Study and Development of Emission Inventory of Twin Cities Kolkata and Howrah of West Bengal. CSIR-National Environmental Engineering Research Institute, Nagpur
2. Damodar, B., Dye, T., Kar, M., Mishra, N., Bakhtawar, A., & Pomeroy-Stevens., A. (2022). Increasing Community Participation in Air Pollution Mitigation in Indore, India. Building Healthy Cities (BHC) project.
3. Guttikunda, S., Ka, N., Ganguly, T., & Jawahar, P. (2023). Plugging the Ambient Air Monitoring Gaps in India’s National Clean Air Programme (NCAP) Airsheds. Atmospheric Environment, 301, 119712.
4. Lee, J., Taherzadeh, O., & Kanemoto, K. (2021). The scale and drivers of carbon footprints in households, cities and regions across India. Global Environmental Change, 66, 102205.
5. Mahajan, A., Ghosh, S., Dhawan, P., & Krishna, B. (2023). The State of India’s Pollution Control Boards Are they in the green? Centre for Policy Research.
6. Negi, R., & Srigyan, P. (2022). Atmosphere of Collaboration Air Pollution Science, Politics and Ecopreneurship in Delhi (1st ed.). Routledge.
7. Portal for Regulation of Air Pollution in Non-Attainment Cities. (2024). Portal for Regulation of Air Pollution in Non-Attainment Cities. https://prana.cpcb.gov.in
8. Roychowdhury, A. (n.d.). Clearing the air in our cities: Agenda for action.
9. State of Global Air: Air Pollution and Health in Cities. (2022). https://www.stateofglobalair.org
10. Times of India. (2024). TMC slams Telangana CM Revanth Reddys-garbage city remark about Kolkata invites him for a visit. 2024.

Dr. Manoranjan Ghosh is Assistant Professor of Climate Change and Sustainability Studies at Symbiosis School for Liberal Arts, SIU, Pune. He holds a PhD in ‘Climate and Development’ from IIT-Kharagpur, and has done a post-PhD fellowship at the National Institute of Urban Affairs (NIUA), New Delhi besides working in the Council on Energy, Environment and Water (CEEW). He has expertise in spatial data analytics, advanced econometrics tools, and participatory appraisal methods. Dr Ghosh has published sixteen journal papers and five book chapters. He is working to design a full-phase BSc course on Environmental and Sustainability Studies at Symbiosis, Pune.

Cover photo: Subrata Biswas/ Greenpeace