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43. The CPCB has relied upon a revised classification methodology based on a modified Pollution Index framework, under which industrial activities are assessed on the basis of their potential to cause air pollution, water pollution, and waste generation, and are thereafter assigned a cumulative pollution index. The stated justification for revisiting the 2016 classification is the experience gained over time, increased use of cleaner fuels, adoption of cleaner technologies, and the need to differentiate between integrated industrial operations and standalone units.

44. A central premise of the CPCB’s reasoning is that a stand-alone cement grinding unit without a captive power plant has a lower pollution potential than an integrated cement plant involving clinker manufacturing and kiln operations. On this basis, the CPCB has treated such units as a distinct sub- category within the cement sector and has placed them in the “Orange” category upon application of the revised scoring methodology. The CPCB has also stated that the revised methodology was placed in the public domain, representations were invited, and the final framework was adopted after examination by a duly constituted committee.

49. The CPCB’s principal justification rests on a comparative distinction between integrated cement plants and stand-alone grinding units, on the premise that absence of clinker manufacturing and captive power generation necessarily results in lower pollution potential. This approach, however, does not address the core concern. The relevant question is not whether a stand-alone grinding unit is less polluting than an integrated plant in relative terms, but whether its pollution potential is sufficiently low to justify a regulatory downgrade that materially relaxes safeguards governing proximity to civilian habitations.