The Provincial Disaster Management Authority (PDMA) has banned a list of activities that contribute to the deteriorating Air Quality Index (AQI) for Punjab, and especially Lahore. This ban was issued on the 15th of October, which is considered the beginning of the ‘smog season’.

A notification issued by the PDMA states that AQI for Lahore and the rest of the province has been deteriorating from ‘satisfactory’ to ‘moderately and poorly polluted,’ causing difficulties in breathing, respiratory tract diseases, and heart-related ailments, especially for children and older adults. Coupled with the COVID-19 threat, poor air quality could exacerbate Punjab’s mortality rate.

It is important to assess how effective PDMA’s ban on economic activities will be in improving Punjab’s air quality. With lack of regulatory capacity and ‘weak’ institutional support to monitor air quality and enforce these bans, the government might run the risk of proposing more than it can handle.

Dawar Hameed Butt, a public policy specialist who is passionate about climate change resilience in Pakistan, explains that PDMA (and EPD before it) lacks capacity to implement these bans. Moreover, the government has conducted no scientific studies to provide evidence for these bans.

From a regulatory standpoint, Dawar adds that “the Punjab Environment Quality Standards (PEQS) for Ambient Air exist and are fairly clear that PM2.5 levels exceeding 35 ug/m3 on average during a 24-hour period are detrimental to the populace’ health. This is the first baseline recommended by WHO as well. Unfortunately, EPD has been under-reporting emissions along with creating its own Air Quality Index (AQI) classification, which thereby allow it to show that there is no significant threat”.

Pakistan has been declared the 2nd most polluted country in the world. Air Quality Index (AQI) for Lahore shows that the air quality has been ‘unhealthy’ every day for the past month.

According to the PDMA notice, a ban was imposed on the following activities:

• Burning of any type of crop residue
• Vehicles emitting visible smoke and pollutants falling into inadmissible limits
• All industries working without emission control system and contributing to a deterioration in Air Quality Index
• All stone crushers operating without wet scrubbers
• Burning of all types of solid waste, tires, rubber, and plastics
• Sale and use of all types of substandard fuels
• All types of encroachments, which cause hindrance in the smooth flow of traffic on public roads including footpaths
• Any kind of parking which may cause hindrance in the smooth flow of traffic
• All types of activities without proper safeguard, which contribute in generating fugitive dust
• Uncovered and open dumping/storage of construction material
• Uncovered transportation of construction and other material like sand, mud, and cement
• Any unauthorized activity which may contribute to formation of smog
• For brick kilns: (i) All brick kilns built on old methodology shall not be allowed to operate from the 7th of November, 2020 to the 31st of December, 2020; (ii) All brick kilns built on zigzag methodology shall be allowed to operate as per SOPs devised by the Environment Protection Department, Punjab; (iii) All brick kilns have to be converted to the zigzag methodology by the 31st of December, 2020; (iv) No brick kiln built on methodology other than zigzag methodology will be allowed to operate after the 31sr of December, 2020

According to Sanval Nasim, an environmental economist and Assistant Professor of Economics at LUMS, these bans are unsustainable in the long run as they carry costly trade offs. Improving air quality requires mitigation measures, which under the current weak policy scenario will take years.

“What we need is sound targeted policy. Think about incentives and markets—cash for clunkers, zero-duty on EVs, pollution charges, congestion charges, minimum engine efficiency and fuel standards. We have the tools and evidence; we don’t translate them to policy,” he adds.

With lack of regulatory capacity and evidence-based policy making, it does no’t seem like the intention is to combat climate change, but only to engage in firefighting immediately before the full onset of the ‘smog months’.

While it is apparent that a ban on a list of economic activities is not a solution to the smog crisis, there is a growing need to create more evidence on emissions-tracking and mitigation measures to move forward in this war against climate change.