The driving policy

The Mashelkar Committee Report on Auto Fuel Policy is seen as contradicting the Supreme Court directives on vehicular emission norms and fuel specifications.

THOSE who have uncritically welcomed and those who have rubbished, the Mashelkar Committee Report on Auto Fuel Policy, which was released in January, have both shown undue haste and enthusiasm. The government at the Centre and the Delhi government belong to the former category and extremist environmental activists belong to the latter. Given that the report will eventually form the basis for a national policy and that it is only an interim report, there should have been sufficient public debate on it before the Cabinet gave its approval.

The Mashelkar Committee was constituted on September 13, 2001, following the Prime Minister's August 30, 2001, decision to recommend an Auto Fuel Policy for the four major cities and the rest of the country, to devise a road map for the implementation of the policy and recommend suitable automobile fuels and technologies and fiscal measures to ensure minimisation of the social cost of meeting environmental quality. If such an exercise had been undertaken before the July 1998 directives of the Supreme Court (see box) with regard to Delhi public transport, the national capital would not have found itself in the mess that it is in today. Enviro-judicial activism, rather than the rational approach of technical evaluation of the technology over a period, was the driving force behind the Supreme Court's order for the introduction of Compressed Natural Gas (CNG), in particular the conversion of the entire fleet of Delhi's diesel-driven buses to CNG mode.

Indeed, the court would have done better in directing the government to lay down strict vehicular emission norms and to evolve policy instruments as well as prescribe technology options to meet the same. In order to prescribe a single-fuel/technology option, that too an evolving one that has had mixed experiences around the world, without a feasibility study in the Indian context, defies logic. The Bhure Lal Committee, which the court had appointed to go into the auto fuel option for Delhi, and whose report was the basis for its directives, lacked the technical expertise to go into a detailed techno-economic exercise which its mandate actually called for.

The Mashelkar Committee's mistake seems to have been that it has tried to be rational in its approach. In a recommendation that makes eminent sense, it has advocated that the government lay down only the emission norms, and the corresponding fuel specifications, without specifying the vehicle technology and the type of fuel. This is a significant departure from the prescriptive directives of the court for Delhi. This would help evolve a flexible national policy that allows a multi-fuel and multi-technology option to meet the prescribed emission norms, the Report has said.

The world over, only vehicular emission norms and the fuel quality necessary to meet those are prescribed. The choice of technology to meet those standards is left to the manufacturers, owners and operators of vehicles. "Locking in to a single technology can result in problems in the long term," points out Dinesh Mohan, Professor at the Centre for Biomedical Engineering and Coordinator of Transportation Research and Injury Prevention Programme (TRIPP) at the Indian Institute of Technology (IIT), Delhi.

He says: "First, it precludes innovation and future research for improvement. Also, it prevents a changeover when better products become available. You cannot change the whole fleet at one go just as the Delhi government is finding it difficult to make a complete switch to CNG. On the other hand, when emission standards are specified, then research and development efforts of manufacturers will aim at providing the most cost-effective solution for the same performance. It makes sense to have a multiplicity of technologies operating at the same time and meeting emission standards so that some of them will continuously be replaced by newer and better ones."

As regards the emission norms, and the corresponding fuel specifications, the committee has recommended the following road map: 1. Bharat Stage-II (BS-II) norms (equivalent to Euro-II norms), currently in force in Delhi, Mumbai, Kolkata and Chennai, should be introduced in Bangalore, Hyderabad and Ahmedabad not later than end-2003. 2. BS-II norms should be in force in the entire country from April 1, 2005. 3. Euro-III equivalent norms for all categories of vehicles (except two-and three-wheelers) should be introduced in the seven metropolitan cities by April 1, 2005. 4. Euro-III equivalent norms for all categories of vehicles (except for two- and three-wheelers) should be extended to the entire country by 2010. The necessity and feasibility of advancing this date should be reviewed on the basis of the experience with BS-II. 5. To meet BS-II and Euro-III equivalent emission norms, matching quality of fuel should be made available concurrently.

To put matters in national perspective, it should be noted that the emission fuel quality norms for the country as a whole is BS-I (equivalent to Euro-I), in force since April 1, 2000, except for the four metropolises where BS-II is in force. The reason for this is the availability of fuel of appropriate quality in different parts of the country. This forms the predominant basis for the road map as well. (As regards two- and three-wheelers, although Euro norms are not applicable, Indian norms are stated to be far more stringent.)

The criticism against the report has been largely from a metro-centric, indeed Delhi-centric, perspective. The Mashelkar Report has, in all, made 20 recommendations. But the criticisms are mainly against those regarding emission norms and fuel specifications.

The Centre for Science and Environment (CSE), whose former Director Anil Agarwal, was a member of the Bhure Lal Committee, said: "The Report... has played into the hands of the polluters... It is so weak and uncaring about public health objectives that it virtually denies millions of urban Indians the right to clean air."

The report rejects the basic premise of a "clean fuel" - in the absolute sense - a phrase that has got tagged to CNG and other alternative auto fuels aimed at replacing petrol and diesel to curb automotive pollution. This too makes sense because, as the report notes, "it is the tail-pipe emissions, and not fuel per se, that affect the ambient air quality." The emissions, in turn, depend upon the efficiency of fuel combustion. Vehicular emissions, therefore, are a function of the type of fuel, its quality, vehicle or engine technology, vehicle maintenance, driving cycle (which in turn depends on vehicle technology, the state of roads and traffic management among other things.)

The criticism against the first, namely the multi-technology option, stems from the fact that the report does not unequivocally advocate the introduction of CNG as the single auto fuel mode as had been done by the Supreme Court in its July 1998 directives. CNG is a gaseous mixture of hydrocarbons (HC), consisting of 80 to 90 per cent of methane, with ethane, propane and butane making up the rest. The high methane content automatically gives a CNG engine a high octane rating (of about 120 units). Relatively speaking, CNG, being a gas, should be a "cleaner fuel" as compared to petrol or diesel simply because combustion of gas is much more efficient than that of a liquid fuel and so, in principle, emissions by a CNG-driven engine would be far less than those by petrol or diesel-driven engine.

The report is being seen as contradicting the court order by legitimising the present state of affairs and allowing the Delhi government merely to retain the BS-II norms. "It is a farce even to talk about letting emission standards govern when we do not have a legally enforceable system to ensure compliance," the CSE statement said. "The problem of enforcement is the same in prescribing a single technology," points out Ranjan Bose of the Tata Energy Research Institute (TERI), New Delhi. "How do we ensure that the CNG engines, particularly the retrofit ones, meet the specifications and the emission norms? A whole range of problems have come up in the use of CNG vehicles in Delhi. For instance, tail-pipe emissions show that there is a good deal of oil admixture in CNG."

Although the court did not specify CNG for taxis and autorickshaws, the price differential between CNG (Rs.12.20 a kg) and petrol (Rs.28.75 a litre) was attractive enough for these modes too to switch to CNG even though, in principle, they could have chosen BS-II vehicles and fuel because these were in force as of April 1, 2000. Moreover, financial incentives by way of low interest loans from the Delhi Finance Corporation (DFC) for old taxis and autorickshaws also facilitated their switch to CNG. This would also explain why taxis, which could have been based on BS-II rating diesel (with a sulphur content of 500 ppm or 0.05 per cent) norms, are not seen on Delhi roads although the prices of diesel and CNG are competitive.

Interestingly, in March 2001, when the debate involving ultra low sulphur diesel (ULSD), with 50 ppm or 0.005 per cent sulphur content, and CNG was raging, the Bhure Lal Committee, on being asked by the court to examine the issue, concluded that CNG is cleaner than diesel no matter what the sulphur content. The committee came to this conclusion essentially on the grounds of suspended particulate matter (SPM - which are particles of less than 10 micrometre in diametre) pollution, which is expected to be negligible in the CNG-run vehicle. SPM pollution, particularly respiratory SPM or RSPM is considered to be carcinogenic when associated with the emitted polyaromatic hydrocarbons (PAH) whose levels in diesel are high. BS-I or BS-II norms do not specify limits on PAH in diesel. A high fraction of RSPM is in the form of particles of sulphate, which are less than 2.5 micrometre in diametre, and that is why reduction in sulphur content is critical for diesel.

However, recent vehicle dynamometer tests (that use simulated actual city driving cycles) with London and New York buses have demonstrated that pollution from ULSD, coupled with advanced technology after treatment devices like particulate traps and continuously regenerating diesel particulate filter (CRDPF), is less than CNG. At very low sulphur content as in ULSD, the particulate matter chiefly consists of soot, which is nothing but unburnt hydrocarbons. CRDPF burns the soot using the nitrogen dioxide (NO2) that is emitted. TERI, which has been arguing in favour of ULSD, is to begin trials shortly on ULSD+CRDPF using seven buses in Mumbai in collaboration with BEST (Bombay Electric Supply and Transportation Undertaking).

Indeed, the black smoke visible in diesel exhausts is essentially owing to soot and it is as regards this "visible pollution" that CNG intrinsically performs better than diesel. As regards "invisible pollution" - among the "regulated pollutants", carbon monoxide (CO), gaseous hydrocarbons and nitrogen oxides (NOx) contribute to this - data of the Central Pollution Control Board (CPCB) from actual driving conditions in Delhi show that even BS-I diesel buses perform better than vehicles using CNG with respect to CO and HC (CNG produces a lot of methane, a greenhouse gas with much greater warming potential than carbondioxide) while the NOx emissions are higher. Naturally, the emissions of CO and HC of BS-II and BS-III diesel engines would be even less. Besides, there are emissions of "unregulated pollutants" such as the highly toxic formaldehyde whose emissions in vehicles using CNG-run vehicles are higher. With rapid advances in technology, diesel appears poised to overtake CNG (as well as other alternative fuels) as a "cleaner fuel". From this perspective too it does not make economic or business sense to get be bound to a specific technology.

Further, it is yet to be demonstrated that conversion to CNG has resulted in overall reduction in pollution, especially given its higher levels of CO and HC emissions. One of the biggest gaps in environmental monitoring in metros like Delhi is the lack of reliable data on apportionment of pollution to the various sources. There is a range of figures that are quoted, from 65 per cent to 92 per cent. The point that the Mashelkar Report makes is that as long as such appointment is not done, it is not possible to set vehicular emission norms based on air quality targets alone, as is being demanded by environmental groups.

If there is evidence for reduction in SPM in Delhi, it still does not prove that it is owing to CNG because SPM comes from a variety of sources like coal or oil-fired power plants, brick kilns, factories, captive power generation units particularly diesel-powered ones in industrial units (there are thousands of such in Delhi) and extensive use of fossil fuel and biomass. Various other pollution reduction measures that have been put in place would have contributed to this - notably the shifting of polluting industrial units away from the city in December 2000 as well as the introduction of BS-II norms and the phasing out of vehicles older than 15 years.

IN an interesting study, Dinesh Mohan and colleagues at IIT-Delhi have shown that all the gains made by the change over of the entire fleet of buses to CNG-mode would be nullified if just 10 to 15 per cent of bus passengers shift to cars or two-wheelers. This scenario is certainly conceivable. Given the present cost of operating CNG-driven vehicles, which is much more than in the case of diesel-driven buses, the per-km tariff in a CNG bus is about 75 paise. This being roughly the same as the cost of running a two-wheeler, any increase in bus fares could result in a modal shift to two-wheelers. Already school and chartered buses have hiked their fares by 70 to 100 per cent. Given the current unmet demand of natural gas for its various end-uses in the power industry, the fertilizer industry and in the cooking gas and transport sectors in Mumbai and Delhi, import of liquefied natural gas (LNG) seems imminent. This would result in the cost of CNG shooting up. Moreover, after the dismantling of the administrative price mechanism (APM) in April, the price cannot be held low artificially and the cost of running vehicles on CNG is bound to go up.

Before prescribing CNG as the fuel for the entire country, it is prudent to look at Delhi's experience in introducing CNG (see box). Besides, the Mashelkar Report has said that, according to the Ministry of Petroleum and Natural Gas (MoPNG), at present the demand for natural gas outstrips supply and the requirements of a mandated switch-over to gaseous fuel can only be met through imports. Some people would argue that natural gas should be imported if need be and that is the price to be paid for clean air and good health. The report has also pointed out that such a single fuel mode policy will reduce the consumption of petrol and diesel. This may, it says, lead to the underutilisation of installed integrated refining and processing facilities resulting in the shortage of other petroleum products also.

The report has also made some pertinent observations with regard to CNG technology. Basically three kinds of CNG technologies are available. The first comprises bi-fuel retrofit engines available for cars and three-wheelers that can run both on petrol and CNG; the second, diesel/CNG retrofit engines where the compression ignition mode is changed to spark ignition mode; and, third, dedicated CNG engines. It points out that bi-fuel capability is an undesirable feature as the engine can only be optimised for one specified fuel. Also, free use of multiple fuels with different emission characteristics may even defeat the aim of meeting emission norms. The conversion of diesel engines requires major modifications, and technologically this is not the best option.

Newly designed and developed CNG engines, used with specially designed chassis, is the best option which, however, would mean higher capital costs to the extent of three to four times compared to retrofit kits. Moreover, experience in New Zealand, which introduced CNG vehicles way back in the 1980s, suggests that the performance of CNG engines deteriorates quickly.

GIVEN the above facts, a long-term study in real Indian driving conditions should have been conducted before the court directed conversion to CNG. Unfortunately, there is no institutional framework to carry out such studies involving diverse fuels and vehicle technologies. As a result, ad hocism - driven more by emotion than reason - often guides policy decisions. Specifying emission norms alone allows for such an institutional framework to evolve so that appropriate choices are made as new technologies and fuels evolve to maturity.

Experience worldwide suggests that CNG is far from being there. As regards the road map for emission norms, the criticism is that it is weaker than the recommendations of the Inter-Ministerial Task Force (IMTF) on fuel quality and vehicular emissions, which was headed by Dilip Biswas, CPCB Chairman, and the Road Map of the Society of Indian Automobile Manufacturers (SIAM). The former submitted its report in March 2001 and the latter's study was presented in March 2000. The Mashelkar Committee, according to the report, took these into consideration in arriving at its final recommendations.

The first part of the criticism is, however, not quite correct. The road map recommended by the IMTF is identical to the Mashelkar Road Map. In fact, the IMTF had said that BS-II may be implemented in a phased manner in the seven metros by 2003-04. The SIAM Road Map was, however, not realistic, says Mashelkar. SIAM had said that the Indian industry would be able to switch Euro-III equivalent vehicle norms by April 1, 2004. It will also be able to meet Euro-IV standards by 2007, it had said. "This," the SIAM report said, "will reduce the gap between European and Indian norms from 13 years in 1991 to one year for passenger cars and two years for multi-utility vehicles and commercial vehicles." However, according to Mashelkar, the Ministry of Industry had told SIAM that its proposal was unworkable. In any case, nothing has happened since March 2000 in terms of acquisition or development of corresponding technologies.

SIAM sources, however, say that their road map was always subject to the availability of appropriate fuel. "There is no business sense in sinking money unless one clearly knows the policy directions. The oil industry has promised only BS-II fuel throughout the country by 2003," they say. It is the projection for the industry to be able to produce the right quality fuels that has formed the basis of the Mashelkar road map as well. "The oil industry and the automobile industry are crucial to the country's economy and any change in their working will affect the public and the economy," the report notes.

According to the report, the investment required to upgrade refineries to produce BS-II petrol and diesel is estimated to be around Rs.17,000 crores. An additional Rs.18,000 crores would be required to produce Euro-III equivalent fuels. These numbers have been arrived at on the basis of detailed calculations by a sub-committee on auto fuel quality. There are significant inter-refinery differences and not all refineries are in a position to produce 500 ppm sulphur fuel, says Mashelkar. While some refineries may find it less costly to shift from BS-I to BS-II fuel, others, particularly of those in the northeastern region, may find the change-over costly and may end up being uncompetitive, the report points out. And, the upgradation could take up to three years.

Likewise, the automobile industry, according to SIAM, may need requires to invest an estimated Rs.25,000 crores. In fact, estimates for Euro-III compliant vehicles are not even clear as technologies are yet to be frozen, the Mashelkar Report says. Also, an estimated Rs.1,040 crores would be required to set up additional testing facilities as per new norms because the existing two centres would not be able to cope with the number. This cost is apart from the cost of setting up Inspection and Maintenance (I&M) and certification centres.

Given the above estimates, it is the perspective of minimising the social costs that essentially dictated the road map, says Mashelkar. There is criticism on the count that the committee has recommended achieving Euro-IV norms only by 2010 when it was definitely possible to leap-frog from Euro-II by 2005. Besides, the fact that Europe is still in the process of firming up Euro-IV norms, based on considerations of cost-effectiveness as well as implementability of this fast track approach, the committee has recommended "analysis of investment and distribution logistics issues for reducing sulphur content in both petrol and diesel from 150 ppm and 350 ppm respectively to 50 ppm (max). This is a kind of half-way house which is easily adoptable because Euro-II engines can run on Euro-IV fuels. Only by resorting to imports could Euro-IV equivalent norms have been advanced, say by five years, at least in the four major cities.

However, the committee appears to have given undue importance to the projections of the industry. From experience with regard to Euro II, it would seem that the industry, if pushed, can really meet the demands, at least on a limited scale. Although there is no quantitative estimate of health costs saved (which is likely to be marginal) by moving from Euro-II/Euro-III to Euro-IV, the committee could have been bolder in making the timetable somewhat shorter.