Clean Air Zones: Where Is the Institutional Architecture to Make Them Work?

(My reflections as a Panelllist at the Mumbai Climate Week)

Zone-based instruments are often presented as an elegant blend of top-down policy and local or bottom-up implementation. National frameworks set air quality standards, assign regulatory responsibilities while cities operationalize them through designated zones such as Low Emission Zones (LEZs) or Clean Air Zones (CAZs).

During Mumbai Climate Week, concepts such as Healthy Air Zones (HAZ) also appeared in discussions. The intention is laudable as here air quality management is not only around emissions but also around health outcomes. But health improvements cannot realistically be promised within short policy implementation cycles. Credible attribution of health benefits would require sustained epidemiological evidence over time, focusing on exposure to air pollution. For this reason, the practical feasibility of the HAZ concept deserves careful scrutiny.

Across several Western cities, the LEZ/CAZ models appear workable. London’s Low Emission Zone is administered by Transport for London. Birmingham and Bath operate Clean Air Zones under city councils. Milan manages congestion and emission control zones through municipal authorities.

In most of these cases, however, transport emissions are the dominant pollution source, and the institutional custodian is typically a transport authority capable of regulating vehicle entry and enforcement.

The governance challenge becomes more complex in cities where pollution sources are far more dispersed and are multi-sectoral. Construction dust, small industrial units, waste burning, bakeries and household fuels contribute significantly to urban pollution. Managing such sources requires authority across multiple domains e.g. construction regulation, MSME compliance, waste management, and use of renewable energy. Assigning such cross-sector responsibility to a single zone custodian is considerably harder than regulating or electrifying vehicles.

The deeper question is therefore not conceptual but institutional.

Who actually governs the CAZ?

One option is to treat the municipal ward itself as the zone, making the ward administration responsible for monitoring local sources such as construction activity, waste burning, and neighbourhood emissions. This could improve local oversight and citizen engagement. However, ward offices often lack authority over major emission sources such as transport fleets, industrial units, or energy use.  Besides, they have weak technical capacity.

Another option could involve appointing a dedicated program manager, possibly a combination of a research and private entity operating under a formal mandate and coordinating with the traffic department, pollution control authorities, and ward administration. Such a model may bring technical capacity and program continuity, but it also raises questions about regulatory legitimacy and accountability.

A similar governance dilemma appears in river water quality management.

Cities frequently focus on improving water quality within the river stretch flowing through their jurisdiction. The Thames in central London, the Sabarmati riverfront in Ahmedabad, the Cheonggyecheon corridor in Seoul, or the Yamuna reach through Delhi. In such cases, the river entering the city often already carries pollutants and flows from upstream regions beyond municipal control and there are numerous sources of non-point sources of pollution that are hard to detect and control. In this sense, improving a river stretch is conceptually similar to the challenges of managing air quality within a CAZ.

In practice, many governments still adopt zone-based or stretch-specific approaches not because they fully solve the problem, but because system-level governance (e.g. on airsheds and watersheds)  is often politically and institutionally difficult. Zones therefore become the most implementable visible interventions to signal positive action. Unfortunately, the institutional architecture required to manage multi-sector zones effectively often remains unclear and is not debated enough. In either cases, the institutional challenges still remain.

Despite these limitations, zones may still serve a useful purpose. They can draw attention to the issue, give citizens something concrete to observe and monitor, and create opportunities for engagement and public debate. In cities where environmental apathy is growing, even this mobilization of attention may itself be an achievement, whether or not it produces a sharp decline in pollution levels. The real question, however, is whether instruments such as CAZs are gradually becoming policy optics, while the deeper governance challenges remain unresolved. We need to introspect.