The Commission for Air Quality Management (CAQM) on Wednesday submitted its comprehensive long-term strategy in the Supreme Court to solve the capital’s perennial air pollution crisis. However, a closer read reveals that this is less a bold strategy and more a bureaucratic regurgitation: the scheme recycles the recommendations of its predecessor, the Environment Pollution (Prevention and Control) Authority (EPCA) of eight years ago, removing specific targets and deadlines and dressing them up with new technology labels.
The Supreme Court has now directed the Delhi government, municipal bodies and NCR state agencies to submit action plans within four weeks on how they will implement the CAQM recommendations. Experts have criticized the Commission for a short-sighted and premature approach to Graded Response Action (GRAP) restrictions – the mainstay of immediate pollution mitigation measures – which are often imposed too late and lifted too early.
CAQM organizes its “long-term solutions” under six broad measures with approximately 41 specific actions, while EPCA details 37 in its 2018 Comprehensive Action Plan. Point-by-point analysis shows that at least two-thirds of the new suggestions deal with similar problems with similar solutions, while there is no mention of why previous plans failed or were never implemented.
Consider the most basic solution: expanding Delhi’s bus fleet. The Supreme Court had first ordered to run 10,000 buses in July 1998. The EPCA report said the Delhi government will have to “ensure full compliance with the 1998 and 2016 orders by December 2018”.
CAQM’s 2026 submission now recommends: “Expansion of city public bus service through e-buses/CNG as per MoHUA’s model norms and service level benchmarks based on population” – without any fleet target or timeline.
According to the latest estimates, there are less than 6,000 buses in Delhi.
EPCA called for “implementation of multi-modal integration plan”; CAQM’s solutions propose “Development of Multi Modal Transport Hub”. Spanning eight years, both plans called for an “integrated traffic system”.
Similar repackaging is seen in vehicle tailpipe pollution monitoring systems, the Pollution Under Control (PUC) framework. EPCA called for “tightening PUC norms for post-2000 vehicles, upgrading in-use emissions testing”. CAQM has recommended “strengthening PUC 2.0 and monitoring of on-road vehicles with remote sensing devices”.
Experts agreed. Sunil Dahiya, founder and principal analyst at EnviroCatalysts, said, “Many of these are simple replicas of older plans with little difference. The plan now requires a base emissions inventory, followed by emissions reduction targets and limits with mandatory timelines. Many of the action plans appear to be repetitive, with a few exceptions such as no new coal plants in a 300 km area.”
Where EPCA fixed dates – “May 2018”, “December 2018”, “mid-2018” – CAQM deployed elastic phrases: “in a phased manner”, “expedited expansion”, “in a timely phased manner”.
Anumita Roychowdhury, executive director of the Center for Science and Environment, said, “While long-term measures are great and give us a direction in which we should move, unless concrete timelines and expectations are set, we will never see results. This is because each measure must be broken down into achievable milestones. We all know what to do but how to do it has to be planned, so that gaps in implementation can be identified and solved one by one.” Can be done.” Roychowdhury was closely associated with the EPCA.
The EPCA was dissolved after the CAQM was established through legislation with quasi-judicial powers.
Then there are strategies that seem to make little difference. EPCA’s 2018 plan calls for radio frequency-based identification (RFID) systems at 13 major border entry points of Delhi to regulate truck traffic, a mechanism that has been in place since 2019. CAQM’s 2026 recommendation includes “installation of ANPR (Automatic Number Plate Recognition) cameras and automated RFID to ensure Multi Lane Free Flow (MLFF) enabled toll/cess collection at all border entry points of Delhi” – admit that entry monitoring through RFID did not help.
Some development is definitely visible. CAQM’s emphasis on electric vehicles and charging infrastructure reflects a policy progression from EPCA’s focus on BS-VI emissions standards, though it also reflects the EV industry’s progress as vehicles become more affordable.
Similarly, CAQM proposes a “technology-driven integrated command and control centre” for pollution monitoring – a centralized enforcement mechanism not detailed in EPCA’s plan. But centralized monitoring makes sense only if decentralized enforcement actually occurs. The 2018 plan identified many of these problems; Their reappearance in the new document is an admission that none of the problems have been resolved.
The expert report accompanying CAQM’s presentation provides evidence of stagnation. Based on a meta-analysis of studies from 2015 to 2025, transportation contributes 23% (winter) and 19% (summer) to PM2.5 concentrations. Dust from roads, soil and construction accounts for 15% (in winter) and 27% (in summer). The contribution of biomass burning is 20% (winter).
These are the same areas – transport, dust, biomass – that dominated EPCA’s 2018 action plan.
CAQM has now recommended strengthening waste collection, complete processing of waste, integration of informal waste pickers and intensive IEC campaigns for citizens to prevent open burning. These general measures are already part of the Solid Waste Management Bylaws for Delhi notified on January 15, 2018.
Bharati Chaturvedi, founder and director of waste management NGO Chintan Environmental Research and Action Group, said some of these measures have been in rulebooks for years but were never implemented. “The recommendations and integration cannot be random. They need defined parameters and well-defined planning with measurable outcomes. The contracts given to the concessionaire need to be completely rewritten,” he said. “We need new contracts to tackle the waste and resulting air pollution crisis and start from the beginning.”
CAQM’s status report states that it has issued “95 guidelines and 17 advisories in addition to various orders, guidelines and official communications from time to time”. But instructions and advice are outputs, not results. The number of instructions issued does not say anything about whether anyone followed them or not.
The Commission acknowledges that “many policy interventions require adequate funding” and implementation “depends primarily on the provision of requisite and adequate funding as well as action plans prepared by the concerned Government/related agencies”.
CAQM’s presentation came after sharp judicial criticism. On January 6, the Supreme Court found that the Commission had “failed in its duty” and lacked “seriousness”, appearing to be “in no hurry to identify the causes of the deteriorating AQI in Delhi-NCR or to come up with long-term solutions”. On 17 December, the court described the pollution crisis as an “annual feature” and called for “practical and practical solutions”.
The implementation roadmap will now go to the same agencies that were to execute EPCA’s 2018 action plan – which included the same recommendations with the 2018 deadline now being recommended again in 2026.
Mukesh Khare, professor and air pollution expert at IIT Delhi, said, “When we talk about mitigation of air pollution sources, the gap that appears again and again is one of implementation and governance. We already know what the major sources are as per the final emissions inventory, but ever since the CAQM started working, there is no proper prioritization of sources.”
Environmental activist Bhavreen Kandhari, who is part of the Warrior Moms group, said that while the measures listed by the CAQM are not new, they largely repeat the 2018 EPCA recommendations that have remained on paper for years. Kandhari said, “Delhi now needs a shift from advice-based pollution control to results-based strict governance; annual emissions reduction targets, legally enforceable deadlines, transparent data on compliance. And this should include penalties for institutional non-compliance and appropriately strong legal action in cases where corruption or deliberate interference compromises implementation. Without this, re-imposing old recommendations will only escalate the crisis rather than solve it.”
