India's Environmental Challenge and Reforms Needed to Set Things Right

 

India Facing Grave Environmental Crisis

 

SUBHASH CHANDRA GARG

Economy, Finance and Fiscal Policy Strategist and Former Finance and Economic Affairs Secretary, Government of India

 

Economic Growth Impacts Environment

Early humans lived as part of the nature. They did not produce any food and ate whatever nature provided in the wild. They did not construct houses to live in. The humans lived without altering nature’s resource base. There was no adverse impact of human’s existence on nature and her environment.

Over the millennia, human ingenuity expanded their ability to produce new goods and services using both organic and inorganic resources. The agriculture expanded food supply which in turn allowed humans to settle and multiply leading to human population grow. The agriculture settlements led to construction of houses. The agriculture and human settlement produced early machines and equipment, which also led to development of handlooms and handicraft. In the agriculture age, however, the use of inorganic materials and fossil fuels were minimal which ensured that impact of economic activities on environment were almost unnoticeable. The nature and humans lived by and large in harmony and the environment stayed healthy.  

Invention of steam engine enabled humans to harness energy at big scale by using fossil fuels- coal, petroleum, natural gas which also allowed production of big and powerful machines and equipment using organic and inorganic materials to produce artificial goods like plastics, cement, steel and so on. Natural products first got supplemented with man-made non-natural products initially. Later, the man-made products overwhelmed the natural products. The fossil fuels were refined and could be used in motor cars, aero planes and other transport machine which eliminated distances and humans could transport goods from any part of the world to any other part of the world.

The industrial revolution brought by the heady combination of fossil fuel energy and powerful machines impacted nature and environment massively. The environmental problems of today are the direct consequence of industrialisation.

Industrialisation was and is still equated with development. Industrialisation ensured better nutrition and made people’s lives more comfortable and richer. The countries which did not industrialise or inadequately industrialised remained poor. Extensive use of fossil fuels, materials and chemicals, however, had adverse impact on environment. Up to a point, nature’s carrying capacity shielded humans from the adverse impacts of industrialisation. However, at some point, the balance tipped and the adverse impact on environment started harming humans. By now, harms have become local (pollution) as well as global (climate change).

Environmental Impacts are Personal, Local and Global

Use of fuels, improper disposal of agro-waste and human waste, use of inorganic materials and by-products of agriculture, industrial and digital production and distribution impact the environment. The impacts which alter the wholesome and sustainable balance of nature and her services- clean air, clean water, green earth, blue skies, ambient temperatures, natural forests, wetlands, other eco-spheres etc.- harm the environment and the people who benefit from and use the services from this balance and quality of environment. The use of fossil fuels, improper and unsustainable use of materials and chemicals and improper disposal of wastes are at the root of adverse environmental impacts.

The adverse environmental impacts operate at three levels- individual or personal, local or social and global. Many impacts affect individuals e.g. slate producing industry causes silicosis to workers.

Most harmful environmental impacts are local- confined to a particular smaller or bigger but localized area. A thermal power plant spewing smoke sends out particulate material of small sizes (2.5 mm and 10 mm), which affect human health and noxious gases- nitrogen oxides, sulphur oxide and mercury. These pollutants spread over a local area and settle down or gets blown away to another local area. The burning of paddy stubble by Punjab farmers in September-October every year to clear their fields to sow wheat spreads black carbon, particulate matter and other pollutants over a larger local area of India. Delhi bears the noxious consequences every year of such stubble burning.

Some environmental impacts are global. The coal-based power plants produce carbon dioxide while burning the carbon in coal. Rotting of agro-waste or growing of paddy in water produce methane. The carbon dioxide and methane are greenhouse gases. These gases once produced remain in the atmosphere for ever until sequestered or converted into basic elements again. Their impacts do not remain localized. The green house gases prevent escaping of heat into the outer atmosphere. These gases act like traps and contribute in heating up the planet. The heating up has consequences which affect people all over the global.

Global Priority is to Control Greenhouse Gases Emissions

While climate change is quite a complex phenomenon and a result of myriad forces- both natural and human induced, the global community has focused on impact of greenhouse gases emissions on global warming. A reasonably steady relationship has been found to exist in terms of the quantity of greenhouses gases in the atmosphere and the rise in mean temperature on earth’s surface and seas.

The scientists believe that incalculable damage would be done to the earth, humans and life on earth if the temperatures were to rise by more than 2% over the pre-industrial average. The humanity can avoid most pernicious consequences if it is able to limit the rise in global temperature in 21^st century to well below 2 degrees Celsius above pre-industrial levels. Paris Agreement is all about attaining this goal and to make efforts if the temperature increase can be limited to 1.5 degrees Celsius.

India Has Low Per Capita But Rising Greenhouse Emissions   

India total greenhouse gas emissions were estimated to be 3.202 million tons of carbon dioxide equivalent in 2014, which made India’s per capita GHG emissions to be about 2.48 tons of CO₂ equivalent per person.  India’s share of total GDG emissions was 6.55% of the total global emissions of 48.89 billion tons of CO₂ equivalent. India’s per capital emissions were far lower than the global emissions of 6.73 tons of CO₂ equivalent.

India’s total GHG emissions of 3,202 million tons of carbon dioxide equivalent for 2.131 trillion dollars of economy meant that energy intensity of India GDP, measured in tons of carbon dioxide equivalent per million dollars of GDP, was 1503 tons of CO₂ equivalent per million dollars of GDP. The global energy intensity was 665 tons of CO₂ equivalent. In this metric, India energy intensity was 2.26 times the global average.

Carbon dioxide forms the largest component of greenhouse gases. India reportedly emitted 2.299 million tons of carbon dioxide in 2018, which was 4.8% more than the previous year.

India made impressive commitments as part of her nationally determined contributions. India’s commitments and performance are rated as in line with limiting the temperature rise to 2 degrees scenario of the world.

India Performs Badly on State of Air Quality Metric

The State of Global Air Report assesses air quality on three important parameters globally- people’s exposure to the PM_2.5 (which represents ambient outside air pollution), to ozone exposure and indoor pollution. The State of Air Report released in October 2020 found that there was a marginal decline in the global level of PM_2.5 exposure over the period 2010-2019. The presence of ozone has, however, increased globally over this period. Likewise, use of solid fuels in homes for cooking and heating which is the primary reason for the indoor pollution has also declined in aggregate globally.

India has been assessed to fare very badly with respect to the two of three metrics- exposure of people to the PM_2.5 pollution and increase of ozone in the air. India, however, has done quite well in reduction of use of solid fuels in homes although the proportion of households using solid fuels still continue to be quite high.

India had the highest population weighted annual average PM_2.5 exposures in the world in 2019 at 83.2 micrograms per cubic meter of air. WHO’s safe limits for weighted annual average PM_2.5 exposures is only 10 micrograms per cubic meter (µg/m³). India was in the least healthy category of exposures between 75-85 PM_2.5 exposures. Over the period 2010-2019, India saw third highest increase in the exposure after Nigeria and Bangladesh. India’s exposure increased by 6.5 µg/m³ over this period whereas Nigeria had the highest increase of 7.5 µg/m³. There were a number of countries which saw decline in the exposure during this period. India’s general quality of air suggests a state of emergency.

In the exposure to ozone also India fared very badly. Ground level ozone is formed by chemical reaction of nitrogen oxide with volatile organic compounds in the presence of sunlight and it is very harmful for human and animal health and also adversely impacts food chain. On average, global exposure to ozone increased from 47 parts per billion (ppb) in 2010 to 49.5 ppb in 2019. India’s average exposure to ozone at 66.2 was the third highest in the world (after Qatar and Nepal) and increased by 9.7 ppb over this period. India had the dubious distinction of seeing the highest increase over this period. There are quite a few countries which decreased the level of ozone in their air, including China, which saw the highest decline of 6.8 ppb over this period.

India performed quite well in handling the indoor pollution. South Asia, which has the second highest use of solid fuels- coal, charcoal, wood, agriculture waste, animal dung and kerosene- in the world recorded largest decline in the proportion of households using solid fuels over the period 2010-2019 from close to 74% in 2010 to about 60% in 2019. In India, about 54 million households stopped using solid fuels for meeting their cooking and heating needs in homes. This was the second largest decline in the world after China which saw reduction in number of households using solid fuels by a whopping 220 million.

49% or a little less than half the people in the world- about 3.8 billion- are still exposed to indoor pollution. Exposure to indoor pollution on account of using solid fuels is the highest in the Sub-Saharan Africa where several countries have almost every household using solid fuels. Good work in India is also partly explained by the expansion of schemes like Ujawala which has led to provision of LPG connection to over 80 million families, most of which were earlier using solid fuels, including kerosene. There is remarkable decline in the use of kerosene in the country.

India, needs to attend urgently to the matter of the worst quality of air in the world, which is still deteriorating. In fact, situation in several pockets is much dire than what the national average conveys. 

India’s Waters are Also Quite Polluted

It is estimated that 70% of surface water in India is unfit for consumption. Another estimate suggests that as much as 40 million liters of wastewater enters rivers, lakes and other water bodies without being treated.

India is a water scarce country. As against international norms, countries with per capita water availability of less than 1700 m³ are categorized as water-stressed. India’s per capital water availability is estimated to be about 1550 cubic meter. The distribution of water over different months of a year and in geographical terms, along with increasing pollution of surface water, has compounded the problem of lesser availability of water.

A report of the Central Pollution Control Board in 2015 announced that the number of polluted rivers in India (the rivers whose water is not fit for drinking) increased from 121 to 275. In terms of polluted stretches, CPCB found 302 polluted stretches on 275 rivers in 2015. The number of polluted stretches increased to 351 in 2018. The problem is getting quite acute in case of ground water as well where besides the availability of ground water going down, the quality of water, including presence of chemicals and other harmful substances, has also been consistently going down.

India Should Set Her Environmental Goals Clearly

Climate Change and Environmental Pollution is very extensive and is caused by numerous factors arising out of almost every aspect of human life. India does not have any specific law to combat climate change though it has a very comprehensive and intrusive environmental protection law which deals with environmental pollution. The environmental problem of India is so massive that it would be impossible for the Government to deal with every polluting element. The climate change and environmental pollution, however, can be dealt with more effectively if India were to focus on some specific pollutants.

There are five such major pollutants which India should focus on:

First, carbon dioxide (CO₂)- it makes up more than two third of the greenhouse gases. If CO₂ emissions can be reduced massively, there is good likelihood that the world can achieve net zero carbon emissions goal.

Second, particulate matter 2.5 (PM_2.5)- the PM_2.5 is the most damaging pollutant and the largest pollutant today. If the PM_2.5 can be reduced substantially, the problem of environmental pollution would largely go and human and animal health would be most protected.

Third, ozone (O)- the surface ozone is the result of nitrogen oxides chemically reacting with organic matter and is a major health hazard. Ozone which escapes to the ozonosphere causes hole in the ozone layer. To fix ozone, one will have to fix the problem of nitrogen oxides as well.

Fourth, burning of solid fuels in households which is the primary reason for indoor pollution and also contribute to release of carbon dioxide.

Fifth, discharge of untreated sewage in the commons- water bodies or land.

If India can manage these five polluting elements and processes, without compromising the production of goods and services or the GDP or national income, India can ensure that the quality of life of its residents would improve massively and would also play its rightful role in solving the problem of climate change.

For setting the specific goals on these five parameters and to realize these goals, without jeopardizing India’s GDP growth, quite a few serious reforms would need to be undertaken.

Establish Environment Ministry as a Separate Ministry to Achieve These Goals

Environment was not neither an international or a national issue at the time when Indian Constitution was made. Environment or environment protection or promotion of environment are not, consequently, mentioned as a subject in any of the three lists of the Seven Schedule allocating business of the Government to the Union, the States or Concurrent subjects. The environment became an international concern and thereafter also the national concern in 1970s. The Government tagged Environment with the Ministry of Forest, as if the Environment was an adjunct of forests and established the Ministry as the Ministry of Environment and Forest.

Forests do act as carbon sinks. Forests are also a good way to convert atmospheric carbon in woods. Forests are, however, not responsible for or directly concerned with the pollution of air, water and non-forest lands. Diversion and increase of forest lands is one of the many ways in which carbon dioxide need to be managed. However, managing pollution of air, water and non-forest lands require a much wider sweep of action- much more related to entire agriculture, industrialisation and urbanization. The environmental agenda is much wider. Forests are one set of interventions and in that manner an agent of the environment agenda.

The state of environmental pollution in India has reached gargantuan scales despite Ministry of Environment and Forest been entrusted with most sweeping authority and powers for last 35 years. The Ministry of Environment has adopted a gatekeeper approach for most economic activities involving large investments. It is necessary to obtain the consent of the Ministry or its authorized delegates before any serious industry or infrastructure can be started in the country. It is tortuous to go through the process to get the consent. The processes set by the Ministry consume years before the consent is available and that consent usually comes with unimplementable conditions. There is very little connect between the process of obtaining consent and significance of impact of such consent on the state of air, water and land pollution.

Basic orientation and purpose of the Ministry needs to be changed. The Ministry needs to be entrusted with clear goals in respect of five key determinants of environmental pollution in India as stated in the previous section. The Ministry should be held accountable for making progress and achieving those goals. The forest part of the Ministry of Environment and Forests should be spun into a separate Ministry and an independent Ministry of Environment should be created to make India achieve its environmental goals.

Environment Ministry should identify the major sources of pollution and carbon emissions and go about taking requisite measures to eliminate the root causes of it. India has taken such initiatives. Emission of carbon dioxide, particulate pollution and nitrogen oxides, besides other pollutants, in Delhi was majorly contributed by the diesel fuel using buses in the national capital. The replacement of diesel engines by the compressed natural gas-based engines in the buses did reduce the pollution and carbon emission load significantly in Delhi.

Replace Technology of Environmental Clearance with Outcome Orientation

Environmental protection has become a prisoner of process. The entire focus of attention is the consent required to be taken for starting a new specified industry or infrastructure work or modify an existing one. The environmental processes have become more draconian than the industrial licencing processes were in 1970s.

The elaborate environmental impact assessment processes have mixed up the matters. There is no clarity what is intended to be achieved. The environmental impact assessment processes instead of quantifying the climate change and environmental pollution impact of the industrial or infrastructure project, gets into impacts on income, employment, livelihood etc. of people living in catchment area of the project, impacts on wild life, diversion of forest lands and natural habitats. These are important aspects but the whole purpose of assessing the impact on environment which is defined to be environmental pollution in the Environment Act get lost and the process degenerates into finding whatever real and imaginable negative impacts on anything or everything.

As such a process is impossible to be satisfactorily completed, the project proponents get into the game of somehow going through the formality of the process, including consultations and obtain approval anyhow. There is also pressure on the Government to exempt industries and infrastructure from the requirement of obtaining environmental clearance or at least to through a less rigorous process, which does not require consultations.

An elaborate and hugely entangled process is not required for almost every project. The environmental impacts depend upon the technology, fuel chosen and the pollutant which the production process generates as byproducts. A thermal power project for let us say 500 MW using coal as a fuel and using a specific technology- sub-critical, critical, super critical etc., using different kinds of machines to control/ reuse of steam, reuse of waste heat, trapping of affluents etc. can be expected to generate a certain quantum of carbon dioxide, particulate matter (ash), nitrogen oxide, sulphur oxide etc. Such an assessment needs expertise on power plant technology and engineering, not a wildlife expert or a forest expert. Such an assessment also does not require any consultation with the tribal or villagers affected. If the power generation is based on renewable technology, there is hardly any generation of carbon dioxide and other polluting gases. 

Unfortunately, the environmental clearance process goes into so many aspects which have very little to do with the environmental impact. The process orientation of the environmental approval needs to be thoroughly rethought. Like licencing of new industry or expansion of existing capacity achieved nothing, so is the requirement of environmental clearance is achieving practically nothing.

The policy makers and regulators must not get lost in the process of clearance. They should focus on how to get the right kind of technology and production processes which don’t use or minimize the consumption of chemicals, fossil fuels, other materials which impact climate change or environmental pollution without sacrificing national output or income.

The Environmental Impact Assessment Rules 2006 currently rules. These rules confer so much discretion on the consent granting authorities that many times these powers have become tools in the hands of Minister and other officials to extract bribes by simply sitting over the approvals. Average time taken to get one Category A project approval exceeds years.

These Rules are under revision. The Government has notified the draft rules 2020. As these rules clarify and simplify the concepts and processes and puts time limits on various stages, the environmental protection lobby, which has vested interest in perpetuating the existing rent generating processes have cried hoarse. The Government has been flooded with thousands of suggestions. Let us see when the Government is able to come out after examination of these suggestions. The Government should in fact be more adventurous in the interest of growth and well-being of people to take out most of the industrial and infrastructure activities where the environmental impacts can be very easily simulated without the needed for such process and consultations out of the requirement to obtain prior consent.

The construct should be simpler. If you intend to establish a thermal power plant based on coal, you would need to go for technology which ensures, let us say, that the carbon used per unit of power generated will not exceed x kg. If you use such a technology, no clearance is required. Or, if you want to be aggressive on carbon control, no coal plants will be established from this year onwards in the country. These are policy choices which should be exercised with due caution and clarity. None of these policy decisions, which actually impact the climate change or generation of environmental decisions, require heavy process of assessment by “experts” and consultations with people.

Process needs to be replaced by right policy choices and robust technological regulation.  

The Environmental Regulatory system in the country needs to move from the dictate-based regulation to the participation based appropriate technology upgradation system. In 2015, the Ministry of Environment passed orders fixing the emission standards for nitrogen oxides (NOx) and sulphur oxides (SOx) for all power plants in the country. For example, for the power plants established between 2003 and 2016, the NOx emissions were to be brought down to 300 mg/Nm³. Several other standards were fixed depending upon the year of plant and some other factors. Unfortunately, the Ministry of Environment had no idea whether appropriate technology exists and how costly it is if it imported. There was also no consideration of how the additional cost would get factored in the cost. In such situations, many times the dictates remain unimplemented. Exactly the same thing happened in case of NOx and SOx dictates. The deadline has gone but there is hardly 5-10% compliance in the country.

The environmental courts like National Green Tribunal have also adopted the dictate methodology. Every now and then orders are passed to stop production or take a particular step with threatened pain of jail penalty. The case in point is the burning of stubble by farmers in Punjab and Haryana. There are several solutions to the problem but instead of coming up with an appropriate solution, including use of public funds for a cause like this, farmers are being targeted only. Despite the pain of criminal punishment, the farmers are not heeding these dictates as the economic logic of preparing the field for sowing wheat in the quickest turnaround time prevails.

There have been efforts lately to declog the system and expedite the environmental clearances. The new Environment Impact Assessment Draft Rules 2020 is a small step in this direction. Unfortunately, the people who are too much concerned with non-environmental issues- mostly of social nature- and who have used the parts of process like consultation to put sands in the wheels of industrialisation, urbanization and infrastructure creation are objecting to these process reforms. These process reforms should be expedited though these would have only limited effect.

The real solution lies in the Ministry to focus on what will reduce carbon and pollution emissions massively without adversely affecting economic growth and employment.

Right Technology, Fuels and Chemicals in Efficient Uses is the Answer

Power generated by renewable and non-carbon fuels reduces emissions and pollution load massively. The Ministry of Environment should worry about and push necessary policy, process and operations reforms to expedite switch towards use of renewable and non-carbon fuels technologies and businesses to become more competitive and profitable than the coal based and other fossil fuel-based technologies. The Ministry of Environment should focus on developing appropriate standards and processes which brings about this change of competitiveness between renewable and fossil fuel businesses.

There is extensive use of diesel generating pumps and also inefficient electricity pumps in agriculture, which results in excessive power consumption and consequential excessive emissions of carbon and pollutants. Instead of subsidizing the electricity for farmers which encourages not only excessive consumption of power but also excessive pumping of water. The Ministry of Environment should undertake a programme which results in replacement of inefficient pump-sets with solar/efficient pump sets.

There are several chemicals use of which in the production process as raw material or to support growth impulses results in leaving such harmful chemicals in soil and in water streams. The Ministry of Environment should concern in developing the standards, taking advantage of global real experience, to push for replacement of harmful chemicals with non or less injurious chemicals.

In short, focus on the cause of emissions and pollutants, make policies and regulations which promote use of alternatives which results in lesser or no emissions and pollutants and work with industry and businesses to make the change happen at the earliest possible protecting the GDP, incomes and employment.

 

SUBHASH CHANDRA GARG

NEW DELHI 24/10/2020