Using evidence to improve pollution regulation in India
Context
Rapid industrial growth in India has greatly improved living standards, but it has come with the cost of widespread environmental damage, including high levels of particulate matter, air pollution and contaminated water resources. Despite recent research linking the high levels of air pollution to avoidable death and disease, pollution control agencies struggle to enforce environmental regulations.
This challenge is prominent in Gujarat, home to India’s most critically polluted industrial cluster and six of its most polluted river stretches. The state government’s emphasis on economic growth and ease of doing business has spurred industrial expansion – particularly in highly polluting industries, such as petrochemicals, pharmaceuticals and textiles – that environmental regulatory capacity has not been able to match. The resulting pollution has increasingly spurred citizen outrage and activism to reduce it. As a result, Gujarat is the only state implementing a court-mandated third-party industrial pollution audit system on top of checks by the GPCB.
While the court-imposed monitoring system to audit industrial pollution was being implemented, none of the parties affected by the mandate – the pollution control board, civil society, industries or private auditors – felt it was working. Between 2009 and 2013, 3ie supported an impact evaluation to find out what would work to improve the state’s environmental audit system for monitoring and regulating industrial pollution. The evaluation, developed by researchers affiliated to Abdul Latif Jameel Poverty Action Lab in close collaboration with the GPCB, studied the effects of changes designed to improve the GPCB’s third-party audit system.
The team identified three mechanisms to improve the audit system as part of the evaluation: (1) random allocation of third-party auditors to firms; (2) predetermined payments from a central pool; and (3) on-site rechecking of a random sample of the auditors’ work.
Evidence
The study showed that the existing arrangement of industrial firms’ hiring and paying their own auditors encouraged corruption and misreporting of industrial emissions. Independent audits with predetermined payments and on-site rechecking of audit data on a random basis produced more accurate information and prompted firms to lower pollution. Compared to firms audited under the earlier system, false reports of compliance with emissions norms reduced by 80 per cent.
Evidence impacts
Type of impact: Change policies or programmes
Decision makers use findings from an evaluation or systematic review to adjust their programming to fix targeting, cash transfer amounts, training modules or other factors that inhibit the policy or programme’s ability to achieve its intended impacts.
This is one of 3ie’s seven types of evidence use. Impact types are based on what we find in the monitoring data for an evaluation or review. Due to the nature of evidence-informed decision-making and action, 3ie looks for verifiable contributions that our evidence makes, not attribution.
Read our complete evidence impact typology and verification approach here.
Close windowThe 3ie-supported impact evaluation’s recommendations prompted the GPCB leadership to formally approve modifications to the board’s environmental audit scheme in 2012. Their revised environmental audit scheme, dated January 2015, cited the findings of the 3ie-supported study. Under the new scheme, independent third-party environmental auditors would be randomly allocated to industrial plants, paid a predetermined fee and have their work rechecked by expert academic auditors.
Type of impact: Improve the culture of evidence use
When decision makers or implementers demonstrate positive attitudinal changes towards evidence use or towards information the research team provides. Examples include strengthening monitoring and evaluation systems, increasing understanding of evidence and openness to using it, integrating these systems more firmly into programming or commissioning another evaluation or review.
This is one of 3ie’s seven types of evidence use. Impact types are based on what we find in the monitoring data for an evaluation or review. Due to the nature of evidence-informed decision-making and action, 3ie looks for verifiable contributions that our evidence makes, not attribution.
Read our complete evidence impact typology and verification approach here.
Close windowIn India, discussions about the study led to a new collaboration to design and evaluate market-based instruments for measuring air pollution from industrial plants. The research team has been working with the GPCB to test continuous emissions monitoring systems and design an evaluation of an emissions trading pilot project.
Type of impact: Inform the design of other programmes
Where findings from the evaluation or review inform the design of a programme(s) other than the one(s) evaluated.
This is one of 3ie’s seven types of evidence use. Impact types are based on what we find in the monitoring data for an evaluation or review. Due to the nature of evidence-informed decision-making and action, 3ie looks for verifiable contributions that our evidence makes, not attribution.
Read our complete evidence impact typology and verification approach here.
Close windowLessons from the evaluation have influenced the National Clean Air Programme action plan, which the Ministry of Environment, Forest and Climate Change issued in 2018. It advises states on 15 measures for multisectoral action on air pollution. The programme encourages other states to adopt the modified Gujarat third-party audit scheme. The national government’s think tank, Niti Aayog, has also highlighted the modified third-party audit scheme as a best practice. More recently, Niti Aayog endorsed the audit norms that the study recommended in its Breathe India Action Plan for Combating Air Pollution.
Researchers’ engagement with the US Environmental Protection Agency about the study findings resulted in the agency’s Next Generation Compliance initiative (2015–2017), including third-party certification as a resource-efficient compliance tool for federal and regional environmental regulators. Guidance and a publicly available compendium of examples from the initiative cite the 3ie-funded study in illustrating how to establish effective independent verification.
Suggested citation
International Initiative for Impact Evaluation (3ie), 2019. Using evidence to improve pollution regulation in India (online summary), Evidence Impact Summaries. New Delhi:3ie.
Related
Strengthening third-party audits to reduce pollution
Abdul Latif Jameel Poverty Action Lab’s case study of how research has informed decision-making in Gujarat
Evidence impact summaries aim to demonstrate and encourage the use of evidence to inform programming and policymaking. These reflect the information available to 3ie at the time of posting. Since several factors influence policymaking, the summaries highlight contributions of evidence rather than endorsing a policy or decision or claiming that it can be attributed solely to evidence. If you have any suggestions or updates to improve this summary, please write to influence@3ieimpact.org