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.

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.

• 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

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.

• 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)

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.

• 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.

• 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.

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

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.

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 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.

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.

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.

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.

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.

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.

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

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).

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

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

Proposes fiscal support to the refineries.

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.

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)

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.

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.

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.