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GS Paper IIIEnvironmental Ecology

CAQM Invokes Stage-II of Graded Response Action Plan (GRAP) in Entire NCR

LearnPro Editorial
22 Oct 2025
Updated 3 Mar 2026
8 min read
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CAQM Invokes Stage-II Measures Under GRAP Amid Delhi’s “Very Poor” AQI Levels

On October 22, 2025, the Commission for Air Quality Management (CAQM) invoked Stage-II of the Graded Response Action Plan (GRAP) across the entire National Capital Region (NCR) after Delhi's Air Quality Index (AQI) breached the threshold of 301, falling into the “Very Poor” category. Under this stage, measures include bans on coal and firewood burning, restrictions on diesel generators, and enhanced vigilance on dust control mechanisms. This decision precedes the annual post-monsoon spiral into toxic air, marking yet another ominous winter for over 30 million residents.

Why This Invocation Signals A Policy Cul-de-sac

For the past decade, NCR residents have been subjected to a now-predictable cycle of winter air pollution reactivating emergency frameworks like GRAP. However, what makes this invocation noteworthy is its blunt admission: the problem persists despite structurally ambitious measures introduced since the CAQM Act, 2021. The Commission’s invocation of Stage-II suggests diminishing returns from earlier action taken under Stage-I (AQI 201–300), which includes modest reductions in vehicular traffic and curbs on public construction dust. Reassuring headlines obscure the blunt truth: these incremental measures in isolation can neither overcome systemic governance deficits nor alter entrenched pollution sources.

Ironically, GRAP itself amplifies the central contradiction. Designed as a short-term emergency response, it now functions as a crutch that deflects accountability from long-term air quality reforms. For example, the recurring reliance on bans (diesel generators, construction dust) creates enforcement bottlenecks that go unattended year after year. Meanwhile, interventions needed to tackle deeper infrastructural failures — public transport expansion, crop-residue fuel alternatives, and high-penetration AQI monitoring — remain piecemeal.

The Machinery: A Complicated Commission and Its Jurisdiction

The CAQM was established under the Commission for Air Quality Management in NCR and Adjoining Areas Act, 2021, replacing its skeletal predecessor: the Environment Pollution (Prevention & Control) Authority (EPCA). Unlike EPCA, CAQM enjoys broader jurisdiction spanning Delhi, Haryana, Punjab, Rajasthan, and Uttar Pradesh. While this theoretically enables regionally coordinated action, its implementation capacity is constrained by overlapping mandates with state pollution control boards, municipal bodies, and transport authorities.

Section 7 of the CAQM Act empowers the commission to issue directions to these entities, but enforcement gaps persist. For instance, complaints about non-functional ambient air monitors across Haryana and overcrowded vehicular inspection centers in Delhi have gone unanswered. Such weaknesses in state-level machinery stunt regional compliance. Beyond jurisdictional complexity, Stage-II restricts diesel gensets used by industries without offering viable alternatives, raising concerns about economic disruption.

Moreover, GRAP’s structure itself raises critical questions. The plan’s reliance on AQI thresholds means implementation often operates with bureaucratic inertia. Satellites and on-ground monitors frequently report delays between AQI breaches and corresponding GRAP action. This procedural inefficiency reflects operational sluggishness rather than proactive governance.

What the Data Really Shows

Despite the invocation of Stage-II, the data illustrates glaring gaps between regulatory intent and pollution realities:

  • Delhi’s average AQI during the last three Octobers was above 310, which is “Very Poor”. Yet, less than 65% of mandated air-cleaning mechanisms were operational per the Central Pollution Control Board (CPCB).
  • Stubble burning remains a critical seasonal contributor, with Punjab recording over 55,000 fire events in October 2024 alone (up from 48,600 in 2023). Any punitive measures on this front have largely failed or proved nominal.
  • The NCR added 2.1 million vehicles in the last two years, with diesel vehicles comprising 39% of this total, aggravating vehicular pollution despite GRAP restrictions.

These numbers underline an uncomfortable contradiction: while CAQM’s measures intensify annually, structural outputs (air quality improvement, regional emissions cuts) remain static. This suggests a coordination deficit at both inter-state and inter-agency levels.

The Unasked Questions: Is GRAP Designed to Fail?

The real critique of GRAP’s invocation lies in its reactive architecture. By design, GRAP responds to AQI levels rather than forecasting emission spikes and deploying preventive measures. This short-term approach cripples its efficacy — instead of mitigating pollution pre-emptively, it becomes a retroactive patchwork of restrictions. Why hasn’t Delhi implemented year-round deterrents targeting primary polluters — whether construction firms, crop management in agrarian states, or diesel logistics operators?

Equally troubling is GRAP’s disproportionate focus on urban interventions at the expense of regional coordination. Punjab's farm residue burning remains untouched by broader GRAP authority, leaving rural emissions to state mechanisms that lack cohesive direction. Meanwhile, local bodies within the NCR allege insufficient financial backing: after GRAP’s implementation in 2024, construction companies failed dust containment directives citing unavailability of government incentives.

Lastly, can GRAP succeed without tackling economic intersections? Restrictions on firms using coal and diesel generators risk shutdowns that ripple through supply chains, particularly SMEs. Without corresponding fiscal cushioning or incentivization, these regulatory moves are at best disruptive or at worst counterproductive.

Lessons From South Korea’s Year-Round Monitoring Model

South Korea’s approach to air pollution offers a stark contrast. Facing PM2.5 levels of 40 μg/m³ in Seoul during 2018–2019, the government implemented a year-round comprehensive plan targeting vehicle emissions and industrial participants. Unlike GRAP’s stage-wise setup, South Korea deployed continuous monitoring stations across urban peripheries, coupled with subsidies for electric vehicle adoption. The result? PM2.5 levels dropped by nearly 25% within three years.

India, by comparison, suffers from fragmented enforcement. While 80 AQI monitoring stations exist in Delhi alone, their operational uptime remains inconsistent. South Korea’s success underscores the importance not only of budget allocation but also reliable instrumentation and coordinated urban-rural implementation.

✍ Mains Practice Question
Prelims MCQs: Question 1: Which stage of the Graded Response Action Plan (GRAP) corresponds to AQI levels of 301–400? A: Stage II B: Stage III C: Stage IV D: Stage I Correct Answer: A Question 2: The CAQM was constituted under which of the following Acts? A: Environment Protection Act, 1986 B: Air (Prevention and Control of Pollution) Act, 1981 C: The Commission for Air Quality Management in NCR and Adjoining Areas Act, 2021 D: Water (Prevention and Control of Pollution) Act, 1974 Correct Answer: C
250 Words15 Marks
✍ Mains Practice Question
Critically evaluate whether the Graded Response Action Plan (GRAP) addresses the structural causes of air pollution in Delhi-NCR or merely functions as a reactive emergency measure.
250 Words15 Marks

Practice Questions for UPSC

Prelims Practice Questions

📝 Prelims Practice
Consider the following statements about the design and implementation challenges of AQI-threshold-based emergency plans like GRAP (as described in the article):
  1. Because actions are triggered after AQI thresholds are crossed, the approach tends to be reactive rather than preventive.
  2. Repeated reliance on blanket bans can create recurring enforcement bottlenecks without resolving underlying sources.
  3. A wider statutory jurisdiction by itself ensures smooth enforcement even when multiple agencies have overlapping mandates.

Which of the above statements is/are correct?

  • a1 and 2 only
  • b2 and 3 only
  • c1 and 3 only
  • d1, 2 and 3
Answer: (a)
📝 Prelims Practice
Consider the following statements about CAQM and inter-agency governance as presented in the article:
  1. CAQM replaced EPCA and was created under the Commission for Air Quality Management in NCR and Adjoining Areas Act, 2021.
  2. Section 7 of the CAQM Act empowers the commission to issue directions to state pollution control boards and other relevant entities.
  3. The article indicates that non-functional ambient air monitors and overcrowded vehicle inspection centres reflect enforcement and capacity gaps at the state level.

Which of the above statements is/are correct?

  • a1 only
  • b1 and 2 only
  • c2 and 3 only
  • d1, 2 and 3
Answer: (d)
✍ Mains Practice Question
Critically examine the effectiveness of AQI-threshold-based emergency frameworks like GRAP in addressing NCR air pollution. Analyze how CAQM’s jurisdiction, overlapping mandates, enforcement capacity, and the persistence of structural pollution sources constrain outcomes, and suggest governance-oriented reforms.
250 Words15 Marks

Frequently Asked Questions

What does invoking Stage-II of GRAP imply for day-to-day pollution control actions in NCR?

Stage-II is triggered when AQI breaches 301 (“Very Poor”), signalling that Stage-I’s incremental steps are seen as insufficient. It escalates to stricter controls like banning coal/firewood burning, restricting diesel generators, and tightening dust-control vigilance across the entire NCR.

Why does the article argue that repeated GRAP invocations reflect a policy cul-de-sac rather than progress?

GRAP is designed as an emergency response, yet its recurring use has made it a routine crutch that can deflect accountability from durable reforms. The article suggests that incremental restrictions cannot overcome systemic governance deficits and entrenched pollution sources without sustained structural measures.

How does the CAQM’s institutional design create both potential and constraints for regional air-quality governance?

CAQM, created under the 2021 Act, has wider jurisdiction across Delhi, Haryana, Punjab, Rajasthan, and Uttar Pradesh, enabling theoretically coordinated regional action. However, overlapping mandates with state pollution control boards, municipal bodies, and transport authorities create enforcement gaps despite CAQM’s power under Section 7 to issue directions.

What operational bottlenecks weaken the effectiveness of GRAP implementation according to the article?

The article flags enforcement bottlenecks from repeated reliance on bans (e.g., diesel generators and construction-related dust), which remain unresolved year after year. It also notes procedural delays between AQI breaches and GRAP action due to the threshold-driven, reactive architecture and sluggish monitoring-response cycles.

What does the article indicate about the gap between regulatory intent and pollution outcomes using the cited data points?

Despite repeated “Very Poor” October averages (above 310) and escalating measures, less than 65% of mandated air-cleaning mechanisms were operational as per CPCB, pointing to implementation deficits. Rising stubble-burning incidents (Punjab’s October 2024 fire events) and rapid vehicle additions, including a large diesel share, indicate structural drivers overwhelming short-term controls.

Source: LearnPro Editorial | Environmental Ecology | Published: 22 October 2025 | Last updated: 3 March 2026

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About LearnPro Editorial Standards

LearnPro editorial content is researched and reviewed by subject matter experts with backgrounds in civil services preparation. Our articles draw from official government sources, NCERT textbooks, standard reference materials, and reputed publications including The Hindu, Indian Express, and PIB.

Content is regularly updated to reflect the latest syllabus changes, exam patterns, and current developments. For corrections or feedback, contact us at admin@learnpro.in.

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