The recent draft notification on utilisation of fly ash for making bricks is poorly designed and, if implemented, will shut down the construction industry.
Most people working in the field of environment believe that the environmental laws of the country are good, but their implementation is poor for various reasons, including corruption and lack of capacity within the environmental agencies. I have a different take on this. My assessment is that the main reasons for poor implementation is the poor design of the laws themselves. Most environmental laws in the country are top-down, and are designed with a poor understanding of the ground realities. Hence, they fail during implementation. Let me illustrate this with the example of the recent draft law published by the ministry of environment, forest & climate change (MoEFCC) on utilisation of fly ash for manufacturing bricks.
The most popular type of brick used for construction in India is fired clay brick (also called red clay brick). These bricks are produced from clay by burning them in a kiln. There are other types of bricks, classified as non-fired bricks (e.g. fly ash bricks, concrete blocks), produced from materials such as fly ash, sand, lime, gypsum and cement. Currently, 80% all the bricks produced in the country are fired clay bricks.
Fired clay bricks have been produced in our part of the world since the days of the Indus Valley civilisation. In fact, the size, shape and quality of bricks used in cities like Harappa and Mohenjo-daro is still a subject of scientific enquiry. But, the production of fired clay bricks has a large environmental footprint.
The fired clay brick industry is the fifth-largest consumer of coal in the country. It is a huge source of particulate matter (PM) emissions and one of the largest emitters of greenhouse gases like carbon dioxide and black carbon. Most brick kilns also use polluting technologies and, thus, do not meet emission norms. But their most significant environmental impact is the destruction of the topsoil. It is estimated that every year 600 million tonnes (mt) of clay, obtained mostly by excavating agriculture fields, is used for the production of bricks. This results in long-term land degradation, endangering food production.
In order to restrict the excavation of topsoil, MoEFCC is promoting the use of fly ash, generated as a waste from coal- and lignite-based thermal power plants (TPPs), for the manufacture of bricks. In 1999, MoEFCC came out with its first notification on the use of fly ash. This notification mandated that within a radius of 50 km from a coal- or lignite-based TPP, fired clay bricks should only be produced by mixing at least 25% of fly ash. Since then, the notification has been amended thrice—in 2003, 2009 and 2016. In each amendment, the radius around TPPs has successively been increased and so has the percentage of fly ash in the fired clay brick.
The latest draft notification, dated February 25, 2019, mandates that, ‘No new red clay brick kiln shall be installed and operated within 300 km from a coal or lignite based thermal power plant and the existing red clay brick kilns located within 300 km shall be converted into fly ash based bricks or blocks or tiles manufacturing within one year from the date of publication of this notification.’ Let us understand the implication of this notification.
India has about 250 coal- and lignite-based TPPs. If one draws a radius of 300 km from each TPP on the map of India, it covers almost the entire country except some parts of the North-Eastern and the Himalayan states. The notification, therefore, practically bans the manufacture of red clay bricks and substitutes it with fly ash bricks. But is this implementable?
India currently produces 200 mt of fly ash annually. Of this, 26% is used for cement production, 30% to fill mines, low-lying areas and build ash dykes and 33% remains unutilised. Only 17.7 mt of fly ash is used for brick and block manufacturing (9% of total fly ash generation). So, why is it that even after 20 years of sustained efforts not even 10% of all the bricks produced in the country is from fly ash? There are two primary reason for this: economics and quality.
Despite the government mandating that TPPs supply fly ash free of cost to brick manufacturers at the site, most power plants are not doing this. Brick manufacturers have to pay the contractors and also for the transportation. Fly-ash brick manufacturers that are closer to the power plants, and need to spend less on transportation, can compete with fired clay bricks. But those that are far can’t compete, and, hence, it is financially unviable for a brick manufacturer to produce fly ash bricks beyond a certain distance from a TPP. But, apart from cost, the quality of fly ash bricks and its acceptability is proving to be the bigger challenge.
Fly ash brick manufacturers struggle to maintain quality because of the wide variations in the quality of fly ash. The best fly ash generally goes for cement production; what remains is supplied to brick manufacturers. There is therefore genuine concern in the construction industry about the quality of fly ash bricks. Until this apprehension is allayed, the acceptability of fly ash bricks will remain poor.
But even if we solve the above problems, can we ban all fired clay brick kilns in next one year and start constructing all our buildings only from fly ash bricks? The answer is no.
The construction industry currently requires 250 billion bricks annually. The weight of each brick is about 3 kg. If we assume that all bricks are produced using only 50% fly ash, we will need 375 mt of fly ash annually. But, our power plants produce only 200 mt and, of this, 50 mt goes for cement manufacturing and 40 mt are poor quality ash that should not be used for brick making. So, we are left with 110 mt fly ash for bricks. This will only produce one-third of the bricks required by the industry. Thus, we do not have enough fly ash to meet the brick demand of the country. This draft notification, therefore, is a classic case of a top-down law that cannot be implemented simply because it would shut down the construction industry.
So, how should we design a law that allows for maximum utilisation of fly ash, significantly reduces the consumption of clay and the air pollution from fired clay brick kilns and yet meets the requirements of the construction industry? Please send your suggestions as I plan to address this issue in my next column.