akistan adopted its first-ever National Clean Air Policy (NCAP) at the beginning of the year 2023. The 33-page document is quite comprehensive. It lists sources of air pollution, a framework for mitigation and an accountability mechanism to curb air pollution.

The policy suggests concrete actions related to the top five sectors contributing to air pollution, i.e., the transportation, urbanisation, industry, agriculture and waste management. The NCAP outlines suggestions regarding each sector. These include an increase in the number of electric vehicles, inspection of vehicles, mass transit systems, efficient and low carbon fuels in the transport sector. For urbanisation, the NCAP promotes urban planning, the greening of ten big cities of Pakistan, vertical housing, and green buildings. Revision of industrial emission standards, compliance, data availability, adoption of fuel quality standards and the latest technology are some of the suggestions outlined to improve the industrial sector. For agriculture, a complete ban on burning of crop residue, a circular economy and management of forest fires are key areas. A complete ban on waste burning and measures for integrated waste management in ten mega cities of Pakistan is also proposed.

The implementation mechanism for the NCAP calls for enforcement plans at federal and provincial levels; identification of funds for the priority mitigation measures; installation of regulations to support their implementation; overcoming technical, social and economic barriers; and the setting up of necessary institutional infrastructure. Implementation of the NCAP will require active participation from stakeholders, including the media, the public, research institutions, civil society and advocacy groups. The most polluting industries will be engaged to include air pollution reduction in their corporate social responsibility (CSR) activities and sustainability policy.

To achieve the clean air targets in Pakistan, the NCAP will host a conference on an annual basis to inform the public and the media about implementation progress. It will be revised every five years. To implement the NCAP, a National Implementation Committee shall be established at the federal level. It shall be facilitated by a Technical Committee. The National Implementation Committee, chaired by the climate change minister, will provide policy direction, review progress and report it to the Pakistan Climate Change Council. The committee shall regularly monitor and update the Pakistan Air Quality Policy every five years.

The technical committee, chaired by the director general for environment, will oversee the policy implementation and relevant plans. The committee will report to the National Implementation Committee. The Ministry of Climate Change (MoCC) will take overall responsibility for supporting the implementation of the NCAP. The relevant ministries and line departments will be responsible for implementing the sectoral recommendations. The provincial governments will develop Provincial Clean Air Action Plans through their Environment Protection Departments. The Pakistan Environmental Protection Agency (Pak-EPA) will develop the Federal Clean Air Action Plan within a year of the approval of the policy.

The NCAP provides institutional guidelines, implementation mechanisms and constitutional clauses to achieve clean air targets in the country. Implementing Pakistan’s Clean Air Policy can reduce PM2.5 emissions by 38 percent in 2030 compared to the baseline scenario and 21 percent compared to 2020 levels.

The Pakistan Environmental Protection Council (PEPC) will oversee the implementation of the NCAP as the Ministry of Climate Change (MoCC) reports progress. Parallel provincial Environmental Protection Councils may also ensure provincial implementation of the NCAP and related provincial action plans. The responsibility for monitoring, controlling and mitigating air pollution is devolved to the provinces under the 18th Constitutional Amendment. Thus, the federal and provincial EPAs set their own air quality standards and report to the line departments. At the federal level, the MoCC coordinates national air quality plans and programmes. The MoCC shall coordinate national and international transboundary air pollution issues and ensure their compliance with international commitments. Furthermore, the MoCC shall support research on environmental issues related to air pollution and their benefits for climate change mitigation.

The NCAP provides institutional guidelines, implementation mechanisms and constitutional clauses to achieve the clean air targets. Implementing Pakistan’s Clean Air Policy can reduce PM2.5 emissions by 38 percent in 2030 compared to the baseline scenario and 21 percent compared to 2020 levels. However, there are some challenges associated with the implementation of the NCAP.

The topmost challenge is the policy formulation in the provinces under the 18th Amendment for the top five sectors, especially laws for vertical infrastructure in big cities and laws related to the environment. Some of the provincial environmental laws lack clarity. The National Implementation Committee and the Technical Committee have members from many departments. This committee is yet to be formed. More clarity is needed on how frequently these committees will meet, how these will work and the way data will be available to the public. There is a history of such committees and councils not convening the necessary meetings. It is yet to be seen how these large committees will agree to convene and report.

Another major challenge is the source of data. Even in the NCAP, the data sources identified for air pollution are private data sources. There are very few air quality monitors across the country. Most of these are operated by the federal and provincial environmental protection departments. There are issues of capacity and human resources in these departments too. There is a huge challenge related to urban and land use planning. Private housing schemes and land mafias are untouchables in Pakistan. Therefore, controlling particulate matter from these sources is nearly impossible. For transportation sector emissions, there are challenges for infrastructure for electric vehicles, inspection of vehicles and parking issues. Many sectors are involved in this, including aviation and maritime transportation. Various regulators continue to follow their own regulations and standards. There would be challenges to legally making them accountable as they can get away with their own clauses and regulations.

To control emissions indoors, the NCAP suggests electric stoves. This can be very challenging in a country where inflation is hitting the roof. Most people will be unwilling to shift to more expensive options until and unless there is a subsidy involved. In the current economic crises, it will be very challenging to convince the industries to invest for clean technology.

Despite all the challenges, there is a complete guiding document to stop air pollution in Pakistan. If implemented in its true spirit, it can make a huge difference. There is a need for political commitment from the provincial governments and all the other stakeholders.

The writer is an environmentalist based in the US. She is also a senior research associate at the Sustainable Development Policy Institute. She tweets at @S_Maryam8