environmental impact assessment in the people's republic of china

PROFILE Environmental Impact Assessment in the People's Republic of China ROBERT B. WENGER* College of Environmental Sciences University of Wisconsin-Green Bay Green Bay, Wisconsin 54311-7001, USA

WANG HUADONG MA XIAOYING 2 Institute of Environmental Sciences Beijing Normal University Beijung, People's Republic of China

ABSTRACT / Environmental impact assessment (EIA) procedures have been in existence in the People's Republic of China over the last decade. The impetus for China's introduction of EIA was provided by the Environmental Protection Law of the People's Republic of China, which was adopted by the Fifth National People's Congress in 1979. The EIA process, which is administrative and not statutorily mandated, has been applied primarily to construction projects.

Four stages are typically involved in an EIA investigation: de-

sign of the investigation, evaluation of background environmental quality, prediction of environmental impacts, and an assessment and analysis of the environmental impacts. A variety of approaches is used for predicting and analyzing environmental impacts, ranging from ad hoc methods to fairly sophisticated mathematical models. The results of the EIA investigation are compiled in an environmental impact statement, which is used as the basis for decision making by personnel in environmental protection departments. The EIA process does not include provisions for citizen notification or involvement.

Views differ concerning the effectiveness of the EIA program in protecting China's natural, social, and cultural environments. Some hold that the EIA program has brought about improvement in environmental protection, while critics con- tend that the program has had little effect in the prevention of pollution. However, most, if not all, observers seem to feel that the program should be continued and improved. A major avenue for improvement is to place the evaluation of a particular project in a regional context.

The origin of environmental impact assessment (EIA) can be traced to the late 1960s when the US Na- tional Environmental Policy Act of 1969 (NEPA) was enacted. In the two decades since then many countries throughout the world have adopted this basic concept (Hollick 1986), among them the People's Republic of China.

The impetus for China's introduction of EIA was provided by the Environmental Protection Law of the People's Republic of China, which was adopted in principle by the Standing Committee of the Fifth Na- tional Peoples Congress in September 1979 (EPL 1979). A portion of Article 6 of this law states: "All

KEY WORDS: EIA process; EIA methods; Environmental impact statement; Effectiveness of EIA; People's Republic of China

1An earlier version of this paper was distributed at a workshop on Environmental Assessment Development Planning held in conjunc- tion with the VII Annual Meeting of the International Association for Impact Assessment, Brisbane, Australia, July 5-8, 1988. 2Current Address: State University of New York, College of Environ- mental Science and Forestry, Syracuse, New York 13210, USA *Author to whom correspondence should be addressed.

enterprises and institutions shall pay adequate attention to the prevention of pollution and damage to the environment when selecting their sites, designing, con- structing and planning production. In planning new construction, reconstruction, and extension projects, a report on the potential environmental effects shall be submitted to the environmental protection department and other relevant departments for examination and approval before designing can be started . . . . " Since the adoption of this law, EIA reports have been completed for approximately 500 large and middle- sized projects in 26 of the 29 (this number is now 30 with the recent addition of Hainan) provinces, auton- omous regions, and municipalities directly under the control of the central government (Li Xing]i 1987).

This paper describes China's EIA system as it has evolved over the last decade. Specific aspects that are discussed in detail are the EIA administrative process, EIA methods and techniques commonly employed in conducting environmental impact investigations, and public involvement in the EIA process. The article concludes with a discussion of the effectiveness of the EIA system in promoting environmental protection and future trends in the continuing evolvement of EIA in China.

Environmental Management Vol. 14, No. 4, pp. 429-439 �9 1990 Springer-Verlag New York Inc.

430 R.B. Wenger and others

EIA Administrative Process

The development of EIA in China can be divided into two periods. In the first period, from 1979 to 1981, several ideas based on EIA procedures and practices in western countries were introduced and ini- tial EIA activities were conducted for several key projects. Mining and power-plant projects were among the first to be subjected to environmental impact investigations. The second period, from 1982 to the present, was launched by an Environmental Science Seminar that was held in Guiyang city in Guizhou Province in 1982. At this seminar, delegates from academic institutions exchanged experiences and ideas that provided a base for the development of guiding principles to be used in conducting EIAs in the entire country. In the second period, which could be called the development phase, EIA activities have expanded rapidly. EIAs have been completed for smelteries, petrochemical and chemical plants, construction materials industries, nuclear power plants, light industries, and large-scale water conservancy projects. In addition, coal-mining operations and airport and seaport projects have been subjected to environmental impact investigations. Work has begun on the assessment of enviromnental impacts of highway and railway projects.

In contrast to its absence in some countries, China's environmental protection law contains a formal definition of environment: "For the purpose of this law, 'environment' means: the atmosphere, water, land, min- eral resources, forests, grassland, wildlife, wild plants, aquatic plants and animals, famous spots and historic sites, scenic spots for sight-seeing, hotsprings, health resorts, nature conservation areas, residential districts, etc." (Article 3, EPL 1979). This definition, with its broad scope, could, it would appear, provide a basis for the application of EIA to all types of proposals that may significantly affect the environment, including projects, policies, programs, and operational procedures. However, to date its application has been limited largely to construction projects. The types of proposals subjected to EIA and the guiding principles for the practice of EIA are usually described in terms of construction projects.

A partial exception to the focus of EIA on construction projects is provided by several nonconstruction projects that have been conducted in the past under the rubric of Environmental Quality Evaluation (EQE). Taken literally from the Chinese language, EQE means an "evaluation of present quality." In the late 1970s and early 1980s, EQEs were conducted in a number of Chinese dries, in which an attempt was

made to measure and describe the existing environmental quality of the areas under investigation. Some of the methods and techniques developed as part of this effort were forerunners to methods and techniques that are presently a part of the EIA process in China. EQE is now considered as a basic step of EIA, and what was once a separate program is now essen- tially the second part of a typical EIA investigation, as described in a later section.

National and provincial projects are subject to China's EIA provisions, but some collective and pri- vate projects are not, especially those located in the countryside. For example, the building of small coal pits in rural areas should be under the jurisdiction of the EIA provisions, but in practice construction often occurs outside the scrutiny of the EIA process. Mea- sures for controlling such enterprises and ensuring that their leaders follow and implement EIA procedures are not in existence at present.

Over the years, as a result of recommendations from conferences and the issuance of various guide- l ines--an example is "Management Rules of Environ- mental Protection of Basic Projects" (MREP 1981)-- an EIA administrative process has emerged. This administrative scheme is depicted in Figure 1.

Before a project is undertaken by a governmental department, a request must be made to the appropriate state, provincial, or city environmental protection department for a ruling on whether an EIA investigation, including a report, hereafter called an environmental impact statement (EIS), is required. After its personnel, sometimes with the assistance of outside experts, conduct a preliminary study, the environmental protection department issues a ruling. I f it is determined that an EIS is not required, the department responsible for the project is so informed and the way is clear for the design of the project to begin. If, on the basis of the preliminary study, the site se- lected is deemed inappropriate or control measures insufficient, in theory the project cannot proceed without the compilation of an EIS, although in practice this stipulation is not always adhered to. Seldom is a project rejected outright based on the findings of the preliminary study. The law itself is very general and does not provide for rejection at this stage. Further- more, as a practical matter, economic forces that lie behind a given project are usually sufficiently strong to make outright rejection an unlikely outcome.

Sometimes the department responsible for the project does not have the necessary expertise or resources to conduct the EIA, and therefore the EIA work is contracted out to professors or researchers at universities and/or research institutes. Professional

EIA in People's Republic of China 431

Verification and monitoring activities (12)

(4': 11)

i Department c3 >

EIA is unnecessary (2')

an EIA

Construction | [ Department Department [Submi t El: fo~,:pporoval (5)

I Contract for EIA work (3)

Group(s) I Responsible fnr EIA

ubmit EIS ( 4 +

-.<

(6)

Not approved (7')

Implementation of environmental protection measures contained in EIS (9)

Figure 1. EIA administrative program (adapted from Wu 1982).

J Decision-

L m*ers 1

Approved (7) (8)

/on Primary <" Conclusions

consultants are not available in China to assist with this type of work. For large projects, several research groups may be involved in various aspects of the EIA work. As an example, in what is probably China's most famous EIA investigation, the Three Gorges Project, research into the potential environmental and ecological impacts resulting from the construction of a large dam across the Yangtze River has been shared among 48 research institutes and departments coordinated by the Yangtze River Basin Planning Office (Shen 1987). When the EIA work is divided among two or more groups, a lead group is responsible for synthesizing the results from all groups and compiling the EIS.

The content of the EIS typically includes the following major components: general statement, survey of the proposed project, investigation of the environmental conditions in the region surrounding the project, analysis and prediction of the short- and long- term impacts of the project upon the environment, environmental monitoring proposals, cost-benefit analysis, a set of conclusions, and existing problems and

proposals for addressing them. In outline and content, a typical EIS in China is similar to those found in many other countries.

When the EIS has been compiled, it is submitted to the department responsible for the project. This department then adds opinions of its own before forwarding it to the environmental protection department. The environmental protection department con- ducts an examination of the EIS to determine if the project with the recommended environmental protection measures meets environmental standards or, as a minimum, incorporates a plan for achieving environmental goals. In reaching this decision, it will take into consideration opinions of those in the department responsible for the project and usually consult outside experts for advice. If the decision is approved, the environmental protection department may add some recommendations of its own to those included in the EIS and then inform the relevant decision makers of its decision. The decision-making body could be the State Economic Commission, the State Planning Corn-


mission, or even the State Council for large national projects and provincial or city governments for middle-sized or small projects. If approval of the EIS is not granted, the environmental protection department informs the department that submitted the EIS, perhaps with recommendations for altering the project plan and/or revising the EIA procedures.

When approval is granted, the decision makers are responsible for implementing the environmental protection measures as specified in the approved EIS and then forwarding their decisions to the department responsible for the project. Including these decision makers, who are neither environmental experts nor experts with regard to the proposal, in the implementation phase is an apparent weakness of the overall EIA process. There is the potential for undue bureaucratic or political interference at this juncture.

The design division of the construction department then draws up construction plans that include the environmental protection measures based on the approved EIS. The environmental protection measures may include monitoring and verification procedures that are to be carried out while construction is in prog- ress and/or after its completion with the requirement that the results be reported to the environmental protection department.

Of course the flow chart depicted in Figure 1 and the above description of the administrative procedures give an impression of a smoothly functioning process that does not always exist in practice. Breakdowns occur and bureaucraticjostlings result in shortcuts that contribute to various types of inferior work and, in some instances, to bypassing established procedures. However, if the administrative process functions smoothly and effectively, it generally follows the format described above. Problems that commonly occur will be discussed in detail in a later section.

EIA Methods and Techniques

EIA methods and techniques are those procedures, approaches, or methodologies used in conducting the environmental impact investigation (Shopley and Fuggle 1984). In this section the EIA methods and techniques commonly employed in China will be sum- marized. There are no formally specified methods and techniques and, therefore, significant variations exist from one project to another. Nevertheless, patterns are present in the methods employed by investigators. Four stages, as shown in Figure 2, are usually included in an EIA investigation: design of the investigation, evaluation of background environmental quality, prediction of" environmental impacts, and an assessment

of the environmental impacts. An important aspect of the investigation is the identification of measures for controlling pollutants and an estimation of the costs of these measures.

The key problems to be addressed in the first stage, the design of the EIA investigation, are the scope of the project, the identification of the factors in the natural and social environments most likely to be affected by the project, and the selection of parameters for evaluating environmental impacts. There is a recogni- tion that this phase can be done well only if input is obtained from several academic disciplines. Another skill required at this stage is the ability to evaluate the opinions of experts from different fields and to syn- thesize them into a workable plan. The depth and breadth of an EIA investigation depend largely on its design. Experience in China has shown that the better the EIA design, the higher is the quality of the overall investigation. There have been cases where those conducting the EIA have failed to grasp the main aspects of the design of the EIA investigation and have, as a result, neglected some key elements. It is recognized that a way must be found to overcome these short- comings.

In the second stage of a typical EIA investigation, an evaluation of the quality of the natural and social environments prior to a project's implementation is conducted. Monitoring, laboratory analyses, and other types of investigative activities are required in order to evaluate the environmental and ecological qualities of the region. In cases where substantial human activities have resulted in a degraded natural environment, at- tempts are sometimes made to conduct comparative studies of regions having features similar to those of the project site but where environmental degradation is not as serious. Background values from such regions may provide a more appropriate baseline from which to assess future impacts than the heavily polluted sur- roundings of a project site. An investigation and evaluation of the social environment in the region surrounding the project site is also usually undertaken at this stage. In historically important regions, the identification of cultural relics, historical sites, and ancient vestiges around and near the project site is usually stressed.

In the third stage, environmental impacts are sys- tematically delineated. The aim is to forecast the type and degree of potential environmental changes that will occur as the result of a project construction. Some impacts, particularly those inflicted upon the social environment, are described in qualitative terms, but considerable emphasis is placed upon quantitative de- scriptions. At this stage environmental protection mea-


Design of EIA

�9 Define EIA scope and precision

�9 Define key factors �9 Choose major parameters

EIA Investigation I

Study of Existing Environmental Quality

Inventory, monitoring and evaluation of background values of �9 natural ecosystems �9 social environment

Prediction of Environmental Impacts

�9 On natural ecosystem (with and without protection measures)

�9 On social environment (with and without protection measures)

I Analysis an, Assessment ' of Envirunmenta[ Impa~ts ] ..........................

i On human ~alth On nature ecosystem On societ,

Figure 2. EIA methodology.

sures are usually identified and the degree to which these measures will mitigate environmental impacts is also predicted. In order to make accurate predictions of environmental impacts occurring after environmental protection measures are in place and to estimate costs of these measures, it is necessary for the EIA investigators to have a basic knowledge of engi- neering processes and technology.

An example of typical impacts upon the natural environment is provided by EIAs of mining operations. In an EIA study of the impacts caused by additional development of the Yongping Copper Mine (Xu and others 1989), potential changes in geochemical and geomorphological conditions were predicted and the concomitant changes in vegetation and ecosystems caused by large-scale soil erosion and water losses were quantified. In addition, the impacts on surface water caused by acid drainage from the mine with its high concentrations of heavy metals and the changes to ag- ricultural ecosystems caused by irrigation with polluted water were studied. Environmental protection measures to counter the effects of heavy metal pollution were emphasized.

Prediction of the impacts on the social environment caused by proposed projects is aimed at measuring the effects on the quality of residential living environments--including such things as noise, traffic conditions, and aesthetics--and on the development of the regional economy. Impacts on historical sites, cultural relics, and scenic spots that are of interest to the indig- enous population and tourists alike also are included.

On the basis of the first three stages, an analysis of

the effects caused by environmental changes on human health, ecosystems, and social systems is conducted. This constitutes the fourth stage of the EIA investigation. Effects on human health caused by environmental changes often are chronic and may become readily apparent only when considerable time has elapsed after exposure has occurred. Accurate assessment of health impacts is difficult and has only begun to receive systematic attention in EIA studies throughout the world (Go and Peterson 1987). In China, such studies are in the rudimentary stage as well. The assessment and analysis of the impacts upon the physical components of ecosystems is more ad- vanced than for the biotic components. There appear to be only a few EIA studies in which comprehensive analyses of animal and plant communities have been conducted.

In the analysis of the impacts on social systems--a concept somewhat more narrowly construed in China than in most western countries--cost efficiency and economic assessments are often stressed. The analytical tool of cost-benefit analysis is used sometimes in an attempt to make rational decisions that address both economic development and environmental protection concerns. In addition to national standards, there are often local environmental quality standards that must be addressed. Guidelines and articles on EIA often include the counsel that investigators should take local characteristics into consideration.

The EIA investigations are not always conducted in the compartmentalized manner suggested by the de- scriptions given above of the four methodological


stages. In the investigative activities, functions listed under two or more stages may be merged and se- quences altered.

A variety of techniques or approaches are used for predicting and analyzing environmental impacts, the major activities under the third and fourth stages. Often the techniques employed are simple and fit under what Shopley and Fuggle (1984) call ad hoc approaches. However, more sophisticated approaches frequently have been used, particularly in recent years. Weighted composite indices have been utilized as a means for comparing alternatives or quantifying impacts (Liu Guangsi 1987, Wang Yun 1987, Ning Da- tong and others 1987b, Ren Jiuchang and others 1987). Mathematical models receive heavy usage for studying various kinds of impacts: air pollutants (Ning Datong 1987, Yu Ke 1987, Cai Cunfu and Wang Hua- dong 1987, Ning Datong and others 1987a, Cai Lin and others 1987, Che Yuhu 1987, Yang Qiansheng 1987), water pollutants (Liu Feng 1987, Xue Jiyu and others 1987, Che Yuhu 1987), soil pollutants (Xu and others 1989, He Jianqun and Xu Jialin 1987, Yang Jurong and others 1984), and noise (Huang Guohe 1987, Zhao Guangfn 1987, Wang Hongzhi 1987). Most of the mathematical models employed are deter- ministic, but predictions and assessments in probabi- listic terms are starting to appear in EIA studies (Chen Feixing 1987, Cai Lin and others 1987, Yang Qian- sheng 1987). The use of remote sensing and specialized cartographic techniques is now fairly common (Li Tianjie 1987, Chu Guanrong 1987, Fan Weihong and others 1987). Additional techniques that have been employed include the analytical hierarchy process (Li Wanqing and Meng Xiaojun 1987, Zhou Haoming 1987), the Delphi method (Yang Jurong and others 1987), synergetics (Sun Benjing 1987), network models and graph theory (Che Yuhu 1987), and input-output analysis (Guo Baoseng 1987). In addition to computer simulations, specialized computer programs have been developed to estimate subsidence of the earth's surface resulting from underground coal mines (Zhao Jizhou 1987) and to provide an environmental information system that can be used to study impacts from nonferrous mining operations (Xu and others 1989). Wind-tunnel simulations are sometimes employed as part of air pollution studies (Ning Datong 1987, Cai Cunfu and Wang Huadong 1987) and simulations of pollutant movements in a water environment are conducted in laboratories to estimate pollutant movements in actual surface water bodies. Many types of chemical analyses have been performed in laboratories, including at least one study on laboratory rats to assess potential threats to human health from

benzo[a]pyrene, a chemical that exists in some atmospheric fly ash (Hou Fuzhong and others 1987).

Public Participation in EIA

In many countries specific mechanisms are in- duded in the EIA procedures to ensure that the public is informed and that opportunities are granted for citizens to review EISs and to formally present their views concerning the recommendations contained in them. In fact, the enhancement of public participation in environmental decision making is often viewed as an important EIA objective (Hollick 1986). At present formal public involvements are not a part of the EIA system in China. The set of procedures depicted in Figure 1 is entirely administrative and bureaucratic in nature, and no provision is included for notifying the general public when EISs have been completed so that citizen reviews can occur, nor are public hearings a part of the process.

Located in every county and city in China is a special office called the Xinfang Office, which exists for the purpose of receiving public opinions and complaints. These offices with their ombudsman-type function exist for the purpose of receiving complaints on all types of issues. Thus, it is possible for citizens to lodge complaints concerning environmental issues, including complaints concerning EISs or EIA activities if, in a rare case, they should be aware of EIA provisions. However, such potential actions are a far cry from formal public participation, particularly since personnel in these offices are not empowered to act, only to serve as vehicles of communication. Included among the complaints that have been received by such offices are some concerned with environmental matters. For example, in the Sichuan Province an of- rice received citizen complaints about dead fish on the Tuo River, which appeared to be the result of industrial pollutants discharged into the river. The complaint led to a research project to determine the cause of the problem.

Article 8 of the Environmental Protection Law (EPL 1979) states that Chinese citizens have the right to bring a complaint before the court against a unit or individual who has caused pollution or damage to the environment. Those who bring such matters to court are to be protected against retaliatory action on the part of the accused units or individuals. There are documented court cases pertaining to environmental issues (Ross 1987, Ross and Silk 1987), although none pertaining specifically to an EIA matter has been found in the literature.

Article 8 would seem to provide an opportunity for


citizen legal action to redress EIA matters such as a failure to conduct proper EIA procedures or a failure to comply with environmental protection provisions contained in the directives provided by the environmental protection department along with its approval of the EIA. Obviously, such legal actions can occur only if citizens are informed, a condition that is very difficult to attain under the present EIA procedures in China.

It seems clear that formal mechanisms for notification of citizens and providing opportunities for them to review and present their views concerning EISs is a necessary ingredient for strengthening the EIA program.

Effectiveness of the EIA Process

As was mentioned earlier, the EIA program in China has been applied primarily to construction projects. Does the EIA program play an effective role in protecting the natural, social, and cultural environments from adverse effects resulting from the construction of the large and middle-size facilities that come under its purview?

Li Xingji (1987) and others have pointed out that the locations of most construction projects have been decided before the EIA work begins. Therefore, the EIA program in China has not had as fundamental a role as in some countries where alternatives to a proposed project must be explicitly examined, including consideration of alternative locations. Such analysis re- quires that the EIA work begin at the planning stage of a project, a formidable challenge to a country that is seeking to develop its economy rapidly. The fact that the EIA process has not been thoroughly integrated into the project planning stage is a reflection, no doubt, of the fact that many decision makers feel that they have little choice but to put economic interests ahead of environmental protection concerns. The primary impact of EIA in China has been to alter project designs so that environmental protection is enhanced. A case study involving an aluminum smelter in Qinghai Province, reported by Yin Guangjin (1987), is probably typical of many projects.

The environmental impact assessment of the smelter project, a large-sized electrolytic aluminum plant, was conducted when the preliminary design scheme had already been completed. According to the design plan, wastewater from the plant was to have been discharged directly into a channel near the smelter. The water in the channel was used for a variety of purposes, including the washing of rice and vegetables and farmland irrigation, by 30,000 villagers

who lived nearby. The researchers determined that the discharge would seriously degrade the water quality in the channel and threaten underground water and water wells close to the channel. In effect the channel would become a sewage canal, particularly during the May-June period when it tends to dry up from heavy irrigation use.

Treatment of the wastewater to maintain water quality standards in the channel was deemed too ex- pensive. Instead, the EIA resulted in a recommenda- tion that would discharge the wastewater into a river that is located at some distance from the smelter. It was determined that the discharge into the river would not violate the state industrial wastewater discharge standards and that the villagers' water supply would be protected. The proposed diverson of the wastewater would require an investment of one million RMB (renminbi) but the accrued benefits were considered to be well in excess of the cost, which would have included long-term penalty payments for discharges into the channel (as of June 1989, at the official exchange rate US $1 equaled 3.7RMB). The proposal was ac- cepted by the smelter, the design institute, and environmental protection departments and approved for implementation by the China National Non-ferrous Metals Industry Corporation.

It should be noted that there are documented cases where recommendations more radical than the type described above have resulted from EIAs. For example, the environmental impact assessment of a coal gas project in Lanzhou resulted in the recommenda- tion that it not be constructed because its impacts, particularly upon the atmosphere from air pollution, would be too severe (Li Guifen 1987). Whether the project will be abandoned as a result of this recom- mendation is not yet clear.

Zhang Dunfu (1987) holds the view that the EIA program in China has brought about a change in tra- ditional economic decision making. Whereas in the past sole attention was given to economic growth at the neglect of environmental protection, the EIA program, he argues, has proved very useful in adjusting economic growth and protecting the environment. Ross (1987) holds a less sweeping view but makes the following positive statement about the environmental impact assessment process for construction projects: "the assessments are rudimentary, but the requirements are real and the compliance rate has risen rapidly."

On the other hand, there are those who hold a critical view of the EIA process in China. Zhu Yimin (1987) states that the EISs for large and middle-scale construction projects have had little effect in deter-


mining reasonable locations, prevention of pollution, and protection of the environment. He goes on to say that much manpower and money have gone into EIA activities but little has been achieved. He attributes this to three major factors: (1) Some units seek permission for design and construction but fail to be specific and maintain strict requirements towards the units that undertake the EIA; (2) researchers often place too much stress on mathematical models and the academic level of assessment at the expense of practical assessment methods; and (3) some environmental protection departments do not enforce laws strictly and reports may be passed easily.

Wu Sishan and others (1982), in referring to the late stage at which the environmental assessment work occurs in the construction project planning process, state that many EISs are, in essence, post-EISs. The same authors complain that the researchers who conduct environmental impact assessments, although knowledgeable in the environmental protection field, often lack familiarity with technical designs and tech- nological processes. Therefore, they state, the researchers encounter difficulties in the analysis of pollutants and lack the skills to judge whether the data and parameters supplied by design departments are correct. This may be due in part to the fact the Chi- nese academics are often disciplinary specialists with limited experience in project activities that place a pre- mium on multidisciplinary approaches. In addition, in China, as in many countries, the academic boundary between environmental science and environmental en- gineering is often a difficult one to cross.

Whatever their views on the effectiveness of the EIA program to date, observers are united on the central point that it is needed to ensure that environmental protection issues in China will be adequately addressed in the future. Proponents, such as environmental leader Liu Peitong (1987), see EIA studies as a tool for promoting a harmonious development between humans and their environment. Even the strongest critics offer suggestions for the improvement of the EIA program rather than advise its disband- ment.

Several obvious areas for improvement have been noted throughout this paper. Among them are more effective and objective administrative procedures, better design of the EIA investigation, greater attention to the biotic components of environmental assessment, and provisions for public involvement in the EIA process. Based on a review of several large projects, Zhang Dunfu (1987) concluded that EIAs bearing regional characteristics have been more suc- cessful in controlling pollution than those that lack a regional context. In view of this, he recommends that

a strategic adjustment occur in China's EIA program by placing the evaluation of particular projects in a regional context. Some steps in this direction have been taken by government officials, who have requested that environmental concerns be addressed on a regional basis along with economic development plans (Che Yuhu 1987).

An academic seminar on EIA was held in Shijiaz- huang, the capital of Hebei Province, in March 1986. A set of proposals based on the deliberations at that seminar chart a course for the future of EIA in China. They are:

1. The term "environment" is a broad concept; be- sides prediction and assessment of environmental pollution, the EIA should study the impacts of projects on the natural ecosystem, and it should be extended to the social and economic factors and the entire human ecosystem.

2. Guidelines should be compiled for EIA, and regu- lations and standards for EIA should be drawn up as soon as possible.

3. In those projects in which EIAs have been completed, a review should be carried out so as to find the existing problems and improve the EIA method.

4. It is necessary to combine the EIA of a single project with the EIA of regional economic development so that the reasonable distribution of construction projects can be achieved and the environmental capacity can be distributed in a unified way.

5. A risk assessment for some projects should be carried out.

Since a broad definition of environment is already in place in the Environmental Protection Law, it would seem that the first statement would be unnecessary. The likely intent is to raise a call for a narrowing of the gap between theory (as embodied in the Environ- mental Protection Law) and practice, particularly in relation to nonconstruction projects.

Summary

In the past decade, an environmental impact assessment program has become firmly entrenched in China. Although presently limited primarily to large- and medium-sized construction projects, a legal basis exists for applying EIA procedures to a wide range of proposals. An EIA administrative process has evolved, but it is not statutorily mandated. The EIA process


does not include formal provisions for citizen notification or involvement.

Four stages are usually included in an EIA investigation: design of the investigation, evaluation of background environmental quality, prediction of environmental impacts, and assessment of environmental impacts. The techniques employed in EIA investigations are rudimentary but have become increasingly sophisticated. The environmental impact statement, compiled by an investigative group, provides the basis for an examination by an environmental protection de- par tment to determine if proposed environmental protection measures are adequate and if approval should be granted for the project design to commence.

Views concerning the effectiveness of China's EIA program differ, but there is agreement that it should be continued and improved. A major avenue for improvement is to place the evaluation of particular projects a regional context.

Acknowledgments

The authors wish to express their appreciation to Professor Che Yuhu for reading a draft of this paper and offering helpful advice and comments. They also would like to thank the referees for suggesting a number of improvements and pointing out several in- consistencies.

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