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Report No. 60155-BD

Introducing Energy-efficient Clean Technologies in the Brick Sector of Bangladesh
June, 2011

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Environment, Climate Change, and Water Resources Unit

South Asia Region

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The World Bank 1818 H Street NW, Washington DC, 20433, USA Tel: 202.473.1000 Fax: 202.477.6391

Energy Sector Management Assistance Program (ESMAP) 1818 H Street, NW Washington, DC 20433, USA Fax: 202.522.3018 All rights reserved Manufactured in the United States of America First printing August 2011 Copyright © 2011

Standard Disclaimer This volume is a product of the staff of the International Bank for Reconstruction and Development/the World Bank. Energy Sector Management Assistance Program (ESMAP) reports are published to communicate the results of ESMAP’s work to the development community with the least possible delay. Some sources cited in this paper may be informal documents that are not readily available. The findings, interpretations, and conclusions expressed in this report are entirely those of the author(s) and should not be attributed in any manner to the World Bank, its affiliated organizations, members of its board of executive directors for the countries they represent, or to ESMAP. The World Bank and ESMAP do not guarantee the accuracy of the data included in this publication and accept no responsibility whatsoever for any consequence of their use. The boundaries, colors, denominations, and other information shown on any map in this volume do not imply on the part of the World Bank Group any judgment on the legal status of any territory or the endorsement or acceptance of such boundaries.

Copyright Statement The material in this publication is copyrighted. The World Bank encourages dissemination of the work and will normally grant permission to reproduce portion of the work promptly.

Photograph Credits The photos published on the cover of the report were produced by Arne Hoel of the World Bank.

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Currency Equivalents (Exchange rate effective April 1, 2011) Currency Unit = Bangladeshi Taka (Tk) US$1 = Tk.71

Fiscal Year July 1 – June 30

Vice-President: Country Director: Sector Director: Sector Manager: Task Team Leader:

Isabel M. Guerrero Ellen A. Goldstein John Henry Stein Herbert Acquay Maria Sarraf

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ACKNOWLEDGMENTS
This report was prepared by a team consisting of Maria Sarraf (Task Team Leader), Lelia Croitoru (Environmental Economist, Consultant), M. Khaliquzzaman (Sr. Environment Specialist, Consultant), Shakil A. Ferdausi (Sr. Environment Specialist) and Jie Li (Energy Specialist). The team would like to thank Dr. Nasiruddin (Joint Secretary), Swapan Biswas (Air Quality Consultant, CASE Project), and Shamim Hasan (Brick Consultant, CASE Project) of the Ministry of Environment and Forests for their input. The study team benefited from the vast knowledge provided by the Bangladesh Brick Manufacturers and Owners Association. Special thanks go to Messrs. Mizanur Rahman, Mohammed Ali Iftekhar, Mia Hossain, Moizuddin Ahmed, and Hassan Faisal for their cooperation and support during various field visits. The report draws on two studies completed by Development Alternatives (India) and Practical Action (Bangladesh) in the context of the Clean Air and Sustainable Environment Project (CASE Credit 4581-BD) and special mention goes to Dr. Soumen Maity and Mr. Iqbal Karim for leading these two highly professional studies. Within the World Bank, the report benefited from input from Mmes/Messrs.: Luis Alberto Andres, Herbert Acquay, Arun Banerjee, Hocine Chalal, Malcolm Cosgrove-Davies, Andras Horvai, Muthukhumara Mani, Michel Pommier, Ernesto Sanchez-Triana, Nadia Sharmin and Christopher Warner as well as administrative support from Poonam Rohatgi and Janet Bably Halder. Finally, we gratefully acknowledge the financial and technical support provided by the Energy Sector Management Assistance Program (ESMAP). A global knowledge and technical assistance partnership administered by the World Bank and sponsored by bilateral donors, ESMAP assists low- and middle-income countries, its “clients,” to provide modern energy services for poverty reduction and environmentally sustainable economic development. ESMAP is governed and funded by a Consultative Group comprised of official bilateral donors and multilateral institutions representing Australia, Austria, Canada, Denmark, Finland, France, Germany, Iceland, the Netherlands, Norway, Sweden, the United Kingdom, and the World Bank.

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TABLE OF CONTENTS
ACKNOWLEDGMENTS .......................................................................................................................................4 T ABLE OF C ONTENTS ........................................................................................................................................5 ABBREVIATIONS ................................................................................................................................................6 UNITS OF M EASURES.........................................................................................................................................7 E XECUTIVE SUMMARY......................................................................................................................................8 C HAPTER 1. I NTRODUCTION ....................................................................................................................14 C HAPTER 2. O VERVIEW OF BANGLADESH ’S BRICK SECTOR ................................................................17 C HAPTER 3 E XISTING BRICK T ECHNOLOGIES ......................................................................................21 3.1. Fixed Chimney Kiln ..............................................................................................................................21 3.2. Zigzag Kiln ............................................................................................................................................23 3.3. Hoffman kiln (natural gas) ....................................................................................................................25 3.4 Environmental and Energy-efficiency Issues .........................................................................................27 3.5 Social Issues ..........................................................................................................................................28 ALTERNATIVE AND I MPROVED BRICK K ILN T ECHNOLOGIES ........................................30 C HAPTER 4. 4.1 Improved Fixed Chimney Kiln (IFCK) .................................................................................................30 4.2 Improved Zigzag Kiln (IZigzag) ...........................................................................................................33 4.3 Vertical Shaft Brick Kiln (VSBK).........................................................................................................34 4.4 Hybrid Hoffmann Kiln (HHK) ..............................................................................................................36 4.5 Environmental and Energy-efficiency Issues ........................................................................................37 4.6 Social Issues ..........................................................................................................................................39 E CONOMIC ANALYSIS OF ALTERNATIVE BRICK K ILN T ECHNOLOGIES ........................40 C HAPTER 5. 5.1 Assumptions for the Selected Technologies ..........................................................................................40 5.2 Methodology..........................................................................................................................................41 5.3 Private Cost-Benefit Analysis ...............................................................................................................42 5.4 Social cost-benefit analysis ...................................................................................................................44 5.5 Sensitivity Analysis ...............................................................................................................................48 C HINA’S E XPERIENCE IN THE BRICK SECTOR ..................................................................49 C HAPTER 6. 6.1 Economic Development: The Driving Force of China’s Brick Industry ...............................................49 6.2 Development of China’s Brick Industry ................................................................................................51 6.3 Government Intervention.......................................................................................................................57 6.4 Current Problems and Challenges Ahead ..............................................................................................59 T OWARD A SUSTAINABLE BRICK SECTOR IN BANGLADESH ............................................60 C HAPTER 7. R EFERENCES ..............................................................................................................................................63 ANNEX A. E STIMATING THE H EALTH I MPACTS OF K ILN P OLLUTION ...................................................67 ANNEX B. DISPERSION OF BRICK K ILN AIR P OLLUTION (PM 10) IN DHAKA ..........................................73 ANNEX C. P OLICIES, L AWS, AND R EGULATIONS IN C HINA’S BRICK I NDUSTRY ...................................76 ANNEX D. P OLICIES, L AWS, AND R EGULATIONS IN BANGLADESH ’S BRICK SECTOR ...........................81

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ABBREVIATIONS

BBMOA BSCIC BTK BUET CASE CBA CBTIA CBRI CDM CEF CERs DA DALY DOE ESMAP FCK GDP GEF GHG GOB HCA HHK IFCK IRR MOEF MOHFW MOI MOLSW MOWA PA PM PSCST SEC SME SPM SZigzag UNDP VAT VSBK VSL

Bangladesh Brick Manufacturers Owners Association Bangladesh Small and Cottage Industries Corporation Bull’s Trench Kiln Bangladesh University of Engineering and Technology Clean Air and Sustainable Environment Cost-Benefit Analysis China Brick & Tile Industry Association Central Building Research Institute (India) Clean Development Mechanism Carbon Emission Factor (IPCC default) Certified Emissions Reductions Development Alternatives Disability Adjusted Life Year Department of Environment (Bangladesh) Energy Sector Management Assistance Program Fixed Chimney Kiln Gross Domestic Product Global Environmental Facility Greenhouse Gas Government of Bangladesh Human Capital Approach Hybrid Hoffmann Kiln Improved Fixed Chimney Kiln Internal Rate of Return Ministry of Environment and Forests (Bangladesh) Ministry of Health and Family Welfare (Bangladesh) Ministry of Industries (Bangladesh) Ministry of Labor and Social Welfare (Bangladesh) Ministry of Women Affairs (Bangladesh) Practical Action (Bangladesh) Particulate Matter Punjab State Council of Science and Technology (India) Specific Energy Consumption Small- and Medium-sized Enterprise Suspended Particulate Matter Improved (Standardized) Zigzag United Nations Development Program Value Added Tax Vertical Shaft Brick Kiln Value of Statistical Life 6

UNITS OF M EASURES

cft ft kg kWh m mg/m3 MW PM2.5 PM10 ppm t tce µg/m3

cubic feet foot kilogram kilowatt hour meter milligram per cubic meter megawatt particulates with diameter less than 2.5 microns or less than 10 microns parts per million ton tons of coal equivalent microgram per cubic meter

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E XECUTIVE SUMMARY

Brick-making is a significant sector in Bangladesh, contributing about 1 percent to the country’s gross domestic product (GDP) (BUET 2007) and generating employment for about 1 million people. Due to the unavailability of stone aggregate, brick is the main building material for the country’s construction industry, which grew an average of about 5.6 percent per year in 1995– 2005. Despite the importance of brick-making, the vast majority of kilns use outdated, energyintensive technologies that are highly polluting. In the North Dhaka cluster 1, brick kilns are the city’s main source of fine particulate pollution 2, accounting for nearly 40 percent of total emissions during the 5-month operating period (Figure 1). This leads to harmful impacts on health, agricultural yields and global warming. Figure 1: Sources of fine particulate pollution in Dhaka
7% 7% 38% 9% Road dust Soil dust Metal smelter 18% 19% Zn source Sea salt 2% Brick kilns Motor vehicle

Source: Begum et al. (2010)

This report analysis the brick sector in Bangladesh and assesses the feasibility of cleaner alternative technologies. Chapter 1 introduces the rationale and study objectives. An overview of the challenges and opportunities of the brick sector is presented in Chapter 2. Chapter 3 describes the main brick technologies currently in use in Bangladesh, while Chapter 4 portrays the main characteristics of cleaner alternative technologies. Chapter 5 estimates in monetary terms the private and social profitability of the selected technologies. Chapter 6 presents lessons from China, the world’s leading brick producer. Drawing on previous chapters, Chapter 7 provides the main conclusions and recommendations for a more sustainable brick sector in Bangladesh.

OBJECTIVES The Fixed Chimney Kiln (FCK) dominates the brick sector in Bangladesh, despite its highly polluting and energy-intensive features. Such technologies as the Improved Fixed Chimney Kiln (IFCK), Improved Zigzag Kiln (IZigzag), the Vertical Shaft Brick Kiln (VSBK), and the Hybrid Hoffmann Kiln (HHK) are substantially cleaner, consuming less energy and emitting lower levels of pollutants and greenhouse gases 3. But implementation of these technologies in Bangladesh is still at a pilot stage; thus, their financial viability still needs to be demonstrated.
The North Dhaka brick kiln cluster consists of 530 closely spaced kilns, located in the Tangail, Gazipur and the northern Upazilas of Dhaka districts (BUET 2007). 2 Fine particulates refer to particulate matter (PM) with diameter of less than 2.5 µm, which is more harmful to health than PM with larger diameter (Pope et al. 2002). 3 BUET 2007; Heirli and Maithel 2008; World Bank 2011a.
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This study’s objectives are: (i) to present the pros and cons of existing and alternative brick technologies 4 in Bangladesh with specific focus on pollution and energy efficiency; (ii) to estimate the private and social benefits of these technologies (iii) to summarize China’s experience in the development of the brick industry, as the world leader brick producer and (iv) to provide concrete recommendations for adopting cleaner technologies in Bangladesh. The originality of this report stems from: (1) primary data collection, based on the IFCK, VSBK and HHK pilot projects 5 and on interviews with FCK owners; (2) first-time economic valuation of the overall impacts of different kiln technologies, and comparison among them; (3) first comprehensive review of 20 years’ of China’s (the world leader brick producer) experience in technology change and government regulation in the brick sector. Thus, this report is expected to substantially bridge the knowledge gap in terms of data collection, methodology and realistic recommendations for the improvement of the brick sector in Bangladesh. SCOPE AND AUDIENCE The study focuses on the brick cluster located in northern Dhaka, which comprises 530 FCKs that produce 2.1 billion bricks annually (14 percent of the country’s brick production). As the brick sector is a prominent contributor to air pollution in Dhaka, it is important to distinguish its contribution to the city’s air pollution from other sources, including transport and other industries. Because of limited data availability, 6 the analysis relies on the most realistic assumptions drawn from monitored data in Bangladesh or neighboring countries (i.e., Nepal and India). As a result, the estimated net returns for each technology are orders of magnitude rather than precise estimates. The primary audience and the main usefulness of the report are: (i) the Ministry of Environment and Forests (MOEF), who can benefit from an evaluation of the real magnitude of the environmental externalities caused by different brick technologies (health problems and carbon emissions); (ii) the Bangladesh Brick Manufacturers and Owners Association (BBMOA), who can use the recommendations as a tool for discussing the importance of the brick sector among other industries, and for introducing cleaner brick practices in the country; and (iii) the Ministry of Industries (MOI),who can use the information to speed up the recognition of the sector as a formal industry. METHOD Estimating the net returns from each technology is based on the Cost Benefit Analysis (CBA)
The analysis covers only a set of technologies for which data could be made available (FCK, IFCK, VSBK, HHK). Other technologies, though successful throughout the region, could not be included, either because of lack of welldocumented information (e.g. IZigzag) or their unlikely viability in the Bangladesh context (e.g. technologies based on non-fired bricks due to the non availability of cement and stone chips and weather conditions). Therefore, the implications of this analysis refer only to the technologies covered by this report. 5 These include an IFCK piloted in Rupganj (Narayangunj) during the preparation of the Clean Air and Sustainable Environment (CASE) project (DA-PA 2009); a VSBK piloted with funding from Energy Sector Management Assistance Program (ESMAP) (DA-PA 2010); and the preparation by the World Bank of an Emission Reduction Purchase Agreement (ERPA) for a HHK in Savar (World Bank 2011a). 6 For example, data on pollutant emissions per unit of bricks and dispersion patterns.
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approach. The analysis measures the net returns from the private and social perspectives, defined as follows: • The private (financial) CBA: The analysis from the entrepreneur’s viewpoint includes all costs and benefits for the entrepreneur. • The social (public) CBA: The analysis from the social viewpoint includes the costs and benefits from the private CBA, as well as the social and environmental impacts of brick kilns, including the health effect of air pollution and the cost of CO2 emissions. Table 1 depicts the valuation methods used to estimate each cost and benefit. The analysis refers to the year 2009, uses a time horizon equal to the life span of a kiln (20 years), and a discount rate of 10 percent. A sensitivity analysis of net returns to changes in discount rates was then carried out. Table 1: Valuation methods used
Type of analysis Private Types of costs and benefits Costs: - Investment, land, buildings, operating costs, taxes Benefits: Value of bricks Costs: - Investment, land, buildings, operating costs; - Health impact of air pollution; - CO2 emissions Benefits: Value of bricks Valuation method Market prices Market prices Real prices Disability Adjusted Life Years (DALYs) Price on the carbon market Real prices

Social

RESULTS The overall results of the economic analysis indicate that: • Cleaner technologies (i.e. VSBK, HHK) are the most socially profitable ones, while polluting technologies (i.e. FCK) are socially unprofitable. VSBK and HHK are the most socially profitable technologies, with net benefits of TK68-75 per thousand bricks. In contrast, the high costs of air pollution and CO2 emissions make the FCK socially unprofitable, with net social costs of TK3 per thousand bricks. (Figure 2). • Though socially unprofitable, FCK is the most commonly implemented technology in Bangladesh. FCK accounts for more than 90 percent of brick kilns in Bangladesh. The low investment cost and the ability to operate on lowlands explain the FCK’s dominance in the brick sector. • Adopting cleaner technologies is hindered by their need to operate on flood-free lands (i.e. highlands) which are scarce and expensive. In addition,
Figure 2. CBA results for different brick technologies
140 120 100 80 60 40 20 0 -20

TK/000 bricks

103 107 108

116

FCK

Private

IFCK

VSBK

-3

43

75 68

HHK

Social

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some technologies (e.g. HHK) require substantial investments, which are unaffordable for most FCK owners who operate on rented land that cannot be used as collateral. Specific results of the analysis related to the kilns’ social and environmental impacts suggest that: • Currently, FCKs contribute up to 20 percent of the total premature mortality caused by urban air pollution in Dhaka (all causes combined). The Bangladesh Country Environmental Analysis reports that poor air quality in Dhaka contributed to an estimated 3,500 premature deaths in 2002 (World Bank 2006) 7. Emissions of PM10 and PM2.5 from the kiln cluster north of Dhaka are responsible for 750 premature deaths annually. Thus, current FCKs are likely to contribute up to 20 percent of total premature deaths in Dhaka due to poor air quality 8. • Replacing the brick cluster north of Dhaka with VSBKs would reduce current premature mortality by more than 60 percent; replacement by HHKs would reduce it by 45 percent.

• Adopting the VSBK or HHK can provide considerable carbon benefits. The FCK provides the highest unit cost of carbon emissions (TK4 per brick 9), primarily because of the high coal consumption. By contrast, the low coal consumption makes the VSBK and the HHK the cleanest technologies in terms of CO2 emissions (less than TK3 per brick). The review of China’s 20-year experience in the brick industry development shows that transformative change occurred through: (i) diversifying raw materials by using mixed waste materials (e.g. fly ash, gangue, coal dust and coal slurry); (ii) diversifying wall material products, by producing hollow bricks, non-fired bricks (now accounting for 50 percent of total bricks) and (iii) increasing the scale of brick enterprises and productivity, thus saving land and energy. A combination of government intervention (e.g., regulations for phasing out traditional solid clay bricks) and financial incentives (e.g., specific funds and preferential tax policies on promoting new brick products) played an important role for the success of this transformational change. This experience suggests that it is now the time for Bangladesh to begin its transformative development. How to achieve this development over the next 20 years is the focus of the next section.
POLICY RECOMMENDATIONS

Bangladesh’s brick sector is characterized by outdated technologies with low energy efficiency and high emissions; low mechanization rate; dominance of small-scale brick kilns with limited financial capacity; and dominance of single raw material (clay) and product (solid clay brick). Adopting gasbased cleaner technologies is hampered by serious energy shortage and land scarcity. How long can the country afford making bricks in this way? The current status is by no means sustainable. Bangladesh has every reason to upgrade its brick sector in order to save valuable natural resources, reduce air pollution, and increase energy efficiency. The government has already established regulations that ban the use of fuelwood and FCKs and has reconsidered the location

Because respirable PM in Dhaka has concentrations exceeding the standards for more than 100 days a year. The industry and transport development after 2002 most likely increased the number of premature deaths in Dhaka; however, updated estimates were unavailable at the time of the analysis. 9 In present value terms.
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and height of brick kiln chimneys. However, transformative development of the brick industry has yet to occur. This report suggests that the development of the brick industry in Bangladesh over the next 20 years should aim at: (i) moving from traditional brick-making technologies (e.g. FCK) to cleaner ones (e.g. HHK, VSBK); (ii) diversifying products (e.g. hollow and perforated bricks) and locally available alternative raw materials; (iii) increasing the proportion of large-scale enterprises with higher capacity to adapt to cleaner technologies. To achieve these goals, a summary of concrete recommendations is provided below. In the short-term: 1. Recognize brick kilns as a formal industry. This would enable easier access to financial resources (which in turn will enable investment in cleaner technologies and access flood free land) and improved working conditions. 2. Create a Brick Technology Center to raise awareness about the benefits of cleaner technologies. The center should: (a) disseminate information on the social benefits provided by cleaner technologies, new wall materials (e.g. perforated and hollow bricks) and alternative raw materials; (b) promote pilot projects of new technologies with improved provisions (e.g., mechanized, higher labor productivity and larger product lines); (c) improve use of existing dissemination channels (e.g., field visits to pilot plants, video demonstrations of the technologies, use of the Bangla language) and introduce new channels (e.g., newsletters, industry journals, conferences, and Internet blogs). 3. Support research and development aiming at: (a) exploring alternative raw materials 10 that are locally available, brick diversification, and use of higher level of mechanization; (b) conducting new studies such as energy consumption studies, land surveys, and brick technology surveys. 4. Facilitate the availability of subsidized credit lines to account for reduced health impacts from pollution and of other economic incentives supporting the production of new wall materials and use of alternative raw materials (e.g. via specific funds and preferential tax policies, as in China). 5. Provide access to carbon markets, on account of the carbon emission reductions provided by cleaner technologies. 6. Train several stakeholders with regard to the benefits of adopting cleaner technologies (e.g. brick owners, workers and the financial sector).

A word of caution should be mentioned about the use alternative raw materials, where strong quality control should be kept in regulators’ mind. Some alternative raw materials, especially wastes, may contain toxics that are harmful to human health. Pertinent policies, laws, and regulations need to be developed and set up to make sure no hazardous raw materials are used while they are adopted in the industry. In the past few years, local governments in China have strengthened regulations to prohibit hazardous materials from being used for wall material production and developed a series of standards for quality control of new products, to safeguard favorable development of this industry.

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In the medium term: 7. Enforce the existing regulations and policies, such as the ban of traditional high polluting kilns (e.g. FCK, BTK), particularly those located close to large population centers, upstream of the wind (north) in the dry season (November to April). 8. Introduce regulations and policies that encourage adoption of cleaner technologies, such as: (a) revise emissions standards for brick kilns under ECR97 to make them technology independent and to encourage brick diversification (e.g., perforated or hollow bricks for partition walls); (b) establish proper emission monitoring for brick kilns; (c) impose an emission levy based on “polluter-pay principle”; (d) design rules and standards for the entire brick value chain: from raw materials to production processes and equipment and final products to building designs and construction processes. 9. Develop industrial parks to accommodate a large number of industries on flood-free land. These parks would mean less cost for kiln owners, due to the economy of scale achieved by providing the basic infrastructure for all kilns (e.g. roads, electricity, water) and other facilities (e.g. schools for the employees’ children). They would also require less land for kilns establishment compared to the current situation 11. 10. Improve working conditions by introducing higher levels of mechanization, social programs to reduce child labor, occupational safety and health measures in kilns.

World Bank (2011) assessed that 6,400 acres of land would be needed over a 20-year program to build new factories in either brick parks or in other places specifically designated for brick production. At the same time, about 3,300 FCK entrepreneurs would have switched to VSBK and/or Zigzag factories, freeing up approximately 8,000 acres of lowland for cultivation.

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C HAPTER 1. I NTRODUCTION

With about 5,000 operating kilns 12, brick-making is a significant sector in Bangladesh (Box 1.1), contributing about 1 percent to the country’s gross domestic product (GDP) and generating employment for about 1 million people (BUET 2007). Brick is the main building material for the construction industry, which has been growing at about 5.6 percent annually between 1995 and 2005, leading to an estimated growth rate of 2–3 percent for the brick sector. Despite the importance of the brick sector, about 95 percent of kilns use outdated, energy-intensive technologies that are highly polluting. Those located in the North Dhaka cluster are the city’s main source of fine particulate pollution 13, accounting for 40 percent of it during the 5-month operating period. This causes harmful impacts on health (from particulate matter) and agricultural yields (from nitrogen oxides) and contributes to global warming (from carbon dioxide). As Dhaka is one of the most polluted cities in Asia (Figure 1.1 14), addressing the impact of brick kilns on pollution in this city is very important.
180 160 140 120 100 80 60 40 20 0 Figure 1.1. PM10 Concentration levels: Dhaka and other Asian Cities

Beijing

Dhaka

New Delhi

Kolkata

Shanghai

New technologies, such as the Vertical Shaft Brick Kiln (VSBK) and the Hybrid Hoffmann Kiln (HHK), are substantially cleaner than the Fixed Chimney Kiln (FCK) currently used. These improved technologies consume less energy and emit lower levels of pollutants and greenhouse gases (GHGs) (BUET 2007; Heirli and Maithel 2008; World Bank 2011a). However, because the use of these technologies in Bangladesh is still in the pilot stage of implementation, their financial viability (compared with that of the FCK) still needs to be demonstrated.

The objectives of this study are: (i) to present the pros and cons of existing and alternative brick technologies in Bangladesh, with specific focus on pollution and energy efficiency; (ii) to estimate the private and social benefits of these technologies (iii) to summarize China’s experience in the development of the brick industry, as the world leader brick producer and (iv) to provide concrete recommendations for adopting cleaner technologies in Bangladesh.

Kiln estimates vary by source, ranging from 4,140 (GEF–UNDP, 2006) to 5,000 (BUET, 2007) and up to 6,000 (informal estimate) (DOE 2010). This report uses the latest survey-based data of 5,000. 13 Fine particulates refer to PM with a diameter of less than 2.5 µm, which are more harmful to health than particulates with larger diameters (Pope et al. 2002). 14 Data refer to 2006 and are based on the Department of Environment (DOE) for Dhaka and http://www.baq2008.org/about-bangkok/air-quality-and-climate-change-action for the other cities

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micrograms per cubic meter

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The study conducts a Cost Benefit Analysis (CBA) that considers not only the direct costs and benefits for the entrepreneur, but also the impacts of air pollution on health and the effects of CO2 emissions on climate change. The analysis focuses on the brick kiln cluster north of Dhaka city, which is one of the country’s major brickfield areas. The originality of this report stems from: (1) primary data collection, based on the IFCK (DA-PA, 2009), VSBK (DA-PA, 2010) and HHK (CDM, 2009) pilot projects 15 and on a series of interviews conducted with FCK owners near Dhaka. (2) first-time economic valuation of the overall impacts of different kiln technologies, and comparison among them; (3) first comprehensive review of 20 years’ of China’s (the world leader brick producer) experience in technology change and government regulation in the brick sector to provide lessons learned for Bangladesh. As such, this report is expected to substantially bridge the knowledge gap in terms of data collection, methodology and realistic recommendations for the improvement of Bangladesh brick sector. As the first attempt to estimate the social impacts of brick kilns in Bangladesh, the accuracy of the estimates is sometimes constrained by data limitations. In some cases, data constraints imposed the use of conservative assumptions. In other cases, the lack of data was replaced by information available from the implementation of these technologies in neighboring countries (e.g. Nepal, India). As a result, all valuations should be regarded as orders of magnitude rather than precise estimates. The study was initiated in 2009, following several consultations with stakeholders in Bangladesh. It draws on two analyses completed under the Clean Air and Sustainable Environment Project (Credit 4581-BD) (DA–PA 2009 and 2010). The present study provides input to a potentially large brick operation that will result in cleaner air quality for the city of Dhaka. This report is organized as follows. Chapter 2 presents an overview of the brick sector in Bangladesh, focusing on its challenges and opportunities. Chapter 3 describes the main brick technologies used in Bangladesh, while Chapter 4 portrays the main characteristics of cleaner, alternative technologies. Chapter 5 estimates in monetary terms the private and social profitability of selected technologies. Chapter 6 presents the experience of China, the world’s leader in brick production. Chapter 7 provides the main conclusions and recommendations for achieving a more sustainable brick sector in Bangladesh.

These include an IFCK piloted in Rupganj (Narayangunj) during the preparation of the Clean Air and Sustainable Environment (CASE) project; a VSBK piloted with funding from Energy Sector Management Assistance Program (ESMAP) and the preparation by the World Bank of an Emission Reduction Purchase Agreement (ERPA) for a HHK in Savar.

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Box 1.1 Brick is an important construction material in Bangladesh. Bangladesh has very limited supplies of natural stones. About 44% of houses in Dhaka (according to the 1991 census) were built using bricks as the major wall material (Rashid, 2007). Bricks are also widely used, not only for housing construction, but also for construction of roads, pavements, bridges, irrigation structures and as aggregate in concrete mix (FAO, 1993).
Houses (dwelling units) by construction material in Dhaka City % Material of wall Total no of houses 31% Straw, Bamboo 342,820 12% Mud, un-burnt brick 125,467 13% C.I. Sheet, Metal 142,319 30%) Coal Gangue Brick Coal Ash Brick Sand Lime Brick 23% Source: MoEP (2009). Note: These brick categories do not exactly match those provided in the text due to the various data sources.

According to the MoEP (2009), China’s brick production increased from 200 billion to 1 trillion standard Chinese bricks during 1982-2008. In the last decade, total production expanded, owing to the growing number of new brick products and the declining use of solid clay bricks (from 600 billion to 400 billion). The new bricks target set for the 11th Five-Year Plan (2005–2010) was above 55 percent, while production of solid clay bricks was below 380 billion (Figure 6.2). The diversity of brick raw material continues to increase. Figure 6.2: Production of solid clay bricks and new brick products, 1995–2010
Billion Standard Brick 1200 900 600 300 0 1995 2000 2005 2008 2010 target (11th FYP)

Solid Clay Brick

New Brick

Sources: Various Chinese sources and author’s own estimates. Note: Data for 2010 represents the estimated target for the 11th Five-Year Plan

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Energy efficiency 87. Improving the energy efficiency of brick-making is strongly aligned with the country’s long-term strategy for sustainable development. Replacing clay with alternative raw materials and using natural drying have improved energy efficiency and saved resources considerably. Zhang (1997) reported that coal consumption per 100,000 bricks declined from 18 tce in 1980 to about 13.8–14.5 tce in 1990. 88 China Brick & Tile Industry Association (CBTIA 2005) estimated that coal consumption decreased from 14.5 tce per 100,000 bricks in the 1980s to 5.3–6.6 tce per 100,000 bricks for the 11th Five-Year Plan (2005-10) (Table 6.6). Table 6.6: Summary of environmental achievements, 1980–2010
Environmenal factor Energy intensity (tce/100,000 bricks) Total energy saved (million tce) Waste used (million t) Clay saved (million t)
Source: CBTIA (2005). Note: n.a. = not available.

1980s 14.5 n.a. n.a. n.a.

1995–2000 n.a. 60 200 n.a.

2000–05 6.6~7.9 32 250 263

2005–10 (target) 5.3~6.6 10 300 n.a.

Wang, Chang, and Zhu (2009) reported that energy consumption per 100,000 bricks for fired wall materials declined from 11.9 tce in 2000 to 9.2 tce in 2007 (Table 6.7). 89 Growing production of new wall materials, which are more energy efficient than solid clay bricks, drove the average increase in energy efficiency. Table 6.7: Energy consumption intensity of fired wall materials in China
Consumption type Coal Electricity Total
Source: Wang, Chang, and Zhu (2009). Note: n.a. = not available.

Unit of measure tce/100,000 bricks kWh/100,000 bricks tce/100,000 bricks

1990 13.8–14.5 n.a. n.a.

2000 11.9 2,900 13.0

2005 10.5 3,300 11.9

2007 9.2 3,700 10.7

Brick-making processes. China uses various brick-making processes. As the brick industry started to diversify, comparing energy efficiency among processes became more complicated. Energy efficiency depends on the raw material used, the final product, and the techniques applied in the processes of brick molding, drying, and firing. According to the energy-efficiency and production scale, 90 fired brick-making processes in China can be categorized into three tiers (Wang, Chang, and Zhu 2009):
For comparison, all the energy efficiency/intensity parameters and pollution indicators in this section are converted into the units used in Bangladesh. In terms of unit energy used by kiln type, the Intermittent kiln has the highest level of fuel consumption per brick. To produce 100,000 bricks, it uses as much as 20–25 tce of coal and no electricity. The Hoffmann kiln uses about 8–10 tce per 100,000 solid bricks, with small plants on the high end and large plants on the low end. Small plants use 3,000– 4,000 kWh per 100,000 solid bricks. However, if the combustion body fuel is mixed with clay, considerable reduction in net energy use can be achieved.The Tunnel kiln has a high level of mechanization, which tends to require more energy than the Hoffmann kiln; thus, the tunnel kiln is reported to consume an average of about 13 (10–15) tce of coal per 100,000 bricks and 3,500–4,500 kWh of electricity. To produce hollow bricks using Tunnel kilns, coal use per 100,000 bricks drops considerably to 8 tce, while electricity use increases to 4,500–5,500 kWh (Zhang 1997).
89 90 87

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Fired wall materials include most brick products (e.g., solid clay bricks and waste-using bricks). Considering external fuel consumption only.

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• The first tier relates to the firing process with coal consumption below 1 tce per 100,000 bricks. The firing process relies mainly on the residual heat from industrial wastes. The main raw materials are shale, coal gangue, and coal ash. Products mainly include hollow bricks, perforated bricks, and hollow blocks. The production process uses vacuum extruder (for molding), artificial drying, and the Tunnel kiln. The enterprises have a production scale of more than 30 million bricks per year and account for 2–3 percent of total enterprises in the brick sector.

• The second tier relates to a coal consumption of 6.6–9.2 tce per 100,000 bricks. Shale or clay is the major raw material, mixed with low-quality coal. Coal gangue or coal ash is the internal fuel. The main products are perforated fired bricks, and the production processes combine natural and artificial drying using either the Hoffmann or Tunnel kiln.

• The third tier is the least efficient, with 10.5–14.5 tce per 100,000 bricks, accounting for the majority of brick-making enterprises (70 percent of the total). It includes numerous small enterprises that produce solid clay bricks by natural drying and firing. It uses the Hoffmann or primitive Hoffmann kilns, located in rural areas, with an annual production of 6–15 million standard Chinese bricks per kiln. 91 Pollution levels. Among the various brick kilns in China, the Intermittent kiln emits the highest levels of SO2 and CO2 (Table 6.8). Table 6.8: Emissions of SO2 and CO2 in China by kiln technology, 1990
Kiln technology Intermittent Hoffmann Natural drying, solid bricks Artificial drying, solid bricks Artificial drying, hollow bricks Tunnel Artificial drying, solid bricks Artificial drying, hollow bricks SO2 emissions (t/million Bangladesh bricks) 6.6 3.6 3.6 2.1 4.6 2.6 CO2 emissions (t/million Bangladesh bricks) 149 82 83 49 105 63

Source: Zhang (1997). Note: The original data, expressed in standard Chinese bricks, have been converted in Bangladesh bricks.

Overall, increasing use of new brick products has accounted for the dramatic growth in China’s brick industry. As the industry began to employ newer technologies and materials, energy efficiency and resource conservation (e.g., clay and arable land) increased. The industry also became more conglomerated, with larger emerging product lines and enterprises. In 2005, the new product lines had an annual average capacity of more than 15 million standard Chinese bricks per line. The capacities of new coal gangue brick and coal ash brick lines are more than 30 million bricks per line on average, with the largest reaching 160 million standard Chinese bricks.

Replacing clay with industrial waste can save energy by using the residual heat as internal fuel; but this alone cannot contribute to reducing CO2 emissions.

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6.3 Government Intervention The Chinese government has promoted a series of policies, laws, and regulations to control solid clay bricks and promote new wall material to save clay, land, and energy. It has also invested considerably in developing new technologies to promote the use of locally available materials for clay replacement. This section reviews the major regulations issued by the Chinese government on the brick industry and the institutions and organizations that have contributed to managing and facilitating its healthy development. Laws and regulations. In 1988, regulation of the brick and tile industry was initiated by the Chinese government with two objectives: (i) to control the use and production of solid clay bricks and (ii) promote research and development (R&D), production, and use of new wall materials. Table C-1 (Annex C) provides a comprehensive list of the major sector-specific laws and regulations issued by the government, including the responsible institutions 92. The Wall Material Renovation program includes all policies, laws, and regulations issued by the Chinese government. Many government offices at the ministry level are involved in issuing, monitoring, and implementing the regulations. 93 • In 1992 the Government started to control solid clay bricks by issuing the “Circular of advice on how to accelerate wall material renovation and to promote energy efficient buildings”. In 1999 the Government banned the use of solid clay bricks in coastal cities and cities where land was scarce. In the same year, the State Office of Wall Material Renovation of the National Development and Reform Commission identified the first 170 cities 94 expected to limit the use of solid clay bricks to certain targets by 2003. In 2005, the Government banned all clay-building products in the 170 cities and extended the regulation to suburban areas. It also banned the use of solid clay bricks in other 256 cities by 2008. In 2004, the Government mentioned for the first time the controlled use of solid clay bricks in small towns and rural areas. It established national targets to reduce their production by 80 billion bricks by 2006 and prohibit their use in all cities by 2010. In 2007, the 11th Five-Year Plan established targets for China’s brick and tile industry, centered on (i) developing new wall materials, (ii) conserving land resources, (iii) saving energy and other resources, and (iv) phasing out outdated technologies.









The compilation is based on a review by Zhang (2009) and the author’s review of government websites (Table C-1). These include the State Council, former Ministry of Construction (MoC), National Development and Reform Commission (NDRC), Ministry of Science and Technology, Ministry of Agriculture (MoA), former Bureau of Land, former Ministry of Economy and Trade, Administration of Taxation, and State Bureau of Quality and Technical Supervision, with strong support from China Bricks and Tiles Industrial Association (CBTIA) and such research institutes as Xi’an Research and Design Institute of Wall and Roof Materials. 94 the municipalities, middle and large cities in the coastal areas, and middle and large cities in provinces where per capita arable land is below 0.8 mou (about 534 m2).
93

92

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Policies supporting new wall materials. Specific policies to support development of new wall materials can be divided in three types, based on their targets: (i) brick industry, (ii) raw materials (upstream sector), and (iii) construction industry (downstream sector). Policy tools include command-and-control and economic instruments. The economic incentives mainly include reduction of and exemption from income tax, VAT, and custom duties, as well as provision of financial support via preferential loans and specific funds. Table C-1 (Annex C) provides specific policies for supporting the new wall materials, based on the CBTIA (2009) and China Energy Information Networks (2010). Main features of policies, laws, and regulations. The main features of the policies, laws, and regulations for the brick and tile industry, based on more than 10 official regulations issued by the government since 1990, 95 are summarized as follows: • Command-and-control was the major regulating measure for phasing out solid clay bricks and polluting technologies; this was facilitated via such economic instruments as specific funds and preferential tax policies on promoting new wall materials. The economic instruments have been essential to adjusting the cost and price gaps between traditional solid clay bricks and new wall materials. • At the outset, national laws set up strategies and macroeconomic development plans pushed by the central and (in many cases) most powerful government ministries (e.g., the NDRC or State Council) and were then detailed with specified regulations and policies. • The theme was changing the market environment, with intervention focused at the enterprise level. • Comprehensive policies, laws, and regulations were designed and issued, and the value chain of bricks was extended to raw materials, production processes and equipment, final products, building designs, and construction processes. Upstream and downstream regulations worked together to help guide brick-sector development in the preferred direction. • Close inter-institutional collaboration was essential for making policies, laws, and regulations work compatibly within the extended value chain of bricks. Table C-1 (Annex C) shows that many policies, laws, and regulations were jointly prepared and issued by several government authorities. • Implementation was devolved from central to provincial, municipal, and local government. • Enterprise conglomeration and technology promotion were jointly supported (since they are usually interlinked, supporting one would benefit the other). • Regulations started from locations with the highest implementation capacity (e.g., municipalities, large cities, and coastal cities with relatively low targets) and then expanded into suburban and even rural areas. • Policies, laws, and regulations have been consistently monitored, reviewed, and evaluated to identify problems that emerged from implementing earlier regulations; thereafter, they were updated by setting up higher targets through more stringent regulations that provided continuous stimulus for consolidating achievements.

95

Order of State Council #82, KJ: [1991] No.619, GF: [1992] No. 66, CSZ: [1994] No.1, CSZ: [1995] No.44, GF: [1996] No. 36, GF: [1997] No. 37, KJH: [1998] No. 68, GBF: [1999] No.72, JZ: [1999] No. 295, CS: [2008] Nos.117 and 156, and so on.

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• To date, government regulations have been driven by energy, clay, and land savings. As a co-benefit, pollution emissions have been reduced substantially; however, emissions control from the brick industry has lagged, compared to other industrial sectors. 96 6.4 Current Problems and Challenges Ahead China’s brick industry is at a critical stage in the process of transforming its industrial structure, and many serious issues remain; key among them are the following:

• Solid clay bricks still account for about half of total brick production. Phasing out solid clay bricks confronts significant barriers. As demand for construction materials escalates with the economy, prices for solid clay bricks become more competitive due to relatively cheap labor and clay. Development of new bricks is hampered. Local governments have substantial influence over the brick industry, and local protectionism prevails. Once the central government removed agriculture taxes, the brick industry became a more important source of local fiscal income, especially in less developed, remote regions. Thus, phasing out solid clay bricks is against local governments’ interest as tax collectors.

• Small enterprises still dominate the brick industry. About 60 percent of brick enterprises produce less than 10 million bricks per enterprise annually, accounting for about 20 percent of total bricks. These enterprises follow simple production and management models, apply outdated technologies, and use unskilled labor. Therefore, their productivity and energy efficiency are also relatively low. In addition, their dominance makes it difficult to phase out solid clay bricks and encumbers the adoption of new technologies.

• Pollutant emissions are rarely controlled and treated. According to the CBTIA (MoEP
(2009), emissions from brick and tile kilns in China are usually not treated. Nationwide, there are fewer than 10 brick and tile enterprises equipped with emissions treatment facilities. 97 In addition, because environmental regulations are loose overall, treatment equipment is not operational most of the time. The brick industry faces two major hurdles to control emissions: (i) most enterprises lack sufficient capital to invest in emissions reduction equipment and (ii) the value added and profit rate are low, leaving little margin for the cost of emissions control. For example, a sulfur scrubber is technologically difficult and unaffordable for small producers. Promoting Tunnel kilns in newly constructed enterprises (and gradually phasing out Hoffmann kilns) and using cleaner fuels (such as industrial waste and low-sulfur coal) can help reducing emissions.

The draft regulation under discussion is related to establishing standards for PM, SO2, NOx, and fluoride. Once finalized, the regulations with emissions indicators will be effective for all new factories immediately after issuance; for existing factories, the new emissions indicators will become effective starting January 1, 2013 (Table C-2, Annex C). 97 For PM emitted during the processes of grinding and transport, some firms have installed bag filters, while most use air-tight treatment to reduce emissions.

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C HAPTER 7. T OWARD A SUSTAINABLE BRICK SECTOR IN BANGLADESH

Bangladesh’s brick sector is characterized by outdated technologies with low energy efficiency and high emissions, low mechanization rate, dominance of small-scale brick industries with limited financial capacity, and dominance of single raw material (clay) and product (solid clay brick). Adopting gas-based cleaner technologies is hampered by serious energy shortage and land scarcity. How long can the country afford making bricks in this way? The current status is by no means sustainable. Bangladesh has every reason to upgrade its brick sector in order to save valuable natural resources, reduce air pollution, and increase energy efficiency. The government has already established regulations that ban the use of fuelwood and FCKs and has reconsidered the location and height of brick kiln chimneys. However, transformative development of the brick industry has yet to occur. This report suggests that the development of the brick industry in Bangladesh over the next 20 years should aim at: (i) moving from traditional brick-making technologies (e.g. FCK) to cleaner ones (e.g. HHK, VSBK); (ii) diversifying products (e.g. hollow and perforated bricks) and finding alternative raw materials that are locally available; (iii) increasing the proportion of large-scale enterprises with higher capacity to adapt to cleaner technologies. To achieve these goals, a summary of concrete recommendations is provided below. Table 7.1 presents a comprehensive set of policy recommendations drawn from this study, together with the institutions responsible for their achievement. In the short-term: 1. Recognize brick kilns as a formal industry. This would enable easier access to financial resources (which in turn will enable investment in cleaner technologies and access flood free land) and improved working conditions. 2. Create a Brick Technology Center to raise awareness about the benefits of cleaner technologies. The center should: (a) disseminate information on the social benefits provided by cleaner technologies, new wall materials (e.g. perforated and hollow bricks) and alternative raw materials; (b) promote pilot projects of new technologies with improved provisions (e.g., mechanized, higher labor productivity and larger product lines); (c) improve use of existing dissemination channels (e.g., field visits to pilot plants, video demonstrations of the technologies, use of the Bangla language) and introduce new channels (e.g., newsletters, industry journals, conferences, and Internet blogs). 3. Support research and development aiming at: (a) exploring alternative raw materials 98 that are locally available, brick diversification, and use of higher level of mechanization; (b)
A word of caution should be mentioned about the use alternative raw materials, where strong quality control should be kept in regulators’ mind. Some alternative raw materials, especially wastes, may contain toxics that are harmful to human health. Pertinent policies, laws, and regulations need to be developed and set up to make sure no hazardous raw materials are used while they are adopted in the industry. In the past few years, local governments in China have strengthened regulations to prohibit hazardous materials from being used for wall material production and developed a series of standards for quality control of new products, to safeguard favorable development of this industry.
98

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conducting new studies such as energy consumption studies, land surveys, and brick technology surveys. 4. Facilitate the availability of subsidized credit lines to account for reduced health impacts from pollution and of other economic incentives supporting the production of new wall materials and use of alternative raw materials (e.g. via specific funds and preferential tax policies, as in China). 5. Provide access to carbon markets, on account of the carbon emission reductions provided by cleaner technologies. 6 . Train several stakeholders with regard to the benefits of adopting cleaner technologies (e.g. brick owners, workers and the financial sector). In the medium term: 7 . Enforce the existing regulations and policies, such as the ban of traditional high polluting kilns (e.g. FCK, BTK), particularly those located close to large population centers, upstream of the wind (north) in the dry season (November to April). 8. Introduce regulations and policies that encourage adoption of cleaner technologies, such as: (a) revise emissions standards for brick kilns under ECR97 to make them technology independent and to encourage brick diversification (e.g., perforated or hollow bricks for partition walls); (b) establish proper emission monitoring for brick kilns; (c) impose an emission levy based on “polluter-pay principle”; (d) design rules and standards for the entire brick value chain: from raw materials to production processes and equipment and final products to building designs and construction processes. 9 . Develop industrial parks to accommodate a large number of industries on flood-free land. These parks would mean less cost for kiln owners, due to the economy of scale achieved by providing the basic infrastructure for all kilns (e.g. roads, electricity, water) and other facilities (e.g. schools for the employees’ children). They would also require less land for kilns establishment compared to the current situation 99. 10. Improve working conditions by introducing higher levels of mechanization, social programs to reduce child labor, occupational safety and health measures in kilns.

World Bank (2011) assessed that 6,400 acres of land would be needed over a 20-year program to build new factories in either brick parks or in other places specifically designated for brick production. At the same time, about 3,300 FCK entrepreneurs would have switched to VSBK and/or Zigzag factories, freeing up approximately 8,000 acres of lowland for cultivation.

99

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Table 7.1. Recommendations and institutions concerned with their implementation
Recommendations In the short term 1. Recognize brick kilns as Small and Medium Enterprises (SMEs) 2. Create a Brick Technology Center 3. Support research and development 4. Facilitate the availability of subsidized credit lines and other economic incentives 5. Provide access to carbon markets 6. Train several stakeholders with regard to the benefits of adopting cleaner technologies In the medium term 7. Enforce the existing regulations and policies 8. Introduce regulations and policies that encourage adoption of cleaner technologies 9. Develop industrial parks to accommodate a larger number of industries Ministry of Industries (MOI), Department of Environment (DOE), DOE, BBMOA, MOEF DOE, Research Institutions and Academic Institutions concerned

MOEF, MOF (Ministry of Finance), Bangladesh Bank, Financing Institutions DOE Brick Technology Center, BBMOA

DOE, MOEF, Bangladesh Standards and Testing Institution (BSTI) DOE, MOEF Bangladesh Small and Cottage Industries Corporation (BSCIC), MOI, DOE DOE, Ministry of Labor and Social Welfare (MOLSW), Ministry of Women Affairs (MOWA), Entrepreneurs, BBMOA

10. Improve working conditions

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———. 2006. Bangladesh Country Environmental Analysis. Report No. 36945-BD. Volume II: Technical Annex: Health Impacts of Air and Water Pollution in Bangladesh. South Asia Environment and Social Development Unit. ———. 2008. Introducing Energy-efficient & Cleaner Technologies & Practices in the Brick-making Sector in Bangladesh, Concept Note, April 2008. ———. 2009. World Development Indicators (WDI). World Bank. Washington D.C. ———. 2010. Data Development Platform. Accessed September 2010. ———. 2011a. Improving Kiln Efficiency in the Brick Making Industry in Bangladesh. Project Design Document Form. CDM-SSC-PDD. Version 04/03/11. World Bank. Washington D.C. ———. 2011b. Alternative cleaner brick making technologies. Proposed technology diversification program. BTOR. Internal document. World Bank. Zhang, Z. 1997. Energy Efficiency and Environmental Pollution of Brickmaking in China, Energy, Vol 22, No.1, pp 33-42 ———. 2009. Some Discussion on the Current Status and Industrial Policies of China’s Brick and Tile Industry, Brick and Tile, Issue 3, pp 34-37.

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ANNEX A. E STIMATING THE H EALTH I MPACTS OF K ILN P OLLUTION

This annex estimates the health impacts of kiln pollution related to (i) infant and child mortality from respiratory diseases caused by short-term PM10 exposure, (ii) adult mortality from cardiopulmonary diseases and lung cancer caused by long-term PM2.5 exposure, and (iii) all-age morbidity resulting from PM10 exposure. Croitoru and Sarraf (2010) provide a detailed case study of the valuation of health impacts on air pollution. A five-step process was used to measure the health impacts: (i) identify the pollutants and measure their concentration, (ii) estimate the population exposed, (iii) establish dose-response coefficients, (iv) measure the health impacts (physical valuation), and (v) measure the health impacts (monetary valuation). Physical valuation was based on the Disability Adjusted Life Years (DALYs), a method developed and applied by the World Health Organization (WHO) and the World Bank in collaboration with international experts that provides a common measure of disease burden for various illnesses and premature mortality (WHO 2009). The method weighs illnesses by severity so that a relatively mild illness or disability represents a smaller fraction of a DALY, while a severe one represents a larger one. The mortality due to health problems is expressed in terms of DALYs: a year lost to premature mortality represents 1 DALY, and future years lost are discounted at a fixed rate of 3 percent. Morbidity is expressed in terms of DALYs and other costs of illness. Monetary valuation used two approaches to estimate the value of 1 DALY. The first one, the human capital approach (HCA), estimates the indirect cost due to productivity loss through the value of an individual’s future earnings (Kirch 2008). Accordingly, 1 DALY corresponds to one person’s average contribution to production, namely the GDP per capita. This method provides a lower bound for the loss of 1 DALY. The second approach, Value of Statistical Life (VSL), measures the willingness to pay to avoid death by observing the individual behavior when trading off health risks and money (Johansson 2006). The VSL is estimated by dividing the marginal willingness to pay for reducing the risk of death by the size of the risk reduction. The value of 1 DALY corresponds to the VSL divided by the average number of discounted years of life lost due to an adult’s death (World Bank 2005). The VSL method provides an upper bound of health damages. The direct, illness-related costs that society incurs are computed using the cost-of-illness approach, which estimates the treatment costs linked to various health endpoints (e.g., hospitalization, restricted activity days, or doctor visits) and the cost of time provided by caregivers to treat sick individuals (e.g., caregiver’s wage).

Step 1. Identify the pollutants and measure their concentration This step estimates the contribution of each brick technology to the average PM2.5 and PM10 concentrations in Dhaka. Estimating the contribution of the FCK to the average ambient PM10 concentration. The PM10 ambient concentration averages 150.5 µg per m3, based on daily measurements for 2006, according
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to the Department of Environment. 100 Guttikunda (2009) states that brick kilns in the cluster north of Dhaka city contributed two-fifths of the measured fine particulates during the five-month operating period. Using a source apportionment model, Begum, Biswas, and Hopke (2010) estimate that brick kilns are the most important source of pollution, with fine-fraction particulates (PM with a diameter of less than 2.5 µg) during kiln operation accounting for 38 percent of total mass.101 Based on these data, the annual contribution of the FCKs to the ambient PM10 concentration is estimated at 14–36 µg per m3, 102 which corresponds to an average of 25 µg per m3 or 17 percent of the average ambient PM10 concentration in Dhaka. Estimating the IFCK, VSBK and HHK contributions to the average ambient PM10 concentration. As most kilns in the North Dhaka brick cluster are FCKs, the contribution of the IFCK, VSBK, and HHK to average PM10 concentration in Dhaka cannot be measured. Estimating these contributions is also difficult, as it depends on several factors, such as: total emissions from each kiln, kiln type, dispersion patterns of these emissions, location of kilns, etc. Use of elaborate dispersion models accounting for all these factors can produce an accurate estimation of these contributions. Time constraints made it impossible to conduct such an analysis in the context of this study. Thus, it is assumed that pollution concentration at a receptor site is proportional to the emission rate. In other words, emission rates are assumed to have a linear impact on the pollutant concentration at the receptor site. Several emission models have used this assumption (e.g. Meaud 2005; Repace 2005). Table A-1 estimates the emissions from each kiln type, assuming that total brick production from the northern brick-kiln cluster (2.1 billion bricks) could be obtained by replacing the 530 FCKs with 530 IFCKs, or 442 VSBKs, or 140 HHKs. The valuation is based on measurements of emissions per brick available in Bangladesh (for FCK, IFCK and HHK), and Nepal and India (for VSBK). Table A-1: Estimate of mass emission load of suspended particulate matter by kiln type
Kiln type Production capacity (million bricks/kiln) 4 4 4.8 15 Number of kilns needed to produce 2.1 bil. bricks 530 530 442 140 SPM emission load (kg/10,000 bricks) 17.1a 8.6b 5.6c 8.7d SPM total emission load from producing 2.1 bil. bricks (000 t/year) 3.6 1.8 1.2 1.8

FCK IFCK VSBK HHK

Sources: aTuladhur, Acharya, and Raut (2006), Baum (2010), and Khan (2008) for FCK; Baum (2010), b Based on emissionsload data for the FCK and BUET (2007) for the ratio in stack emissions between the FCK and the IFCK; c Based on measurements per 10,000 bricks of 3.1–28 kg of SPM for 4 VSBKs in India (Ministry of Environment and Forests, 2007) and 5.3–7.2 for 2 VSBKs in Nepal (IEM 2004). d Khan (2008) for HHK.

PM values are monitored on a 24-hour average basis; however data are not available for all days in a month, and the number of days per month for which data are monitored is also unequal. 101 Data refer to the 2005–06 operation period. Other contributors to fine-particulate pollution include motor vehicle (19 percent), road dust (18 percent), soil dust (9 percent), metal smelter (7 percent), Zn source (7 percent), and sea salt (2 percent). 102 Accordingly, Khaliquzzaman (2006) estimated the contribution of FCKs to the average PM10 concentration at 12.56 µg/m3, as a population-weighted average for each thana of Dhaka; this result is in line with the lower end of the range found in Begum, Biswas, and Hopke (2010).

100

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Table A-2 estimates the contribution of each kiln type to the average PM10 concentration, assuming it is proportional with the emissions ratio between the selected kiln types. For example, the contribution of the IFCK is estimated at 12.5 µg per m3, using the ratio of the SPM emission loads between the IFCK and the FCK (1.8/3.6). The PM10 levels are then converted to PM2.5 levels, using a factor of 0.6 (Cohen et al. 2004). Table A-2: Summary of contribution to average PM10 and PM2.5 concentrations, by kiln type
Kiln type Production capacity (million bricks/kiln) 4 4 4.8 15 Number of kilns needed to produce 2.1 bil. bricks 530 530 442 140 Contribution to average PM10 concentration (µg per m3) 25.0 12.5 8.2 12.7 Contribution to average PM2.5 concentration (µg per m3) 15 7.5 4.9 7.6 Sources for estimating contribution to average PM10 concentration Begum, Biswas, and Hopke (2010) = 25.0 * 1.8/3.6* = 25.0 * 1.2/3.6* = 25.0 * 1.8/3.6*

FCK IFCK VSBK HHK
*

See Table A-1.

Step 2. Estimate the population exposed Since no accurate information was available on the population exposed to PM10 and PM2.5 from the brick industry, this was estimated by multiplying the total population of 12.8 million in the metropolitan Dhaka area (BBS 2009) by a coefficient of exposure. It is sometimes argued that all people in Dhaka are exposed to these pollutants due to north-south winds during the brick season. 103 Because of data uncertainty, it was conservatively assumed that about 90 percent of Dhaka’s total population, or 11.5 million is exposed.

Step 3. Establish dose-response coefficients The health impacts on mortality and morbidity were valued based on international coefficients developed in the scientific literature. Mortality. The impacts of PM10 and PM2.5 on mortality can be estimated based on mortality rates due to specific diseases and the relative risk (RR) functions provided below (Ostro 2004). As PM2.5 data were not available for Bangladesh, they were estimated by converting PM10 levels using a factor of 0.6 (Cohen et al. 2004). The threshold levels used were 10 μg per m3 for PM2.5 and 20 μg per m3 for PM10, based on WHO air-quality guidelines (WHO 2005). 104 • For mortality related to short-term exposure of children under 5 years,

103 104

Personal communication with I. Hossain, September 2009. These figures represent the baseline concentrations below which there are no health impacts.

69

RR = exp[β (x-x0)], where β ranges between 0.0006 and 0.0010, x = current annual mean concentration of PM10 (μg per m3), and x0 = baseline concentration of PM10 (μg per m3). • For cardiopulmonary mortality related to long-term exposure of adults over 30 years (Pope et al. 2002), RR = [(x + 1)/(x0+1)]β,

where β ranges between 0.0562 and 0.2541, x = current annual mean concentration of PM2.5 (μg per m3), and x0 = baseline concentration of PM2.5 (μg per m3). • For lung-cancer mortality related to long-term exposure of adults over 30 years (Pope et al. 2002), RR = [(x + 1)/(x0+1)]β,

where β ranges between 0.08563 and 0.37873, x = current annual mean concentration of PM2.5 (μg per m3), and x0 = baseline concentration of PM2.5 (μg per m3). Morbidity. The impacts of PM10 on morbidity considered the health endpoints of chronic bronchitis, hospital admissions of patients with respiratory problems, emergency room visits, restricted activity days, lower respiratory infections in children, and general respiratory symptoms. The health effects of air pollution were then converted to DALYs (Table A-3). Table A-3: Dose-response coefficients for morbidity and DALYs by annual health endpoint
Annual health endpoint Chronic bronchitis (per 100,000 adults) Respiratory hospital admissions (per 100,000 people) Emergency room visits (per 100,000 people) Restricted activity days (per 100,000 adults) Lower respiratory illness (per 100,000 children) Respiratory symptoms (per 100,000 adults) Dose-response coefficient* 0.9 1.2 23.5 5,750 169 18,300 DALYs lost per 10,000 cases 22,000 160 45 3 65 0.75

Sources: Ostro (1994), Abbey et al. (1995), and Larsen (2004). * Expressed per 1 ug/m3 annual average ambient concentration of PM10.

70

Step 4. Measure the health impacts (physical valuation) Estimating the health impacts of a certain technology is based on its added contribution to PM10 and PM2.5 average ambient concentrations. For example, the health impacts of FCKs stem from their contribution of 25 µg/m3 to the PM10 average ambient concentration. Overall, the loss of DALYs per million bricks is the lowest for the HHK (1.6) and VSBK (1.9) and the highest for the FCK (5.5) (Table A-4). Table A-4: Estimated loss of DALYs from kiln pollution
Annual health endpoint DALYs lost per 10,000 cases Mortality related to short-term exposure to PM10 (under 5 years old) Cardiopulmonary mortality related to long-term exposure to PM2.5 (over 30 years old) Lung cancer mortality related to long term exposure to PM2.5 ( over 30 years old) Total mortality Chronic bronchitis (adults) Respiratory hospital admissions Emergency room visits Restricted activity days Lower respiratory illness (children) Respiratory symptoms Total morbidity Morbidity plus mortality DALYs per million bricks Sources: World Bank 2005, Larsen 2004. 80,000 80,000 Total DALYs per Kiln FCK IFCK (4 million) (4 million) 2.0 8.8 VSBK (4.8 million) HHK (15 million) 3.9

1.0 4.6 0.2 5.9 0.0 0.1 0.3 1.7 1.9 1.4 5.3 11.2
2.8

0.8 3.7

0.0 80,000 0.4 11.3 0.0 0.1 0.6 3.4 3.8 2.7 10.6 21.9 5.5

0.2 4.7 0.0 0.0 0.2 1.3 1.5 0.9 4.0 8.6
1.8 0.0 3.9 0.0 0.2 1.1 6.5 7.2 5.1 20.2 24.1 1.6

22,000 160 45 3 65 0.75

Step 5. Estimate the health impacts (monetary valuation) The total cost of the health impacts of pollution includes the monetary value of the DALYs estimated in Step 4 and the cost of illness (Table A-5).

71

Table A-5: Summary of damage cost of air pollution caused by brick kilns
Annual health damages Damage Min Max Average cost (million TK/kiln) (TK/brick) Present value of health damages Averag Damage Min Max e cost (million TK/kiln) (TK/brick)

Kiln type (million bricks) FCK (4) IFCK (4) VSBK (4.8) HHK (15)

2.5 1.3 0.9 4.7

14.0 7.1 5.7 26.7

8.2 4.2 3.3 15.7

2.1 1.1 0.7 1.0

20.6 10.5 8.3 39.3

117.1 59.8 47.4 223.6

69 35 28 131

0.9 0.5 0.3 0.5

Note: Based on GDP per capita, VSL, PV of more than 20 years, and a 10-percent discount rate.

Valuing DALYs. Estimates of DALYs lost are based on the HCA as a lower bound and the VSL as an upper bound, thus obtaining a wide range. Applying the HCA, 1 DALY corresponds to the annual GDP per capita, or TK93,500 (2008) (World Bank 2010). 105 Using the VSL method, 1 DALY in Bangladesh is equivalent to TK620,000, after adjusting for GDP per capita differences between the United States and Bangladesh. 106 Cost of illness. This includes the direct cost of treating illnesses, the value of lost work days, and the value of the time spent by caregivers with sick children. Interviews with Bangladesh health experts revealed estimates of the costs of hospitalization (TK1,500 per day), 107 doctor visits (TK400 per visit), 108 and emergency visits (TK400 per visit). 109 The World Bank (2006) estimated the value of lost work days and lost caregiver time at TK60 per day. These figures reflect the economic cost for treatment by most privately-owned clinics and hospitals. In conclusion, the FCK is the most polluting technology, causing annual health damages estimated at about TK0.9 per brick. By contrast, the VSBK is the cleanest technology, with TK0.3 per brick in estimated damages, closely followed by the HHK, with TK0.5 per brick.

Because 2009 data was unavailable at the time of this writing, 2008 data (the most recent available information) was used. 106 The United States Environmental Protection Agency (EPA) uses a VSL for the U.S. for 2006 (http://yosemite.epa.gov/ee/epa/eed.nsf/pages/MortalityRiskValuation.html#currentvsl). Using a GDP deflator of 1.1 (2008/2006), GDP for the U.S. of US$46,700 per capita, and GDP for Bangladesh of US$1,335 per capita (based on an exchange rate of 1US$ = TK70) (World Bank 2010), the VSL for Bangladesh is estimated at TK15.5 million. Dividing by a 25-year period, 1 DALY is equal to TK620,000. 107 Minimum unit cost per bed in a cabin (based on communication with private facilities). 108 The range is TK300–500 (based on communication with private hospitals). 109 The nominal cost of emergency visits is free; thus, the economic cost is assumed to equal the cost of doctor visits.

105

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ANNEX B. DISPERSION OF BRICK K ILN AIR P OLLUTION (PM 10) IN DHAKA

This annex explains the dispersion of air pollutants using a simplified dispersion model. This approach uses a numerical procedure, with fed-in data on sources (e.g., GPS coordinates, emissions, and stack heights) and atmospheric conditions (e.g., temperature, wind speed and direction, mixing height, stability, and precipitation conditions in the form of six hourly data). The numerical procedure calculates pollutant concentrations at given receptor sites. Stack-emissions data are expressed in SPM, while concentrations are calculated for PM10. The dispersion model considers settling of particles of various sizes. BUET (2007) reports model results in terms of averages for a brick-kiln operation period. Model calculations for the 530 kilns of Dhaka city are quite complex. PM10 concentrations have been calculated for 12 locations within roughly a 20 x 30 km area, where most of the Dhaka population resides. These concentrations were used to calculate the annual population exposure to PM10 concentrations (Figure B-1). Figure B-1: Locations in Dhaka for which numerical values for PM10 concentrations were calculated

Source: BUET (2007).

73

Of the 530 kilns in the North Dhaka cluster, those located at distances of 5–30 km from the city center have the greatest effect on Dhaka’s air pollution due to prevailing wind conditions during the brick-burning season (Figure B-2). Figure B-2: Location of brick kilns that contribute most to Dhaka’s air pollution

Source: BUET (2007).

The standard FCK chimney height is 120 ft (36.6 m), twice the assumed average height of 60 ft for the newer kiln types. At a distance of 5 km or more, a small change in stack height (about 20 m) has no appreciable effect on ground-level concentrations (Figure B-3). Figure B-3: Effect of stack height on ground-level PM10 for constant stability classification

Source: BUET (2007).

74

The dispersion model included the impact of changes in wind conditions on concentrations, based on data measurements at six-hour intervals. The effect of wind conditions on concentrations is much greater than that of a small (20 m) change in stack height (Figure B-4). Figure B-4: Effect of stability classification on ground-level concentration for a fixed chimney height

Source: BUET (2007).

Based on the above findings, it can be concluded that exposure data used in the health impact calculations are robust.

75

ANNEX C. P OLICIES, L AWS, AND R EGULATIONS IN C HINA’S BRICK I NDUSTRY

Table C-1: Review of government policies, laws, and regulations for China’s brick industry
Year Policies, laws, and regulations 1992 “Circular of Advice on How To Accelerate Wall Material Renovation and To Promote Energy Efficient Buildings” (GF[1992] No.66) Government units and responsibility Approved and issued by: State Council Submitted by: former Construction Material Bureau; former Ministry of Construction, Ministry of Agriculture, former Bureau of Land Details To accelerate wall-material renovation and development of energy-saving construction, the circular asked relevant government offices to set up policies, laws, and regulations to promote new materials, technologies, and policies to control production and use of solid clay bricks; specifically, they were advised to: • Develop and implement the national new wall material industry development outline and annual plan. • Guide the improvement of national construction materials. • Establish standards for new wall material use, design, and construction rules. • Promote wall material renovation; new types of wall material development; and use of new technologies, techniques, and equipment. • Guide management of a special fund for wall rebuilding and materials reinforcement. Remarks

1999 “Advice on How To Promote Modernization of Housing Industry and To Enhance the Housing Quality” (GBF: [1999] No. 72)

This notice announced the start of China’s wall material renovation. The Advice encouraged the development of new materials and technologies to improve building and relevant parts system. Beginning State Council Office June 1st 2000, use of solid clay bricks was forbidden “in coastal and other cities where land resources are rare” and control of the production and use Issued by: Former Ministry of Construction, of other clay products was also called for, based on possible conditions. former State Planning Commission, State Economic and This notice set one of the benchmarks for development of China’s brick industry. Trade Commission, Ministry of Finance, Ministry of Science and Technology, State Administration of Taxation, State Bureau of Quality and Technical Supervision, Construction Material Bureau

Forwarded by:

76

Beginning June 1st 2000, all new buildings in municipalities, medium and Started from the demand side. Former Ministry of Construction, large cities in coastal areas, and medium and large cities in provinces where per capita arable land is below 0.8 mou (about 534 m2) were advised State Economic and Trade to gradually phase out use of solid clay bricks according to their local Commission, State Bureau of conditions, with a deadline of June 31st, 2003. Quality and Technical Supervision, Construction The State Office of Wall Material Renovation of the National Material Bureau Development and Reform Commission identified the first 170 cities under the SCB phase-out deadline. Executed by: State Office of Wall Material This was the first wall material regulation with a defined timeline for Renovation, National specific regulated objects. Development and Reform Commission Issued by: This circular required that the first batch of cities (among the 170 regulated Follow-up 2004 “Circular of Advice on Further Implementation National Development and by the prohibition of solid clay bricks) that failed to meet their objectives policies to assess of Prohibiting the Use of Reform Commission, Ministry of adopt firmer measures to achieve them by the end of 2004. It also required and monitor local governments to organize and facilitate research and development to Solid Clay Bricks”1 Land and Resources, former former (FGHZ[2004] No. 249) Ministry of Construction, provide technology to support the wall material renovation, prohibit solid regulations and clay bricks, and help to expand the use of new materials in construction. Ministry of Agriculture consolidate results. For the first time, the notice mentioned small towns and rural areas and the government’s commitment on wall material renovation was further defined. Issued by: This standard prescribed the terms and definitions, categorization, 2005 The National Coercive Industrial Standard: Standardization Administration technology requirements, testing measures and rules, and quality “Industrial Standard of of China examination for brick and tile firing kilns. It covered firing of common, Kiln for Firing Brick and (JC: [2005] No.982) perforated, hollow, and decorative bricks and hollow building blocks. Tile” State Council According to this notice, the 170 cities already under regulation of 2005 “Notice about Further Advancing the Wall (GBF[2005] No. 33) prohibiting solid clay bricks should push toward phasing out all clay Material Innovation and products and extend regulations to suburban towns. Other cities should Promoting Energy also prohibit or restrict production and use of solid clay bricks, following Conservation national arrangements, and gradually extend regulations to suburban and Construction”2 rural areas. 1999 “Circular on Cleaning out Backward Products in Housing Construction” (JZF: [1999] No. 295)

Issued by:

The notice set targets to: • Reduce production of solid clay bricks by 80 billion by the end of 2006. • Prohibit the use of solid clay bricks in all cities and reduce nationwide production to under 400 billion by the end of 2010.

77

The notice clearly defined nationwide requirements under the initiative prohibiting solid clay bricks. The notice identified the second batch of 256 cities under the time 2005 “Notice of the List of the Issued by: Second Batch Cities National Development and constraint to ban use of solid clay bricks by the end of 2008. Local Banning Solid Clay Reform Commission, Ministry of governments were required to make their own annual plans. Brick by the Set Time” Land Reform, former Ministry of Construction, Ministry of Agriculture (FGHZ: [2005] No.2656) Issued by: The circular was issued in response to a rebound in use of solid clay bricks 2007 “Circular on Further Enhancing former Ministry of Construction to meet the dramatic increase in demand for building materials due to fast Implementation of (JK: [2007] No. 74) growth of urban and rural construction. It stressed the importance of Banning the Use of Solid awareness raising, leadership, management, and monitoring. It suggested Clay Bricks”3 expanding areas where solid clay bricks were banned and required local governments to help improve the quality and support of research and development in applying new wall materials. It pushed local governments to improve the collection, management, and application of wall material renovation funds and—in coordination with construction, tax, and wall material renovation institutions—implementation of preferential tax policies on new wall materials. Issued by: The plan set up targets to: 2007 “The 11th Five-Year Plan on Brick and Tile National Development and • Develop new wall materials. In the 11th Five-Year Plan (2005– Industry in China”4 Reform Commission 10), new wall materials were to increase at a rate of not less than 10%; the plan called for development of hollow and heatinsulated wall materials and product improvements to increase energy savings for building. • Conserve land resources. By 2010, the total production of solid clay bricks was to be controlled at less than 380 billion per year, thus reducing their annual production by 20 billion; the plan called for fired hollow products to reach 210 billion (a 5% rate of increase per year) and waste-using bricks to reach 230 billion, thereby saving about 170 million t of clay. • Save energy and other resources. By 2010, energy consumption standards were to be reduced from about 5–6 tce per 100,000 bricks in the 10th Five Year Plan (2000–05) to about 4–5 tce per 100,000 bricks, leading to 10 million tce of energy saved and 300 million t of waste usage. • Phase out outdated technologies. The plan strictly followed the National Coercive Industrial Standard, “Industrial Standard of

Start from simple parts and continue improving requirements. Achieve penetration in the end.

78

2007 “ Bulletin on Promoting, Issued by: Limiting, and Prohibiting former Ministry of Construction Technologies in Construction in the 11th Five-Year ” (issued in batches) 2008 “Energy-Conservation Issued by: Ordinance of the Civil State Council Construction”

Kiln for Firing Brick and Tile” (JC982-2005), banning energyintensive small vertical kilns, small horse-shoe kilns, and small Hoffmann kilns with fewer than 18 gates. For new fired wall materials, the average single-line production capacity was required to reach at least 30 million standard bricks, with production capacity of products from coal gangue, coal ash, etc. comprising at least 50 million standard bricks. In the first batch issued in 2007, the bulletin prescribed that light- and high-strength building materials, green new materials, and waste-using, perforated and hollow materials should be promoted in application.

Promote application.

The ordinance targeted strengthened management of energy conservation for civil construction, reduced energy consumption of buildings, and enhanced energy efficiency. It promoted use of new energy-saving technologies, materials, and equipment and limited or banned energyintensive ones. It called for departments and institutions in charge of energy savings and construction in the State Council edit, update, and broadcast the promoted, limited, and/or prohibited content; construction and design units could not use technologies, materials, and equipment listed in the prohibited content.

Facilitating policies, laws and regulations in both upstream and downstream industries is essential for implementation.

Regulation on air pollution from the brick-and-tile industry 1996 “Emission Standard of Air Pollutants for Industrial Kiln and Furnace” 2009 “Emission Standard of Air Pollutants for the Brick and Tile Industry” This is the current emissions-standard regulation for the brick and tile industry. It is general for all industry furnaces and kilns; though not designed specifically for the brick and tile industry, it has played an important role in controlling brick-and-tile industry emissions and promoting advanced technologies. In June 2006, the former State The standard is under revision. Broad consultation was carried out in Environmental Protection Agency November–December 2009.5 issued a request to formulate the “Standard.” (Consultation Draft) Drafting was led by the Chinese Research Academy of Environmental Sciences, with involvement of the Xi’an Research and Design Institute of Wall and Roof Materials. Issued by: former State Environmental Protection Agency (GB: [1996] No. 9078)

79

Table C-2: Limits on air-pollution emissions
Maximum allowable emissions concentration (mg/m3) NOx Production process Existing firms Raw material breaking and molding Drying and firing New firms Raw material breaking and molding Drying and firing 50 50 700 400 6 100 100 850 400 6 PM SO2 (counted by NO2) Fluoride (counted by Fluorine)

80

ANNEX D. P OLICIES, L AWS, AND R EGULATIONS IN BANGLADESH ’ BRICK SECTOR
Year Policies, laws, and regulations The Brick Burning (Regulation) Act of 1989 Government responsibility DOE, MOEF Details Bangladesh’s first brick-making law banned the use of firewood for brick manufacturing and introduced licensing for brick kilns. The 1989 Act was amended to regulate the location of brick kilns. The new provision required that brick kilns not be set up within 3 km of the upazilla or district center, municipal areas, residential areas, gardens, and the government’s reserve forests. The GOB introduced a rule that made the use of 120ft chimneys for brick kilns compulsory. GOB issued notification that environmental clearance certificates would not be renewed if owner did not shift to alternative fuel and improved technologies by 2010. A new notification was issued banning FCK operation three years from this date. The revision of Act has the objective to facilitate transition of the brick industry for improved energy efficiency and lesser pollution level. This Act provided limited provisions for the conservation of the environment Prioritizes areas of attention for Environment Conservation. This Act provides for conservation of the environment, improvement of environmental standards and control and mitigation of environmental pollution. Sets air emission standards for industries including brick kilns. Sets Ambient Air Quality for criteria pollutants and Vehicular Emission standards Remarks Use of firewood has large been discontinued, but in remote areas this practice still continues on a limited scale. Using the given criteria, it is nearly impossible in reality to find land for brick kilns in Bangladesh. The BBMOA often cites this as a major deficiency in the law. Despite this amendment, the location requirements have not been enforced. This requirement was successfully enforced, especially in the vicinity of urban areas, and most Bull’s Trench Kilns (BTKs) were upgraded to FCK technology. However, some BTKs continue to operate, albeit illegally. This regulation has not been implemented since little on-the-ground activity occurred to facilitate the switch. Activities are being undertaken under GOB’s CASE project with World Bank support Still in process. Promulgation may take more than one year.

1989

2001

Revision of the Brick Burning (Regulation) DOE, MOEF Act of 1989

2002 Oct. 2007 March 2010 July 2011

Brick Burning rules

DOE, MOEF

GOB Notification GOB Notification Revision of Brick Burning Act

DOE, MOEF DOE, MOEF DOE, MOEF

Regulations on air pollution Environment Pollution control DOE, MOEF 1977 Ordinance,1977. Environmental Policy MOEF 1992 and Action Plan 1995 Environmental Conservation Act (ECA), 1995 Environmental Conservation Rules (ECR), 1997 Revision of ECR97 DOE, MOEF

This ordinance had limited provisions and was replaced by ECA95. This is a document of intent, without legal mandate. The ECA of 1995 provides the necessary legal framework. The 1977 ordinance is replaced by this Act. The Government can issue notification in the official Gazette and make rules for carrying out the purposes of this Act, including emission standards. The SPM standard for brick kiln emission is set at 1000 mg/m3, which is rather lenient. Even this standard could not be enforced due to limited capacity in the DOE. PM2.5 standard is defined and violation of ambient air quality standards can be enforced under this rule.

1997 2005

DOE, MOEF DOE, MOEF

81…...

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... Hierarchy of T(X) and SONET SONET (Synchronous Optical Networking) is a standard multiplexing protocol that transmits multiple trains of binary information through optical fiber (fiber optics cable) using either laser or LEDs (Light-emitting Diodes). Less transmission rates are required in this optical transmission of information. TL1 is the protocol used by SONET equipment, which is a telecommunication language used for configuring and programming of SONET network elements. The following are some of the key advantages of SONET: - High-capacity fiber optic transport - System of synchronous signal level - High-level of OAM&P (Operations, Administration, Maintenance, and Provisioning) capability - Automatic protection switching - High-degree of interoperability between different vendor platforms - Offers fault tolerance and reliability. - Lower network costs The following are some of the key disadvantages of SONET: - It is not used for daily internet needs - It is basically used for high-speed network backbones by the carrier networks such as Verizon, Cox, and Comcast - Requires stricter synchronization schemes - It is very much expensive because of the fact that it uses Fiber Optics and because of its complex and other costly equipment. Aside from SONET, there is also T(X),......

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