EMBARGOED TILL WEDNESDAY 15 DECEMBER 4:00 AM IST

Nitrogen Dioxide Levels: An Analysis of States crossing safety standards

1. BACKGROUND
- What are NOx gases and their sources
- Winter implications on Nitrogen Dioxide (NO2) levels across India
- The health impacts of NO2

2. THE DELHI CASE STUDY

- Annual trajectory
- Transport Sector
- NO2 emissions from Thermal Power Plants surrounding Delhi

3. ANALYSIS OF CULPRIT STATES

- The three problem states
- Analysis for NO2 trends from monitoring stations across Uttar Pradesh,
Rajasthan & Delhi

4. QUOTES

BACKGROUND
What are NOx gases and their sources
Nitrogen Oxides are a family of toxic, highly reactive gases which form when fuel is burned at high
temperatures. NOx pollution is emitted by automobiles, trucks and various non-road vehicles like
construction equipment, boats, etc. Industrial sources of NOx are essentially fossil-fuel based power
plants, incineration plants, wastewater treatment facilities, glass and cement production facilities
and oil refineries. It is not only during combustion processes that nitrogen oxides are released, but
also when working with nitric acid. Agriculture is also becoming increasingly relevant as a NOx
emission source.

Winter Implications on Nitrogen Dioxide (NO2) levels across India

An analysis of air quality monitoring data from the Continuous Ambient Air Quality Monitoring
System (CAAQMS) across the 23 states and non-attainment cities, listed in the National Clean Air
Programme (NCAP), has clearly highlighted that winter season has not only resulted in high
particulate matter (PM) levels, but also impacted polluting gases like nitrogen oxides (NOx). In India,
the meteorological condition is highly conducive for rapid conversion of the precursor gases like
nitrogen dioxide and sulphur dioxide (NO2 and SO2) to secondary PM2.5. Hence, to control PM2.5,
the emission control of the precursor gases is necessary. Local level exposure to NO2 leads to a range
of environmental and health impacts as well.

The health impacts of NO2

Nitrogen dioxide (NO2) is an irritant gas, which at high concentrations causes inflammation of the
airways. NOx reacts to form smog and acid rain as well as being central to the formation of PM and

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ground level ozone, both of which are associated with adverse health effects. A recent study
identified that annual average concentrations of NO2 due to fossil fuel consumption in transport
across states in India puts vulnerable people on the streets -- like hawkers, vendors and the homeless
-- at higher risk during the COVID-19 pandemic.

High levels of nitrogen dioxide are also harmful to vegetation—damaging foliage, decreasing growth
or reducing crop yields. Nitrogen dioxide can fade and discolour furnishings and fabrics, reduce
visibility, and react with surfaces.

THE DELHI CASE STUDY

Annual trajectory
A deeper dive into Delhi’s annual NO2 levels since 2013 revealed that the national capital has not
been able to maintain levels within CPCB’s annual average limit of 40 ug/m3 in the period for which
data was analysed. The graph below shows that in the last 8 years between 2013 and 2020, Delhi’s
average annual NO2 levels ranged from 61-73 ug/m3. While 2020 is the only year when the annual
average NO2 in Delhi was 61 ug/m3, the lowest in the last 8 years, it is worth noting that despite the
complete nationwide lockdown which halted all transport, industrial activity and many other NO2
emitting sources for three months, the year’s average could not be anywhere close to the CPCB
safety limit of 40 ug/m3. 61.7 ug/m3 levels in 2014 seem to be lowest in the last eight years. From
2015 to 2018 there’s a clear y-o-y incline in levels, with 2018 and 2019 experiencing 73.66 and 71
ug/m3 respectively.

Image: Annual average Nitrogen dioxide (NO2) concentration in Delhi from 2013 to 2020 (In ug/m3)
Data Source: National Ambient Monitoring Programme. Compiled by Respirer Living Sciences

Transport Sector
Delhi’s air quality control measures for vehicular emissions, like introducing CNG autos, country’s
largest and busiest metro rail network, introdcuing BSVI fuel since early 2018 and scrapping vehicles
older than 15 years are all progressive policies. However, the data undoubtedly shows that the

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increased volume of transport has thrown a spanner on these efforts. Delhi’s progressive EV policy
released in 2020, requires more focus on mass mobility with public transportation and last-mile
connectivity solutions. Since India’s PUC programme does not capture tiny particles and NOx, the
monitoring of emissions from vehicles is very weak and largely uncontrolled.

On Supreme Court’s directive to investigate Pollution Under Control (PUC) centres not just in Delhi
but also NCR, a report in 2017 was submitted by the Environment Protection Control Authority
(EPCA), which was dissolved in 2020 to replace it with the Commission for Air Quality Monitoring in
Delhi NCR and Adjoining Regions (CAQM). The report raised “serious quality concerns” in the way
PUC tests are conducted and equipment are maintained at these centres across the NCR region. The
weaknesses in compliance are evident due to lack of regulation of a very decentralised setup. The
failure rate of PUC tests was reported as very low – in Delhi only 1.68 per cent of diesel vehicles
failed the smoke density tests and about 4.5 per cent of the petrol vehicles failed the CO and HC
tests. Thus, this programme is not even designed to catch 15 to 20 per cent most grossly polluting
vehicles in the fleet. Comparatively, the tests prescribed for petrol vehicles are more evolved and
complex. In diesel vehicles, the one and only test is the smoke density test.

NO2 emissions from Thermal Power Plants surrounding Delhi

A 2021 study by IIT Delhi’s CERCA analyses NO2 emissions from nine thermal power plants around
the world’s most polluted megacity, Delhi. The study establishes that it is easy to distinguish the
individual NO2 plumes emitted from specific sources such as thermal power plants (TPPs) and over
the Delhi city and adjoining satellite towns, where transport is the other critical emitting sector.

Image: The 9 Thermal Power Plants analysed in the IIT Delhi CERCA study

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Image: The 9 Thermal Power Plants analysed in the IIT Delhi CERCA study

The analysis confirms that emissions from individual TPPs do not conform to their operating capacity.
The nine TPPs in the vicinity of the world’s most polluted megacity, Delhi emitted NO2 in the range of
8.00–30.56 Kt in 2019. The NO2 emissions vary seasonally and are not uniform throughout the year.
However, the possible reasons behind the variation of NO2 emissions across the TPPs may be
attributed to the plant’s age, its maintenance standard, capacity utilization of the various TPPs, and
lesser performance efficiency of the burner compared to the other units of the same category.

The analysis further revealed that NO2 emission reduced significantly (ranging between 41%–290%)
during the COVID-19 lockdown period from March 25, 2020, to April 30, 2020, compared to the same
period in 2019 due to the reduced operating capacity of the plants. During the lockdown, the NO2 in
the city outflow was also significantly reduced due to restrictions on traffic movement.

The National Clean Air Programme recommends several action points to control emissions from TPPs
1. Conversion of all older coal-based TPPs into natural gas fed power plants
2. Requirement for optimizing the use of existing power plants by emphasizing capacity utilization of
natural gas/clean fuel-based TPPs
3. Stringent compliance with the emission norms prescribed in the direction dated December 2017
issued under EPA 1986 by all TPPs
4. Accentuation on improved power dependability to remove diesel generator activities especially in
urban areas

Due to hazardous air quality in November 2021, CAQM issued direction on 26th November 2021
directing all power plants except five (Rajiv Gandhi TPP, NTPC Jhajjar; Rajiv Gandhi TPP, RGTPS, Hisar;
Panipat TPS, HPGCL; Rajpura TPP, Nabha Power Ltd., and Talwandi Sabo TPS, Mansa) to be under
shut-down till 30th November 2021. The directions were further extended till 15th December on
30th November 2021 as the air quality was still in adverse range. There are 12 power plants within a
300 km radius of Delhi, out of which only the Mahatma Gandhi TPP and Dadri TPP have installed flue

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gas desulphurisation (FGD) units to control sulphur dioxide (SO2) emissions. A recent analysis by
Centre for Research for Energy and Clean Air (CREA) estimated that If power plants with FGD
commissioned (Mahatma Gandhi and Dadri power plant) are operated at 85% plant load factor,
these two plants alone will produce around 314 MUs/Day, including other sources, and imports,
making a case for shutting down power plants within 300Km during the winter season. While the
analysis is focussed on controlling SO2 emissions, a case for shutting down TPPs around Delhi will
help control all pollutants including NO2.

ANALYSIS OF CULPRIT STATES

NO2 is one of the criteria air pollutants monitored by the Central Pollution Control Board (CPCB) as
part of its nationwide regulatory monitoring.

The three problem states

An analysis conducted by NCAP Tracker across all 23 states listed in the National Clean Air
Programme (NCAP) showed that average NO2 levels in three (3) states -- Uttar Pradesh, Rajasthan
and Delhi -- breached the CPCB safety limits in the month of November 2021, in comparison to those
in October 2021. The Central Pollution Control Board (CPCB) has set 40 ug/m3 as annual safety limit
for NO2 emissions and 80 ug/m3 as the 24hr safe limit, while the World Health Organisation (WHO)
limits it to 10 ug/m3 and 25 ug/m3 respectively in its revised 2021 air quality guidelines.

Images: Delhi average NO2 readings for Oct and Nov 2021 (Left & Right respectively)
Source: NCAP Tracker

Images: Rajasthan average NO2 readings for Oct and Nov 2021 (Left & Right respectively)
Source: NCAP Tracker

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Images: Uttar Pradesh average NO2 readings for Oct and Nov 2021 (Left & Right respectively)
Source: NCAP Tracker

Table 1: NO2 trends in Delhi, Uttar Pradesh and West Bengal

STATES/ Average NO2 levels Average NO2 levels in No of CAAQMS
CITIES in Oct 2021 Nov 2021 monitoring stations in
each city/state

UTTAR PRADESH 28 54

Baghpat 28 60 1

Bulandshahr 37 59 1

Firozabad 35 47 1

Ghaziabad 38 70 4

Gorakhpur 2 1 1

Greater Noida 42 65 2

Kanpur 18 62 4

Lucknow 30 58 7

Meerut 33 59 3

Moradabad 21 34 1

Muzaffarnagar 18 52 1

Noida 37 57 4

Gorakhpur 2 1 1

Hapur 7 31 1

Prayagraj 17 39 3

Varanasi 18 41 4

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 Agra 18 36 6

DELHI 39 66 40

RAJASTHAN 34 54

Ajmer 26 39 1

Alwar 27 45 1

Bhiwadi 35 63 1

Jaipur 41 70 3

Jodhpur 34 72 1

Kota 27 33 1

Pali 31 25 1

Udaipur 37 53 1
(Note: Number of monitors in each city may differ during Nov 2020 and Nov 2021).

Table 2: Daily and annual average trends across all CAAQMS monitoring sites in Delhi, Uttar
Pradesh & Rajasthan
S No. Monitoring Location NO2 No. of Days Annual
Daily Avg NO2 >80 NO2
>80 ug/m3 Avg
ug/m3 365 days >40
Avg for monitored ug/m3
Nov 2021 Nov20-Nov21

DELHI
1 Anand Vihar, Delhi - DPCC 131 30 73
2 Nehru Nagar, Delhi - DPCC 108 30 62
3 Okhla Phase-2, Delhi - DPCC 110 30 53
4 Dr. Karni Singh Shooting Range, Delhi - DPCC 133 27 63
5 Pusa, Delhi - IMD 114 27 43
6 IHBAS, Dilshad Garden, Delhi - CPCB 105 26 52
7 East Arjun Nagar, Delhi - CPCB 125 25 66
8 Mandir Marg, Delhi - DPCC 89 25 66
9 Jahangirpuri, Delhi - DPCC 99 24 48
10 Jawaharlal Nehru Stadium, Delhi - DPCC 109 22 64
11 IGI Airport (T3), Delhi - IMD 111 20 56

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 12 Patparganj, Delhi - DPCC 90 20 32
13 Pusa, Delhi - DPCC 83 19 47
14 Ashok Vihar, Delhi - DPCC 87 15 45
15 Punjabi Bagh, Delhi - DPCC 83 15 52
16 R K Puram, Delhi - DPCC 72 11 38
17 Mundka, Delhi - DPCC 73 11 38
18 NSIT Dwarka, Delhi - CPCB 67 9 31
19 DTU, Delhi - CPCB 44 7 61
20 Narela, Delhi - DPCC 62 6 37
21 Sonia Vihar, Delhi - DPCC 69 5 39
22 Shadipur, Delhi - CPCB 52 2 49
23 Aya Nagar, Delhi - IMD 35 1 17
24 Wazirpur, Delhi - DPCC 59 1 41
25 Lodhi Road, Delhi - IITM 55 1 44

RAJASTHAN
26 RIICO Ind. Area III, Bhiwadi - RSPCB 63 6 41
27 Police Commissionerate, Jaipur - RSPCB 94 23 53
28 Adarsh Nagar, Jaipur - RSPCB 68 7 36
28 Collectorate, Jodhpur - RSPCB 72 11 29
30 Ashok Nagar, Udaipur - RSPCB 53 1 31

UTTAR PRADESH
31 Sanjay Palace, Agra - UPPCB 49 2 22
32 Yamunapuram, Bulandshahr - UPPCB 59 2 24
33 Sanjay Nagar, Ghaziabad - UPPCB 96 25 61
34 Vasundhara, Ghaziabad - UPPCB 80 15 37
35 Loni, Ghaziabad - UPPCB 72 8 35
36 Indirapuram, Ghaziabad - UPPCB 22 1 37
37 Knowledge Park - V, Greater Noida - UPPCB 98 22 62
38 Nehru Nagar, Kanpur - UPPCB 131 26 68
39 Central School, Lucknow - CPCB 109 27 48
Talkatora District Industries Center, Lucknow -
40 CPCB 78 14 44
41 Lalbagh, Lucknow - CPCB 66 2 45

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 42 Gomti Nagar, Lucknow - UPPCB 89 2 33
43 Pallavpuram Phase 2, Meerut - UPPCB 77 15 102
44 Sector-1, Noida - UPPCB 116 27 64
45 Sector-116, Noida - UPPCB 67 4 42
46 Nagar Nigam, Prayagraj - UPPCB 63 2 29
47 Ardhali Bazar, Varanasi - UPPCB 65 4 56

Analysis for NO2 trends from monitoring stations across Uttar Pradesh, Rajasthan & Delhi

Graph: NO2 levels across all the CPCB monitoring locations in Delhi, UP and Rajasthan

Graph: Locations with highest number of days breaching the CPCB set daily limit for NO2.

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Delhi
An analysis of the monthly average NO2 levels for all 40 monitoring sites in Delhi maintained by the
Continuous Ambient Air Quality Monitoring System (CAAQMS) establishes that 25 locations out of a
total of 40, in the national capital had NO2 greater than 80 ug/m3 in November 2021 for days
ranging from 1 to 30 days. Meanwhile 18 locations breached the annual average limit of 40 ug/m3,
the data was calculated from 01-12-2020 to 30-11-2021 (365 days). 15 locations had levels greater
than 80 ug/m3 average for the month of November 2021, 9 of which were above 100. (Refer to the
above graph and table for specifics on locations)

Anand Vihar, also listed among Delhi’s 13 most polluted hotspots by CPCB, clocked 131 ug/m3
average for November 2021. Clearly local sources like the Inter-State Bus Terminus (ISBT), the
Ghazipur landfill site and the NH24 highway in the area are transporting emissions from heavy
vehicles and other sources to this monitoring site. The ambient PM2.5 at Anand Vihar was recorded
at 250 ug/m3, its possible that near-surface exposure levels will be much higher for the population in
that area, in comparison to ambient exposure levels. Dr Karni Singh Shooting Range at 133 ug/m3
NO2 monthly average levels is situated in a large expanse of green and flanked by residential
colonies, however heavy construction equipment and nearby activity in Tughlakabad Industrial Area
can be factors at play. Out of Delhi’s 13 pollution hotspots, seven had annual average limits greater
than 40 ug/m3 – Jahangirpuri (48), Anand Vihar (73), Ashok Vihar (45), Wazirpur (41), Punjabi Bagh
(52), Okhla Phase II (53) and RK Puram (72).

More locations which recorded November averages for NO2 levels in triple digits in the national
capital are East Arjun Nagar (125), IGI Airport (111), Dilshad Garden (105), Jawaharlal Nehru
University (109), Nehru Nagar (108) and Pusa Road where the monitoring site maintained by the
Delhi Pollution Control Committee (DPCC) records 83, while the India Meteorological Department’s
(IMD) monitor records 114. These levels are also juxtaposed with parts of the city with much lower
NO2 levels, like CRRI Mathura Road (19), North Campus (5), Siri Fort (10) and Lodhi’s IMD monitor
(15), while the Indian Institute of Tropical Meteorology (IITM) monitor at Lodhi Road records 55.
Clearly micro-strategies need to be developed to address these hyperlocal sources in vicinities to
address NO2 emissions.

The wastewater treatment plant in Sonia Vihar could be responsible for a large share of its 69 ug/m3
NO2, while the industrial activity in areas like Mundka (73), Narela (62), Okhla Phase 2 (110) can be
the contributing factor for high NO2 levels. Areas like Ashok Vihar (87), Maya Puri (52), Wazirpur
(59), Punjabi Bagh (83) near the arterial roads of Delhi are affected by heavy vehicular emissions,
while major traffic junctions like Mandir Marg (89), Patparganj (90), RK Puram (72), NSIT Dwarka (67),
Nehru Nagar (108) also face the brunt of hyperlocal sources like vehicular emissions.

Uttar Pradesh
NCR Cities - Ghaziabad, Noida, Greater Noida - November monthly average in satellite towns of Uttar
Pradesh (UP) surrounding the national capital show Ghaziabad at 70 ug/m3, Noida (57) and Greater
Noida (65). Heavy vehicular movement, industrial activity, heavy construction and peripheral
highways are all contributing factors. However, once we drill down deeper into each city, the two
monitoring sites in Greater Noida point towards the source of the problem. Knowledge Park-III
accounts for 33 ug/m3, while Knowledge Park-V is at 98 ug/m3 monthly average, 62 ug/m3 annual

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average and 22 days when levels remained greater than 80 ug/m3. Clearly pointing towards the need
for local administrative interventions at the latter location.

Out of 4 locations in Ghaziabad, Indirapuram is within safe limits (22) and Loni records 72, while
Sanjay Nagar (96) and Vasundhara (80) breach the daily average. Sanjay Nagar also crossed the
annual average with 61 (40 ug/m3 is annual limit) and experienced 25 days where daily limits were
breached (80 ug/m3). The Uttar Pradesh Pollution Control Board (UPPCB) identified construction
waste and unpaved roads as major sources of pollution in Ghaziabad. Industrial and vehicular
emissions and open-air garbage burning are also major contributing factors.

Meanwhile Noida’s 4 monitors point towards Sector-1 as a clear culprit at 116 ug/m3 November
average and Sector-116 at 67 ug/m3. However, the PM2.5 levels of all 4 locations in Noida are not
vastly different; Sector-125 (227), Sector-62 (216), Sector-1 (218) and Sector-116 (245). Both these
locations also breached the annual limits – Sector-1 (64) experienced 27 days where levels were
greater than the daily average and Sector-116 (42 ug/m3) with 4 days of breached NO2 levels.

An analysis by Legal Initiative for Forests and Environment (LIFE) of the city action plans submitted by
Ghaziabad and Noida claimed that plans for both large metropolitan areas are nearly identical. Same
actions have been given for the two cities, which means that their specific pollution profiles have not
been taken into account at all. Both plans lack specific targets for pollution reduction.

Lucknow - Out of seven monitoring stations in Lucknow, the Nishat Ganj station does not provide any
readings, while Kukrail Picnic Spot station situated in the wooded outskirts of the city records 7
ug/m3 avg NO2 for Nov 2021. Traffic heavy locations like Lalbagh and Gomti Nagar recorded 66 and
89 ug/m3 respectively, while Talkatora Industries Centre recorded 78 and Central School a whopping
109 for November 2021. These vast differences in data from monitoring sites resulted in Lucknow’s
average NO2 levels for November at 58 ug/m3, but clearly hyperlocal monitoring data can help
develop targeted air quality management plans which can help the local population in affected areas.
Meanwhile the PM2.5 levels in November 2021 in the city are; BR Ambedkar University (103),
Central School (116), Gomti Nagar (97), Kukrail (99), Lalbagh (104), Nishat Ganj (null) and Talkatora
District Industries Centre (186). 4 locations had NO2 levels greater than 80 ug/m3 – Central School
(27 days), Talkatora (14), Lalbagh and Gomti Nagar 2 days each. Central School, Lalbagh and Talkatora
Industries Centre stations also breached the annual average NO2 limit of 40 ug/m3.

Kanpur - The biggest outlier in the state of Uttar Pradesh is the Nehru Nagar site in Kanpur recording
a monthly average NO2 levels of 131 ug/m3. The monitor at IIT Kanpur does not provide NO2 data,
Kidwai Nagar remains within CPCB’s safety limits (34) and NSI Kalyanpur at 22. Hence, the city’s total
monthly averages to 62, but clearly there is a need for improved data monitoring at all sites and local
source management at sites like Nehru Nagar situated in the bustling and congested heart of the
industrial city. The annual average for Nehru Nagar at 68 crossed the safety limit of 40 ugm3 and
experienced 26 days of NO2 levels greater than CPCB’s safety limit of 80. WHO’s prescribed daily
average is 25 ug/m3 and annual 10 ug/m3. Meanwhile the PM2.5 levels at all four locations in the
city are; Kidwai Nagar (118), IIT Kanpur (169), Nehru Nagar (173) and Kalyanpur (119).

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Varanasi - Out of four monitoring sites in Prime Minister Narendra Modi’s Parliamentary
constituency, Varanasi, one is located in the green campus of Banaras Hindu University (BHU)
recording 18 NO2 and 96 PM2.5. The heavily crowded and busy traffic area of Ardhali Bazaar
recorded monthly average NO2 levels at 65 ug/m3, Maldahiya (40) and Bhelupur (38). Ardhali
Bazaar’s annual NO2 average was almost 1.5 times of the CPCB limit at 56 ug/m3. Varanasi as one of
the Smart Cities is undergoing massive infrastructure project development, the power shortages are
compensated for by diesel gensets like most tier 3 towns in India and unlike the 15 years limit for
scrapping old vehicles in Delhi, Uttar Pradesh’s transport scrappage policy allows for 20 year old
vehicles to ply on the roads. With limited resources for monitoring and compliance, vehicles older
than 20 years may also be plying on the city roads and interior lanes, adding to transport emissions in
the city.

Meerut - With three CAAQMS sites in the city, Meerut recorded a monthly average of 59 ug/m3.
Pallavpuram Phase-2 recorded the highest NO2 at 77, followed by Jai Bhim Nagar at 53 and Ganga
Nagar at 47. The city’s average NO2 level is more than double of WHO’s daily average of 25 ug/m3.
The annual NO2 average in Pallavpuram touched 102, almost 2.5 times of CPCB standards and 10
times of WHO’s annual limits of 10 ug/m3. With increasing two wheeler and four wheeler ownership
in cities, urban planning has not been able to absorb these developments keeping environment
impacts in mind. In recent years, with the expansion of the city of Meerut to Mohiuddinpur on Delhi
Road, Daurala on Roorkee Road, Gokalpur on Garh Road and Ganganagar on Mawana Road, along
with other establishments such as residential colonies, industries, connecting roads and motorway
junctions have only increased. Against this background, the state government commissioned the
Meerut Development Authority (MDA) to draw up the Meerut Master Plan 2021. The work will be
carried out in three phases. The PM2.5 levels breached CPCB limits by more than 5 times in the
month of November; Pallavpuram Phase-2 (213), Jai Bhim Nagar (202) and Ganga Nagar (197).

The ‘Comprehensive Environmental Pollution Index’ (CEPI) carried out by Ministry of Environment &
Forests (MoEFCC) in association with CPCB and IIT Delhi in 2009 identified nine critically polluted
Areas (CPA) in Uttar Pradesh -- Mathura, Kanpur, Moradabad, Varanasi-Mirzapur,
Bulandshahar-Khurja, Firozabad, Gajraula area, Agra, Ghaziabad and 4 severely Polluted Areas which
were Noida, Meerut, Aligarh and Singrauli (UP & MP). The NO2 analysis for some of the cities in Uttar
Pradesh reveal that many of these cities have consistently been pollution hotspots and need long
term pollution management strategies. NO2 monthly average in November in Industrial cities like
Bulandshahr was 59 ug/m3, Baghpat (60), Firozabad (47) and Muzaffarnagar (52). All these cities
have only one CAAQMS monitoring station therefore hyperlocal monitoring and analysis of local
sources’ impacts can not be derived accurately. Out of these cities, Bulandshahr was the only one
with 2 days in the year when NO2 levels crossed 80 ug/m3.

Gorakhpur - The only station to record 1 ug/m3 NO2 levels in the entire state of Uttar Pradesh was
UP Chief Minister, Yogi Adityanath’s constituency, Gorakhpur. While the CM has been lauding the
‘Gorakhpur Model’ for tackling air pollution, the CAAQMS monitor was installed only in June 2021 as
there is no prior air quality monitoring data available. The PM2.5 level in the city for November is 139
ug/m3, the highest recorded this year. However the NO2 levels since June have been a static 1
ug/m3, raising doubts on the monitoring of the precursor gas.

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Image: Screenshot of the CAAQMS monitoring graph for NO2 in Gorakhpur for 2021. Source: NCAP Tracker

Rajasthan
The desert state of Rajasthan has 8 non-attainment cities -- Jaipur, Jodhpur, Udaipur, Ajmer, Alwar,
Bhiwadi, Kota and Pali -- and 10 CAAQMS monitoring stations. Five of these locations experienced
days where NO2 levels crossed daily averages – RIICO Industrial Area, Bhiwadi (6 days), Police
Commissionerate Jaipur (23 days), Adarsh Nagar Jaipur (7 days), Collectorate Jodhpur (11 days) and
Ashok Nagar Udaipur (1 day). Only the capital city, Jaipur has 3 monitoring sites while all other cities
have one CAAQMS monitor each. November 2021 monthly average NO2 level for Rajasthan is 54
ug/m3. According to Global Burden of Disease 2017, Rajasthan recorded the highest number of child
mortality due to air pollution, 126 per lakh.

Jaipur - Police Commissionerate in Jaipur crossed the annual average with 53 ug/m3, almost five
times of WHO’s annual limit of 10. Open waste burning, diesel vehicles and traffic jams are major
contributors of NO2 in the city. The PM2.5 levels at these three locations were -- Police
Commissionerate (99), Adarsh Nagar (111) and Shastri Nagar (95). A source apportionment study for
Jaipur conducted by IIT Kanpur claimed that NO2 levels in winter are higher than those in summer at
all sites and the levels meet the national air quality standard of 80 ug/m3. The highest NO2 levels
were observed at Ajmeri Gate, a commercial site exposed to emissions from vehicles, road dust,
garbage burning and restaurants. In addition, high levels of NO2 are expected to undergo chemical
transformation to form fine secondary particles in the form of nitrates, adding to high levels of
existing PM10 and PM2.5.

Bhiwadi, which is part of Delhi-NCR and home to a range of large, medium and small-scale industries
from steel mills and furnaces to automobile and electronics manufacturing, is among the most
polluted in the state with high PM 2.5, PM 10 and NO2 concentration throughout the three years
(2019- June 2021). According to an assessment by Centre for Science and Environment (CSE) and the
Rajasthan Pollution Control Board in 2020, the Bhiwadi Industrial Area contributes around 65% to the
industrial pollution load of the region (Jaipur-Alwar-Bhiwadi airshed). The NO2 for the month of Nov
in Bhiwadi was 63 ug/m3, annual average NO2 was 41 and 6 days where levels were greater than 80

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ug/m3. Bhiwadi’s PM2.5 average for November was 195. Meanwhile Alwar’s NO2 is 45 and PM2.5 is
68 ug/m3, its monitor is located in Moti Doongri.

Jodhpur & Udaipur - Jodhpur’s monitor installed at Collectorate recorded monthly average NO2
levels at 72, almost triple of WHO’s daily average limits (25 ug/m3) and PM2.5 at 108. The Blue City
experienced 11 days where NO2 crossed daily average of 80/m3. Meanwhile Udaipur’s NO2
breached to 53 according to the CAAQMS monitor at Ashok Nagar. Jodhpur and Udaipur ranked
among the 100 most polluted cities in the world according to the WHO ranking in 2018, indicating
industrial and vehicular exhaust emissions with limited monitoring mechanisms.

QUOTES

Prof S N Tripathi, Civil Engineering Department, IIT Kanpur & Steering Committee Member,
National Clean Air Programme, MoEFCC
“NOx is showing an increasing trend in different cities of the country and particularly for Delhi NCR.
Daily exceeding values for any particular period of time, and overall average levels in NCR indicate
that NOx values are far greater than annual safety limits prescribed by CPCB, leading to both short
term and long term exposure to people. This can have serious health implications. Therefore, these
need to be urgently looked into and corrective and mitigative measures need to be taken so that NOx
values can be brought within control in Delhi NCR and other parts of the country.”

Dr Arun Sharma, Director, National Institute for Implementation Research for Non-Communicable
Diseases (an ICMR body)
“NO2 as a gas has not so serious effects on the health of the people but it’s secondary effects through
increase in PM2.5 concentrations and augmentation of Ozone formation are a matter of concern. In
18 cities across the states of Rajasthan, Uttar Pradesh and NCT of Delhi, the average NO2
concentration were higher than the CPCB prescribed limit of 40 mcg/L3 in the month of November
2021. The only way that the NO2 levels can be controlled are by reduction at source as fixation of
NO2 in the air along with SO2 is cause for acid rain.

The process of metabolizing the NO2 in the human body is also not favourable, as nitrogen fixation
leads to increased urea formation. High levels of urea have adverse effects on the human nervous
system. A look at the accompanying table shows that maximum concentration is seen either in
densely populated urban areas or in towns with heavy concentration of industries, where habitation
in poorly ventilated low income housing is predominant. Thus a large segment of the population with
relatively less access to quality health care are likely to be affected, hence reduction at source
remains key intervention to minimize the impact of high NO2 concentration on human health.”

Ronak Sutaria, Founder & CEO, Respirer Living Sciences

“While 'non attainment' cities in India are governed based on their PM2.5 and PM10 levels, it is
equally important to track NO2 levels at a hyperlocal level in urban cities in India. Given that sources
of NO2 emissions tend to be vehicles as well as from industries, it is important to know the hotspots
of NO2 pollution as these over time contribute to a significant increase in the more toxic and
carcinogenic PM2.5 pollution.

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The NO2 data presented here analyzed from the over 300 continuous CPCB monitors across India give
a useful insight into which neighbourhoods are more toxic than others. Affordable NO2 monitoring
technologies are now available to increase this NO2 monitoring at an acceptable accuracy for every
urban neighbourhood of India.”

Aarti Khosla, Director, Climate Trends

“This data gives a clear idea of what goes into making PM2.5 particulate and that we must have this
knowledge before taking steps to reduce pollution. Focusing on such information should allow the
local and state governments, the Centre, as well as citizens, to know where to act. Having year long
above average concentrations of nitrogen dioxide which is evidently in busy traffic or high density
industrial areas shows where action should be.’’

About NCAP Tracker

NCAP Tracker is a joint project by Climate Trends and Respirer Living Sciences to create an
online hub for the latest updates on India’s clean air policy, the National Clean Air
Programme (NCAP). It is designed to track India’s progress in achieving the 2024 clean air
targets set under the NCAP. The NCAP Tracker enables this by compiling and evaluating
various levels of air quality data and closely tracking the effectiveness of the clean air
policy. The tracker compiles and analyses information on air quality and budget allocation
that is publicly available or provided by the government of India.

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