Daily Times

The second part of the op-ed series examines the rationale of the NCAP and offers a cost-benefit analysis of expected benefits vis-à-vis associated costs. The policy is primarily seeking a public good in the social policy domain by trying to resolve air quality issues in Pakistan in terms of the realization of health, economic, development, climate change and environmental benefits as ancillary outcomes of the policy. Since climate change and environment are generally cross-cutting themes in other social sectors like health, agriculture and economic development the policy interventions could have been made integral to the sectoral policies of health, agriculture and development to address the issue of clean air in a befitting manner. It has been observed that Pakistan’s policy environment is overcrowded, and policies mostly add to the shelves of ministries and departments in Pakistan without making significant headway in the implementation domain. Another associated observation is that policies particularly in the social sector like NCAP are donor-driven seeking the attention and support of international donors or at best prompted and facilitated by donors. The NCAP also lists eleven policies that relate to clean air policy issues and tend to address the same.

The NCAP seems to have been prompted by the conventional policy process wherein the ‘rationality model’ serves as the basis of a policy change or new policy design. This public policy choice, like in many other cases in Pakistan, is a reaction to a worsening situation of public concern created by incessant repeat of extreme smog and air pollution episodes witnessed in urban cities in Pakistan particularly in Lahore and major cities in its proximity in Punjab.

NCAP requires people to change the conventional norms and adopt new ways.

One can argue that there remained a dearth of credible research, data and evidence-based on which generally a ‘rational actor’ would act. The rational actor needs to have the required information to make the best possible choices, however, in the public policy domain choices are also made based on hypothesis and an incremental approach in such a scenario could be resorted to and application of such policy decisions tends to inform, through continuous monitoring and evaluation, if the policy decisions are delivering effectively or otherwise. Therefore, it is not the ‘need for’ or ‘utility’ of NCAP that could be a subject matter of criticism rather the delay in introduction and implementation of NCAP could be questioned. In short, we see that Hoefer’s ‘rational actor’ which means a decision-maker who tries to efficiently maximize gains and minimize losses has not been found that efficient in the case of NCAP.

The process to follow, if using the rational actor theory, is to define the problem; determine evaluation criteria; identify alternatives; evaluate such alternatives with a view of maximizing gains and minimizing losses vis-à-vis desired values; select preferred policy options and finally implement policy. The NCAP seems to have generally followed the same process.

Cost-benefit analysis

Air pollution causes an estimated cost of USD 500 million in health care on an annual basis in Pakistan, alone, therefore, the policy implementation in its letter and spirit will significantly contribute to the improvement of human development in Pakistan. According to statistics, particulate matter has caused an increase of 764,400 deaths over 25 years, globally, while in Pakistan such a number has recorded a continuous increase. For example, Pakistan recorded a 64% increase i.e. 135,100 deaths in 2015 compared to 82,300 deaths in 1995.

There is a need for extensive research on quantifying the actual costs of long-term exposure to air pollution as its negative impacts not only affect mortality rates or health but also on behaviours of human beings, their social interactions etc. Moreover, the public policy priorities of taking action to contain air pollution, and ancillary costs vis-à-vis decisions to prioritize economic development, reduce poverty, and enhance investment in infrastructure, industry, agriculture, urbanization and energy sectors need credible data to understand potential costs to make informed decisions. For example, the China-Pakistan Economic Corridor (CPEC) is likely to further enhance emissions and contribute to air pollution thus undermining the effective implementation of NCAP.

There is also another angle to gauge the policy and its implementation based on E. Richard Scott’s Trichotomy. According to it, we witness how the policy fits into regulative, normative and cultural-cognitive domains and how the sectoral recommendations will pose a challenge to the above set domains which will determine its viability and sustainability over the long term.

The policy sets a general standard of air quality for Pakistan, which would serve as a guideline for all stakeholders to work on, especially the provinces. In its implementation, the policy requires the provinces of Pakistan not only to follow their respective goals falling under the policy but also to support and coordinate with other provinces and the federation in achieving the policy goals. NCAP stresses heavily on the Regulatory framework which asks for resource mobilization. Given the financial position of the governments both at the provincial and federal levels, this seems to be a difficult proposition. It requires legal support for its implementation, which requires existing laws to be strictly implemented and new laws to be framed where missing. This area has always been the weakest one given Pakistan being low ranking in the ‘rule of law’ index framework.

The technological framework required for bringing the desired modifications in different sectors, as enunciated in the policy and infrastructure required for the above changes is again a weak area. We can say that the policy desires a lot of things to be done on the regulative side, but it fails to address the issue, of how to provide or create these regulatory frameworks.

NCAP also requires a response from the public on the normative front. It requires people to change the conventional norms and behaviours and adopt new ways of doing different activities which fall under the domain of the policy. It requires people to do course correction without much help from the government. Given the education level and financial constraints, it will always be difficult for people to switch to new ways of life. Calling for adopting electricity ovens instead of gas burners at homes not only requires a lot more finances at a personal level but given the electricity generation capacity and use of fossil fuels in the generation of electricity which still constitutes a major contributor to total electricity generation in Pakistan, will offset the advantages foreseen by switching to electricity stoves than gas burners. It will increase the cost for both the government and the people

(To be concluded).

The writer works at a public policy think tank. He can be reached at saudzafar5@gmail.com