The discrimination meted out to the brick kiln industry by way of the aforesaid recommendations
can clearly be seen from the fact that the CPCB itself observed in its Report that the findings of the
study on "Source Apportionment of PM2.5 and PMIO of Delhi NCR for identification of major
sources" prepared by ARAI and TERI for Department of Heavy Industry, Ministry of Heavy Industries
and Public Enterprises in the year 2016 indicates that the brick kiln industry contributed about 5 &
7% with respect to PMIO emissions in winter and summer respectively to the ambient air of DelhiNCR. It has also been observed by CPCB, citing the aforesaid Report, that further reduction of 4% in
total PMI0 was expected after conversion to zig-zag technology, which has now been implemented
by brick kilns in Delhi-NCR. Further, the number of brick-kilns operating in Delhi-NCR has also
reduced after the complete ban imposed on nonzig-zag brick kilns. Thus, the current contribution of
brick-kilns to pollution in Delhi-NCR is only about 1-2%. True Copy of Relevant Extract of final Report
titled "Source Apportionment of PM2.5 and PMI0 of Delhi NCR for identification of major sources"
prepared by ARAI and TERI for Department of Heavy Industry, Ministry of Heavy Industries and
Public Enterprises alongwith its executive summary is annexed herewith as ANNEXURE-A-2. 12. The
ban imposed on operation of brick kilns due to lack of supportive carrying capacity in Delhi-NCR is
manifestly arbitrary and discriminatory because all industries that contribute to pollution in DelhiNCR are required to reduce their emission load in the interest of cleaner air. The entire burden of air
pollution cannot be placed on one industry. As a matter of fact, as per several expert bodies,
comprehensive action has to be taken by all industries contributing to pollution in Delhi-NCR. None
of these expert bodies recommend banning or shifting out of brick kilns from Delhi-NCR. Rather, the
universally recognized long term action plan for reduction of emission load from brick kilns is
conversion of the Bull Trench K:ilns to Zig-Zag Brick Kilns. The brick kiln industry has duly cooperated
in this area, at significant cost to each brick kiln, by converting to zig-zag technology. Thus, in these
circumstances, it is manifestly arbitrary and unfair to ban one industry that has actually adopted the
technological recommendations for reducing its emission load. True Copy of Report titled National
Clean Air Programme by Ministry of Environment, Forest & Climate Change, Government of India,
2019 is annexed herewith as ANNEXURE-A-3. True Copy of the NITI Ayog Report of the Task Force on
Clean Industry titled'Action Plan for Clean lndustry' is annexed herewith as ANNEXURE-A-4 . True
Copy of Report titled 'Market Transformation towards Energy Efficiency in Brick Sector' by Bureau of
Energy Efficiency is annexed herewith as ANNEXURE-A-S