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India’s air quality

management needs
transboundary accountability
to be effective
Existing policy levers and lessons from global experiences
can help form an airshed-level air quality management
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By Kalyani Tembhe (https://www.downtoearth.org.in/author/kalyani-

tembhe-191812)
Published: Wednesday 08 November 2023

While the twin factors of the winter season and farm stubble
burning exacerbate pollution levels in the country, they don’t
entirely define the causal relationship of this problem. Photo:
Vikas Choudhary / CSE
Vikas Choudhary / CSE

Like every year, air quality in the Delhi-

National Capital region and surrounding
areas has dipped to the ‘severe’ category
of the Air Quality Index for the last few
days. While news outlets paint the
pollution problem — which affects other
parts of the Indo-Gangetic Plain too — as
a ‘winter’ issue caused by burning farm
residue, it is important to understand this
is not the case. Air pollution is an all-year,
multi-source and multi-pollutant problem
and not a seasonal, single-source one.
State and federal governments have
implemented a plethora of seemingly
effective initiatives and mandates over
the years to combat the winter spike, but
to no avail. Every winter, when the wind
flow becomes stagnant and surface
temperature inversions take place in the
northern plains, air pollution levels rise,
particularly around the time farmers burn
farm residues and Diwali is celebrated.
While the twin factors of the winter
season and farm stubble burning
exacerbate pollution levels, they don’t
entirely define the causal relationship of
this problem.
Air pollution dispersal is a well-known
phenomenon. When we talk about how
stubble burning in Punjab and Haryana
affects pollution levels in Delhi-NCR, we
address the transboundary dispersive
properties of pollution. But despite this
awareness, most air pollution mitigation
strategies have been city-centric and have
repeatedly failed to deliver the desired
results.
The National Clean Air Programme
(NCAP) is one such flagship initiative.
While NCAP initiatives are bound by
citywide jurisdictional boundaries, air
pollution abides by no such limitations.
Meanwhile, millions of residents are
forced to breathe in dangerous levels of
pollutants with no respite.

What more needs to be done?

Pollution mitigation strategies are only as
effective as the science behind them.
While regulation of local polluting sources
is important, it is equally important to
mitigate the upwind pollution sources that
significantly contribute to a city’s local
pollution.
There is evidence of inter-state
transboundary dispersion of air pollution
in India. Depending upon the weather and
meteorology, the transboundary air
pollution received by a state can exceed
50 per cent. Depending on the topography,
meteorology and climatic conditions, the
transboundary dispersion of air pollution
can either worsen or improve the air
quality of a region.
Cross-state air pollution dispersal in India

Source: Xinming Du et al. 2020, Cross-

state air pollution transport calls for more
centralization in India’s
environmental federalism, Atmospheric
Pollution Research
 Pollution Research
Consequently, the cities and the regions
downwind of this transboundary
dispersion have to address the pollution
generated in other regions upwind of
them. If a significant amount of the
pollution a region faces comes from
sources outside of its jurisdiction, it
becomes challenging to mitigate air
pollution in that area due to limited
jurisdictional power.
The lack of accountability of the upwind
jurisdictions in the regulatory proceedings
and the limited jurisdictional power of the
downwind regions allow the upwind
polluters to profit from the pollution-
causing activities, while the downwind
states have no power to mitigate the
sources that are adding to their local air
pollution.
If not addressed, this not only contributes
to the regulatory incompetence of the
downwind regions but renders pollution
mitigation strategies ineffective, which
has been proven time and again. While
there is an annual slew of analyses
highlighting the quantum of
transboundary pollution and the
corresponding jarring health impacts, it is
imperative to integrate these results into
drafting a robust transboundary or
airshed-level air pollution mitigation
framework.

What is airshed air pollution

What is airshed air pollution
management

An airshed is defined as a geographic

area with common meteorology,
topography and climate, which govern the
dispersion of its unique air mass. In air
quality management, an airshed can be
defined and delineated in many ways
depending on the type of emissions,
topography, meteorology and
jurisdictional boundaries. Airshed air
quality management brings the entire
airshed under one regulatory framework.
Regional airshed-level air quality
management is not a new concept and
countries like the United States (US),
China and the European Union have
already successfully implemented such
frameworks
With the exception of the Commission for
Air Quality Management in National
Capital and Adjoining Areas (CAQM), the
current air quality management in India is
predominantly city-centric. Moreover,
despite having a regional plan, the CAQM
has witnessed lopsided implementation.
Uniform implementation of all strategies
across the region is required, but due to
the lack of a legal or institutional
framework for regional air quality
management, there is a significant
asymmetry in the scale of action across
the region.

Policy levers in India

Policy levers in India
Despite the lack of an institutional
framework for regional implementation,
there are certain aspects of the CAQM
that form a foundation for an effective
regional framework.
The Commission for Air Quality
Management in NCR & Adjoining Areas
Act, 2021 vested the CAQM with the
power to “to take all such measures, issue
directions and entertain complaints, as it
deems necessary or expedient, for the
purpose of protecting and improving the
quality of the air in the National Capital
Region and adjoining areas”. The Act
recognised the transboundary nature of
air pollution and granted a cross-sectoral
and cross-jurisdictional authority to
CAQM.
Strictly speaking, there is no legal hurdle
to implementing a regional air quality
management framework. Under the
Article 19 of the Air Act, 1981, a state
government in consultation with the State
Pollution Control Board is vested with
power to declare, alter or merge the “Air
Pollution Control Area” wherein the
provisions of the Act will be applicable
within its jurisdiction.
The scope of this provision can be
expanded to cover more jurisdictions and
pollution sources under a single air quality
management framework well within the
ambit of the Air Act.
We can also draw lessons from the
airshed-level air quality management
frameworks that have been implemented
in other parts of the world. Two of such
effective frameworks are the Cross-State
Air Pollution Rule (CSAPR, also called the
Good Neighbor Policy) in the US and the
Long Range Transboundary Air Pollution
(LRTAP) in Europe.
(LRTAP) in Europe.

Drawing lessons from global

experiences
In 1979, 32 countries in the pan-European
region signed the convention on LRTAP,
called the Air Convention, within the
framework of the United Nations
Economic Commission for Europe to
investigate and address the causal
relationship between the long-range
transboundary air pollution and the local
air pollution episodes on the continent.
The US implemented the CSAPR in 2016
to address interstate pollution’s impact on
downwind air quality after many
litigations and policy initiatives.
There are several salient features of these
frameworks. For example, accountability
is legally binding. The upwind polluting
regions are legally bound to address their
transboundary pollution to the downwind
regions through air pollution mitigation
plans and strategies.
There is a separation of scientific and
technical activity from the political
negotiation process, which has allowed
the insulation of the scientific work.
Moreover, the contribution of pollution
screening threshold to the downwind
regions is clearly defined to remove any
ambiguity and chances of multiple
interpretations. Air quality monitoring
networks in the US are also driven by
scientific studies and analysis rather than
jurisdictional boundaries.

Like any other legal framework, these two

Like any other legal framework, these two
have their own set of issues. The LRTAP
lacks a formal procedure for resolving
conflicts arising from the interpretation or
application of the document.
In the US, the implementation and actions
are heavily dependent on the bureaucratic
presidential cycles and the willingness of
the emitting states to cooperate despite
the legal backing of the CSAPR and the
Clean Air Act. It was only recently on
March 15, 2023 that the EPA implemented
limits on nitrogen oxides at power plants
and industrial sources under the Good
Neighbor Rule.
The policy levers for regional air quality
management have already been laid in the
country. Using these provisions as a
foundation and drawing lessons from
global experiences, an airshed-level air
quality management framework can either
be integrated within the current Air Act
1981 framework or a new framework can
be promulgated.
This way not only the polluters, both local
and transboundary, will be held aptly
accountable but, the residents can also
hope to see some real change in the air
they breathe.

Air Pollution
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 transboundary pollution
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When science showed in the

1970s that gas stoves
produced harmful indoor air
pollution, the industry
reached for tobacco’s PR
playbook
Industry-funded studies successfully muddied the waters
and stalled further federal investigations or regulations
addressing gas stove safety
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NEXT BLOG ❯

By Jonathan Levy, (https://www.downtoearth.org.in/author/jonathan-levy-

222879)
Published: Wednesday 08 November 2023
Photo: iStock

In 1976, beloved chef, cookbook author

and television personality Julia Child
returned to WGBH-TV’s studios in Boston
for a new cooking show, “Julia Child &
Company
(https://juliachildfoundation.org/timeline/),”
following her hit series “The French Chef.”
Viewers probably didn’t know that Child’s
new and improved kitchen studio,
outfitted with gas stoves, was paid for by
the American Gas Association
(https://drive.google.com/file/d/1asSgPpVbTEwC5DzzUglnxxnvnr17Qsn7/view?
usp=sharing).
While this may seem like any corporate
sponsorship, we now know it was a part
of a calculated campaign by gas industry
executives to increase use of gas stoves
across the United States
(https://s3.documentcloud.org/documents/23812229/aga-
monthly-196901.pdf). And stoves weren’t
the only objective. The gas industry
wanted to grow its residential market, and
homes that used gas for cooking were
likely also to use it for heat and hot water
(https://theconversation.com/why-gas-
stoves-matter-to-the-climate-and-the-gas-
industry-keeping-them-means-homes-will-
use-gas-for-heating-too-197866).
The industry’s efforts went well beyond
careful product placement, according to
new research
(https://climateinvestigations.org/report-
gas-industry-campaign-to-manufacture-
controversy-health-risks-of-gas-stove-
emissions/) from the nonprofit Climate
Investigations Center
(https://climateinvestigations.org/who_we_are/),
which analyzes corporate efforts to
undermine climate science and slow the
ongoing transition away from fossil fuels.
As the center’s study and a National
Public Radio investigation
(https://www.npr.org/2023/10/17/1183551603/gas-
(https://www.npr.org/2023/10/17/1183551603/gas-
stove-utility-tobacco) show, when
evidence emerged in the early 1970s
about the health effects of indoor nitrogen
dioxide exposure from gas stove use, the
American Gas Association launched a
campaign designed to manufacture doubt
about the existing science.
As a researcher who has studied air
pollution for many years
(https://scholar.google.com/citations?
user=iR82G3IAAAAJ&hl=en) — including
gas stoves’ contribution to indoor air
pollution and health effects — I am not
naïve about the strategies that some
industries use to avoid or delay
regulations
(https://global.oup.com/academic/product/doubt-
is-their-product-9780195300673?
cc=us&lang=en&). But I was surprised to
learn that the multipronged strategy
related to gas stoves directly mirrored
tactics that the tobacco industry used to
undermine and distort scientific evidence
(https://ajph.aphapublications.org/doi/full/10.2105/AJPH.2011.300292)
of health risks associated with smoking
starting in the 1950s.

A look at the environmenta…

Climate change • Climate change refers to long-term

shifts in temperatures and weather patterns. Human…
activities have been the main driver of climate change,

The gas industry is defending natural gas stoves,

which are under fire for their health effects and
their contribution to climate change.
Manufacturing controversy
The gas industry relied on Hill & Knowlton,
the same public relations company that
masterminded the tobacco industry’s
playbook
(https://www.latimes.com/archives/la-
xpm-1994-09-18-tm-40179-story.html) for
responding to research linking smoking to
lung cancer. Hill & Knowlton’s tactics
included
(https://climateinvestigations.org/report-
gas-industry-campaign-to-manufacture-
controversy-health-risks-of-gas-stove-
emissions/) sponsoring research that
would counter findings about gas stoves
published in the scientific literature,
emphasizing uncertainty in these findings
to construct artificial controversy and
engaging in aggressive public relations
efforts.
For example, the gas industry obtained
and reanalyzed the data from an EPA
study on Long Island
(https://s3.documentcloud.org/documents/23684646/air-
pollution-abstracts-vol-6-issues-5-8.pdf)
that showed more respiratory problems in
homes with gas stoves. Their reanalysis
(https://s3.documentcloud.org/documents/23785753/mitchell-
et-al-1974-survey-of-the-incidence-of-
respiratory-disease-in-households-using-
gas-and-electric-cookery-session-v-paper-
4.pdf) concluded that there were no
significant differences in respiratory
outcomes.
The industry also funded its own health
studies in the early 1970s, which
confirmed large differences in nitrogen
dioxide exposures but did not show
significant differences in respiratory
outcomes. These findings were
documented in publications where
industry funding was not disclosed
(https://doi.org/10.1016/0013-
9351(79)90074-4). These conclusions
were amplified in numerous meetings and
conferences and ultimately influenced
major governmental reports summarizing
the state of the literature.
This campaign was remarkable, since the
basics of how gas stoves affected indoor
air pollution and respiratory health were
straightforward and well established at
the time. Burning fuel, including natural
gas, generates nitrogen oxides: The air in
Earth’s atmosphere is about 78 per cent
nitrogen and 21 per cent oxygen
(https://education.nationalgeographic.org/resource/atmosphere/),
and these gases react at high
temperatures.
Nitrogen dioxide is known to adversely
affect respiratory health
(https://www.epa.gov/no2-
pollution/basic-information-about-no2).
Inhaling it causes respiratory irritation and
can worsen diseases such as asthma.
This is a key reason why the US
Environmental Protection Agency
established an outdoor air quality
standard for nitrogen dioxide in 1971
(https://www.epa.gov/sites/default/files/2020-
07/documents/fr-1971-04-30-
co_phchemoxids_hcs_no2finaldecision_0.pdf).
No such standards exist for indoor air, but
as the EPA now acknowledges, nitrogen
dioxide exposure indoors also is harmful
(https://www.epa.gov/indoor-air-quality-
iaq/nitrogen-dioxides-impact-indoor-air-
quality).

(https://images.theconversation.com/files/556944/original/file-
20231031-27-khx5m4.png?ixlib=rb-
20231031-27-khx5m4.png?ixlib=rb-
1.1.0&q=45&auto=format&w=1000&fit=clip)
More than 27 million people in the US have
asthma, including about 4.5 million children
under age 18. Non-Hispanic Black children are
two times more likely to have asthma compared
with non-Hispanic white children. EPA
(https://www.epa.gov/asthma/asthma-
awareness-month)

How harmful is indoor exposure?

The key question is whether nitrogen
dioxide exposure related to gas stoves is
large enough to lead to health concerns.
While levels vary across homes, scientific
research shows that the simple answer is
yes — especially in smaller homes and
when ventilation is inadequate.
This has been known for a long time. For
example, a 1998 study that I co-authored
(https://doi.org/10.1080/10473289.1998.10463704)
showed that the presence of gas stoves
was the strongest predictor of personal
exposure to nitrogen dioxide. And work
dating back to the 1970s showed that
indoor nitrogen dioxide levels in the
presence of gas stoves could be far
higher than outdoor levels
(https://doi.org/10.1021/es60158a013).
Depending on ventilation levels,
concentrations could reach levels known
to contribute to health risks
(https://doi.org/10.1289/ehp.1306673).
Despite this evidence, the gas industry’s
campaign was largely successful.
Industry-funded studies successfully
muddied the waters, as I have seen over
the course of my research career, and
stalled further federal investigations or
regulations addressing gas stove safety.
This issue took on new life at the end of
2022, when researchers published a new
study estimating that 12.7 per cent of US
cases of childhood asthma — about one
case in eight — were attributable to gas
stoves
(https://doi.org/10.3390/ijerph20010075).
The industry continues to cast doubt on
gas stoves’ contribution to health effects
(https://www.nytimes.com/2023/01/29/climate/gas-
stove-health.html) and fund pro-gas stove
media campaigns
(https://www.motherjones.com/environment/2020/06/gas-
industry-influencers-stoves/).

A concern for climate & health

Residential gas use is also controversial
today because it slows the ongoing shift
toward renewable energy, at a time when
the impacts of climate change are
becoming alarmingly clear
(https://theconversation.com/climate-
damage-is-worsening-faster-than-
expected-but-theres-still-reason-for-
optimism-4-essential-reads-on-the-ipcc-
report-202116). Some cities have already
moved or are considering steps to ban
gas stoves in new construction
(https://www.boston.com/real-
estate/real-estate-
news/2023/07/25/mass-bill-would-ban-
gas-stoves-new-construction/) and shift
toward electrifying buildings
(https://chicago.suntimes.com/2023/10/3/23896185/electrification-
chicago-new-buildings-gas-stoves-heat-
transition-ordinance-hall-knudsen-op-ed).
As communities wrestle with these
questions, regulators, politicians and
consumers need accurate information
about the risks of gas stoves and other
products in homes. There is room for
vigorous debate that considers a range of
evidence, but I believe that everyone has a
right to know where that evidence comes
from.
The commercial interests of many
industries, including alcohol, tobacco and
fossil fuels, aren’t always compatible with
the public interest or human health
(https://doi.org/10.1016/S2214-
109X(16)30217-0). In my view, exposing
the tactics that vested interests use to
manipulate the public can make
consumers and regulators savvier and
help deter other industries from using
their playbook
(https://applications.emro.who.int/docs/FS-
TFI-198-2019-EN.pdf?ua=1).
Jonathan Levy
(https://theconversation.com/profiles/jonathan-
levy-1165039), Professor and Chair,
Department of Environmental Health,
Boston University
(https://theconversation.com/institutions/boston-
university-898)
This article is republished from The
Conversation
(https://theconversation.com) under a
Creative Commons license. Read the
original article
(https://theconversation.com/when-
science-showed-in-the-1970s-that-gas-
stoves-produced-harmful-indoor-air-
pollution-the-industry-reached-for-
tobaccos-pr-playbook-216698).

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