Airsheds Do Not Respect District Lines

Pritiraj BrahmaFounding Partner, Pritiraj & Partners · 16 April 2026

India measures air pollution by city and manages it by municipality. The pollution arrives from a region several hundred kilometres wide. The mismatch is the whole problem.

ProvenancePublished 16 April 2026; revised 31 August 2026 to add two figures and a provenance line. Source categories are drawn from source apportionment studies across northern India, which consistently identify agricultural residue burning, thermal power generation, brick kilns, industrial fuel use, transport and dust as dominant contributors; the control column in Figure 1 is this Review’s reading of statutory municipal authority, not a published dataset. The Commission for Air Quality Management in the National Capital Region and Adjoining Areas was established by statute in 2021. National Clean Air Programme targets run against a 2017 baseline; the million-plus city air quality grant is the Fifteenth Finance Commission’s. Monitoring density is described qualitatively because the station list changes continuously; readers should treat the distribution, not a station count, as the finding.

India's air quality policy has the wrong unit. We fund cities to fix air that is not made in cities, then measure the failure and fund it again.

Every winter, the same sequence: air quality in the northern plains collapses, emergency measures are announced, construction halts, schools close, blame is exchanged between states, and by March the subject disappears until the following November. The sequence repeats because the policy architecture is built around the wrong geographic unit.

Pollution behaves as an airshed — a regional atmospheric basin, in the Indo-Gangetic Plain's case spanning several states and hundreds of kilometres. Governance is organised around municipal corporations and state pollution control boards. A city can execute every measure available to it and still breathe air formed largely outside its jurisdiction.

Four findings anchor this analysis:

1. The National Clean Air Programme is funded through cities. NCAP set particulate reduction targets against a 2017 baseline for a set of non-attainment cities, with funding flowing substantially to urban local bodies, and the Fifteenth Finance Commission provided a separate million-plus city air quality grant. The money is real; the unit of accountability is a municipality.
2. The largest sources are not municipal. Source apportionment studies across northern India consistently identify agricultural residue burning, thermal power generation, brick kilns, industrial fuel use and transport as the dominant contributors, alongside road and construction dust. Of these, an urban local body controls dust and some local transport. It controls none of the others.
3. The one genuinely regional institution is narrow in scope. The Commission for Air Quality Management in the National Capital Region and Adjoining Areas, established by statute in 2021, is the correct institutional form — a body with jurisdiction across state lines over a defined airshed. It exists for one airshed. The Indo-Gangetic Plain extends far beyond it, and no equivalent body governs the rest.
4. Monitoring density determines what is managed. Continuous ambient monitoring stations are concentrated in large cities. Rural and small-town exposure — where a large share of the affected population lives, and where biomass cooking fuel adds a substantial indoor burden — is comparatively unmeasured. What is not measured does not enter a target, and what is not in a target is not funded.

The seasonality trap

There is a second structural error, and it is about time rather than space. Air quality attention peaks for roughly six weeks a year, which is exactly when almost nothing durable can be done.

Emergency measures — construction bans, vehicle restrictions, school closures — manage exposure during an episode. They do not reduce emissions across the year, and they impose their cost on daily wage earners in construction and transport, who lose income during precisely the weeks the measures apply. The interventions that would actually work — crop residue management equipment and alternative straw markets, brick kiln technology conversion, industrial fuel switching, LPG and electric cooking penetration, freight routing — all require procurement, financing and installation during the eight months when nobody is paying attention.

An air quality programme that operates in November is a public relations programme. The work is done in April.

Where the money actually went

The argument that the unit determines the outcome is testable against the spending, and the spending confirms it.

The environment ministry told Parliament that roughly ₹9,650 crore had been released to the 131 identified cities from 2019-20 to 2023-24 — around ₹1,292.50 crore through NCAP itself, of which ₹480.92 crore had been utilised, and ₹8,357.51 crore through the Fifteenth Finance Commission's million-plus city air quality grant, of which ₹5,835.03 crore had been utilised. The Centre for Research on Energy and Clean Air, in its 2026 progress report on the programme, puts cumulative releases across both channels at ₹13,415 crore against ₹9,929 crore utilised, a rate of about 74 per cent.

The decisive figure in that report is not the utilisation rate. It is the composition: 68 per cent of NCAP spending went to road dust management.

Read that against the source apportionment. Of the dominant contributors to particulate load across the northern plains — agricultural residue burning, thermal generation, brick kilns, industrial fuel use, transport, and road and construction dust — a municipal corporation has authority over dust and some local transport, and over none of the rest. Two-thirds of the money went to the one source the accountable unit is able to act on. That is not a misallocation by any individual official; every one of them spent within their powers on a genuine contributor. It is the predictable output of funding a municipality to fix a regional problem. Give a city the money and the target, and it will buy what it can lawfully buy: water sprinklers, mechanical sweepers and paved shoulders.

The target itself has moved rather than been met. NCAP originally sought a 20 to 30 per cent reduction in PM10 against a 2017-18 baseline by 2024; that was revised to up to 40 per cent, or attainment of the 60 microgram standard, by 2025-26. Revising a target is sometimes sound policy. Revising one while spending two-thirds of the budget on a source that was never the principal cause is the sequence this Review keeps recording — a deadline moved because the design could not deliver it, with the design left unexamined.

The counter-case, honestly stated

Two arguments deserve weight. First, some genuine progress has been recorded: PM2.5 and PM10 levels have declined in a number of NCAP cities against baseline, and the household LPG expansion has meaningfully reduced indoor biomass burning, which is the exposure that kills most people. Second, an airshed authority raises a real federal objection — it places a body above elected state governments on matters including agriculture and industry, which are state subjects. The CAQM's own history shows how contested that authority is in practice.

The federal objection is serious and it is not a reason to keep the wrong unit. It is a reason to design the regional body as a compact between states with a published cost-sharing rule, rather than as an authority imposed on them.

What we would do

1. Fund the airshed, not the city. Air quality money should flow to a regional body with a published emission inventory and reduction plan, which then contracts with cities, districts and industries. Cities remain implementers; they stop being the accountable unit for something they do not control.
2. Move the calendar. Set procurement and installation deadlines in the first half of the year, and report compliance in June. Judge a state on what it installed in April, not on what it banned in November.
3. Pay for residue, do not penalise it. Fines for stubble burning have been levied for years without changing the practice, because the farmer has no economical alternative in the narrow window between harvest and sowing. A guaranteed offtake price for collected residue, with aggregation and transport funded, converts a disposal problem into a revenue line.
4. Expand monitoring to where people actually live. Low-cost sensor networks, calibrated against reference stations, in small towns and rural blocks. Coverage determines the target, the target determines the money.
5. Publish exposure, not just concentration. Population-weighted exposure is the number that corresponds to health outcomes. Reporting city-average concentration flatters cities with monitors in low-traffic areas and tells a citizen nothing about the air they personally breathe.

India has the institutional model it needs — a statutory body with jurisdiction over an airshed rather than a municipality. It has built exactly one, for one region, and it manages the problem in the six weeks each year when the least can be done about it.