What are current challenges of NCAP performance assessment framework — and its potential solutions

Since the inception of India’s National Clean Air Programme (NCAP), the path to cleaner air in 131 cities has been marked by evolving metrics and methodologies for evaluating performance. These efforts, however, have varied significantly across cities that qualify for NCAP funding, those that get 15th Finance Commission (also called XV-FC) grant and the Swachh Vayu Survekshan (SVS) rankings, which were introduced in 2022.

As the programme nears its end, the need to fine-tune evaluation metrics becomes more apparent, especially as the focus shifts from PM10 (pollutant particles 10 micrometres or less in diameter) to a multipollutant approach centred on PM 2.5.

A recent evaluation by the Delhi-based think tank Centre for Science and Environment highlighted concerns about the ineffective metrics used to assess city performance and presented a comprehensive agenda for reform to ensure the programme achieves its objectives more effectively.

How cities have been evaluated so far

During the initial phase of the programme in 2020-21, the focus for 82 NCAP cities was on developing comprehensive clean air action plans, which accounted for 40 per cent of the evaluation weightage. The remaining 60 per cent focused on enhancing pollution monitoring mechanisms, conducting rigorous source-apportionment studies and implementing city-specific action plans.

In contrast, 49 cities under the XV-FC focused on lowering PM10 levels and increasing the number of days with good air quality (AQI greater than 200), with 70 per cent of the evaluation weight assigned to these criteria. The remaining 30 per cent adhered to the NCAP city evaluation parameters.

In 2021-22, the second phase of city performance assessment for 82 NCAP cities streamlined its criteria to focus exclusively on PM10 reduction. All evaluation weight (100 per cent) was allocated to targets for reducing PM10 concentrations by 3-15 per cent, aiming for an overall reduction of up to 40 per cent by 2026.

In contrast, 49 cities under XV-FC were evaluated based on significant reductions in PM10 levels and greater improvement in the number of good air quality days (15 per cent or more) compared to the previous year.

During the third phase of assessment in 2022-23, the Union Ministry of Environment, Forest and Climate Change (MoEF&CC) launched an initiative called Swachh Vayu Survekshan (SVS) to rank cities based on air quality and the implementation of NCAP-approved activities. SVS introduced a population-based ranking system, marking a significant shift. This new assessment allocated weightage across eight sectors, prioritising actions such as biomass and municipal solid waste burning, road dust management, and vehicular emissions. 

The sectors assigned the highest weightage (20 per cent) include biomass and municipal solid waste burning followed by road dust, vehicle emissions and industrial emissions. Only 2.5 per cent of the weight is given to improving PM10 concentrations and public awareness campaigns, whereas dust from construction and demolition waste is given a 5 per cent weightage.

Evolving methods of performance assessments for NCAP/ XV-FC cities

Challenges in evaluating 131 NCAP cities

In the first phase, the evaluation could not be comprehensive in the first year. As of September 2021, 125 cities had received approval for their city action plans, while only 58 cities had submitted their micro action plans. Only 12 cities had completed source apportionment studies, 72 cities were in progress and 42 were still in tendering stage. Several cities were still in the stage of evaluation and seeking approval.

So, the first phase underscored significant disparities among the 131 cities, revealing that many lagged behind in critical preparatory measures such as developing comprehensive action plans and conducting detailed source apportionment studies until as late as 2021.

During second method of assessment, the average annual PM10 concentration for XV-FC cities was calculated after removing 2 per cent outliers for both years for comparison of values. It means 2 per cent extreme/worst conditions (seven to eight days out of 365) have not been considered. This results in the normalization of data, which moderates the situation of the data that fails to indicate the actual reduction in PM10 and rise in good days for a year. 

Furthermore, the annual data does not consider unhealthy exposures since it excludes exceptional situations (2 per cent outliers), which is crucial in view of human health impact.

In the third phase of assessment under SVS, PM10 concentration improvements were given a minimal weight of just 2.5 per cent, which raises concerns about whether the impact of efforts to lower particulate matter levels is properly reflected. Furthermore, SVS lacks comprehensive comparison parameters, categorising 131 cities solely based on population without considering important factors such as area, topography, and geography.

Hence, the city rankings based on different assessments do not match each other. The comparison of PM10 improvement in NCAP / XV-FC cities and level of action along with the PM10 improvement under SVS shows they do not always correspond. There is no way to establish the link between action and improvement in PM10 levels.

For instance, Delhi ranked 9th under SVS for implementing policy measures but is at the bottom, scoring zero, under NCAP assessment for not improving PM10 levels.

The need for new performance assessment framework

As the NCAP approaches its final stages, there is a pressing need to refine evaluation metrics to encompass a broader, more inclusive approach. Currently, cities are evaluated based on PM10 levels and general air quality data, which overlooks sector-specific initiatives. Consequently, cities that have not shown progress in reducing PM10 levels are often unfairly classified as non-performers, despite substantial efforts.

SVS gave a mere 2.5 per cent weightage to improving PM10 concentration for city rankings. The second assessment, on the other hand, gave this criterion its full attention. NCAP’s fundamental objectives are undermined by the minimal weight assigned to PM10 concentration, a critical programme target.

To accurately evaluate the performance of these 131 cities under NCAP, XV-FC and SVS assessments, it is crucial to develop robust new metrics. A comprehensive framework should be established, incorporating sector-specific actions and adopting a multi-pollutant approach that includes both PM10 and PM2.5 data.

From a public health perspective, the focus should shift to the more harmful PM2.5, establishing it as the benchmark for performance-linked funding. This shift would ensure a more accurate and fair assessment of city efforts and progress in improving air quality.

A comprehensive framework incorporating sector-specific actions and adopting a multi-pollutant approach that includes both PM10 and PM2.5 data.