IMPLEMENTING GRADED RESPONSE ACTION PLAN

(GRAP) IN DELHITHROUGH SECTORAL APPROACHES

By
Dr. J. K. Moitra
Vice President : IAAPC
(Ex-Scientist CPCB)

Workshop on Role of Cities in Addressing

Air Pollution to Protect Public Health

5th & 6th December 2018

Ahmedabad
 History of GRAP

Direction passed by Hon’ble Supreme Court in WP (C) 13029-1985. MC Mehta Vs

Union of India. Directed the Central Govt to examine the Graded Response
Action Plan to different levels of air pollution in NCR as proposed by Central
Pollution Control Board and issue appropriate notification u/s 3(1) of
Environment (Protection) Act 1986.

Hon’ble Supreme Court further directed that the implementation of GRAP shall be
under the orders of Environment Protection Control Authority.

In pursuance of the aforesaid direction, MoEF&CC issued Notification entrusting the

implementation of GRAP to EPCA dated 12-1-2017.

MoEF&CC examined the GRAP on 10-1-2017 and took following decisions:

1. AQI for implementation of GRAP should be based on the readings of at least
50% CAAQMS.
2. GRAP should be seen as an evolving plan
3. Task force headed by CPCB created comprising MS of NCR states, IMD, Health
experts and air pollution expert.
4. Mandate of Task Force should include consideration of various measures
required to different levels of AQI for appropriate recommendations to EPCA. 2
Air Quality Index (AQI)

AQI
parameters: 8
Minimum
Parameters
PM2.5, PM10 &
NO2 to
calculate AQI.
Monitored
continuously
using CAAQMS
AQI given on
hourly and
daily basis)
Peak value of
parameter
used for AQI
3
 AQI Categorization based on health impacts
(original wordings)
AQI Associated Health Impacts

Good Minimal Impact

(0-50)
Satisfactory May cause minor breathing discomfort to sensitive people.
(51-100)
Moderately polluted May cause minor breathing discomfort to people with lung disease
(101-200) such as asthma, and discomfort to people with heart disease,
children and older adults.
Poor May cause breathing discomfort to people on prolonged exposure,
(201-300) and discomfort to people with heart disease.
Very Poor May cause respiratory illness to the people on prolonged exposure.
(301-400) Effect may be more pronounced in people with lung and heart
disease.
Severe May cause respiratory impact even on healthy people, and serious
(401-500) health impact on people with lung/heart disease. The health impacts
may be experienced even during light physical activity.

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AQI Categorization based on health impacts

5
Monitoring Stations in Delhi for AQI
Delhi Pollution Control Committee: 24 CAAQMS
Central Pollution Control Board: 6 CAAQMS
SAFAR / IMD: 8 CAAQMS

6
 Major sources of air pollution in Delhi/ NCR

1. SO2, NOx, PM emission from 13 coal based power plants located in NCR-Delhi.
2. About 8 lacs DG Sets are in operation in commercial / industrial & residential areas of
NCT Delhi.
3. Large numbers of small scale industries located in Delhi and NCR emitting air
pollutants beyond the prescribed standards.
4. Uncontrolled growth of vehicles population in NCR. More than 100 lacs vehicles are
registered in NCT Delhi alone (60-70% are two wheelers)
5. Transport fuel quality issues in NCR petrol pumps, specially adulteration of fuel .
6. Very poor inspection and maintenance system for in-use vehicles. PUC system which
is in operation is serving limited purpose.
7. Inefficient public transport system in NCR forcing public to use personal vehicles.
8. 550 million tons of agriculture residue are burnt mostly in northern states causing
serious air pollution in NCR during winter months.
9. Large construction activities in NCR, generation of dust.
10. Emission from existing waste to energy plants
11. Emissions due to burning of industrial wastes, garbage, plastic, rubber, etc in NCR
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 PM apportionment in Delhi

 Winter (PM2.5)
NO3 - SO4-2 NH4+ : 28%
TC (Total Carbon) (Elemental Carbon) + (Organic Carbon) 23%
Total : 51%
 Summer (PM2.5)
NO3- SO4-2 NH4+ : 17%
TC (Total Carbon) = (Elemental Carbon) + (Organic Carbon) 9%
Total : 26%
Source --IIT Kanpur Report 2016

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 Graded Response Action Plan for Delhi & NCR
(Blue for transport sector, magenta for industries and green
for other sector)

Severe+ or Emergency (ambient PM 2.5 or Agency responsible/

PM10 concentration values of 300 µg/m3 or Implementing Agency
500 µg/m3 respectively persist for 48 hours
or more)
Stop entry of truck traffic into Delhi (except Municipal Corporations and Traffic
essential commodities) Police of Delhi and NCR Towns

Stop construction activities Delhi Pollution Control Committee/

Municipal Corporations of Delhi and NCR
towns
Introduce odd and even scheme for private Secretary cum Commissioner of Transport
vehicles based on license plate numbers and Department, NCT of Delhi, and Transport
minimize exemptions Commissioners of NCR towns

Task Force to take decision on any additional  

steps including shutting of schools

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 Graded Response Action Plan for Delhi & NCR

Severe (ambient PM2.5 or PM10 Agency responsible/

concentration value is more than
Implementing Agency
250 µg/m3 or 430 µg/m3 respect)
Close brick kilns, Hot Mix plants, Stone
Chairpersons Delhi Pollution Control Committee,
Crushers State Pollution Control Boards of Haryana,
Rajasthan, and Uttar Pradesh
Superintendent of Police and Deputy
Commissioner of respective districts
Shut down Badarpur power plant and Chairpersons Delhi Pollution Control Committee,
maximize generation of power from State Pollution Control Boards of Haryana,
existing natural gas based plants to Rajasthan, and Uttar Pradesh
reduce operation of coal based power
plants in the NCR.
Intensify public transport services. Secretary cum Commissioner of Transport
Introduce differential rates to Department, NCT of Delhi, and Transport
encourage off-peak travel. Commissioners of NCR towns
Chairperson, Delhi Metro Rail Corporation
Chairperson, State Transport Corporations
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 Graded Response Action Plan for Delhi & NCR

Severe (ambient PM2.5 or PM10 Agency responsible/

concentration value is more than 250
Implementing Agency
µg/m3 or 430 µg/m3 respectively)
Increase frequency of mechanized cleaning All road owning agencies including
of road and sprinkling of water on roads. Municipal Corporations of NCT of Delhi
Identify road stretches with high dust and NCR towns, Public Works
generation. Departments and National Highway
Authority of India

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 Graded Response Action Plan for Delhi & NCR

Very Poor (ambient PM2.5 or PM10 conc value is

between 121-250 µg/m3 or 351-430 µg/m3 respect)
Stop use of diesel generator sets
Agency responsible/
Implementing Agency
Chairpersons DPCC, State Pollution Control Boards
of Haryana, Rajasthan, Uttar Pradesh

Enhance parking fee by 3-4 times Municipal Commissioner

Municipal Corporations of Delhi and NCR towns
Increase bus and metro services by augmenting Principal Secretary, Dept of Transport Delhi
contract buses and increasing frequency of service Delhi Transport Corporation (DTC)
Delhi Integrated Multi-modal Transit System Ltd
Delhi Metro Rail Corporation (DMRC)
State Transport Corporations in NCR towns
Stop use of coal /firewood in hotels and open Municipal Corporations of Delhi and NCR towns
eateries
Residential Welfare Associations and individual Resident Welfare Associations
house owners to provide electric heaters during
winter to security staff to avoid open burning
Alert in newspapers/TV/radio to advise people with Chairpersons, Delhi Pollution Control Committee,
respiratory and cardiac patients to avoid polluted State Pollution Control Boards of Haryana,
areas and restrict outdoor movement. Rajasthan, and Uttar Pradesh

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 Graded Response Action Plan for Delhi & NCR

Moderate to poor (ambient PM2.5 or PM10

Agency responsible/
concentration value is between 61-120 µg/m 3 or
101-350 µg/m3 respectively) Implementing Agency

Stringently enforce/ stop garbage burning in Municipal Commissioner of Delhi and NCR Towns
landfills and other places and impose heavy fines
on person responsible

Close/ stringently enforce all pollution control Chairpersons, Delhi Pollution Control Committee,
regulations in brick kilns and industries State Pollution Control Boards of Haryana,
Rajasthan, and Uttar Pradesh

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 Graded Response Action Plan for Delhi & NCR

Moderate to poor (ambient PM2.5 or PM10

Agency responsible
concentration value is between 61-120
µg/m3 or 101-350 µg/m3 respectively) /Implementing Agency

Stringently enforce pollution control in Plant in-charge of power plants in NCR, and DPCC and SPCB
thermal power plants through SPCB of Haryana, Rajasthan and Uttar Pradesh
monitoring
Do periodic mechanized sweeping on Municipal Corporations of Delhi and NCR towns
roads with heavy traffic and water Commissioners, Traffic Police of Delhi and NCR towns to
sprinkling also on unpaved roads every identify roads with heavy traffic and provide information to
two days respective Municipal Commissioners
Chief Engineers of CPWD, PWD of Delhi and NCR towns to
identify unpaved roads with heavy traffic and provide
information to Municipal Commissioners
Strict vigilance and no tolerance for visible Commissioner or Officer in Charge, Transport Department and
emissions – stop plying of visibly polluting Traffic Police of NCT Delhi and NCR towns
vehicles by impounding or heavy fine.
Strict vigilance and enforcement of PUC
norms

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 Graded Response Action Plan for Delhi & NCR

Moderate to poor (ambient PM2.5 or PM10

Agency responsible
concentration value is between 61-120 µg/m3 or
101-350 µg/m3 respectively) /Implementing Agency

Stringently enforce rules for dust control in
construction activities and close non-compliant sites
Ensure fly ash ponds* are watered every alternate
day during summer months (March – May).
Deploy traffic police for smooth traffic flow at
identified vulnerable areas
Strictly enforce Supreme Court order on diversion of
non-destined truck traffic and ensure only trucks
registered after 2005 are allowed entry into Delhi
Commissioner or Officers in charge of Police
Departments of Delhi and NCR towns
Plant in charge of Power Plants in Delhi and NCR
towns
Commissioners Traffic Police of Delhi and NCR
Towns
Municipal Corporations of NCT of Delhi and NCR
towns
Traffic Police of NCT of Delhi and NCR towns

Strictly enforce firecrackers o

nChief Controller of Explosives
Petroleum & Explosive Safety Organizations
Commissioner of Officer in charge of licensing in the
police departments of Delhi and NCR

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 Graded Response Action Plan for Delhi & NCR

Moderate to poor (ambient PM2.5 or PM10 Agency responsible/

concentration value is between 61-120 µg/m3
Implementing Agency
or 101-350 µg/m3 respectively)
Information dissemination Social media, Chairpersons, Delhi Pollution Control
mobile Apps should be used to inform people Committee, State Pollution Control Boards of
about the pollution levels, contact details of Haryana, Rajasthan, and Uttar Pradesh
control room, enable them to report polluting
activities/sources to the concerned
authorities, and actions that will be taken by
government based on the level of pollution.

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 Achievements & Drawbacks

1. Introduction of BSVI Fuel and start of BSVI vehicles (Mercedes, Volvo)

2. Closure of Coal Based Power Plants (partially and fully)
3. Action on 10 year old and 15 year old vehicles
4. Based on GRAP, many directions were given by NGT, High Court and Supreme Court
5. (Prosecution of responsible officials, imposition of fines on agencies, restriction on
fire crackers)
6. Better compliance by industries and construction activity
7. Public became conscious and are now in demanding mode
8. Time targets set and incentivisation done for including Electric & Hybrid vehicles
9. Multiple agencies are now sitting together and discussing plans

DRAWBACKS
1. GRAP is an evolving subject. It is subject to change in NAAQS (first one notified in
1994, last one notified in 2009, new standards are expected. More and more health
data is available now and hence both NAAQS and AQI is subject to change.
2. CAAQMS and AQI data not applied to improve human health
3. New air pollutants of significance in Delhi NCR are not considered (like H 2S),
4. Economic benefits /losses of GRAP is not assessed. 17
 Way Forward for the non-attainment Cities

1. SPCB has powers under section 17 of Air Act 1981 to plan programs for the
prevention, control & abatement of air pollution and to secure the execution thereof
2. Plan program to ensure 30% reduction in air pollution load in Delhi NCR and all the
102 non-attainment cities (as per the direction of Hon’ble Supreme Court)
3. Ensure quality check and data assurance of CAAQMS through appropriate calibration,
spare parts and routine maintenance

4. Use AQI and Forecasting to advise / inform public about proper time-activity pattern,
use of pollution prevention gadgets and precautions to follow for good health.

5. Rationalise the conceptual framework of AQI based on data generated over last 2
years. Consider the requirement of CAAQMS for ammonia, lead and SO 2.

6. Use source apportionment study to identify and quantify emission sources

7. Use carrying capacity study in a city to plan the resource and industrialization

8. Develop framework for health emergency in AQI based on EC & OC in PM 2.5 & PM10

9. Stop sale of BSIV compliant vehicles from April 2020

10. Set time targets and incentivise adding Electric & Hybrid vehicles 18
 Way Forward for the non-attainment Cities

11. Develop methodology and specifications of low cost instruments applicable for
community level monitoring (outdoor) and personal exposure monitoring (indoor)
12. Develop SOP for establishing monitoring network and parameters required for
abatement of specific air pollution issues in a community
13. Stop coal and MSW based power plants, and construction activity during winter
14. Increase carrying capacity of arterial, sub-arterial and collector roads
15. Implement new norms for TPP (before December 2022)
16. Incentivise burning of hazardous wastes and other residues in Cement Kiln
17. Incentivise use of agriculture residue for power generation
18. Prohibit use of coal, firewood & kerosene within 25 km of city limit
19. Link PUC with registration and insurance of motor vehicles
20. Use air pollution control in crematoria, clean tandoors in dhabas/eatouts.
21. Prosecute officials responsible for controlling air pollution
22. Ensure uninterrupted electric power and regulate use of DG sets (capacity & time)

23. Restrict sale of fire crackers

24. Encourage use of Wind Augmentation and Purifying Unit to reduce exposure
25. Develop standards for Air Purifiers
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