Rising heat and worsening air quality in our cities are bringing climate urgency into sharp focus. As researchers across the globe drive scientific breakthroughs and develop innovative policy tools on multiple fronts, a simple truth remains. A policy idea is only as good as the systems beneath it. Working on an Emissions Trading Scheme (ETS) for sulphur dioxide pollution in Maharashtra, I have seen this firsthand. The market mechanism may be the most visible part of these programmes, but it is rarely the reason they succeed or fail.
As ETS gain traction as a market-based tool to address industrial air pollution, implementation experience across Indian states points to the merit of robust data infrastructure and sustained institutional capacity. Gujarat’s particulate matter ETS, the world’s first market for particulate pollution, is celebrated for proving that market-based regulation can raise compliance, cut pollution, and lower costs for industry simultaneously. What gets less attention is what actually made it possible: Continuous Emissions Monitoring Systems (CEMS).
CEMS were installed across participating factories to generate live, verifiable data on what each chimney was releasing. This is the foundation the entire market rests on. Without reliable data, there are no credible permits, no meaningful trades, and no way to enforce anything.
The Emissions Market Accelerator (EMA) recognised that data infrastructure isn’t just support work, it’s the foundation that makes emissions markets function. So rather than copying Gujarat’s model wholesale into other states, EMA focused on extracting what actually made it work: standardised monitoring and reporting, regulator training, and industry engagement that makes compliance the norm rather than a scramble.
Each new state, with its own industrial base, regulatory capacity, and pollutants, tests it and refines it, so the model keeps getting more robust and easier to deploy. The framework built for Gujarat is not the framework being used in Maharashtra or Rajasthan; it is a more evolved version of it.
This is the framework I have seen come to life in Maharashtra, where a sulphur dioxide ETS is being developed with the Maharashtra Pollution Control Board. Capacity-building has not been a box to tick before the market launches; it has run in parallel with every stage of design. I have sat in sessions with regional pollution control officers learning how a trading market functions day to day and seen the value of industry workshops that walk factory representatives through trading rules before they are expected to follow them. Regular CEMS data quality checks catch the kinds of errors, flatlined sensors, zero values, outliers, that, left uncorrected, would quietly hollow out the market’s integrity.
These adaptations are already shaping EMA’s approach in Rajasthan, where baseline surveys are now assessing institutional and industry readiness before market design even begins. That sequencing matters. One of the most important things the framework has learned is where to start, not with market rules, but with an honest assessment of whether the data and institutions to support them exist yet.
The real measure of any environmental programme is not how it performs while external support is present, but whether it survives without it. The goal of all this groundwork is that state governments eventually are equipped with trained people, live data systems, and institutional knowledge to run these markets on their own. That, more than any market design innovation, is what makes pollution trading both sustainable and replicable.