In January 2010, the Union Ministry of Environment and Forests took a radical step to rein in the growing levels of industrial pollution: it declared a moratorium on setting up new industries in 43 critically polluted industrial clusters across the country. This was a small victory for those fighting against the proliferation of dangerous industries in areas that were already suffering from extremely poor environmental and health quality. The triumph, regrettably, proved short-lived.

Over the next five years, first the United Progressive Alliance government and then the National Democratic Alliance government lifted the moratorium from 37 of the 43 clusters. They did so not because the clusters showed remarkable reduction in pollution levels or because preventive steps were taken against further environmental damage. They lifted the embargo because the “initiation of implementation” of government action plans was deemed enough.

When time came for a reassessment of the government’s policy on identifying industrial clusters with high levels of pollution, the Central Pollution Control Board, a statutory body under the Environment Ministry, suggested revising its methodology. The proposed methodology appears to be much weaker.

Avoiding complexities

The last methodology, devised in association with the Indian Institute of Technology, Delhi, calculated a Comprehensive Environmental Pollution Index value based on pollution levels in ambient air, ground water and surface water. The 43 clusters that were declared critically polluted in January 2010 scored more than 70 (out of 100) on the CEPI.

The suggested methodology does not change the formula to calculate CEPI, but it does amend the factors to be considered and the weightage attached to each factor. The rationale given is that it will eliminate subjective or “debatable” factors and retain “factors which can be measured precisely”. Also, according to the Central Pollution Control Board, “health studies require huge funds and [are] time consuming as well as complex due to difficulty in finding truly representative data”.

An analysis of the proposal shows that it is a poorly reasoned document that is likely to weaken the current methodology. While suggesting a new approach, the Central Pollution Control Board doesn’t provide any data or explanation of whether, and why, the current methodology failed in correctly identifying polluted areas. It also does not discuss the methodological difficulties it faced in 2009-2010, the concerns raised by the stakeholders, and whether it took into account the views of the people who may have benefited from the moratoriums.

It is true that the proposed methodology may make it easier to calculate the CEPI value for an area. But it is also likely that it will result in fewer areas getting included in the “critically polluted” category, thus limiting the impact of pollution control policies.

The proposal continues the Source-Pathway-Receptor approach of the current methodology: calculating levels of pollution for each of these separately and attaching different weights.

1. Source
The factors to calculate pollution at “source” are the same as before: nature of toxins present in the air and the scale of industrial activity. But their weightage has reduced from 30% to 20% of the total score, even though these factors can be objectively determined and precisely measured.

2. Pathway
Pathway is currently calculated based on the ambient concentration of the pollutant besides evidence of adverse impact on people (symptoms of exposure, fatality or disease) and on eco-geological features (symptoms of exposure, significant/irreparable loss or damage to flora/fauna).

The proposed methodology replaces all these factors with a single one: level of exposure. This is calculated by multiplying the ratio of samples that exceed the ambient air quality standards to the total number of samples with the exceedance factor (the amount by which a pollutant exceeds a standard or permissible measurement).

The main problem with this proposal is that sample results can easily be tinkered with to show lower level of exposure. Given the high weightage attached to this factor (50%), a manipulated sample can completely skew the results in a particular cluster – making it appear much less polluted than it is.

3. Receptor
As for the Receptor, the current methodology considers the number of people potentially affected within a 2-kilometre radius of the pollution source, the level of exposure, and the additional risk to sensitive receptors such as children.

While the level of exposure is retained in the proposal, the other two factors have been deleted. In their place appears “impact on human health” with a weightage of 10% (lower than the earlier 30%). The impact will be calculated based on the rise in the cases of asthma, bronchitis, cancer, respiratory infection, gastroenteritis, diarrhoea, etc. as reported in “three-five major hospitals” over two consecutive years. It is unclear why this data on health impacts – presumably more reliable and easier to procure – could not have been incorporated in the current methodology.

The proposed methodology also appears to ignore victims of pollution other than humans, such as flora and fauna, ecologically significant sites and historical or archaeological sites. Further, it’s not clear why sensitive receptors like children have been dropped from consideration, even though the current methodology asks an objective question with a yes/no answer, not requiring extensive investigation.

4. Additional high-risk element
A fourth factor, the Additional High Risk Element, is based on the adequacy of pollution control facilities in large, medium and small-scale enterprises. The methodology and weightage (20%) of this has not been changed. It is determined based on status reports of the past two years, but, curiously, the Central Pollution Control Board does not seem concerned about the reliability of these reports.

Close monitoring and regulation of critically polluted areas is a necessary policy goal. With environmental quality worsening rapidly in most parts of the country, and particularly in industrial clusters, the government needs to urgently adopt stringent remedial measures. It needs to enhance pollution control initiatives like the CEPI-based moratorium, not limit their scope. But first it is crucial that critically polluted areas are properly identified through a robust methodology that takes into account qualitative and quantitative factors. If there is any uncertainty, policy makers must err on the side of caution: cast a wider net and protect public health and the environment, until more reliable data to the contrary surfaces.

The writer is an environmental lawyer and a Fellow at the Centre for Policy Research in New Delhi.