Response on behalf of the Appellant on the report of the Ministry of Environment, Forest and Climate Change of July 2020 in the matter of Conservation Action Trust & Others Vs Union of India & Others).The case is against the expansion of ship breaking yards in Alang by adding more area of the inter-tidal zone for the purpose of breaking old ships on the beach. The beaching method is the least environment friendly and has the highest pollution potential.

The MoEF&CC report did not analyse several key parameters which are specific to ship recycling and breaking activities. These include, polycyclic aromatic hydrocarbons, polychlorinated biphenyls, and organotins. Most of the sampling locations are too remote to represent areas impacted by ship-breaking activities.

The report found concerningly high levels of heavy metals in the sediment analysis. In addition to the alarmingly high levels of heavy metals in the sediment samples, the report has also found that mercury levels in the water samples to be exceeding standards. With respect to impact on marine biodiversity, the report used data from 1997-2007 and 2007- 2008 as a baseline to evaluate the results of the 2020 study. The report says that the impacts of ship-breaking are negligible because many of the chosen parameters showed little change between 1997 and 2020.

The report failed to assess the impact from the toxic substances on marine biodiversity and the the impact on fish catch from traditional fishing activities, said Conservation Action Trust.