Category: Blog

Many farmers consider stubble burning as the most effective and cost-efficient way to clear land for the next planting season. However, the environmental and health costs of agricultural stubble burning far outweigh the short-term economic benefits for farmers. This necessitates policy actions that offer environmentally friendly and affordable alternatives for farmers.

Despite the risks and safety concerns, burning of crop residue is an extremely common and widely acceptable practice in Pakistan especially in the rice-wheat belt of the country. Agriculture accounts for a fifth of Pakistan’s GDP and is largely concentrated in the Punjab province. Between October and January every year, out of 8.5 million tonnes of rice residue produced, at least 3.6 to 5 million tons is burnt to clear the fields for sowing wheat. Burning stubble remains the fastest and most affordable way to prepare fields for subsequent planting seasons.

Environmental impact of stubble burning

Around this time, Punjab witnesses a significant deterioration in air quality, while Pakistan’s largest urban centres, Lahore and Karachi already rank amongst the most polluted cities of the world. The sharp increase in air pollution is caused by crop burning fires along with thermal inversion – a meteorological phenomenon in which particulate matter and other pollutants trapped in air, mix with condensed water vapour to form smog. This amplifies and prolongs the smog phenomenon in winters. In fact, Pakistan’s only comprehensive source apportionment study by the Food and Agriculture Organisation (FAO) in 2018 attributes 20% of the air pollutant emissions in Pakistan to crop burning.

Figure 1: Pollution sources in different studies across Pakistan

Note: This graph illustrates the underlying sources of smog in Pakistan as identified by geographic information system – R-SMOG (Source).

Air pollution has many direct and indirect costs; it can cause premature death, reduce work productivity and educational attainment, and can be particularly damaging for pregnant mothers and children. All of this is estimated to cost Pakistan up to 6.5% of its annual GDP. An improvement in Pakistan’s air quality on a scale similar to China’s can lead to an increase in average life expectancy of its residents by 1.2 years. Some of the measures by the Chinese included prohibition of coal-fired power plants in the most polluted regions, restricting the number of cars on the road, and introducing all-electric buses. China also shut down many of its coal mines. Crop burning not only contributes to air pollution but over time it also leads to nutrient loss, depletion of soil organic matter, reduction in beneficial soil biota and soil fertility by 25% to 30%, and it also undermines the soil’s capacity for water retention.

A consequence of market failure?

The excessive reliance on crop burning stems from a market failure around externalities where the true social cost of crop burning is not recognised and exceeds the private costs incurred by farmers while burning stubble. Globally, crop burning remains the largest contributor to black carbon – formed by the incomplete combustion of fossil fuels, wood and other fuels – which disappears after a few weeks but its impact on global warming is several thousand times more than carbon dioxide (found in vehicular emissions). Information asymmetries lead farmers to think they are cost saving by burning stubble and they are often unaware of the adverse long-term implications on the environment, crop productivity and farming costs. If farmers understood the social costs (cost to the health and environment), they may be more willing to adopt alternative methods of residue management with much lower social costs.

However, many farmers lack the tools, knowledge or resources to adopt more environmental-friendly alternatives which include both in-situ and ex-situ mechanisms. Ex-situ residue management methods include biomass power plants and biofuel projects whereas in-situ management of crop residue is through the use of appropriate equipment such as Happy Seeders (discussed below). Often farmers are not fully aware of the alternatives and its harmful effects. Evidence shows farmers aware of negative effects of crop burning are less likely to burn residue. Farmers also lack knowledge about how crop residues can be incorporated back into the soil and the kind nutrients needed for the crops. However, any awareness raising campaign should be run parallel to implementing practical solutions that empower farmers both technically and economically.

The current policy approaches

In 2019, the Government of Punjab introduced a ban on crop burning for one month starting in October each year. The district government, with support from the Agriculture Department can fine up to PKR 50,000 (US$ 300) per acre if a farmer is caught burning stubble. However, enforcement and compliance remain weak especially in the absence of feasible alternatives and agricultural fires continue to occur. Farmers do not find the fine prohibitive, and without access to affordable alternatives, crop burning is likely to persist. Penalising farmers in this situation is not politically viable either and these bans can only be effective if alternatives and information about them is available and accessible.

In 2020, the Punjab Agriculture Department launched a programme to subsidise a bundle of equipment, Rice Straw Shredders and Happy Seeders. They make the rice stubble more manageable and then incorporate it back into the soil, eliminating the need to burn. In 2021, the government decided to pay 80% of the costs (around US$ 2100) to 500 farmers out of 2300 selected through a lottery system. The Happy Seeder equipment can potentially reduce greenhouse gas emissions by 78% per hectare.

Leveraging this random assignment of machinery, a group of researchers based at the IGC1 are planning to evaluate the hypothesised impacts. They will in particular assess whether in the short term, subsidising green technology reduces pollution by shifting farmers away from crop burning. Their on-going study also intends to measure impacts of the technology itself while also investigating factors that influence uptake in the context of heavy government subsidies. Complete residue removal is around 34% costlier for farmers than complete burning and costs approximately US$ 55. The average subsidy required to incentivise farmers to move towards alternatives is anywhere between US$ 11 and US$ 30 per acre. Incidentally, this was the amount that Punjab and Haryana states had planned to pay farmers in 2019. Thus for an approximate 4.6 million acres, it would cost between US$ 50 to US$ 138 million per year.

Exploring other options?

Payments for ecosystem services (PES)

One policy option for reducing stubble burning can be providing payments for ecosystem services (PES), made to farmers who agree to manage land/activities by adopting environmentally and ecologically friendly practices. Such a system can potentially be executed through a conditional cash transfer (CCT) programme via Pakistan’s umbrella social protection platform Ehsaas with support from the Department of Agriculture. Ehsaas manages Pakistan’s flagship and one of South Asia’s largest cash transfer programmes called the Benazir Income Support Programme (BISP).

CCTs have often been used to restore efficiency where externalities exist and/or improve equity by targeting the poor. CCTs that offer PES to reduce crop burning have shown success in India. CCTs can also make alternatives more economically viable and incentivise their adoption by farmers.

The government can use existing infrastructure to roll out this programme. It has in place a Kissan (farmer) card through which eligible farmers can register for and avail such payments digitally. Applications can be verified by local staff and targeting can rely on the socio-economic registry maintained by BISP and the database at the department. Some payment can be made upfront to help build trust and give farmers a financial cushion to purchase/rent Happy Seeders or other equipment. Farmers could then call relevant teams to check compliance before sowing wheat and receive the remaining amount. Overall payments should be large enough to cover the cost of stubble removal.

Boosting demand for bioenergy

About 25% to 40% of any crop has value as food while the rest which is often wasted can be a low-cost source of raw material for bioenergy. However, commercial markets for biomass-energy in Pakistan are not well developed. The total rice and wheat potential available for energy generation in Pakistan is more than 600,000 terajoules with an annual production of approximately 40 million tons. Government intervention can activate these markets and provide farmers an alternative use for crop residue and an opportunity to earn additional income by selling residue. This can also encourage the production of renewable/alternative energy.

For this, the government needs to establish a practical business model and a bio-waste supply chain system that connects farmers to these markets. Government could also setup storage facilities for crop residue in areas with a high incidence of crop burning or rice production. It would also be important to take steps to boost demand for bioenergy that would encourage private sector participation in supply chain operations. This could include estimates of how much residue could potentially be used up, and accordingly create markets for briquettes made from crop-residue; introducing policies mandating neighbouring thermal power plants to co-fire crop residue with coal; initiating minimum usage ratios of crop residue biomass in industrial boilers and biomass electricity generation projects (the Central Electricity Authority of India (CEA) recommends a blend of 5 to 10 % of biomass). In return, farmers can receive compensation through direct deposits into their banks or through their Kissan cards.

To change the well-established habit of crop burning, a lot of effort will be required to provide education, raise awareness, and build capacity of farmers. While it may be a tall order, its impact can be considerable and far-reaching towards a more sustainable future.

Hina Shaikh is a Country Economist for the International Growth Centre (IGC) in Pakistan.

This blog originally appeared on the International Growth Centre’s (IGC) website here.

By Emun Hafeez

This blog draws upon findings from the policy note, prepared by Consortium for Development Policy Research (CDPR) in collaboration with UK Aid-funded Sustainable Energy and Economic Development (SEED) Programme, titled “Financing Sustainable Tourism in Khyber Pakhtunkhwa: Mobilizing Local Resources” and explores the opportunities and challenges of creating a self-sustaining system of tourism development in the province of Khyber Pakhtunkhwa (KPK). 

Pakistan boasts a myriad of natural marvels and a rich cultural heritage. With mighty mountains and lush green hills in the North to rolling deserts in the South and a plethora of religious and cultural landmarks scattered all over, the country offers much in the way of tourist destinations. Unfortunately, the country had been afflicted with poor internal security for the past two decades but now as the security situation improves, both domestic and international interest n in visiting these picturesque sights has grown, so much so that Pakistan was named the top tourist destination in 2020 by Forbes and Conde Naste Traveler. However, as with any diamond in the rough, it is imperative to invest  time and resources under good governance to reap the full benefits of what nature and history has to offer.

The province of Khyber Pakhtunkhwa has seen an unprecedented increase in tourists in recent years. While this growth has resulted in the creation of economic opportunities and bolstered the hospitality and tourism service sector in the region,  dearth of adequate resources and infrastructure has made it difficult to cater to this massive influx of tourists especially during peak season^[1]. This lack of capacity creates adverse economic and environmental impacts which are preventable. The biggest challenge impeding capacity building and infrastructure development in the region remains lack of revenue and resources available for the development, upgradation, and  maintenance of tourism sites.

Learning from Global Experiences

Global experience demonstrates that the best way to promote tourism development is by embedding a self-sustaining system of revenue generation and expenditure within the region. International best practices further indicate that the most transparent and efficient way of achieving this is through local governments. Local governments have the capacity to ring-fence  revenuesi.e.  guarantee that funds allocated for a particular purpose will not be spent on anything else. Revenue collected via hospitality and tourism activities as well as through user fees, tolls and charges can be invested in tourism development in the region. Studies have shown that local tax collection earmarked for specific purposes and uses, in accordance with the preference of consumers, creates better incentives to pay that otherwise may be weak or absent in a centralized tax and expenditure system.

However, hypothecation (or ring fencing) of taxes comes with a caveat; complete reliance on locally generated revenues to fund tourism development can be counterproductive given the procyclicality of tax revenues. This can result in a shortage of funds and consequently impede provision of tourism products (goods and services) during economic downturns. Hence, a hybrid model or what is known as weak hypothecation is preferred world over. This is when a portion of revenue from the central pool also goes towards tourism development in addition to what is generated through earmarked taxation.  

An important benefit of taxing certain tourism related activities is that it helps mitigate the effect of negative externalities associated with tourism such as degradation of environment and natural resources. Moreover, money generated through such taxes can be used to build resilient systems of tourism which are better equipped to absorb shocks resulting from climate change and pandemics^[2].

Potential for Ring Fencing Taxes for Tourism in KPK

In Pakistan, tourism is a provincial subject and hence budgetary decisions are made at the provincial level. All revenue collected in KPK goes into a provincial consolidated fund and the provincial government then makes expenditure decisions for various sectors specified in the annual budget. Furthermore, constitutional provisions do not allow for ring-fencing at the broader, provincial level. However, there is potential for ring-fencing through  various authorities operating within the province as these authorities^[3] have the mandate to decide how to use revenue generated through several tools at their disposal.

This prospective avenue for ring-fencing is constrained by its own set of issues. There is significant overlap in administrative jurisdictions across these authorities and local bodies resulting in an administrative spaghetti bowl with multiple departments, overlapping jurisdictions, regulations, and numerous taxes/levies making tourism administration and management exceedingly complex.

Local Challenges for Investing in Sustainable Tourism

Lack of Tax Compliance: The most prevalent issue in KPK is the lack of tax compliance within the tourism industry. Due to seasonality of revenues business owners and service providers attempt to maximize revenues during peak season to tide them over during dry spells. Without a steady stream of tax revenue, the entire case for hypothecation falls flat as there are no funds to apportion. In recent years successful efforts have been made to increase compliance but more  needs to be done to reach a self-sustaining level of revenue.

Ecological and Environmental Threats: Unchecked flow of tourists poses serious threats to the environmental integrity of the region. Pigouvian taxes^[4] can be used to regulate the flow of tourists and to mitigate negative externalities caused by commercial activities such as deforestation, pollution, solid waste disposal etc. The provision of a public good or a service can be connected directly to a fee or a charge to create willingness to pay.

Complicated Regulatory Landscape: As highlighted above the overlapping administrative jurisdictions make tourism management exceedingly difficult. To overcome this, it is imperative to improve interdepartmental and inter-authority communication and cooperation with a clear delineation of mandate and jurisdiction of each department/authority.

Lack of Private-Sector Engagement: The private sector has limited engagement with the authorities which dampers its ability to influence decisions which affect the region. This acts as a disincentive to pay taxes/levies or fees to these authorities even if the money is being spent locally on improving public services and infrastructure. Formalization of private sector engagement with the authorities is essential to garner their support and increase compliance.

Revenue Leakages and lack of skills: Much of the investment in tourism products in KPK comes from outside the province which means revenues generated leak out to wherever the holding companies are based. Additionally, low levels of economic activity and development and lack of a skilled workforce in the region constrain local involvement in the tourism and hospitality industry. Hence, there is an urgent need to focus on the capacity building and skills training of locals. 

Lack of Data on Tourism: The dearth of data on tourism in terms of tourism flows, grading of restaurants and hotels limits the capacity for evidence-based policy design for the tourism sector.

Key Policy Message

The premise of a self-sustaining tourism development system is contingent upon the province’s ability to extract a steady stream of tax revenue from its tourism industry and the exercise of taxing tourism related activities can only be successful if the money collected translates into tangible infrastructure and improvement in systems as this reinforces incentive to pay such taxes. Moreover, local support for the tax regime is essential for its success and can only be achieved when there is sufficient pay-off for locals of the region in terms of job creation and increased economic prosperity. Investment in enhancing the skills of locals is essential to increase the value of contribution of locals to the tourism sector which will in turn increase the portion of revenue generated and retained in the region.

Emun Hafeez is a Research Associate at the Consortium for Development Policy Research.

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^[1] Turab (2022)Financing Sustainable Tourism in Khyber Pakhtunkhwa: Mobilizing Local Resources

^[2] Turab (2022)Financing Sustainable Tourism in Khyber Pakhtunkhwa: Mobilizing Local Resources

^[3] Khyber Pakhtunkhwa Tourism Development Authority, Galiyat Development Authority, Kaghan Development Authority and the upcoming Upper Swat Development Authority.

^[4] A Pigouvian tax is a tax on a market transaction that creates a negative externality, or an additional cost, borne by individuals not directly involved in the transaction. Examples include tobacco taxes, sugar taxes, and carbon taxes

Since March 2020, schools across the world have either been completely closed, or  operated under strict COVID-related restrictions. This has affected 1.6 billion learners globally, resulting in substantial learning losses and plummeting enrollment rates (World Bank, UNESCO, UNICEF 2021). The lockdowns left almost 50 million children in Pakistan and 12 million children in the province of Punjab out of school (Zakaria 2020). By the third school reopenings (September–October 2021), 21% of adolescent boys and 8% of adolescent girls in Punjab had dropped out of school. Those who remained within the schooling system incurred major learning losses. A study by the Punjab Examination Council indicates a decrease in the academic performance of Grade 5 children in Punjab in 2020. With an increase in dropouts and substantial learning losses, there is a need to chart future steps to recovery. This webinar aims to outline how dropouts can be reintegrated into the schooling system and how learning losses can be overcome with an underlying focus on technological and innovative solutions.

Why have so many children dropped out of school?

There are several reasons for the increase in dropouts.

1.  First, income losses incurred during the pandemic left families financially vulnerable, due to which many children were forced out of school. Many students, particularly boys, also had to enter the labour force prematurely to make up for income losses, resulting in a higher dropout rate for boys (21%) as compared to girls (8%) in Punjab.
2.  Second, lockdown measures kept families housebound, increasing the gendered burden of work; girls spent more time doing household chores instead of studying. This can encourage parents to keep their daughters at home even after school reopenings, particularly in a cultural milieu which puts a lower value on girls’ education.
3. Third, many students were not able to continue learning through remote learning programs (TeleSchool and TaleemGhar) due to a lack of access to technology and the absence of conducive learning environments at home. This has made catching up difficult, resulting in many families opting not to send their children back to school (Geven et al., 2022).
4. Fourth, many families have also opted to engage their children in religious education, which many consider an alternative to formal schooling in Pakistan.

Has remote learning worked to reduce learning losses?

In addition to the issue of dropouts, COVID-19 has also resulted in learning losses for those that remain within the schooling system. While the government launched a distance learning program early in the pandemic, its uptake has been limited. In Punjab, by the time schools reopened in September–October 2021, only 8%  of girls and 2%  of boys were engaged in distance learning (Geven et al., 2022). There are multiple reasons for the resistance to remote learning uptake. Some of them are listed below:

1. Access to technology is severely limited in Pakistan, especially in remote regions, and within disadvantaged groups. According to the Pakistan Demographic and Health Survey (DHS) 2017, only about 15% of households of the poorest quintile owned a television. Comparatively, within the wealthiest quintile, around 96% owned televisions. Access to the internet and smartphones is even more unequal; only 12% of Pakistani households have access to the internet.
2. Even where households have access to technology, devices may have to be shared between family members. Additionally, most houses lack spaces which are conducive to learning which make it difficult to keep students engaged with distractions around.
3. Most curricular content is scripted in Urdu, which can make it inaccessible to families fluent only in regional languages.
4. Due to COVID-related income shocks, many boys may be prematurely pushed into the labour force, which can limit the amount of time dedicated to learning.
5. Girls are expected to do household chores. Since school reopenings in September 2021, girls spent about twice as much time as boys on family care (Geven et al., 2022).
6. Societal attitudes towards watching television have also impacted uptake. A recent study noted that television in Pakistan is considered to be a medium to access entertainment, which adds to the hesitation in its use for education. Some fathers also prohibit their daughters from accessing television (Malik et al., 2022).
7. Alternatives like private tutoring are costly, and can only be accessed by relatively advantaged groups.

As a result of these factors, students have undergone learning losses amounting to around 0.6 years of learning-adjusted schooling, according to early estimates (Geven and Hasan 2020).

Percentage of people who had watched the TeleSchool transmission
Source: Gallup Pakistan, 2020

How have other countries re-integrated students into the school system and mitigated learning losses?

Following are some models of recovery adopted in other developing countries.

Tackling Dropouts: To address the issue of increasing drop-outs, several countries have initiated back-to-school campaigns to re-integrate children into the schooling system. In Kenya, community-based household mobilizations led to 96 percent of learners eventually re-enrolling. Additionally, in Mexico and Brazil, governments have adopted conditional cash transfers, tying cash support to families to school enrollment.

Overcoming Learning Losses: Similarly, to overcome learning losses, many countries have adopted some form of remedial learning.  In 2020, the Philippines government established summer schooling for students who had received a grade lower than 75 percent in the previous school year. While evidence on the effectiveness of such programs is still limited, interventions that focus on targeted instruction, with extended instruction time and condensed curricula are potential options to be explored for learning recovery (World Bank, 2021).

Building Resilience: School closures are not unique to COVID-19 and are likely to occur in the future as a result of climate-related disasters, conflicts, and public health emergencies. Remote and hybrid education is expected to continue after the pandemic (World Bank 2021). In case of repeated closures, strengthening remote learning systems is key. Many developing countries have employed multimodal strategies to ensure widespread access. In Peru, for example, the authorities have deployed a multi-modal strategy based on an assessment of the availability of different modes of technology and have used multiple channels like radio, television and the internet to stream educational content. Additionally, educational content has been created in nine native languages, making it more widely accessible . Moreover, telecommunication operators agreed to zero-rate the program’s core digital site so that students can access all available educational resources without paying for the bandwidth. This was combined with regular communication of weekly schedules for learning sessions, frequent teacher-student follow-up, and a strong monitoring system to understand the program’s coverage and engagement.

How can these strategies be implemented in Pakistan?

While cross-country examples can shed light on innovative strategies, Pakistan’s recovery strategy needs to be anchored in evidence, with considerations for capacity, budget constraints and other relevant factors.

There are no neat solutions to the losses faced by the education sector in Pakistan during COVID-19 but there are a few areas which require greater focus from policymakers. Some questions to be explored for future interventions are:

• What strategies can be employed to re-integrate drop-outs into the formal schooling system?
• What can an effective strategy for remedial learning look like in Pakistan?
• How can we improve the current system of remote learning to build resilient systems by establishing learning continuity between the home and school environments?
• How can government initiatives address gender-related inequalities in re-integration and learning loss?
• How can stakeholders in the wider ecosystem be leveraged to provide learning solutions to address learning loss?

Sources:

• “The State of the Global Education Crisis: A Path to Recovery”. World Bank, UNESCO, and UNICEF, 2021.
• “Brief on Learning Continuity Amidst COVID-19”. UNICEF, 2020.
• Geven and Hasan, “Learning Losses in Pakistan Due to COVID-19 Closures: A Technical Note on Simulation Results”. World Bank, 2020.
• Geven et al. “SMS Girl Data Insights”. World Bank, 2022.
• Malik et al. “Girls’ Lived Experiences of School Closures: Insights From Interviews With Girls and Mothers in Punjab, Pakistan” South Asia Gender Innovation Lab, World Bank, 2022.
• Muñoz-Najar et al. “Remote Learning During COVID-19: Lessons from Today, Principles for Tomorrow”. World Bank, 2021.
• Zacharia, Sharon, “Pakistan: TeleSchool and Taleem Ghar (Educational TV at home)”. World Bank, OECD, Global Education Innovation Fund, 2020.
• “Remediating Learning Loss”, World Bank, 2021.
• “Assessment of Students’ Learning Loss: COVID-19 in Punjab”, Punjab Examination Council, 2020.

The scenes in Lahore look eerily similar to those of a sci-fi dystopian movie. A grey haze has descended upon the city. Lahoris walk around wearing protective face masks – not because of Covid-19 – this time, it is the smog which poses a serious health risk to the people of the city.

A worrying trend is in play in Lahore for the past few years. As the winter months approach, the city is wrapped in dense, unbreathable smog. The city frequently features in the list of cities with the worst air quality in the world, often topping the list during the winter months. This constantly deteriorating air quality poses a severe health risk to Lahoris who are exposed to the polluted air containing particulate matter 2.5 (PM2.5), which are fine particles less than three percent the diameter of a strand of human hair, easily absorbable within the bloodstream and gravely risking health. A study conducted by Sanval Nasim (LUMS) and Faiza Sharif (GCU) highlighted that PM2.5 exposure increases the incidences of cancer and cardiovascular and respiratory diseases such as ischemia, myocardial infraction, asthma, and bronchitis.  A separate study conducted by Sanval Nasim and Mahnoor Kashif highlighted the impacts poor air quality has on the financial sector when impaired cognitive ability and mood changes due to exposure to polluted air affects investor behavior and can drive substantial variation in returns on the stock market.

So, while there is evidence of increased health and economic risks associated with poor air quality, why is it that Lahore and other cities of Pakistan continue to face this issue year in year out and why have government actions been ineffective in dealing with it?

Sources of Air Pollution

Presently, there is a lack of research on source appropriation for the existing poor air quality. However, one study carried out by the Food and Agriculture Organization (FAO) in 2018 highlighted broadly the main polluting sectors to be transport (43% of total share in emissions), industry (25%), agriculture (20%), and power (12%).

Poor fuel quality and older automobiles with inefficient engines are leading sources of vehicular emissions. Annual rice stubble burning season which begins around the October-November period in Punjab is another leading source of smog as farmers across the province begin to prepare the crop fields for planting of wheat.

While we may be able to pinpoint the sources which contribute to poor air quality in Lahore and Punjab in general, there also needs to be an acknowledgement on the behalf of the government that its regulatory policies against these emission sources have been negligible and toothless in producing any tangible change.

Lack of Policy Implementation

A closer look at the existing policy to tackle smog and poor air quality will reveal that this issue is not one of lack of legislation or laws, rather a failure of governance. Detailed policy measures exist at both federal and provincial levels, but due to poor implementation the problem still persists. The mandate to control the various causes of air pollution fall under different departments, and bringing the relevant departments together to devise and coordinate a cohesive anti-pollution strategy is a major challenge. This inter-departmental lag contributes to regulatory deficiencies.

In the face of such failures, the air pollution crisis has been declared an emergency and the Provincial Disaster Management Authority (PDMA) has been forced to step in as a coordination department.

A case in point of this inefficient implementation is the Punjab government’s initiative to equip older brick kilns with modern zig-zag technology to reduce emissions. Converting brick kilns with modern technology across the province was no easy feat, as there were many non-conforming kilns which had to be severely fined to force them to adopt the new technology.  Additionally, lack of technically adept and skilled labour has also been a deterrent in the adoption of zig-zag technology. There is also the issue of incorrect categorization since brick kilns continue to be categorized as part of the cottage industry, which means that they are exempt from the policies and regulations pertaining to large scale industries, making it difficult to regulate them and encourage them to conform to modern technologies.

Vehicular emissions which are a major contributor to poor air quality need tighter controls too. The government has requested oil marketing companies to import Euro 5 fuel which is significantly cleaner and reduces emissions compared to the more widely available Euro 2. However, there has not been a revision of the fuel standards set by the Environmental Protection Agency (EPA). The 2016 fuel standards set by the EPA which were developed around Euro 2 need to be revised to Euro 5, so the discrepancy between word, letter and spirit is diminished.

State Responsibility

The burden and responsibility essentially lie with the state in this regard. The sectors that are responsible for their share of air pollution will almost always try to mitigate their costs rather than to reduce emissions, while the citizenry and civil society can, at most, serve supporting roles to create pressure for improved regulations. It is the government itself that needs to spearhead the required initiatives. There are examples which demonstrate lack of prioritization by the government such as when the Pakistan Environment Protection Agency (PEPA) mandated that the Pakistan Environment Protection Council (PEPC) convene at least twice a year, yet failed to do so in the past many years.

On paper Pakistan has excellent environment related legislations, but failure in implementation and lack of resource capacity does not allow effectively achieving the goals set by them. In an attempt to devolve powers to the provincial governments, the bureaucratic lag has been exacerbated where multiple departments have overlapping or cross-cutting jurisdictions which leads to inefficient execution of laws and regulations. Consequently, there is little accountability of which department is to be held responsible when regulations are violated.

There is a dire need to break this cycle of bureaucratic futility by redefining the mandates and jurisdictions of each department and how they may interact and support each other in effective implementation of laws.

Way Forward for Future Policy Actions

The Punjab Government in October 2021 declared smog a calamity and instructed the PDMA to take action against crop burning in the province to reduce emissions. The government also shifted all schools and private offices to remote work on Mondays till January 15, 2022 in hopes that the number of vehicles on the road will reduce. But again, these measures are neither sufficient nor appropriate to curb emissions in the province. The government must realize now that addressing crisis situations should not warrant a knee-jerk reaction such as closing down schools, rather it should have effective laws and regulations in place with a robust implementation mechanism.

Revision of Devolution of Powers – Empowering Local Bodies over Departments

Admittingly, there is considerable devolution of powers from the federal to provincial levels in the air quality policy landscape. The provincial governments have departments which in turn work with the district level administrators to ensure that rules and regulations are abided by. However, due to overlapping jurisdictions, contributors to air pollution and violators of environmental laws are able to escape fines which is why there is an imperative need for a local government structure that can take on a more hands-on approach in curbing emissions and clamping down on violators.

Comprehensive Automobile Legislation

Much of the data points to automobiles as a major contributor of emissions and pollution. As previously pointed out there is existing regulation of shifting to cleaner Euro-5 fuels across the country but that is only part of the solution. The preponderance of old vehicles with inefficient engines is equally responsible for emissions which is why the automobile legislation should focus on effective motor vehicle testing regime and a plan to phase out old/polluting vehicles. This can be done through incentivizing car manufacturers and banks in aiding citizens to finance new vehicles in place of their older vehicles.

Additionally, there should be a focus on public transport legislation whereby incentives are provided to citizens and organizations to take up public over private transport. To this end, the focus of the government should be large private companies and major emitters to shift all their employees to public transport.

The electric vehicle policy introduced in 2019 shows the government’s strategy for overhauling transport in the country in the coming years. However, this will only be successful when recharging stations become ubiquitous across the country, which is why oil marketing companies will also need to start incorporating electric vehicle charging ports at their fuel stations all over Pakistan.

Urban Policy and Design

The air quality crisis also needs to be viewed in the larger context of urban planning and land-use. There is a need to influence policy/decision making to consider environmental factors as part of the planning process. Pakistan requires a very solid, integrated green and sustainable urbanisation plan for the country which can then be filtered down to the provinces. It continues to allow cities to grow and central business districts develop without proper zoning strategies and without keeping in mind the ecological footprint of such development. Zoning regulations should clearly separate industrial areas from residential areas; business centers should be moved into SEZs.

The automobile policy is closely tied in with urban policy and currently, planning is personal transport/car-centric with no regard for environmental consequences. Promotion of public transportation, facilitating non-motorized transport, and imposing land use related costs for use of personal transport have to be factored into urban planning.

It is evident that tackling the smog and air quality crisis requires a holistic approach which combines effective legislation and stringent implementation protocols. At the same time there needs to be a realization on part of the government that the make-shift policy measures to tackle emergency situations is a regressive way of governance and that it ought to invest in strengthening its response system via a strong local body set up.

Sheheryar Khan is a Communications Assistant at the Consortium for Development Policy Research

This article is based on the discussion from a workshop organized by CDPR on Lahore’s air quality and the IGC report “Charting Pakistan’s Air Quality Policy Landscape”.