For years, the national capital region has been grappling with worsening pollution levels. Now it seems more like an annual affair – rather a pastime for many – discussing the air quality index or AQI levels, which start rising with the onset of winter.  

This year too, Stage I of the Graded Response Action Plan (GRAP) was invoked in Delhi-NCR in October, and within days, GRAP II has kicked in.

Sadly, that has been the case for almost 10 years now.

GRAP was first implemented in 2017 with the aim of tackling air pollution by imposing restrictions. Clearly, it has failed to deliver the desired results.

Experts told The Secretariat that GRAP as a measure has proved to be an eyewash and such piecemeal steps to tackle pollution will not work. The Centre for Research on Energy and Clean Air too has revealed that GRAP is ineffective. 

By all counts, a holistic approach is needed, not a seasonal one.

"Invoking GRAP is more like an emergency plan and such measures can never have a long-term solution," said economist Nirupama Soundararajan.

As another winter sets in, the bigger question is whether these interventions are addressing the sources of pollution or simply managing episodes of poor air quality.

Anumita Roychowdhury, executive director at the Centre for Science and Environment (CSE), told The Secretariat, “GRAP on its own cannot fight pollution. It is an emergency response mechanism, not a mitigation plan. It can only blunt peak smog episodes during extreme weather conditions; reducing pollution requires sustained action against the baseline emissions that fuel the crisis.”

Seasonal Versus Annual

The trouble is, a decrease or increase in AQI is not enough to determine if a specific air pollution control action has been effective.

The Council on Energy, Environment and Water (CEEW), a climate thinktank, has highlighted the need for a systematic framework for the impact assessment of air pollution control interventions to see if they are resulting in a corresponding reduction in emissions.

The dispersal of pollutants is influenced by weather conditions. Pollution levels can be altered by low wind speeds, shallow atmospheric boundary layers, and temperature inversions that can hold emissions near the ground.

The winter weather—such as boundary layer drops, wind stilling, and temperature inversions—routinely masks emission changes.

“People with asthma and COPD are particularly affected in winter as a combination of cold air, poor dispersion, and air pollution may worsen their condition”, said Aditya Nag, Pulmonologist, NIIMS Hospital.

Fortis Hospital, Noida, for instance, is reporting 25 to 30 daily pulmonology cases, with complaints of coughing, wheezing, breathlessness, and other respiratory complaints.  

What GRAP Entails

GRAP aims to tackle this in four stages.

Stage one relies on compliance with current pollution control measures, instead of fully stopping economic activities. Construction and demolition sites need to have prescribed dust-control measures, and authorities responsible for the maintenance of roads are obligated to conduct mechanised sweeping and sprinkle water at sites. Municipal bodies must ensure regular waste lifting and prevent open burning.

It also mandates stringent enforcement of Pollution Under Control (PUC) certificates, compliance by polluting industries, and adherence to the specified operating parameters of diesel generator sets.

Civic organisations, the traffic police, pollution control units and other bodies are in charge of enforcing this. But in GRAP I, construction cannot be banned, also this stage does not impose a blanket ban on vehicles coming to Delhi from outside.

The restrictions increase as the AQI increases.

Currently, GRAP II is in place in Delhi. It kicks in when the AQI is above 300. Similarly, the third and fourth stages come into play when the AQI goes above 401 and 451 respectively.

But Soundararajan cautioned against treating clean-air action as a seasonal exercise.

“Pollution control cannot be treated as a seasonal exercise. It requires a sustained, year-round approach rather than measures that are intensified only when the air quality deteriorates during the winter months,” she said.

In addition to emergency action, CEEW underlined the need for reliable electricity, enhanced public transport, consistent dust management, and industrial compliance.

Cost Of Compliance

Blanket, reactive bans under GRAP, such as halting construction, restricting older vehicles, and shutting diesel generators— that sometimes become necessary to fight severe pollution – disproportionately penalise daily-wage labourers, informal micro-enterprises, and commuters without offering viable alternatives.

During GRAP II, for instance, restrictions on coal and firewood in tandoors are in place, along with conditions governing backup generators, which are crucial to keep a business running.

For smaller eateries and businesses, implementing functional changes, such as how equipment is used, is not easy and has implications for fuel consumption and operational costs. 

Soundararajan said compliance requirements place a heavier burden on smaller establishments. “Smaller businesses are being closely monitored and made to comply with these restrictions despite the costs and disruption they face. But is the government applying the same level of scrutiny to larger businesses? Are they being held to the same standards?”

Economist Rahul Ahluwalia said it was important to consider the economic trade-off: “The most important thing is the cost-benefit ratio: what is the cost we are paying, and what is the benefit?”

How Beijing Did It

The experience of China shows the effectiveness of continuous implementation of pollution controls throughout the year backed by structural changes. The government took steps to cut down the usage of coal and replaced polluting boilers, introduced stricter emission norms for industries and vehicles under its 2013 Clean Air Action Plan.

The initiative was not limited to the capital, as it also rolled out to the Beijing-Tianjin-Hebei regional framework based on the understanding that pollution knows no administrative boundaries. 

The United Nations Environment Programme (UNEP) suggests that PM2.5 concentration in Beijing reduced by 35% from 2013 to 2017, and the rest of the region saw a 25% decrease in concentrations of PM2.5.

The Road Ahead

Roychowdhury also highlighted the need for a comprehensive approach, such as regional airshed management, cleaner industrial technologies, freight decarbonisation, and transport electrification.

“This requires very stringent source-level compliance rates, including tracking the percentage of non-compliant construction sites covered and penalised, the volume waste segregation, collection, and unsegregated waste diverted from open burning.”

She also suggested “augmentation of public transport services and upscaled vehicle electrification, enforcement against non-approved industrial fuels, and real-world compliance”.

All the experts The Secretariat talked to emphasized the importance of year-round measures.

“The bigger focus has to be on predictable, year-round systemic infrastructure to reduce seasonal disruptions. For instance, small businesses use diesel generator (DG) sets because distribution utilities fail to supply uninterrupted industrial and residential power. Supplying 24x7 reliable electricity eliminates reliance on DG sets without requiring sudden punitive bans,” said Roychowdhury.

“Instead of shutting sites mid-work—which strips labourers of wages—enforce standardised, year-round construction dust management,” she said.

These include mandatory windbreaks, misting cannons, automated wheel-washing bays, and certified recycled aggregate procurement. If a temporary ban on construction is warranted, then suitable compensation for the loss of wages of workers must be mandated and implemented.

“Cities must scale public transport two to three times, with electrification and feeder networks to metro stations, and make transit reliable and universal every single day,” she said.

Among other measures to tackle pollution holistically ae accelerating piped natural gas and clean electricity supply lines across all settlements and designated industrial clusters across the NCR – and these must be implemented at scale and with speed.

For the Delhi government of Chief Minister Rekha Gupta, tackling pollution as promised may prove to be an acid test. “You won’t need to leave Delhi this winter,” she had promised people in February 2025.

One and a half years later, the air in the Indian capital does not seem to have turned a new leaf.

For Delhi-NCR, it may be time for a paradigm shift from seasonal curbs to long-term targets, coordination and accountability.