Clean Air needs Systemic Capacity, not just Resources
India has already taken important steps in recognising urban air pollution as a systemic challenge and aligning resources towards it. The next step is to ensure that cities are not only funded to act but are also institutionally empowered.
Since 2019, Indian cities have become an integral part of the air quality management strategy in the country. The National Clean Air Programme (NCAP) and the Fifteenth Finance Commission (FC) brought policy attention, performance-linked funding, and a new expectation: that urban local governments (ULGs) would lead the fight against pollution.
This shift has undoubtedly spurred action and created momentum, but as with all programmes, it has also revealed where the next set of challenges lie. The capacity gap in cities. With increase in funding toward air quality management, so did the monitoring infrastructure and the reporting apparatus. But the city governments lacked institutional capacity to turn all of this into sustained
outcomes, more so given that air quality has not been their traditional domain.
The question, therefore, is no longer only about what is being done, but whether the ULGs are equipped to do it. In most ULGs, air quality is managed as an additional charge and is assigned
to an engineer or staff member already carrying other responsibilities. There are no dedicated teams, no defined mandates, no clear authority to hold other departments accountable (especially when action is required outside of the city governments) or influence how and where money gets spent.
To address this gap, the Central Pollution Control Board (CPCB) appointed 74 consultants on contract across ULGs and State Pollution Control Boards (SPCB) in 2024 to support air quality management. The appointment ensured that all million-plus cities under the 15th FC million-plus challenge grant were covered, either through a consultant posted directly at the ULGs
or through placement at the SPCB in that city. Of the 74, around 28 were appointed in other NCAP non-attainment cities, with placements split between ULGs and SPCBs.
They were appointed with domain expertise to strengthen city-level planning, coordination, and implementation. We examine why this effort could not add up to bring the change it promised.
Providing resources is not building institutional capacity These consultants were initially placed on one-year contracts, that got extended for another year, and when that lapsed last month (March 2026), they got a fresh six-month extension. The first extension itself was delayed and many consultants worked for months without salary disbursement, and such incremental extensions do not inspire stability.
Consultant positions being advisory, lacked decision-making authority, so despite expertise they were often limited to functions such as air quality data management and reporting. In several cities, they were made to support solid waste management and other routine ULGs tasks. In one city, the consultant assigned to the city was required to split their time weekly between the ULGs and the SPCB in another city, to fill the vacant position at SPCB.
While these consultants were located in the ULGs, they were not integrated into municipal structures or accountability frameworks. As a result, there was limited ownership at the city government level over how this capacity was utilised. Without clearly defined roles or institutional anchoring, their work was often shaped by immediate administrative needs; with limited influence on long-term air quality objectives.
Providing skilled individuals is not the same as building institutional capacity. Institutional capacity is reflected not just in the presence of expertise, but in the ability of systems to use it to inform decisions and sustain implementation. This gap has shaped how cities have hitherto responded to available funding.
Funding has enabled cities to undertake a range of interventions. The process also stipulated due steps like source apportionment studies and clean air action plans. However, the choice of final actions by cities has often leaned towards those that are administratively feasible and within direct municipal control, such as road and pavement work, mechanised sweeping, dust suppression, and machine procurement, and chosen basis existing priorities and ease.
Improvements in air quality therefore has been uneven across cities, and higher levels of fund utilisation have not consistently translated into better outcomes. This is not a reflection of effort, but of the conditions under which cities are operating. When institutional capacity is limited, cities tend to prioritise actions that can be delivered within existing systems.
More complex interventions, requiring inter-departmental coordination, technical planning, and sustained engagement, remain harder to design and implement. Efforts without strengthening institutional capacity can’t be sustained. They fade away. Funding can support actions, but outcomes sustain only when systems are in place.
Recommendations
Moving forward, strengthening institutional capacity must become central to how cities approach air quality management. This requires building systems that can sustain actions over time. We suggest a three-pronged strategy:
Cities need dedicated Clean Air Cells to serve as the institutional backbone for proactive air quality governance within ULGs. For this, there should be recruitment of full-time technical experts, including environmental engineers, data managers, and urban planners, dedicated exclusively to air quality management. These roles should not be treated as additional responsibilities, but as core functions within the ULGs.
The Cell should also comprise representatives from key line departments and independent experts, and should have its own mandate, its own budget, and the authority to coordinate
between line departments and shape how resources are allocated.
Urban Air Quality should have ULGs at the centre, where the elected government and officials are able to coordinate necessary actions from all other departments concerned for concerted actions as per plans.
Performance indicators need to evolve to reflect how cities are building and using institutional capacity, not just outcomes and fund utilisation. This includes indicators such as whether trained staff are being retained, whether emission inventories are informing action plans and whether coordination mechanisms across departments are functional.
India has already taken important steps in recognising urban air pollution as a systemic challenge and aligning resources towards it. The next step is to ensure that cities are not only funded to act but are also institutionally empowered.
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