EPCA report number 9 (November 2004)
Report on the increase in the number of three-wheelers in Delhi
In response to the Hon’ble Supreme Court Order Dated October 8, 2004
In response to the I.A. 217 of 2003
(In the matter of W.P.(C) No.13029 of 1985; M.C. Mehta v/s UOI & others)
Environment Pollution (Prevention & Control) Authority
for the National Capital Region
1. Report on the increase in the number of three-wheelers in Delhi
The three-wheeled scooter rickshaw (TSR) plays a very important role as intermediate public transport in the country. Delhi has around 53,262 registered three-wheelers as of August 31, 2004 running on compressed natural gas (CNG). The Hon’ble court has time and again discussed issues pertaining to three-wheelers in Delhi, from the point of congestion and also of pollution. The order of December 1997 imposed a cap on issuing fresh permits to the three-wheelers in Delhi. Registration was allowed only on replacement basis. In December 2002 however the Hon’ble court allowed a further
increase (5,000) in the number of three wheelers.
2. EPCA’s mandate
The Malawa Ram Market Association in an application filed in the Hon’ble court has sought further increase in the number of three-wheelers. Based on their plea the Hon’ble
court on October 8, 2004 ordered,
“Meanwhile, the Delhi government may move EPCA for additional demand of
TSR as interim measure.”
EPCA reviewed the current status of three-wheelers in Delhi and has discussed the matter with representatives of the Delhi government. Its recommendations in this report are broadly in consonance with the Delhi government’s policy in this regard.
EPCA realised it was necessary to undertake a technical assessment of the existing three-wheelers on the road, in order to consider any increase in the numbers in the city. This is because it has been noted that the current fleet of three-wheelers on road emit visible smoke. This when this fleet is relatively new and runs on clean fuel. This report to the Hon’ble Supreme Court considers all these matters.
3. Background to the three-wheeler issues
Over the years a series of orders have been issued by the Hon’ble court on the issue of three-wheelers and the problem caused due to the emission and congestion.
Order dated 16.12.1997:
“One of the major pollutants identified in the various affidavits as well as in the
latest status report filed by the government the TSR using a two-stroke engine…
It would be in the interest of the environment to freeze the number of TSRs at the
level at which they are actually in use in Delhi. We therefore direct there would
be no grant of fresh permits in case of TSR, save and except by way of
replacement of an existing working TSR with a new one.”
Following this vide notification dated 23rd April 1997 the department froze the number of autorickshaws at the existing number at that time i.e. 82,138. The department started registering three-wheelers only as replacement of existing three-wheelers.
Order of July 28, 1998:
Replacement of all pre 1990 autos and taxis with new vehicles on clean fuels by
Financial incentives for replacement of all post 1990 autos and taxis with new
vehicles on clean fuels by 31.3.2001”
As per the court order the government has also implemented the provision for financial incentives for replacement of old three wheelers with CNG three-wheeler. So far, the Auto-Rickshaw Branch of the Transport department, has allowed the following incentives:
1. Sales tax exemption being given in 4002 cases
2. Interest subsidy amounting to Rs 1,34,15,770/- have already been provided in
Order dated 17.9.2001:
“We however wish to clarify that there is no order of the court which either
compels conversion of autos or taxis to CNG single fuel mode or prohibits the
use of Euro II new taxis or four stroke autos on clean fuel.”
In the light of this the government of Delhi, took the decision to ban registration of two-stroke auto rickshaws running on petrol or CNG in the national capital territory of Delhi with effect from May 1, 2002. But four-stroke three-wheelers running on low benzene petrol are allowed.
Order dated 20.12.2002:
“Meanwhile, we modify the order dated 16th December 1997 and permit fresh
registration of 5,000 (five thousand) new Auto Rickshaws on CNG/LPG mode.”
Order dated 8.10.2004:
“Meanwhile, the Delhi government may move EPCA for additional demand of
TSR as interim measure.”
The court order came in the light of the Interim Application (I.A.) filed by the Malawa Ram Market Association that prayed:
; To modify the order dated 16.12.97 of this Hon’ble Court and direct the State
Transport Authority to allow the registration of new TSR and grant fresh permit to
new TSR to be on CNG and not by way of replacement only;
; To direct the state transport authority to grant permits according to the motor
4. Background of EPCA’s deliberations on 3-wheelers
EPCA would like to point out that the issue of the increase in the numbers of three-wheeler has been dealt in the report, Second generation reforms for air pollution control in Delhi: Examination of the issues raised in the IA 179 submitted by the Amicus curiae
submitted to the Hon’ble court in April 2003. The key recommendations of the EPCA April 2003 report were:
; Potential demand for the services of three-wheelers in Delhi and the extent of the
increase in their numbers to be allowed
; A composite plan on how would these be deployed in case of further expansion
in their numbers.
; Innovative models possible for short-haul/feeder services of these vehicles
especially in the context of Metro Rail’s expansion plans and decongesting the
main arterial roads
; Incentive schemes for encouraging phasing in of battery operated three-wheelers
EPCA had also recommended “it would be prudent enough to ensure that any further increase in the number of registration beyond what has already been permitted should be in the zero emission categories namely the battery-operated electric three-wheelers,
in addition to CNG and LPG.”
EPCA thus is looking at the three-wheeler issue again in the light of the Hon’ble court’s order dated October 8, 2004. The problem of visible smoke from three-wheelers is well known. EPCA would like to point out that the technical issues pertaining to the three-wheelers were discussed with Bajaj Auto at earlier occasions before. In their earlier deliberations with the EPCA, Bajaj had always maintained that the problem of white smoke emissions is an inspection and maintenance issue.
In its submission to EPCA on March 2003, Bajaj had pointed out that their analysis clearly shows that the primary cause of smoke emission is lack of proper maintenance of the vehicle as per recommended schedules and use of sub standard change parts. The main elements of the analysis were:
1. The relative percentage of smoking vehicles is higher among the vehicles of
older vintages (registered 2 to 2 ? years ago) than among the newer ones
2. There are no smoking vehicles among those registered in the last one year
3. There are significant proportions of non-smoking vehicles in all the age groups
4. The main reason for visible smoke emissions is abnormally high lubricating oil
5. High lubricating oil consumption is primarily caused by accelerated abrasive wear
of the piston/piston ring assembly due to ingestion of airborne dust from the
6. Ingestion of airborne dust is caused by improper fitment of air filter element in its
housing during fitment after periodic cleaning and/or use of sub standard filter
element at the time of replacement
7. Owners of a large number of vehicles who followed the recommended
maintenance schedule did not report the problem of smoke or high oil
consumption. On the other hand all vehicles that showed visible smoke emission
and high oil consumption were invariably with owners/drivers who did not follow
the recommended maintenance practices
Given the problem from the existing three-wheelers, EPCA felt it necessary to review the technical aspects of the three-wheelers. EPCA was surprised to know that the problem of polluting 3-wheelers still persists and it has actually grown much worse. Initially though the white smoke problem was confined to the retrofitted two-stroke three-wheelers, it has now came to light that four-stroke are also equally emitting white smoke. This finding of EPCA was corroborated by the recent pollution drive against transport vehicles by the Delhi transport department.
5. Problem of visible pollution from three-wheelers
EPCA was obviously concerned about the polluting three-wheelers in Delhi, which were negating the impact of the CNG programme in the city. The Transport Department of Delhi conducted a special drive against three-wheelers and other vehicles, which emit visible smoke. The drive was undertaken from October 4 to October 14, 2004. During the drive around 168 three-wheelers were caught for emitting visible smoke. Out of the 168 three-wheelers except three, which belonged to the Scooters India, the rest numbering 165 three-wheelers belonged to Bajaj.
Pollution drive of Transport department, Delhi from October 4 to October 14, 2004
Year Series Numbers Percent of Engine
1998 DL 1 RC 38 22.62 2 stroke
1999 DL 1 RD 41 24.40 2 stroke
2000 DL 1 RE 45 26.79 4 stroke
2001 DL 1 RF 14 8.33 4 stroke
2001 DL 1 RG 21 12.50 4 stroke
2002 DL 1 RH 3 1.79 4 stroke
DL 1 R 1 0.60
DL 1 W 5 2.98
Source: Compiled with the help of data from Transport Department, Delhi
According to the information provided from the Transport Department, with the help of registration numbers, EPCA was able to ascertain the year and the make of the vehicles. It was found that close to 50 per cent of the three-wheelers caught were four-stroke (See Visibly polluting three-wheelers). Again in the similar pollution drive in the following two weeks also, many three-wheelers caught emitting visible smoke were four-stroke. This proves that majority of the four-stroke three wheelers do have a problem of visible smoke, which needs to be addressed. The data also goes against the claims of the Bajaj Auto, which had a viewpoint that only some four stroke three wheelers have a problem of visible smoke.
Visibly polluting three-wheelers
Visible smoke from three-wheelers
0.00per centage of the total199819992000200120012002
Registration years of three-wheelers
Source: Delhi department of transport
EPCA then held a meeting on October 23, 2004 with the auto drivers associations, dealers and the manufacturers to discuss the issues at hand (see Annexure 1 for list of people who attended the meetings). The auto drivers association also confirmed that not only two-stroke, but four stroke three-wheelers were equally polluting. Technically four-stroke three-wheelers should not emit visible smoke. But the actual data from the Delhi transport department shows it is not the case. EPCA takes a very serious note of the white smoke problem.
6. EPCA’s observation
A. Technical report
Given the mandate of October 8, 2004 from the Hon’ble court, and the persistent problem of white smoke emission from three-wheelers, EPCA closely assessed the demand for an increase in the number of three-wheelers in Delhi. EPCA has looked at the operating parameters of the three-wheelers in Delhi, their economics, and have also done the technical assessment of the in-use three-wheelers. EPCA has further ascertained the engine related causes of white smoke from three-wheelers and the possible remedial measures.
1. Reason For Visible Smoke
In three-wheelers, visible smoke emission is due to excessive lube oil consumption because of abnormal wear of piston rings/cylinder liner. The purpose of piston rings is to maintain a pressure tight seal between the piston and cylinder wall, to aid in controlling oil, to permit proper lubrication of the cylinder and to assist in the cooling of the piston. The quality of the piston ring is important factor. With poor quality piston rings, it is possible that lubricating oil leaks from oil sump to the combustion chamber causing smoke.
a. Lubrication Method
There is a difference in the method of lubrication used in two-stroke CNG engine three- wheeler and 4-stroke CNG engine three-wheeler. While the former employs an additional lubricating oil pump, the later uses only splash system of lubrication.
The splash system is usually designed with an oil reservoir in the base of the engine. Dippers on the lower ends of the connecting rod dip into this oil in the reservoir, splashing the oil in the form of a spray throughout the inside of the engine. The oil spray and the return drip lubricate the internal parts of the engine. The return drip is sometimes directed into pockets above the main and camshaft bearings. The oil drains to the bearings by gravity through holes leading to the bearings.
In the two-stroke engine, faults in the lube oil pump can lead to excessive lube oil consumption.
b. Quality Of Oil
The visibility level of smoke can be controlled by using the latest quality of oil, that is optimally required by the engine. Further, new two stroke engine oils (2T oils) have now been developed that use a blend of mineral and synthetic base oils with better burning quantities. Oils that comply with the JASO FC quality level bring about a substantial reduction in the visibility of the exhaust. A Central Government mandate allows the sale of only those 2T oils that conform to the API TC grade for various performance characteristics and JASO FC grade for smoke performance. But it has been noted that many drivers use loose (illegal) oil, which is cheaper and unfortunately, freely available in Delhi in their vehicles.
c. Piston Rings
Piston ring designs vary in circumference, joint construction, anchoring, cross section, and the ring pressure exerted against the cylinder wall. When installed in the cylinder, the piston ring must exert a pressure against the cylinder wall if a gastight seal is to be maintained. The total pressure exerted by piston rings against the cylinder wall varies from seven to twelve pounds. High ring pressures, besides causing a drag on the engine, result in excessive wear on the cylinder walls and piston rings, and are often responsible for the scuffing or scoring (scratches), which may occur on the face of the ring.
Piston rings are designed with faces of different widths to satisfactorily maintain compression and reduce oil consumption. The oil rings must meter sufficient oil to the upper part of the cylinder to lubricate the cylinder wall and the compression rings. When the pistons have the proper cylinder clearance, the bottom edge of the piston removes most of the oil from the cylinder wall on each downward stroke, permitting the rings to properly control cylinder lubrication. When piston clearances are excessive, the pistons cannot scrape their share of oil from the cylinder wall, with the result that the rings are forced to control much more than the normal amount of oil. This often results in excessive cylinder lubrication and oil consumption.
Some piston rings are plated with cadmium, tin or chrome, while others have a black magnetic oxide or phosphate coating on all surfaces of the piston ring. Since scuffing or scoring between two metal surface can occur only if the two surface are absolutely free of plated, oxide, or phosphate deposits, the coating applied to the rings tends to prevent scuffing or scoring of the piston rings bring the break-in period.
2. Suggested technology Improvements
On the basis of these findings, the following technology improvements have been discussed with M/s Bajaj Ltd. These include design optimisation, improved quality control and use of emission control technologies. Some of these are:
i) Improving the design of the piston and piston rings
ii) Use of better quality of ring material
iii) Optimisation of engine air intake system, including improvement of air cleaning
iv) Optimisation of lubrication system including oil pump design in case of 2-stroke
v) Use of optimally designed catalytic converter
vi) Optimisation of engine cooling system
vii) Improvement of chain drive system used in 4-stroke three-wheelers
B. Management related issues
B.1. Economics of three-wheelers
In most of the cases it was found that the three-wheeler driver was not the owner of the vehicle, he was running the vehicle on a rental basis. The ownership structure thus is very peculiar; in Delhi most of the three-wheeler drivers are not the owners. Many surveys over the years have shown that invariably the driver is not owner.
The economics of the rented three-wheelers works in a similar pattern across the city, only the rates differ. For instance renting four-stroke three-wheeler is costlier than renting a two-stroke three-wheeler. Again for renting a new three-wheeler the driver has to pay a higher price, as compared to an older three-wheeler. Thus there are various factors that actually determine the rents. Generally the renter has to pay a fixed sum, ranging from Rs 170 to Rs 250 to the owner everyday. So this is the first cost for the driver of three-wheeler. Apart from the rent, he also pays for the gas, which comes to around Rs 50 per day. Thus the cost of operating a rented three-wheeler comes to around Rs 300 per day. Anything above this figure is the earnings of the three-wheeler driver. On an average a three-wheeler travels around 100 km per day. The three-wheeler operator on a normal day is able to do a business of Rs 400- Rs 450. Thus given this background a three-wheeler operator renting a three-wheeler makes around Rs 3,000 to Rs 4,500 on a monthly basis. If an owner operates the three-wheeler, assuming the same calculation, they would do a net business of over Rs 13,000 per month.
Three-wheeler operators are of the view that any minor expenditure on three-wheelers, to the extent of Rs 50 to 100 is borne by them. Anything above that amount or any work on the three-wheeler engine is to be borne by owner. The cost of the lubricating oil is also borne by the owner of the vehicles. EPCA would like to point out that all the above stated findings from the study were corroborated by the various Unions of three wheelers from Delhi, in the meeting held by EPCA on October 23, 2004.
EPCA observes that this ownership structure affects the maintenance of a three-wheeler. The renter of the three-wheeler doesn’t pay much attention to the condition of the three-
wheeler, as the vehicle doesn’t belong to him. On the other hand the owner of the three-
wheeler is also least concerned- he is more interested in the fixed amount of money which he gets each day for renting out his three-wheeler. EPCA feels this structure of operation of three-wheelers also adds to the maintenance problem. EPCA therefore is of the view that the owner of the vehicle should take the responsibility of the three-wheeler condition, irrespective whether he is driving or renting out his three-wheeler. EPCA
recommends that the owner should always buy branded lubricating oil from an authorised service station. This would solve few of the existing problems caused due to the use of cheaper recycled lubricating oil by the owners/drivers.
B.2. What is the number of three-wheelers on roads
The registered number of three-wheelers is obviously not the correct representative of the numbers actually on road. This has always been the point of contention, and also of confusion. We don’t have any estimation as to how many number of three-wheelers are
plying on road.
The registration of the three-wheelers in 1997 was around 82,138, as per the data submitted by the Delhi transport department in the court. After the Hon’ble Court imposed a freeze on the numbers, the registration of the autos was corrected and in 2002 it was ascertained that there were around 43,000 autos, which were replaced and registered in the city. It will be recalled that the Hon’ble Court had asked for replacement of the existing autos on the road. Interestingly, only 43,000 were replaced as a result of this order. The assumption therefore, is that only half of the registered number were on road and were therefore, replaced. This is also assuming that all vehicles were indeed replaced.
Number of registered three-wheelers in Delhi
Figures for the year 2004 are upto August 31, 2004
1. Anon 2004, Economic Survey of Delhi 2003-04, Transport Chapter 12, Table 12.2 Government of National Capital Territory of Delhi
2. Transport department of Delhi
Currently, according to the information provided by the Delhi transport department as of August 31, 2004 the total number of registered three-wheelers are 53,262. Out of this, around 34,526 are the original equipment make and the rest around 18,736 are retrofitted and largely two-stroke. Transport department also points out to EPCA that registration have slowed down considerably over the years as not many were on road and hence few came up for replacement, based on the court order. Registrations currently done are largely done under the permission granted by the Hon’ble court order dated December 2002.
Given the considerable gaps in the data, it is very difficult to ascertain the age profile of the current three-wheeler fleet on road. However EPCA was able to get an idea of the age profile of three-wheelers on road with the help of registration series data. For instance the series DL 1RC was in 1998. Similarly the series DL 1 RD was in the year 99. With the help of this series registration figures, it can be safely said that the on an average three-wheelers on Delhi’s road are 4 to 5 years old. Currently the series in 2004, which is being used for registration, is DL 1RJ.
7. EPCA’s conclusions
EPCA held a meeting on October 23, 2004 with the various Unions of three-wheelers in Delhi, the Malawa Ram Market Association and the transport department of Delhi. EPCA at this point would like to point out that the Malawa Ram Market Association is a trade association, whose only interest is to increase the numbers of three-wheeler in the market. Meanwhile the various Unions representing the three-wheelers were unanimous on not increasing the number of three-wheelers.
On October 30, 2004 EPCA also held a meeting with the Bajaj Auto to discuss the technical issues in their three-wheelers raised in the EPCA technical report, and also to discuss with them the engine related problem faced by the three-wheeler operators in Delhi.
EPCA pointed out to Bajaj that how its four stroke three-wheelers were consuming more lubricating oil than the two-stroke three-wheelers. EPCA also pointed out many technical defaults in the CNG three-wheeler of Bajaj. The representative of Bajaj Auto present at the meeting agreed to the findings of the EPCA’s technical report and acknowledged the fact that in the initial years of the introduction of the four-stroke CNG three-wheelers there were technical problems. Bajaj has given an undertaking to the EPCA that it would submit a report on technical improvements on four-stroke three-wheelers and will also replace the existing defective parts on-road fleet of 3-wheelers at the manufacturers cost.
8. EPCA’s recommendations
It is clear from the above examination of technical and management issues that there are problems with the existing three-wheelers on road. The overall conclusions are as follows:
a. The data from the visible pollution drive of the Delhi government shows that
autos are contributing to the pollution load in the city. This is when these autos
are relatively new (with the average age being between 4-5 years) and run on
b. The data also reveals that contrary to the perception the 4-stroke vehicles also
emit visible smoke. Roughly half the vehicles stopped on the road because of
visible smoke, were 2-stroke and the other half 4-stroke. Therefore, the problem
concerns both new as well as the converted vehicles.