Introduction

Air pollution in India has transcended the realm of an environmental problem to become a profound developmental and public-health challenge. The right to life under Article 21 of the Constitution inherently includes the right to breathe clean air, and Article 48A and Article 51-A(g) place a responsibility on the state and citizens respectively for protecting the environment. Yet, many Indian cities witness sustained high levels of particulate matter, leading to reduced life-expectancy, increased morbidity, and compromised quality of life. In this context, the Graded Response Action Plan (GRAP) was formulated to provide a structured and time-bound mechanism that triggers specific measures when air-quality deteriorates beyond certain thresholds. This editorial examines the genesis, current status, legal framework, challenges and way forward for GRAP, situating it in India’s larger quest for sustainable urbanisation and ecological governance.

Background & Context

India’s approach to air-quality management initially focused on establishing ambient air quality standards, emission norms for industry and vehicles, and urban air-quality monitoring networks. However, the episodic nature of severe pollution—typified by smog events in winter, regional transport of pollutants, and rapid escalation of particulate levels—revealed that long-term norms alone were insufficient. In the National Capital Region (NCR), recurrent pollution spikes during autumn-winter exposed the need for a responsive system. Against this backdrop, the Graded Response Action Plan (GRAP) was introduced for Delhi-NCR as an operational protocol based on Air Quality Index (AQI) thresholds. The framework established multiple stages—each invoking specific sets of regulatory and mitigation measures—thus enabling authorities to act in a graded manner according to severity of pollution. Over time, the responsibility for GRAP has been placed in the hands of the Commission for Air Quality Management (CAQM) for the NCR and adjoining areas, reflecting a shift toward adaptive and crisis-governance in the air-quality domain.

Current Scenario

As of late 2025, the Delhi-NCR region continues to face acute air-quality challenges. Monitoring data show persistent episodes where the AQI exceeds the ‘Very Poor’ or even ‘Severe’ categories. For instance, on the eve of Diwali in October 2025 the AQI in several stations crossed 300, invoking Stage-II of GRAP in Delhi-NCR. Authorities responded by activating a 12-point plan under Stage-II, including suspension of construction, restrictions on diesel generator sets and vehicle curbs. The national programme for clean air—the National Clean Air Programme (NCAP)—has set a target of reducing PM concentrations by up to 40 per cent or achieving national ambient standards by 2025-26 in 131 cities. Despite efforts under NCAP and implementation of GRAP-stages, many cities show slow progress. A review indicates that out of the NCAP-designated cities, only a minority have achieved significant reduction in PM10 concentrations. The frequent invocation of GRAP in the NCR points to its dual interpretation: as a necessary emergency brake and as a symptom of underlying structural failures in managing pollution sources.

Government Policies & Legal Provisions

The GRAP framework is anchored in India’s environmental policy and legal architecture. The Air (Prevention and Control of Pollution) Act, 1981 empowers central and state pollution control boards to prescribe standards and take measures to control air-pollution. The Environment (Protection) Act, 1986 further provides broad powers to the Government to protect and improve the environment, under which regulations and notifications like GRAP can be issued. The National Clean Air Programme (NCAP), launched in January 2019, enjoins non-attainment cities (131 in number) to prepare city-specific action plans with the objective of reducing concentrations of PM2.5 and PM10 by 20-30 per cent initially and later revised to up to 40 per cent by 2025-26, relative to a 2017 baseline. GRAP sits within this ecosystem as an operational mechanism in the NCR—linking AQI thresholds to prompt actions. The activation of GRAP-Stage-II by CAQM in October 2025 for the Delhi-NCR region is a case in point of the legal-policy link translated into field implementation.

Challenges / Issues

  1. Structural versus episodic responses: GRAP is inherently designed to respond to acute condition of pollution. While that is valuable, it risks sidelining the underlying structural sources—vehicular emissions, construction dust, biomass burning—which demand long-term management rather than episodic fixes.
  2. Multi-agency coordination and enforcement: Effective implementation requires seamless cooperation between municipal bodies, state pollution control boards, transport departments and construction agencies. Fragmented jurisdiction and delayed action undermine efficacy.
  3. Meteorology and regional transport: In the NCR, local emissions are compounded by stubble burning in adjacent states and adverse weather conditions. GRAP cannot address these cross-boundary and meteorological variables directly, yet they significantly drive pollution spikes.
  4. Scalability of the model: GRAP has been tailored for the Delhi-NCR context. Replicating similar stage-based response plans in other polluted cities requires adaptation to local emission profiles, institutional capacities and meteorological patterns.
  5. Equity and livelihoods: The measures under GRAP—construction bans, vehicle restrictions, generator curbs—can affect livelihoods of daily-wage labourers, small contractors and drivers unless mitigated. Environmental regulation thus must balance health protection and socioeconomic equity.
  6. Citizen awareness and behaviour change: Many emergency measures demand public cooperation—using public transport, avoiding open burning, curtailing private vehicle use. Without sustained behaviour change, the effectiveness of GRAP remains limited to top-down mandates.

Way Forward

To ensure GRAP evolves beyond being a mere emergency stop-gap and becomes part of a sustainable air-quality governance ecosystem, the following pathways merit attention:

  1. Embed GRAP into a continuous governance framework so that responses are not merely reactive but integrated with year-round monitoring, forecasting and preventive interventions.
  2. Strengthen institutional coordination by establishing a real-time data-sharing dashboard across agencies—meteorology, transport, pollution boards, urban local bodies—so that decisions under GRAP are triggered with speed and clarity.
  3. Scale the GRAP concept to other cities under NCAP by tailoring graded action plans to local contexts—source profiles, meteorology, institutional capacity—and ensuring local ownership.
  4. Focus on structural source reduction: accelerate electric-mobility adoption, upgrade public transport, enforce construction-dust management, incentivise clean agriculture practices like residue management to reduce stubble burning.
  5. Incorporate livelihood support into action plans: when construction bans or vehicle curbs are invoked, provide alternative scheduling, compensation or social protection to affected workers so that health goals and equity go hand in hand.
  6. Promote citizen engagement and behavioural change through sustained awareness campaigns, school programs, real-time public air-quality information, and behavioural nudges to reduce private vehicle use and open burning.
  7. Establish a system of monitoring, review and adaptive learning: periodic audits of GRAP activations, outcome assessments, feedback loops and revision of stage thresholds based on experience and technology advancements.

Significance for Exams

For Prelims

  • The National Clean Air Programme (NCAP) launched in 2019 targeting up to 40 per cent reduction in PM10 by 2025-26.
  • GRAP implementation in Delhi-NCR, with Stage-II invoked in October 2025 when AQI crossed 300.
  • Legal basis: Air (Prevention and Control of Pollution) Act, 1981 and Environment (Protection) Act, 1986.
  • Defined AQI thresholds for GRAP in Delhi-NCR: e.g., Stage-I for AQI 201-300, Stage-II for AQI 301-400.
  • 131 non-attainment cities under NCAP required to prepare action plans.
  • Evidence that fine particulate pollution (PM2.5) reduces average life expectancy by over 5 years in India.
  • 12-point action plan under GRAP Stage-II in Delhi-NCR as of October 2025.

For Mains

  • GRAP as an exemplar of adaptive governance linking environmental thresholds to operational response.
  • The interplay of local emissions, regional transport (agricultural residue burning) and meteorology in urban air pollution—an integrated challenge.
  • Role of institutional architecture: CAQM, municipal agencies, pollution control boards, integrated data systems.
  • Equity dimension of environmental regulation: balancing urgent health imperatives with livelihoods and economic activity in urban-construction sectors.
  • The scalability challenge: transferring the GRAP model from Delhi-NCR to other Indian cities under NCAP.
  • Behavioural change and citizen participation as critical enablers of effective air-quality governance.

For Interview

  • GRAP shows that environmental regulation cannot be purely preventive; crisis-responsive frameworks are essential in fast-changing urban contexts.
  • While GRAP ensures prompt action, true success lies in embedding such mechanisms into structural reform of transport, industry and agriculture.
  • Citizens are not mere recipients of top-down orders; sustainable clean air requires them as active participants in reducing emissions and supporting governance.
  • The model of graded response could serve other domains of environmental policy—urban flood management, heat-wave response and disaster governance—highlighting the value of stage-based governance.

In Short

The Graded Response Action Plan has introduced a structured, threshold-based operational layer to India’s air-quality management system. Yet, for sustained improvement in clean air, the focus must shift from episodic crisis interventions to long-term structural reforms, institutional coordination, citizen behaviour change and equity-sensitive governance.