Ban! Ban! Ban! Diesel Vehicle Ban. Construction Ban. What is next?
Five years of working in the Ministry and another 17 years in the Railways has exposed me to the decision making process in the government and the perennial question as to why our bureaucracy is fondly termed as babudom. With my little but incisive experience in the working of ministry I have seen, quiet often, important policy decisions being taken on the basis of “I think” and “I feel” conjecture, eventually culminating to formulations of new government policies impacting the nation.
I am not here to either criticise or generalise the system of taking decisions or to comment on quality of decisions but just want to highlight how the decisions need objectivity and a well-defined process based on rational approach.
A false sense of “wisdom” dominates the minds of those in high positions of power. Thus, subjectivity in decision making creeps in instead of rational approach.
Though the National Green Tribunal (NGT) is not a part of the government, yet the culture and ethos of working in the position of power – administrative or otherwise – looks no different!
A sense of objectivity appears to be missing even in this decision of banning diesel vehicles of more than 10 years of age in Delhi. I would not focus on the overall economic angle though I am a firm believer any decision impacting the general public shall essentially be backed up with economic analysis and impact.
To illustrate, let us take the Respirable Suspended Particulate Matter (RSPM or PM10) in the capital’s air at 316 µg/m3 (micrograms per cubic meter), which is way above the permissible limit of 40 µg/m3.
Therefore, the objective way of decision should be that with this ban there would likely be a reduction of, say, 30 per cent in RSPM, so that the target and expected achievement is predefined.
Further, the decision to ban vehicles over 10 years old defies the logic. Why not 11 years, or why not 15 years or anything in between? Additionally, whether the tribunal has consulted the manufacturers that ageing beyond 10 years makes the vehicle unable to remain within the prescribed standards of pollutants is another question.
Objectively, to arrive at the age of ban the process could have been to ban vehicles more than 15 years for a month (or any defined time period), and monitor vigorously and carefully the reduction in level of pollution. Based on this a ban for 10 years could have been imposed.
This data needs to be studied and analysed in terms of the pollutants, diesel vehicles are prone to create. This way it would meet an objective criteria for ageing decision. And who knows after this exercise we arrive at the conclusion that the exclusion of diesel vehicle had a negligible impact on environment.
Simultaneously, a random sample of say 1000 diesel vehicles should be examined in detail on daily basis for say 30 days. The data of their exhaust based on the type, make and year of make needs to be analysed. These two studies and similar such other model of studies would enable not only NGT but also the administrative authorities to make a decision which is well informed.
Such data may also throw other solutions to the same problem, say, for example a device to control, an essential Road Worthy Certificate to be updated each year by few accredited centres etc. Such rational methodologies could be a guiding factor based on the cost analysis for such decisions.
A large sample of data and analysis thereof would throw not only solutions but be a potent argument for any authorities who would pass the ‘Public Test’ to convince masses in general and interest groups in particular.
Besides, once the cause is diagnosed, one can look at the solutions different countries have approached to the problem, which could be like that of Germany which offers an incentive to replace the vehicle or implements a heavy tax which would go in the environmental pool to be created by the government to improve environment by other means.
The idea is to create an objective approach to any decision-making process and not base it on “I think” and “I feel” approach.
Such rational approach is not only a right way for any administrative decision but also any quasi-judicial or judicial decision, and not a decision that can be termed as arbitrary. Unfortunately, we are not accustomed to taking decisions following such an approach of using sufficient statistical data analysis. But, a changed approach is the need of the hour! The writer held formerly the posts of Deputy Secretary of Mines, Director in Ministry of Fertiliser and Chief Engineer in Indian Railways.