National Clean Air Policy 2023: Policy Critique – III

Author: Saud bin Ahsen

The most difficult part as far as policy implementation is concerned will relate to the change envisaged in the Cultural-Cognitive domain. Policy has failed to consider this aspect of the policy and it’s going to be the factor which will hinder it the most in implementation of the policy. In the absence of public transport, burning of waste, no access to clean drinking water, lack of accountability of government functionaries it is difficult to expect people to change their behaviors. Developing a theme for a society to adopt, role models are required to be produced. The policy is completely silent on this. The policy calls for public awareness programs but so far, no such thing could be seen. Use of social media is also not forthcoming. Civil Society is also not engaged for this purpose which if given some support in developing some themes can play very effective role in making this policy a success.

The cultural-cognitive dimensions are the common social structures and common beliefs which are shared by the people in a society. The NCAP has cultural-cognitive dimension because the subject policy cannot be implemented, and neither can it be effective unless and until the societal norms and cultural habits are also in consonance with the regulations required under NCAP. The participatory approach by the non-state actors is the basis for the implementation of NCAP.

The regulatory framework is designed to enhance compliance by all actors as their corporate social responsibility. The national legislative regulatory frameworks which strengthen NCAP mechanism are embodied in the Pakistan Environment Protection Act 1997(PEPA), the National Environmental Policy 2005, the Pakistan Climate change Act 2017, the National Climate change Policy 2021 and the updated nationally determined contributions NDC 2021, respectively. The regulatory frameworks provide prohibitions, penalties, and enforcement to prevent and control pollution. It provides numerous interventions for improving air quality with respect to vehicles, industries, solid waste burning and natural dust.

With the advent of smog season this year, the implementation of Punjab’s Clean Air Policy 2023 shall be the real test.

However, there is no single unit responsible for “quality management and control” of air pollution. There is strong need for establishment of an “Authority” which could coordinate between inter-governmental and inter-sectoral actors for unified implementation of the policy across the country.

For the implementation of stringent protocols, massive Cultural Revolution is required, which is possible only through active participation of all actors, governmental and non-governmental.

The provincial landscape of NCAP 2023 implementation in case of Punjab reveals that Punjab has come up with its Clean Air Policy (with phased action plan) promulgated in April, 2023.

In analysis, the above plan provides for a realistic goal-oriented strategy which can be replicated in other provinces and is supplemented by Punjab Environmental Protection (Smog Prevention & Control) Rules 2023. NCAP 2023 has been implemented through Punjab’s Phased action plan in a multi- staged process. There appears a recognition of the magnitude of issue involved as reflected from penalties provided in Schedule to Punjab Environmental Protection (Smog Prevention & Control) Rules 2023 (Notification 96 of 2023, The Punjab Gazette (Extra-ordinary), p.5071-5072, June 07, 2023) Penalty for non-conversion to zigzag technology by Brick kilns on first occurrence is Rs 1,00,000-500,000 followed by demolition of kiln on subsequent occurrence. Penalty for excessive Emissions by industrial unit, business concern etc. in first occurrence is Rs 1,00,000-500,000 followed by Rs 600,000 to 1,000,000 in subsequent violation.

However as discussed in forgoing analysis above, the successful implementation of NCAP 2023 is depends upon the concerted efforts of all stake holders, realistic approach and the necessary resources allocation. With the advent of smog season this year, the implementation of Punjab’s Clean Air Policy 2023 shall be the real test.

Thus, policy makers in Pakistan face number of obstacles which includes limited financial, human and technical resources, therefore, can pursue small number of strategic interventions at the same time to mitigate air pollution in the country. Air pollution and Climate change are inextricably linked global issues. Integrated Assessment of air pollution and climate change is required to make an all-encompassing integrated policy for both issues, based on evidence. In this regard, there are four sets of recommendations.

Adequate Resource Allocation: (a). Allocate sufficient financial and human resources to support the implementation of the policy; (b) Prioritize funding for air quality monitoring, enforcement, research, and public awareness campaigns; (c). Seek opportunities for public-private partnerships and international collaborations to gather resources and expertise.

Enhance Coordination and Stakeholder Engagement: (a). Establish a dedicated agency or committee responsible for coordinating and overseeing the implementation of the policy across relevant sectors; (b). Engage and consult with various stakeholders, including government agencies, industry representatives, civil society organizations, and academia, to ensure a collaborative approach and buy-in for implementation.

Public Awareness and Behavior Change: (a). Launch comprehensive public awareness campaigns to educate citizens about the adverse effects of air pollution and the importance of individual actions in improving air quality; (b). Encourage behavior change through incentivizing the use of public transportation, promoting walking and cycling, and discouraging open burning and the use of polluting fuels.

Collaboration and Knowledge Sharing: (a). Foster collaboration and knowledge sharing among different regions within Pakistan and internationally to exchange best practices, experiences, and expertise in combating air pollution; (b). Learn from the experiences of countries that have successfully implemented similar policies and adapt their successful strategies to Pakistan’s context.

By implementing these recommendations, Pakistan can achieve a more effective and comprehensive implementation of the National Clean Air Policy 2023, leading to improved air quality and better health outcomes for its citizens.

(Concluded)

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

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