How bad is air pollution?
Santosh Harish: Air pollution is the single largest environmental and occupational risk factor to public health globally. Per the Global Burden of Disease estimates, it accounts for something like 6.67 million deaths a year, as of 2019 — which, to give context, is about 12% of all deaths globally. Not all of this is particulate matter. Particulate matter is the vast majority of this, but a small fraction of this is what’s called ground-level ozone. But yeah, it’s pretty bad. When I started working on air pollution, which is about roughly a decade back, some of these high numbers were hard to come to terms with. It almost seems implausibly large, intuitively, because you’re like, it’s presumably bad for your lungs or something, but could it really be this bad?
So the thing about air pollution, which makes it so harmful — in particular particulate matter air pollution — is that particulate matter is not a single substance. It’s a cocktail of various things that are in the air that just happen to be finer than 2.5 microns in diameter — which is a tiny fraction of how thick your hair is. It is composed of a variety of chemical substances, some of which are relatively harmless, some of which are extremely toxic. So it could be stuff like soil dust, which is naturally occurring, or sea salt — which are likely to be not particularly harmful. And then there is stuff like lead and other heavy metals that are suspended in the air. There are inorganic compounds like sulphates and nitrates which originate from vehicle emissions, from coal power plant emissions and so on. So it’s a variety of different things.
Because these particles are as fine as they are, they are able to enter the lungs, enter the systemic circulation — and then basically these various things that have no business being in our body can travel to different organs and cause a variety of different harms.
Rob Wiblin: What is perhaps the most outrageous or emotionally grabbing example of air pollution to you?
Santosh Harish: One thing that comes to mind is municipal waste burning that happens in many cities in the Global South. Basically, this is waste that gets collected from people’s homes, and instead of being transported to a waste management facility or a landfill or something, gets burned at some point, because that’s the fastest way to dispose of it — which really points to poor delivery of public services. But this is ubiquitous in virtually every small- or even medium-sized city. It happens in larger cities too, in this part of the world.
So I think that’s something that truly annoys me, because it feels like the kind of thing that ought to be fairly easily managed, but it happens a lot. It happens because people presumably don’t think that it’s particularly harmful. I don’t think it saves a tonne of money for the municipal corporations and other local government that are meant to manage it. That’s one example that comes to mind. I find it particularly annoying simply because it happens so often; it’s something that you’re able to smell in so many different parts of these cities.
Another which seems downright evil to me is a whole bunch of industries that tend to not use the pollution control equipment that they have in their facilities already. And just basically dump the flue gas, as it’s called — the gas that gets emitted from the various processes in the industry — without the emission controls, in the middle of the night, when it’s not obvious and it can’t be detected as easily as it would in the day. And this is basically to, again, save what I suspect is change in terms of maintenance and operation costs of this equipment. You have the equipment and there are these standards. So that’s I think downright evil on the part of these industries.
Misconceptions about air pollution
Santosh Harish: One that is actually a significant hindrance to effective policy in India and similar countries is that air pollution is assumed to be an urban problem. This was certainly true in big industrial cities and so on, where air pollution started becoming visible and salient — thinking of London, Pittsburgh, Los Angeles.
In places like India, though, that’s just not true, because rural air pollution can be significant. In fact, on average, rural exposure is not very different from urban exposure. One of the largest sources of air pollution exposure in India, in Pakistan, a whole bunch of other countries, would actually be the household burning of solid fuels: wood and dung cakes and things like that.
So it’s actually not at all an urban issue alone, and historically, it has been treated as that. For example, there are no rural air quality monitors in India. It’s sort of a chicken-and-egg thing. Until recently, the response to why there aren’t monitors there was that we know villages are clean; that’s where you go when you have respiratory problems and so on, right? So it neither gets measured — because it’s assumed to be not a problem — and because there isn’t any measurement to suggest otherwise, that never really gets updated.
Because there are alternative sources of data now — satellite-data-based estimates of air pollution, for example — I think there is growing evidence that rural air pollution can be substantial, and therefore there has been a growing demand for air quality monitoring in rural areas.
Another misconception that in some ways we touched upon is that there are sort of “safe” levels of air pollution; it’s only the truly apocalyptic levels — that one sees, for example, in winters in places like Delhi and so on — that’s what harms you. That, unfortunately, just doesn’t seem to be true. Impacts have been detected at much lower levels that were previously considered safe.
An unusual type of misconception that’s sometimes popular in government circles is that air pollution is something that you can build immunity to.
Rob Wiblin: Oh, wow. I’ve never heard that one.
Santosh Harish: Yeah, it’s something that’s as ridiculous as that sounds.
Rob Wiblin: I guess it’s like if you go out in the sun a lot, maybe you get a tan, which slightly helps you to not get sunburned. But I don’t imagine your body can do that with particulate pollution.
Santosh Harish: Yeah, so there is this insistence by I certainly don’t think all regulators, but by some, that Indian lungs, for example, are just better able to handle air pollution than, for example, American lungs. Because we’ve been exposed to it over a period of time.
Rob Wiblin: You’re used to it.
Santosh Harish: We have gotten used to it, so we don’t routinely fall sick when the levels of air pollution are high. And when somebody’s visiting Delhi or something, you feel it — you feel the difference quite viscerally. So that clearly points to Indian lungs being better adapted. That’s of course nonsense, but it’s unfortunately a persistent myth that has been hard to shake off.
One of the implications of that also has been a general scepticism towards the public health impact estimates from sources like the GBD here. So there’s an insistence that we need more indigenous research, studying health impacts in Indian populations, and that these extrapolations from other parts of the world are just not reliable.
Why air pollution has gotten worse in India
Santosh Harish: I think at a high level it’s less about policy mistakes than it has been about policy neglect. So the Air Act in India dates back to 1981, and in many ways the regulatory apparatus that resulted from the Air Act reflects the understanding of that time. There are pollution control boards at the state level and at the central or federal level, and these have been primarily set up to deal with industrial pollution, because at the time that was the general sense, that this has got to be an industrial emissions problem.
Over time, in the mid to late 1990s, primarily because of civil society advocacy and the interventions of the judiciary, the Supreme Court of India, it expanded to include vehicular emissions in big cities. But until maybe the middle of the last decade — around 2013, 2014, 2015 — in many ways air pollution once again started becoming more visible in Indian media, and therefore it became more salient, and there were a bunch of these source apportionment studies that got commissioned and got publicised. That was it; that was basically the extent to which the regulatory apparatus was readied. So these other sources, like waste burning or household burning, were completely neglected, right?
Household burning, for example, I think we’ve still not recovered from that. It’s assumed that the household burning of solid fuels is something that leads to indoor air pollution, and that it really doesn’t have much of an impact on pollution outdoors. That’s just not true as per the literature. So that’s been completely neglected, and treated as a distinct problem. Because the regulatory apparatus has been set up for industrial pollution, the pollution control boards are not really well equipped to deal with the updated understanding of where air pollution seems to come from, and therefore what you ought to be doing about it.
So if you consider, for example, waste burning: this is something that really falls under the jurisdiction of the municipal corporations — the local government. The municipal corporations have never had to think about air pollution ever, right? This simply isn’t something that they think of as something that falls under their mandate, until at least very recently. And therefore the agencies that are supposed to be doing something about air pollution — the pollution control boards — don’t have the jurisdiction on this source; while the agencies that do have the jurisdiction have not had the regulatory experience or the capacity to deal with this. Therefore it has sort of fallen between the cracks a bit.
In terms of policy missteps, though, when it comes to industrial pollution, the regulatory regime in many ways has not been designed in a manner that is flexible enough and sufficiently in sync with the challenges of regulation in the field. So with industrial emissions, typically the way regulation functions is that all of these industries that pollute have chimney stacks from where the flue gas and the other pollutants escape. For the longest time, across the world, regulation was basically about the height of the chimney stack: the assumption was that you make that tall enough, and the impacts are not felt in the immediate vicinity. Which is not untrue, except that pollution can travel, and over time all of this adds up.
So the next generation of regulation in many ways was to set standards for what the concentrations of pollutants in these chimneys could be. There is a mechanism by which the pollutants are measured in the chimney. You compare it with what the regulatory standard ought to be. In order to comply with these standards, the industries basically install a bunch of pollution control equipment — scrubbers and filters and things called cyclones and so on — which are meant to clean up the air. And regulators basically measure this from time to time. If you’re found to be above the standards that have been given to you, there is some form of punitive action.
The way this mechanism has been set up in India has relied on what are called command-and-control instruments. Basically, there is a standard, and you’re meant to be under that standard. Somebody comes and measures this from time to time. If you’re above that standard, it is a criminal offence, and therefore there’s going to be a lawsuit filed against you. You could land up in jail and pay a fine of some kind. In practice, the legal system in India is backed up: most cases take years and years and years. The actual compliance against these standards is quite poor: based on some data from a few years back, something like 50% of industries in the state of Maharashtra, for example, were not in compliance with the particulate matter norms.
So there’s widespread noncompliance, the pollution control boards are understaffed, and there is no real mechanism by which they can go after these many industries that are flouting the law. As a result, for the most part, the regulatory regime just sort of fails. So if a particular industry is found to be noncompliant, there is a gentle slap on the wrist, there is some kind of polite correspondence where the regulator writes to the industry and asks them to explain themselves, and it sort of ends with that. There is very little action taken.
The policy misstep, I guess, is that the evolution that the regulatory framework should have had over time — from being reliant purely on these extremely rigid, some may say even sort of draconian, command-and-control type regulations towards a wider variety of more flexible tools that allow the regulator to levy fines without having to file a criminal lawsuit and so forth — that evolution just did not happen. And as a result, noncompliance became widespread. The amount of industrial activity in the country increased; the pollution control boards were never really able to keep up with it. And the one source of air pollution that ought to have been regulated well also did not see much progress.
Why aren't people able to fix these problems?
Rob Wiblin: From what I’ve heard, I think you mentioned in a talk that, oddly enough, in India, when air pollution comes up, city governments can turn to outdoor air purifiers, for example, as a possible solution. Maybe because it’s very visible and it kind of looks cool, but it is incredibly expensive and incredibly ineffective, as you might imagine, sticking an air purifier outside: there’s only so much that is possibly going to do if you haven’t done anything to control the source of the air pollution.
What is going wrong there? Why aren’t people able to fix these problems, given that it seems kind of obvious what improvements there might be?
Santosh Harish: Right. So starting with the outdoor air purifiers, I guess the charitable way of seeing it… I mean, I’m a fairly optimistic person, so I guess one way you could see this is that this, in some ways, is a manifestation of the public demand for cleaner air going up, and governments at least being forced to do something. And smog towers, as they are called, you could imagine the case for them: that they’re sort of plausibly useful, they’ll do something; they’re physical, visible manifestations of the intent of governments to clean up the air. And perhaps equally importantly, it leaves nobody worse off in the near term.
That’s one reason why smog towers are so attractive. Most regulation has winners and losers. And here, except for the taxpayers who might not be noticing it, nobody’s really left worse off, and therefore it is politically very viable. But yeah, let’s be clear: this is an absolute waste of resources. They will do absolutely nothing. I mean, sure, they may clean up the air a couple of metres away from wherever they are stationed, but it’s highly ineffective.
Part of the problem here seems to be that the sources are visible, sure. For some of them, there are obviously good longer-term actions that you ought to be taking. So vehicles are a problem: you need to reduce the number of private vehicles on the road; you need to reduce the number of dirty vehicles on the road. So you can have a bunch of policy actions that try to clean up the fleet, that could potentially improve the public transport infrastructure in cities and things like that.
But in the near term, which most governments try to optimise for, one of the challenges is that we don’t have a menu of easy-to-implement, scalable solutions. I think that has been one of the challenges. I think there’s a legitimate uncertainty. You know, if you were a municipal commissioner in one of the Indian cities, or you were the secretary in the Department of Environment at a state level, and you had a pot of money to be able to deploy, I do think that there is a certain gap in terms of saying, “OK, here are the top 10 things that you ought to be doing; here are the most cost-effective interventions that you ought to be investing in.” I think that there’s actually a significant gap in the literature. It’s not sufficient to say that you need to have more buses on the roads: that might not be under your mandate, or that might be much more expensive than you can afford in the near term with the constraints you’ve got.
I think that’s been one of the challenges with being able to make progress in India. As a result, for the most part, what the cities have been doing is basically dust-control type measures: having these mechanical street sweepers clean up the roads. They’ll do something; we don’t necessarily know how much they actually improve the air pollution even on these roads.
That’s, for example, some of the stuff that we’ve just funded, to try and get a handle on how much of an impact this might truly have. It’s not obvious at all that these are cost-effective things to be putting your money behind, but it’s the kind of thing where it’s not expensive enough for the government agencies not to be able to procure them. Again, it’s the kind of capital investments that the corporations can do more easily than some of the harder improvements — in terms of how you operate, how waste management in a particular city functions. That’s a systemic thing, right? It’s much easier to purchase 10 of these street sweepers or something, put them on the road, and hope to God that it makes a difference. And unfortunately, that’s what they’ve been doing.
The role that courts have played in air pollution regulation in India
Santosh Harish: The judiciary has played an outsized — in many ways, a completely unintuitive — role in air pollution regulation in India. Basically, there’s this instrument of public interest litigations (PILs) that have been instrumental in leading to these court judgments. Some of these PILs, by the way, are still active. So they’re cases that were initiated in the mid to late ’90s that are still running today.
Rob Wiblin: You’re saying that the court cases are still ongoing?
Santosh Harish: The court cases are still ongoing. In a sense there have been multiple orders and judgments, but it hasn’t concluded. And the court continues to play this quasi-executive, sometimes quasi-legislative, role in designing policy. Some of those interventions, I think, were ultimately good and resulted in improvements. Some of those judgments have actually been pretty poor. The courts are simply not the places for some of these decisions to be made.
Rob Wiblin: Yeah. In general, we don’t expect courts to be a good place to be doing cost-benefit analysis and setting budgets and so on. It’s not the strength of lawyers.
Santosh Harish: That’s exactly right. And it’s also not the place where you necessarily have a democratic reconciliation of the various people who are affected by the judgments. I mean, the case that you mentioned of getting the buses off the road and this mandate that buses can only run on compressed natural gas. It’s not obvious if the state government or the federal government would have made that call, because it’s not obvious that it passes muster in terms of who’s left worse off. It did paralyse public transport in Delhi. It’s also true that we can be reasonably confident that Delhi’s air quality actually improved for almost a period of five to eight years as a result of that ban.
Like you said, the long-term impact was that more people then relied on private vehicles, because the number of vehicles in Delhi boomed. And that was the reason there was an uptick again in pollution levels, which eventually resulted in increased attention and increased acknowledgment of the problem in like 2014, 2015. The catalyst in 2014, 2015 was, unfortunately, again the courts.
So that problem of policy neglect has manifested in the executive — and to an even larger extent, the legislature — completely ignoring the problem and the judiciary having to step in. The judiciary is sort of limited to fairly blunt instruments. The courts are not the places for cost-benefit analysis, as you put it, and that has unfortunate consequences. That’s increasingly less and less the case, though. The courts have become less activist-y over time.
The smog towers in Delhi, by the way, was a direct result of a court judgment. The outdoor air purifiers came as a direct result of the courts basically demanded that Supreme Court demanded that these be set up, because something has to be done for Delhi’s air quality.
Can philanthropists drive policy change?
Santosh Harish: Yeah, I’m definitely fairly bullish about the possibility of progress through the work that individual researchers and think tanks and policy advocacy groups can do. I think there are certain areas where the possibilities of leverage are pretty high and therefore small grants can have outsized impact.
One constraint as a grantmaker here is, because I represent an international foundation and the foreign funding rules in India are fairly restrictive — and this is especially the case when it comes to environmental work, which I think has often been interpreted as being adversarial when it comes to industrial and economic development in India — that does restrict the types of grants that one could make.
So for example, we talked about how the judiciary has had a huge influence. I am fairly ambivalent about the overall impact that the courts have had. I do think that some good things have happened as a result of it, but I also think that they are not necessarily the places where this decision making should be done. But either way, that seems like a potentially important institution to be able to influence or work with. But as a grantmaker, that’s something that I can’t touch, or at least have chosen not to touch. There is following the letter of the law — there are certain things that you can and cannot do — but there’s also the spirit of the thing. And we have been fairly careful.
Media is another important agent of change. Arguably one of the things that ended up leading to this increased pace of activity since maybe 2015, 2016 was that media outlets took notice, and there were just a lot more stories. And over a period of time, these stories became more and more sophisticated in their understanding of the signs of air pollution and what governments ought to be doing and not doing and things like that. So that had an important role. Again, that’s something that, as an international foundation, we can’t make direct grants to.
Rob Wiblin: Oh really? It’s just not permitted?
Santosh Harish: It’s not permitted. You cannot fund journalists to write stories, because it could be interpreted that this is basically a foreign actor trying to influence the media discourse, and therefore the general narratives within a country. So some of those are the types of things that could plausibly lead to changes and have very high leverage, but stuff that we cannot and should not do.
Rob Wiblin: It’s off the table, unfortunately.
Santosh Harish: They’re off the table. As an Indian citizen, I understand where this comes from. Some of it seems to me as being potentially defensive, but this really feels above my pay grade. I think it’s entirely reasonable to be compliant with the spirit of some of these restrictions, even if that means that you do have some opportunities off the table. I wish there was more domestic funding in India that was trying to go behind these opportunities and be engaged in air quality. That, unfortunately, has not been enough of the case. It’s a fairly neglected area, even from a domestic funding standpoint.
So we’ve had to therefore restrict ourselves to certain types of grantmaking opportunities. But I do think that there is still plenty of highly cost-effective opportunities on the table.