SHUTTERING OF BRICK KILNS IS NOT AN ULTIMATE SOLUTION

About 97% of Pakistanis are living in areas where the annual average PM2.5 level exceeds the countrys PM 2.5 standards. This has led to a loss of 3.8 years life expectancy of an average resident of Punjab.The situation in Lahore is even worse, an expected 5.3 years of life expectancy loss has been reported due to high particulate matter, followed by Faisalabad with 4.8 years, relative to the WHO guideline. These figures have been recently reported in Air Quality Life Index Report in 2019 by University of Chicago. Whereas, Global Burden of Disease 2019 report stated ~ 128,000 Pakistanis deaths in 2017, due to diseases attributed with air pollution. What are we waiting for?

Smog is considered as one of the most severe environmental hazards of Punjab (now spreading to the broader swathe of the country), causing serious health related issues and social losses for the past several years. Though, Environment Protection Department (EPD) Punjab has developed Punjab Smog Policy 2017 but the effectiveness of policy is in great debate among many stakeholders, since its approval. Smog Commission 2018 also showed dis-satisfaction on the smog policy and presented its recommendations which were made part of the orders of the court and are enforceable as such. However, EPD Punjab is still struggling in application of these recommendations and the policy, for the last one year. The story doesnt end here. Air quality data of Punjab is scant and scientifically backed information is limited and scattered. EPD Punjab does not have any environmental monitoring plan and has never prepared the State of the Environment Report.

Resultantly, the department is unable to identify the real causes of smog in the province. This raises the question on the credibility of the smog policy-2017 and demands for an evidence-based approach. Considering this situation, Food and Agriculture Organization (FAO) Pakistan published a report in January 2019 that provides scientific evidences regarding the real cause of the smog formation in the province along with some policy recommendations. This report can help to line-up the existing policy components based on of the most appropriate and achievable solutions while considering the most polluting source. However, the Punjab Smog Policy has never been revised nor an effective and attainable action plan has been developed on the basis of court orders and FAO report.

Each year, just before the smog season starts, the Punjab Government uses its legal powers and shuts down the brick kilns, bans crop burning, charges heavily to the polluting factories and farmers and starts enforcing emissions regulations on factories and vehicles.

Smog has come again as a serious health hazard for the citizens of Punjab, especially for the vulnerable groups (e.g. children, women and elderly people). With the arrival of rains this year, the smog may suppress but this doesnt nullify the fact that pollution and its sources remains present and continuously produce toxic emissions in the air. In the recent high level meetings, Punjab EPD had asked the departments to submit their action plans and awareness raising plans to combat smog. Unfortunately, such actions end up with the same fate each year since 2011. This year, the department has again announced the closure of brick kilns and other polluting industries for the next few months and impose ban on burning of crop residues, municipal solid waste, tyres, plastics, polythene bags, rubber and leather items etc. under Section 144(6) of Criminal Procedure Code 1898.

These actions could be immediate solutions and speedy remedy, but not a regular practice or a permanent answer to rid-off smog. Each year, such directions leave many people unemployed not only at brick kilns but also in the construction industries. In addition to this, it increases the price of bricks and financially loses to the industrial sector should not be ignored either. It is crucial to understand here that Punjab is not alone in its effort to improve air quality and there is much to be learned from other states of the world. Many regions and cities in the world are working under various acts, regulations, policies, plans or programs to improve air quality at local and regional level with a special focus on smog pollutants such as in Ontario, Canada (region/province) or Beijing, China (city). Ontarios Anti-Smog Action Plan (ASAP) 1998-2015 is a well-known example of reducing harmful pollutants by target-oriented concrete actions and unique partnership with multi-stakeholders. Keeping the fact that cleaner air is everybodys business the Ontario plan focuses on organizations, industries (manufacturing, transportation, construction, etc.), governments and individuals to work together for a healthier and cleaner environment. The government of Ontario considered the need of an up to date and more comprehensive study on smog polluters for evidence based decision making. Other than, mandatory monitoring and reporting, promotion of research and development, awareness and capacity building or public disclosure of information, Ontario government developed a strict accountability mechanism and disciplined management policy for evaluation of air quality targets and emission reduction goals.

The government also introduced an Awards Committee Framework which gives Awards to those stakeholders who prove to be innovative and benefit Ontario by making contributions to smog or greenhouse gas emissions reduction in Ontario.This Ontario plan was devised till 2015 with a flexibility in addition of more stakeholders in their Anti-Smog Accord (partners) and more stringent standards for emission reduction.

Whereas, Chinas policy frameworks are short term but consistent and flexible towards more stringent reforms in the new action plans. Considering the fact that the war against smog is not over in China, this case still provides strong evidence that tangible policy actions can lead to efficient and effective results. In each upcoming plan by Chinese Government, the challenges faced in reaching the target and lessons learnt from implementation of previous plans are considered.

While existing governance system pushed forward to be more rigorous and planning was targeted at local level, especially in case of Beijing where number of blue sky days increases after Beijing local action plan. However, the major turn in air quality improvement was observed when these emission reduction targets were linked with promotions of government officers, called as Cadre Evaluation System. This driving factor covers the Local government officials at or above the county level which are responsible for environmental protection in their jurisdiction.

If the annual targets of emission reductions are not met, then the local leaders are ordered to rectify within a time limit. If the five years target failed, they would get a veto. This shift provided incentives for local leaders to pay attention on smog reduction and air quality improvement in the region. Conversely, Punjab Smog Policy doesnt contain any plan to investigate the source of pollutants. The Root Cause Committee recommendations in Smog Commission Report also remains silent on such initiatives. The claim in the Policy that crop burning in India is a major concern of smog in Lahore followed by agriculture, transportation and industrial sources in Punjabs territory was not scientifically and statistically proven. This was verified by FAO report R-Smog 2018, when technical result showed transportation sector as a major culprit (43%), followed by Industries (25%) and agriculture sector (22%).

Though, smog is not a local problem and stubble burning in India is contributing in smog pollution in Punjab, but the weightage of the aforementioned culprits is varied. Unlike Ontario or Beijing, the Policy and Smog Commission Report does not provide any time frame and targets for emission reduction. There is no reference document available regrading involvement of important stakeholders in the policy development process. Without such involvement, it would have been a very challenging task for EPD to enforce environmental quality standards in the province and encourage industries for self-monitoring and regulation. These documents are also silent on Introduction of system of Incentives/Awards/Promotions and awareness/capacity building of stakeholders like government agencies, municipalities or district authorities, etc. for successful implementation of action plan.

Technology transfer element is also missing in the policy. However, Public Health Emergency Committee under Smog Commission has highlighted the need of long-term research programs in partnership with local universities to gather relevant data on air quality and its effects on citizens exposed to air at different AQI levels, which is not implemented yet. Accountability mechanism is another component that is missing in the smog policy. However, it talks about oversight and coordination by Punjab Environment Protection Council (PEPC). It is worth mentioning here that PEPC has conducted only 2 meeting over the last 6 years.

One in 2013, the second was in 2017 and the next meeting of PEPC is expected in the first week of January 2020.Prime Minister Imran Khan has recently announced a plan to curb smog in the country which includes shift to euro IV and V by the end of 2020; 3-year warning to oil refineries to improve oil quality; a shift towards electric vehicles; import of new machinery to make use of the post-harvest rice crop; financial aid to use zigzag technology to brick kilns; removal of Import duties on scrubbers used in steel factories along with an urban forestry initiative in 60,000 kanals of land in Lahore.

However, these measures cannot be executed without an effective implementation & accountability strategy and engagement of multi-stakeholders. Nevertheless, the current situation demands a concrete, time bounded and target oriented, attainable action plan for Punjab; continuous commitment and strong political will as well as robust policy instruments to achieve air quality improvement goals, rather than only focusing on closure of industries before and during smog season. Long-term emission control mainly rely how well strategies and policy instruments are designed and how they are enforced.

Overall governance structure and appropriate legal and regulatory framework also play an integral role in successful implementation of such instruments.

Transparent supervision mechanism, public awareness and capacity building of private and public sector and timely disclosure of information are equally important. Immediate approval of Restructuring Plan is also crucial for the EPD and its allied agencies to strengthen the different roles allow for a balance between efficient and effective administration i.e. Supervisory, Enforcement, Regulatory and Advisory.

With the launch of Punjab Green Development Program (PGDP), we are expecting much from the Environment Protection Department, Government of Punjab to address environmental issues and promote green development in the province.