Why do we condemn the proposed roadmap of the Auto Fuel Policy?

Chapter-wise comments on the key recommendations and issues in the Report of the Expert Committee on Auto Fuel Policy released by the Government of India in August 2002

Have they got their guiding principles right? No

Chapter 1
Executive summary
Comments
This chapter summarises the issues and overall recommendations of the Report.

Additionally it lists the
Guiding principles for the auto fuel policy as the committee set for itself. These are as follow:

  • Public health is a prime concern and air quality is crucial factor in determining the public health. Therefore, holistic policy is needed to draw out a sound policy. (P 4)
  • Primary goal is to ensure sufficient reliable and economic fuel supplies to support economic and social development.
  • Within the overall framework of the national policy take special city specific measures
  • Build on the currently available infrastructure to get maximum out to meet public health goals.
  • Minimise social costs for meeting air quality targets.
  • Evidence based analysis using scientific validated data especially under Indian conditions needs to be the cornerstone of any sound policy.
  • Rather than rigid and prescriptive policy a flexible policy, which allows choice of fuel and technology combination for meeting norms, was desirable.
  • Transparency in policy crucial.

 

In this chapter we will comment only on the guiding principles as comments on other issues and recommendations have been made under the relevant chapter heads.

Guiding principles emphasise what is passively feasible within the available options and infrastructure and do not set principles to drive auto fuel policy to hasten the future roadmap to meet clean air targets. Holistic approach is not same as the best approach to meet the public health objectives.

To set as a goal the need for scientifically valid data in Indian conditions is welcome but it is also more important to recognise the need for preventive and corrective action based on what is already known and technology solution already available elsewhere. Waiting to revalidate what is already known will only hold up action and increase risk to public health.

Preventive and precautionary principles are not part of the guiding principles yet.

The principles have very categorically asked to avoid taking `prescriptive approach’ (read CNG). It is important to recognise that the fuels switch approach in Delhi is an intermediate strategy to get past poor fuel quality norms. We can avoid `prescriptive approach’ (CNG) only if more stringent standards of Euro IV are brought forward.

Modify the guiding principles to enable leapfrogging strategy for the country.

The committee was not even asked to address public health concerns while charting the roadmap

Chapter 2: Background and the terms of reference Comments
Terms of reference: (P 22)
  • To recommend an Auto Fuel policy for the country, including major cities and devise road map for its implementation, taking into account the vehicular emissions norms.
  • To recommend suitable auto fuels and their specifications considering I) availability and logistics of fuel supplies, ii) the processing economics of auto fuels and iii) the possibility of multi-fuel use
  • To recommend attributes of the automobile technology, fuel mixes relevant, price environment for ensuring minimising social cost of meeting given level of environmental quality
  • To recommend institutional means of certification of different technology and fuel mixes as also monitoring and enforcement measures.
 

Nowhere in the terms of reference given by the ministry of petroleum and natural gas to the committee it is mentioned that auto fuel policy must be designed to address public health objectives and air quality targets.

This therefore sets the tone of the Report, which aims to improve the roadmap marginally and incrementally at least cost over an extended period of time.

The committee has added public health concern in its guiding principle as an after thought following public criticism over its interim report first released in January 2002.

Flawed methods and warped conclusions

Chapter 3: Approach and methodology Comments
Methodology adopted for this report has been discussed We have comments to make on the methodologies applied by various agencies that were commissioned by the committee to undertake specific studies that became the basis of many conclusions and recommendations of the Report. We have given our comments on them in the relevant chapters.
Chapter 4
Air Quality Standards and Air Pollution
Comments
Issues raised in this chapter:

Ambient air quality standards and monitoring

  • Long-term standards have been set to protect population from regular high level of exposure and short-term standards to control acute exposure. (P 31) Standards have been set for SO2, NO2, SPM, RSPM, lead, CO, and Ammonia. (P 31)
  • Land-use based standards are in place – residential, industrial, and commercial (P 31)

 

 

The report claims that for annual average mean average of 104 days measurements are taken twice a week 24 hourly at uniform interval. (P 31)



Need revision of the ambient air quality standards to include new pollutants of concern. Set standards for PM 2.5, benzene, and sulphates. Expand monitoring facilities for ozone, benzene, PAH, and trace metals in cities.

 

We do not agree with land-use based standards. The purpose of the standards is to protect public health. In cities like Delhi all land use categories are densely populated. For instance, Shahadara, which is classified as industrial area, is also one of the densely populated areas in Delhi. Lax ambient air quality standards for such areas can have serious public health implication. So set uniform but stringent standards that are close to the current standards for sensitive areas to provide adequate margin of safety.

As of date monitoring in many cities do not even follow this basic criteria of monitoring one third of days in a year. Therefore, annual average cannot be calculated. Only monthly average is reported which is quite meaningless, as these values cannot be directly compared with any standard, as standards for monthly average do not exist. Improve monitoring for more comprehensive risk assessment.

Other issues in air Quality monitoring
  • The report admits to the limitations in the current process of monitoring that compromise data quality such as probability in variations, biases due to involvement of large number of monitoring agencies, personnel, equipment for sampling, analysis and data reporting (P32).

 

 

 

 

 

Discussion on this issue is very vague and does not provide any plan of action to deal with the current limitations. Even the plan for national air quality monitoring programme detailed out for budget requirement in the annexure 4.2 does not indicate any further plan for improvement in terms of additional pollutants to be monitored and expansion and improving the monitoring network etc.

We note with concern the delay in data reporting by monitoring agencies. Reporting of national data lags by 1-2 years. CPCB should coordinate with all monitoring agencies across the country for fast computation and compilation of data.

The system should be geared for daily reporting for health alters. Since in Delhi CPCB is responsible for air quality monitoring and reporting of data, it should coordinate with other agencies in the city like NEERI to improve the system.

Discussions on the contribution of vehicles to ambient air pollution load:
  • Figures have been cited from European Auto Fuel programme to prove that vehicles are not the primary contributor of particles. It states "PM 10 contribution from the transport sector exhaust in the EU s small i.e. 14 percent in 1990 and 1995, while it was estimated to be 11 percent in 2000. This is of the same order of magnitude as deduced in the Indian studies, wherein the contribution has been estimated to be between 3 percent to 22 percent (P 49).

 

 

The Report has pointed out correctly the limitation of the current studies and lack of inventories to be able to make precise estimates of emissions from different sources.

It is not clear why the report is consistently trying to draw conclusions from Auto Oil Programme of Europe and other studies to emphasise and imply that vehicles contribution to particulate pollution is not that significant.

The committee in fact should explain why therefore Europe even with transport sector contributing only 11 percent of PM 10, is taking more aggressive action compared to what Auto Fuel Policy is proposing when even the limited

Indian data is showing that vehicles can contribute double -- as much as 22 percent of the PM10.

It is also very important to note that Indian vehicular fleet is very different from that of Europe. Two stroke two wheelers predominate the Indian fleet and their emissions particularly that of particulate matter has not been discussed or quantified.

Chapter 4 recommends the following: (P 49-50)

Reduce emissions from all sectors to improve air quality. For improving air quality target pollutants in order of importance will vary from sector to sector.

Need for further studies on the following:

i) Source apportionment and characterisation

ii) Emissions inventory

iii) Modelling

Records two studies to be undertaken by CPCB:

i) "Development of emissions factors for on road vehicles" under the World Bank EMBCTA project

ii) "Development of reduction strategy of RSPM in Delhi and Kanpur" under the World Bank EMBCTA project.

 

These recommendations are like wish list as there is no clear target for undertaking these studies or responsibilities fixed to carry out these studies by the regulatory agencies in a time bound manner.

We note with even greater concern that the emission factor development study by CPCB has been abandoned since the release of this report. Instead of CPCB taking up these studies with external funding as was originally planned, we have been given to understand that four refineries are now going to fund such study on emissions inventory and emissions factor development.

Auto Fuel policy should aim at enabling the regulatory agencies to develop these policy tools. Letting refineries and industry develop inventory would bring in bias in policies, as there is conflict of interest.

 

 

According to Auto Fuel Policy vehicles are the least of all our problems

Chapter 5: Motor Vehicle Growth, Urban Road Traffic and Air pollution Comments
This chapter analyses the contribution of vehicles to air pollution load and the possible impact of the proposed roadmap:

Committee’s own projection of the impact of its proposed roadmap on the emissions load:

Early introduction of Euro IV norms in 2005 in major cities will result in the reduction of auto particulates only by around 2-4 percent compared to if Euro III is introduced in 2005. (P 66).

But Euro III in 2005 will cut particulate emissions load by 40 percent

It further states that if business as usual scenario is allowed to continue till 2010, the pollution load due to traffic would remain virtually the same as in the base year. This is in spite of the estimated increase of about 50 percent in the traffic loads. This is expected as newer technology is expected to replace the older ones. (P 79).

 

 

The basis of these calculations and projections have not been explained anywhere.

It seems that the concept of the incremental benefit of introducing Euro IV emissions standards are grossly misunderstood. Any improvement from unregulated or poorly regulated scenario shows much larger reduction in percentage terms that makes further reduction seem marginal. But incremental gains with greater advancements are more relevant from the standpoint of meeting air quality targets.

Since details of the calculation are not available it is difficult to understand their conclusions about the projected pollution load from vehicles in Delhi.

All the more reason why the studies commissioned by the committee to draw conclusions from their assumptions is critical to understand the biases in the report.

Findings of two studies by NEERI and CRRI on estimating vehicles’ contribution to air pollution load have been presented in this chapter. (P 62)

NEERI’s source apportionment study in Kanpur:

  • The study concludes that auto exhaust at kerb side emit 16 percent of RSPM. Auto exhaust along with diesel generator sets is responsible for 32 percent, 22 percent, and 39 percent of RSPM in industrial, commercial, and residential areas respectively. Around one third of RSPM is from re-suspended dust and earth crust. Industry and other sources contribute 25 to 40 percent of PM10. (P63)
  • Various studies conducted in India and other countries including Kanpur study, indicate that RSPM/PM10 is contributed mainly by auto exhaust is not correct.
  • In India particularly, in the northern and the central India contribution of natural dust, resuspension of traffic dust and use of fuels for non auto purposes like diesel generator sets to the total RSPM is high.
It is important to assess these studies, as the findings of these studies are the basis of the proposed roadmap on emissions standards and the projected impact of the proposed roadmap on emissions standards. There are many issues that cast doubts on their methods. Some examples:

If the NEERI study admits that impact of natural dust on RSPM can be high, then why was this study conducted only in the month of May when high dust levels are common. Why is there no data on seasonal variation correlated with meteorological data? This would bring out how during winter months RSPM levels can peak when occurrence of natural dusts storms are minimal. CSE’s analysis of seasonal data provided by CPCB for Delhi shows that RSPM levels during winter can be higher than the summer levels due to inversion conditions. In the Report it is admitted that though the 10-day monitoring was planned for continuous 24 hour monitoring every day as per standard practices due to frequent power breakdown and dust storm actual monitoring could not be done for 24 hours. Yet the figures in the Report are on 24-hour basis. This does not meet the rigours of scientific monitoring. On the basis of such unrepresentative and inadequate monitoring far reaching conclusions have been drawn.

Why two different sources of pollution – on road vehicles and non-road sources like diesel generator sets have been clubbed together to estimate pollution load. This is not a scientific approach and is grossly misleading.

 

CRRI study on Urban road traffic and air pollution in major cities (P 65) concludes:

The report presents trend in growth in vehicle population and air pollution in different cities and concludes:

  • Trends in the ambient air quality change in most cities do not establish any direct relationship with pattern of automobiles. (P 62)

 

 

 

Some conclusions about vehicle fleet in Delhi:

High percentage of vehicles are younger and of new technology. 90 percent of vehicles have maximum age profiles as follow: 2 wheelers: 9-13 years, motor cars: 9-17 years, 3 wheelers 4-11 years, goods carriage: 9-17 years old. The age profile of 90 per cent on road vehicles in Delhi is 11 years for two wheelers, 9 years for motorcars, 4 years for three wheelers and 9 years for goods carriage.

Weighted average age of two wheelers: 5.18 years, cars: 4.06, three wheelers: 2.08 and goods carriage: 4.89.

Pollution load from vehicles is highest from automobiles in Delhi.

 

 

 

 

Conclusions are very sweeping when the report itself admits the limitation of the air pollution data and inadequate registration data for vehicles. This kind of crude correlation underestimates vehicles contribution to air pollution load. When data is so limited and data quality so dismal then why is the report repeatedly drawing conclusion to state that vehicles do not pose significant problem.

 

In order to estimate emissions load from vehicles in Delhi CRRI study has tried to generate data on the number of vehicles on road, age of vehicles, number of incoming traffic, selected emissions and deterioration factors and so on.

The surveys conducted for the study suffer from limited sample size, inadequate and unscientific time frame for surveys and lack of clear rationale for selection of locations for correlating air pollution and traffic volume.

In fact monitoring has been done only for a day in all the sites and that cannot be considered representative. Worse, in some sites like Africa Avenue, and Ashram Chowk monitoring was done on Sundays (Feb 24 and March 3) with minimum traffic on road.

Conclusions have been drawn based on extremely small sample size.

For instance in fuel station survey a total of 33 out of about 500 fuel stations were selected for survey, that is, just 6.6 per cent. Out of these 33, 24-hour survey was done at 3 stations (0.6 per cent of all stations), 12-hour daytime survey was done at 28 stations (5.6 per cent) and 12-hour overnight survey was done at 2 stations (0.4 per cent). This in essence means just one percent of the stations were expected to reflect the nighttime traffic pattern. Moreover, just 21.5 per cent of the vehicles entering these fuel stations were interviewed. This information has then been ‘analysed to understand the distribution of trips and registration details of the vehicles besides the average distance travelled per day.’

Moreover, out of the 52 midblocks, traffic count survey was conducted for 24 hours only in 16, and for the rest survey was conducted for 16 hours. Barring two locations (where the survey was done on two days), the survey was conducted only for a day at all locations.

14 intersections chosen for survey, 12 of them for 12-hour period (8:00 to 20:00) and two for 24-hour period. Yet again, the survey is conducted for one day. ‘On the basis of factors evolved from 16-hours and 24-hours counts of midblocks, the traffic flows at the intersections have been expanded to 24 hours.

24-hour surveys conducted at 10 outer cordon points for a day. The survey shows that 248,000 vehicles enter the city and 270,000 vehicles leave the city every day. Why only in ten sites? Sample size interviewed was 3.4 per cent.

The survey seems to have underestimated the number of trips made by commercial vehicles, which are expected to maximise their business trip. The fuel station survey finds that 16 per cent of hcvs, 41 per cent of mavs, and 32 per cent of light commercial vehicles (lcvs) are satisfied to make occasional trips. Similarly, the number and age of incoming traffic estimates are also based on extremely limited sample size. On the basis of this the report estimates that by-passable goods traffic are responsible for 6.6 percent of the PM.

We would like to point out that transit traffic in Delhi is a serious issue and the Supreme Court has already given direction to bypass the vehicles that do not have business in the city. Policies with regards to this can suffer if proper estimates are not made.

Moreover, if it is understood, as the Report states that, the vehicle registration data does not represent the actual number of vehicles on road it is more appropriate to recommend designing of policies to get the registration process corrected in all cities first.

In Delhi reduction in emissions load from automobiles has resulted mainly from successive improvement in emissions norms and auto fuel quality during 1996-2001. (P 66)

(The CRRI study categorically mentions that "The popular perception that the air quality in Delhi has improved only due to CNG is not borne out by this technical study P 7)

Emission factors:

These statements betray bias. It is not clear why it is important for the Committee to isolate and underplay the role of CNG in lowering the pollution load in the city. While it states that vehicular PM emissions have declined by as much as 88 percent since 1996, CNG’s contribution is only 12 percent (p8).

Interestingly, the emissions factors selected for CNG buses are that of converted buses and not the OEM designed dedicated models. This is misleading, going by the reports own admittance of how emissions load calculation can vary widely depending on the selection of emission factors. It states "variation of 10-20 percent in emissions factors are likely to result in 15-25 percent variation in the estimation of PM load." When used cumulatively, and deftly, even such small variations have the potential of making a huge difference in the total emission load.

The report uses emission factors for all vehicles except cng vehicles from those cited in the report Transport Fuel Quality for Year 2005 published by the cpcb in 2000. It uses emission factors for cng vehicles as given by the Indian Institute of Petroleum, Dehradun. Why was the vast data with ARAI and other testing agencies, which are testing most of the CNG buses for type approval were not utilised effectively?

Therefore it is essential to take a hard look at the sanctity of the emission factors used by the report.

The question of acceptability of the factors loom large particularly in the case of emission factors for particulate matter from two-wheelers (both two-stroke and four-stroke), since till date particulate matter emissions from these vehicles do not need to be certified and are therefore not tested. Particulate matter emissions were not regulated for even diesel vehicles before 1996. Use of any emission factor for these vehicles therefore needs to be justified, which the report does not.

Deterioration factor

Again, crri borrows the deterioration factors from the cpcb report on Transport Fuel Quality for Year 2005. Again, as in the case of emission factors, the cpcb report does not say anything from where it derived these deterioration factors, and how are these figures justifiable in the Indian scenario.

While the deterioration rates improve with the improvement in technology for all petrol vehicles, for petrol cars, the deterioration rate suddenly becomes higher for the age group of 5-10 years, in comparison to the age group of 10-15 years, and comes down again for newer cars.

The deterioration rates used for diesel vehicles are more astonishing. All diesel vehicles are shown to have no deterioration right from brand new vehicles to 20-year old vehicles.

Accepts that air pollution affects health. But hides behind the degree of uncertainty in the health studies: Downplays health effects of vehicular particulate emissions especially from diesel vehicles.

Chapter 6: Health Effects of Air Pollution Comments
The Committee commissioned a study to Industrial Toxicology Research Centre, Lukhnow to provide appraisal of health impact of air pollution with reference to vehicular pollution.  
Issue 1: Some observations based on survey of studies on health effects of air pollution

Much less certain are the extent to which primary PM10 from road transport is responsible for the health effects of PM10. (P 95).

Human nostrils filter out 99 percent of the inhaled large and medium sized PM emitted by vehicles. The rest may enter the lungs and may get removed by mucous. Some of the smallest are deposited in the alveoli and are of concern. Scientific studies have linked fine particles with health problems. (P95)

Committee’s analyse of the information on health impact of air pollution is key to the rationale for the proposed roadmap.

While the concern over particulate pollution is driving regulations around the world this report is at pains to understate the impact of PM especially vehicular PM on health.

Issue 2: problem with diesel particulates

Particulate matter which may give the impression that abatement of diesel engine sources could have a large impact on air quality in a non industrial a city. Modelling abroad show that future large cuts in particulate matter from vehicles may have small impact on PM10 concentration except those immediately adjacent to the busiest roads. (P 92).

 

 

This is too generic and misses the point of health risk from diesel emissions. The Report should take cognisance of the state of the art information on toxicity of the diesel emissions as documented by the US Environment protection Agency and California Air Resources Board etc while charting the toxic reduction programme. USEPA for instance has undertaken the health assessment of diesel engine exhaust after the California Air resources Board branded diesel particulates as toxic air contaminant in 1998 after a 10-year review of diesel exhaust. This assessment guided the USEPA to set the most stringent emissions standards for heavy-duty vehicles for 2007 that are expected to cut emissions by as much as 95 percent. .

The report states that available studies indicate that vehicular emissions are one of the causes of for respiratory and ocular ailments and organ systems. But the studies do not establish a cause and effect relationship between pollutants and health. (P 99)

So the Report has recommended three-year epidemiological studies in 11 cities, studies on health and environmental economics of air and vehicular pollution. (P100)

The chapter has not pointed out how the government should take preventive and corrective action based on the studies that already exist. Even as we generate more information it is important to act on the available information, integrate health-based criteria in the policy-making system.

 

Only harping on the fact that there is need for more local information and downplaying the import of the studies conducted worldwide on health effects of air pollution is only a ploy to put off the issue and not address it headlong. In risk reduction strategies it is more important to take preventive action. There is nothing in this report to state how such preventive strategies can be devised.

Unfocussed discussions on the capability of our refineries to do better

Chapter 7 Availability, demand and security of supply of auto fuels.

Chapter 8: Auto Fuels – Petrol and diesel

Comments
Issue 1: The Report gives an overview of the current fuel norms in different countries. PP118-122

The report further details out the fuel quality requirements to meet different mass emissions standards: Bharat Stage II, III, IV. PP 124 -132.

 

The report points out that sulphur content in diesel in India is lower than most of the developing countries.

The Report only talks about the norms that are prevalent but give no idea about the direction in which the countries are moving to cut emissions drastically. For policy making it is very important to understand how in India we can leapfrog to meet better standards and evaluate strategies to meet those standards. This focus is missing in this Report.

Refinery configurations have been discussed loosely but there is no discussion on how the refineries with more advanced capacities can be made to produce better quality fuels for selective introduction of advanced norms in critically polluted cities.

Issue 2 Adulteration

Various strategies for controlling adulteration have been discussed.

 

While we agree that responsibility for dispensing the right quality of fuels should be made obligatory to the oil companies the recommendations at present do not have enough teeth. This policy will have to be detailed out in terms of how to establish accountability of the oil companies for the quality of fuel sold at their retail outlets and severity of the punitive action upstream to act as an effective deterrent.

A fuzzy roadmap on alternative strategies

Chapter 9: Alternative auto fuels – CNG and LPG  
In view of the availability and security of supply considerations, relatively higher cost of alternative fuels and investments requirements and the commensurate emissions benefits the Committee is of the view that it is advisable to have an optimal mix of fuel and technology to help development of new technologies. The issue of alternative fuels has not been put in a correct perspective. CNG in Delhi was not mandated just as yet another choice of fuel. It was introduced with the specific objective of leaping the emissions levels way ahead of the poor emissions standards prescribed for petrol and diesel vehicles. Fuel neutral approach is possible only if very stringent standards are prescribed for all vehicles. The proposed roadmap that mandates only Euro II for the whole country and Euro III in select cities in 2005 will rely considerably on the alternative fuels to get past the poor emissions norms. Therefore, ignoring to recognise the unique merit of the strategy and also failing to propose a strategy to promote CNG and LPG in critically polluted cities of India is losing out on an opportunity to leap ahead while our refineries take their own time to improve the quality of patrol and diesel.

 

Chapter 10: Motor vehicle Technology
Chapter 11: Other alternative fuels and technologies
Comments
Discusses appropriate fiscal and regulatory policies to support effective implementation of research, design and development projects on alternative fuel technology like bio fuels, battery, fuel cells etc (P181) We need a clear policy on this and time bound implementation programme.

Dismally weak roadmap: This cannot clear up air in any city

Chapter 12: Proposed vehicular emissions norms for new vehicles Comments
This chapter proposes the roadmap for future mass emissions standards for vehicles

Entire country: 2005: Bharat Stage II norms, April 2010: Euro III equivalent norms

In 11 critically polluted cities of Delhi, Mumbai, Kolkata, Chennai, Bangalore, Hyderabad, Ahmedabad, Pune, Surat, Kanpur and Agra Euro III norms from 2005, and Euro IV from April 2010.

2-3 wheelers:

Entire country: Bharat stage II norms from April 2005

Bharat stage III norms preferably from April 2008 but not later than April 2010.

We do not agree with this road map on emissions standards. Delhi and other three metros that have already implemented Euro II norms in 2000 should not wait till 2010 to get Euro IV norms. Advance Euro IV norms to 2005 so that these cities do not lose the benefits that these have accrued on account of various orders from the Supreme Court on improving fuel quality, advancing vehicular standards, phasing in cleaner fuels and so on.

 

We demand independent assessment of the refiner costs to meet tighter standards

Chapter 13: Investment requirements for upgradation of fuel quality and vehicular technology  
Issues: To meet the proposed road map of Euro III in 2005 and Euro IV in 2010 the total investment will be Rs 18,000 crore by 2005 and additional Rs 12,000 crore in 2010. (P 195)

Proposes fiscal support to the refineries.

To meet the proposed emissions norms SIAM estimates that the automobile industry would need to invest Rs 25, 000 crore.

Worldwide it has been found that it is more cost effective to make one big jump than spread resources thin as the Report is recommending. Move incrementally from Euro II to Euro III and so on. It has not been estimated and shown the cost effectiveness of tightening the time frame for the proposed emissions standards and find fiscal strategies to implement them.

Auto fuel policy estimates that Rs 10,000 crore has already been invested to achieve the overall fuel quality improvements till date. Out of this nearly the half of the investment was made to set up diesel hydro-de-sulphurisation plants in 9 refineries -- Rs 5,568.31. Further, refinery modifications to meet tighter norms are being considered prohibitive. The policy document claims that the cost to meet its proposed roadmap would require an investment of around Rs 18,000 crore to meet Euro III norms in eleven cities and Euro II in the rest of the country by 2005 and an additional investment of around Rs 12,000 crore to achieve Euro IV in eleven cities and Euro III in the rest of the country by 2010. Typically, there is no explanation forthcoming with regard to the detail of the costs.

Based on the information available from other parts of the world on the cost of refinery improvements to meet tighter standards we do not have any confidence in these cost estimates.

We recommend more rigorous and transparent cost assessment of improving fuel quality and vehicular technology and designing of fiscal strategy based on those realistic estimates.

Assessment of the weaknesses in the current system cosmetic. So are the solutions.

Chapter 14: reduction of pollution from in-use vehicles  
Issues: Recommends for NCT Delhi:

New PUC checking system for all categories of vehicles by Oct 1, 2003

Other metros April 2004

Whole country April 2005 (PP219-220)

I&M system for all categories of vehicles in NCT Delhi by April 2005

Other metros April 2006

Whole country, April 2010 (PP219-220)

For new PUC system recommends adoption of the computerised PUC system developed by SIAM (P209)

Even though the Committee has pointed out the problems with current idling tests conducted under the current PUC programme, it has not pointed out how this programme should be upgraded. Its only idea of upgradation of the PUC centres is to add computers and a web camera without improving the norms and adding more parameters for regulation.

The report has also not evaluated the limitations of the free acceleration smoke tests for diesel vehicles and the immediate need for its replacement with transient loaded test for effective monitoring.

Since the Report is suggesting continuing with computerised PUC till the time improved I&M system and test procedures are in place it is more important to improve the PUC programme holistically.

Secondly, there is a need to phase in the advanced I&M programme immediately. Giving more time to expand and invest in the current PUC programme will create entrench business interest and rolling them back later to phase in centralised and advanced testing centres will be very difficult.

Public transport: No clear strategy or focus

Chapter 15: Bus transport system  
Issue: Improving buses and bus system will play a central role in increasing the share of passengers travel in cities, but unless strong policies to dampen the growth in scooters, motorcycles and cars are applied it may be a losing battle. (P225) This has been listed as an argument but not worked out how it should work. This should be read along with emission charges and other strategies for controlling private vehicles, which have been loosely discussed in other chapters. There is a need for a composite regulatory and fiscal policy to control ownership and usage of vehicles in the cities.

A good idea. And that’s all.

Chapter 16: Economic instrument for mitigating auto emissions Comments
Issue 1: To deal with the price distortion of fuels the report proposes the following guiding principles for taxation:

Domestic relative prices should be aligned with the international relative prices.

If the auto fuels meet the recommended emissions norms, the choice of fuel should not be distorted by way of taxes. Maintenance of relative prices with appropriate consideration to energy content should be a desirable goal of taxation policy.

 

 


The committee has recommended duty and tax cuts to encourage cleaner fuels and technology.

While there is a need for rationalisation of prices of fuels and make it more market driven, and remove inefficient use of fuels, from the environmental point of view there is a need for differentiated taxation policy to support introduction of cleaner fuels like CNG, LPG and (even near zero sulphur diesel).

Keeping this in view the Delhi government has exempted CNG from sales tax altogether. Introduction of alternative fuels as and wherever done had the support of the state by way of financial incentives.

The Supreme Court has also asked the EPCA to examine the taxation policy worldwide to promote environmentally friendly fuels. It is therefore important that the government is asked to come up with a policy on differentiated taxation policy immediately. If cleaner fuels are replacing dirty fuels it is important to price them competitively.

In principle fiscal support to industry and refineries have been accepted and also recommended by the Committee. But the committee has taken a typical approach of tax cuts that will lead to revenue losses – that will never find support from the government. It should have thought through a revenue neutral approach to deal with cost of improvement.