Incorporating cleaner production analysis into environmental impact assessment in china

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INCORPORATING CLEANERPRODUCTION ANALYSIS INTOENVIRONMENTAL IMPACTASSESSMENT IN CHINAWenming ChenChina National Cleaner Production CenterKimberley A. WarrenUniversity of Hong KongNing DuanChina National Cleaner Production CenterAn environmental impact assessment (EIA) system was established in 1979 inChina. Although EIA was designed as a tool for pollution prevention, inpractice it has been based on end-of-pipe (EOP) treatment control since itwas first introduced. This approach has ensured an overwhelming focus byenterprises on the use of EOP treatment, rather than pollution prevention, tomeet environmental standards, and it has produced a low rate of operation forEOP facilities. The low operation rate for EOP facilities can be traced to thetraditional EIA system: it leads project proponents to develop large EOPtreatment facilities, but once the main production lines are put into operation,proponents rarely have sufficient funds to operate the treatment facilities. Thispaper analyzes problems that exist in the EIA system in China, and it describesthe Cleaner Production Index and Evaluation System, which is being proposedby environmental authorities in China to evaluate EIA projects based on cleanerproduction criteria. The paper also suggests how cleaner production analysiscan be integrated into the EIA system to improve it. 1999 Elsevier Sci-ence Inc.Development of the EIA System in ChinaThe evolution of Chinas environmental impact assessment (EIA) systemcan be divided into four phases: preparation phase (19721979), preliminaryAddress requests for reprints to: Wenming Chen, China National Cleaner Production Center, No. 8,Dayangfang, Anwai, Beijing 100012, Peoples Republic of China.ENVIRON IMPACT ASSESS REV 1999;19:457476 1999 Elsevier Science Inc. All rights reserved. 0195-9255/99/$see front matter655 Avenue of the Americas, New York, NY 10010 PII S0195-9255(99)00023-2458 WENMING CHEN ET AL.implementation phase (19791986), overall implementation phase (19861990), and intensification phase (1991present). The preparation phasefor EIA occurred during the 1970s, when environmental protection wasbeginning in China. Because of serious pollution problems, some regions,for example, Beijing, began to conduct environmental quality assessments(EQAs) in the early 1970s.In 1973, the technical team for A Study on Environmental QualityAssessment for the Western Suburbs of Beijing was established. The studyfocused on how to protect the environment of Beijing in the short and longterm. Nanjing City in Jiangsu Province and Maoming City in GuangdongProvince also conducted their own EQAs during this period. During thepreparation phase, environmental scholars in China also began researchon EIA. In 1977, the Chinese Academy of Sciences organized a seminaron Regional Environmental Science to promote EQAs in large- andmedium-sized cities in China. After the seminar, EQAs were conducted insome large cities (e.g., Shanghai, Tianjin, and Guangzhou) and for somewater basin regions (e.g., Songhua River, Tumeng River, and the WestLake of Huangzhou City) (NEPA 1996).The first clear requirement for EIA was contained in the first version ofChinas basic environmental law, Environmental Protection Law of thePeoples Republic of China (for trial implementation), issued in 1979. Thislaw established EIA as a compulsory environmental management program(NEPA and the National Peoples Congress 1989), and it marked the begin-ning of the preliminary implementation phase (19791986). In 1981, theState Planning Commission, State Construction Commission, State Eco-nomic and Trade Commission, and the Environmental Protection Commit-tee of the State Council (1981) issued Management Procedures for Envi-ronmental Protection of Capital Construction Projects, which outlinedrequirements for the EIA system. The first EIA conducted for a proposeddevelopment project in China was the Environmental Impact Assessmentof Yongchuan Copper Mine. This EIA was carried out between 1979 and1981, and it evaluated the impacts of the proposed mine on surface waterand air quality.In 1986, the Chinese government modified the 1981 version of the Man-agement Procedures for Environmental Protection of Capital ConstructionProjects. (NEPA 1986). The new version more clearly defined the scope,content, management limitations, and responsibilities linked to EIA. Dur-ing the overall implementation phase (19861990), the National Environ-mental Protection Agency (NEPA, which was transformed into the StateEnvironmental Protection Administration, SEPA, in March 1998) and othergovernment bodies issued a number of administrative regulations relatedto EIA, including procedures for issuing licenses to organizations qualifiedto conduct EIAs (NEPA 1989). The rate of compliance with EIA was highduring the overall implementation phase: between 1986 and 1990, morethan 90% of medium and large construction projects conducted EIAs.CLEANER PRODUCTION ANALYSIS AND EIA 459Despite the EIA programs success during the overall implementationphase, several key concerns were identified during this period. First, mostEIAs were conducted after projects had been sited and production pro-cesses had been designed. The relative timing of activities was such thatEIAs tended to focus on end-of-pipe (EOP) treatment and to neglect issuesrelated to alternative facility siting and cleaner production. Second, manyof the EIAs carried out during this period were of poor quality, and imple-mentation of the EIAs and/or mitigation measures was low. Third, smallindustrial projects, especially those involving township-and-village indus-trial enterprises (TVIEs), frequently avoided the EIA system. This lack ofparticipation was the result of an early focus of the EIA program on large-and medium-sized projects, thus enabling small-sized projects and TVIEs toescape detailed scrutiny by local environmental protection bureaus (EPBs).Local governments vested interests (i.e., ownership of TVIEs) in the devel-opment and success of rural enterprises also shielded TVIEs from environ-mental scrutiny and created de facto exemptions for TVIEs from EIA andother regulatory requirements in the 1980s. In some cases, local govern-ments applied intense pressure on local EPBs to approve projects involv-ing TVIEs.After 1990, two trends emerged concerning EIA in China. The firstrelates to the specific content of the EIA. During the 1990s, the EIAexpanded in scope from assessments that primarily covered impacts ofindustrial pollutant discharges to those that were broader and more ecologi-cal in nature. The second trend concerns what has come to be termedregional environmental impact assessment. Whereas prior to 1990 EIAswere mainly conducted for individual development projects, after 1990EIAs also were required for entire regions. For example, EIAs have beenconducted for river basins and for entire industrial development areas (e.g.,the Pudong area in Shanghai).More recently, in November 1998 Chinas State Council approved arevised version of the Management Procedures for Environmental Protec-tion of Capital Construction Projects. The new guidelines (State Council1998) contain specific provisions for cleaner production (Article 4), and theystate that all industrial construction projects should adopt low-polluting,energy-saving CP technologies that reduce pollutant discharges. The revi-sions provide an implicit mandate for all large-, medium- and small-sizedindustrial construction projects to include considerations related to cleanerproduction (CP) in the context of EIA. Last, SEPA is currently consideringthe application of strategic environmental assessment systems (CER1999). Such systems move beyond EIAs for projects and apply EIA proce-dures to government economic and environmental policies.EIA Process for Construction Projects in ChinaAll new construction projects, expansions or renovations of existing facili-ties in China must comply with the Management Procedures for Environ-460 WENMING CHEN ET AL.mental Protection of Capital Construction Projects to receive project ap-proval from governmental agencies, such as planning or land managementdepartments. The guidelines establish an overall environmental manage-ment system for construction projects, which consists of five stages: Project proposal Project feasibility study Project design Project construction, and Inspection and approval (of the completed project).The first two stages of the system are part of the EIA regulatory process;the latter three stages are carried out under the three synchronizationsprogram. This program stipulates that environmental protection measuresthat are identified in the first two stages of the EIA management processmust be designed, constructed, and operated simultaneously with the design,construction, and operation, respectively, of projects main facilities.The project proposal stage is designed to provide a brief introduction tothe project, including facility siting issues and potential environment im-pacts. In the second stage, the project feasibility study, an EIA is carriedout. In theory, this suggests that project proponents carry out EIA analysesprior to the design stage of their projects. However, in practice it is commonfor project proponents to write their project proposals after decisions aboutthe projects location and final design have been made. Thus, major deci-sions regarding process technologies and plant design are made prior tothe feasibility study phase, i.e., before an EIA is carried out. As discussedlater, by bringing their completed plant and treatment facility designs tothe table at such an early stage, project proponents make it difficult foralternative project designs (e.g., cleaner production technologies) or facilitylocations to be considered and integrated into subsequent EIA analyses.EIA Management ProceduresIn China, the scope of the EIA, and the procedural requirements thatproject proponents must satisfy, depend on the potential environmentalimpacts of the project. In general, if the anticipated environmental impactsare judged by environmental authorities to be significant, project propo-nents must complete a comprehensive EIA and submit an environmentalimpact statement (EIS).1If the projects environmental impacts are anticipated (through the proj-ect proposal) to be small, the procedural requirements for the EIA aremuch simpler, with proponents typically only filling out a brief environmen-tal impact form (EIF). The EIF contains the proposed projects location;main products and raw materials, particularly toxic ones; water and energy1 We follow translation of Sinkule and Ortolano (1995) of the Chinese phrase, baogao shu, as environmen-tal impact statement; this phrase also can be literally translated as an environmental impact report.CLEANER PRODUCTION ANALYSIS AND EIA 461consumption; estimated total pollution discharges and main environmentalimpacts; and pollution control measures, including treatment and recyclingand reuse measures.Environmental authorities determine whether an EIS or EIF is requiredthrough project classifications. New construction, expansion, and renova-tion projects in China are divided into three classes (A, B, and C) accordingto their potential degree of environmental impacts. National and localenvironmental protection agencies are in charge of the classification aparticular project receives. Class A means the project may cause significantnegative environmental impacts. For Class A projects, proponents mustprepare a comprehensive EIA analysis, the result of which is the filing ofan EIS with responsible environmental authorities. Class B projects maycause limited unfavorable impacts to the environment. Class C projects donot cause unfavorable impacts to the environment. For both Class B andClass C projects, an EIF must be filled out and filed with relevant environ-mental agencies, but an EIS is not required. (However, if subsequent re-views of the EIF indicate that the pollution generation or toxic chemicalhandling aspects of these projects is indeed significant, an EIA will berequired.)Evaluation and Approval of EIAsIn China, the agency responsible for examining and approving an EIA isdetermined based on the level of investment of a project. Only SEPA(and its authorized representatives at the provincial and municipal levels)approves EIAs for projects with investment levels greater than 200 millionyuan (about $24 million US). Provincial- and municipal-level EPBs reviewprojects requiring investments between 50 million and 200 million yuan, andcity-level EPBs evaluate EIAs for projects costing less than 50 million yuan.As discussed earlier, to initiate the EIA process, a project proponentmust first submit a project proposal, which contains a preliminary analysisof the estimated environmental impacts, to the responsible environmentalagency: SEPA or a provincial, municipal, or city EPB. The responsibleenvironmental agency reviews the project proposal, solicits comments fromits own staff and external sources (e.g., industry experts), and then schedulesa meeting with the project proponents to discuss their projects classification.If the environmental agency classifies the project as Class B or Class C,project proponents need only fill out an EIF. In the case of an EIF, theproject proponents are not obligated to use the services of a certified EIAorganization (e.g., an environmental institute or consulting company), butmay have their own staff (often with the assistance of local EPB staff)complete the EIF.22 An EIA licensing system limits the number of institutes or companies that qualify as certified EIAorganizations in China. The authority to provide EIA certification rests with SEPA. Environmental institutesor consulting companies submit an application (and often complete training courses) for EIA certification,and SEPA evaluates the application, primarily based on the experience of the institute or company with462 WENMING CHEN ET AL.If the project has been classified by the environmental agency as ClassA, the project proponents are obligated by law to hire a certified EIAorganization to assist them with the EIA analysis and submission of anEIS. A contract is signed between the organization conducting the EIAand project proponents, and the EIA is started. The organization conductingthe EIA prepares an outline of the EIA for the project and then submitsit to the responsible environmental agency (SEPA or an EPB) for reviewand approval. When preparing the EIA outline for their clients, the certifiedEIA organization is responsible for identifying the potential environmentalmedia to be impacted by the proposed project and the appropriate levelof analysis to be undertaken in the EIA. The organization preparing theEIA accomplishes this by dividing the EIA into various individual impactassessments based on the environmental elements (i.e., media) to beimpacted (e.g., an air EIA, a surface water EIA, a noise EIA, and so forth).Technical guidelines prepared by NEPA (1993) provide a basis for de-termining the EIA classification for individual environmental elements.Based on a combination of a projects anticipated discharge load and receiv-ing waters, environmental elements of an EIA are classified as either ClassA, Class B, or Class C. The classification assigned to each element deter-mines: (1) the prescribed level of impact analysis required (e.g., a highlycomplex computer model simulation for air quality versus a simple estima-tion of total air pollutants emitted) for each element;3 and (2) the level ofmonitoring and sampling (e.g., water quality) that must be undertaken aspart of the EIA.4 Class A elements of an EIA require the most detailedevaluations, whereas Class B elements can be less detailed. The analysisfor Class C elements can be the least detailed.Once the EIA outline has been submitted to the responsible environmen-tal agency, a review meeting is convened to evaluate the content of theproposed EIA outline and review the classification levels (Class A, ClassB, or Class C) of different EIA elements. After the review meeting isEIA. SEPA also distinguishes in its EIA certification program between organizations that are legallycertified to conduct Class A project EIAs (i.e., more difficult and complex EIAs) versus Class B and ClassC project EIAs.3 For example, according to national criteria, if a new construction project discharges wastewater to alarge-scale surface water body that is defined by national standards as a category I, II, or III zone, andthe proposed wastewater to be discharged from the project is more than 20,000 m3/d and contains at leastthree kinds of pollutants, then the water element of the EIA is Class A. (In China, water bodies are dividedinto five classes according to their end use and water quality protection goals, with Class I being of thehighest quality and Class V being of the poorest quality.) If a new construction project dischargeswastewater to a large-scale surface water body that is classified as category IV or V by the nationalstandards, and the wastewater to be discharged is more than 20,000 m3/d with at least three kinds ofpollutants, the water element of the EIA is Class B. Finally, if a new construction project dischargeswastewater to a small-scale surface water body, and the wastewater is between 200 and 1,000 m3/d with atleast three kinds of pollutants, the water element of the EIA is Class C.4 For example, if a new construction project discharges less than 50,000 m3/d of wastewater to a large-or medium-sized lake, monitoring requirements are as follows: one sample is required for every 1 to 2.5km2 for Class A, one sample per 1.5 to 3.5 km2 is needed for Class B, and one sample for every 2 to 4 km2is required for Class C. (It should be noted that certain cities, such as Shanghai, apply stricter EIAclassification criteria than the national criteria just described.)CLEANER PRODUCTION ANALYSIS AND EIA 463completed, the organization conducting the EIA carries out the EIA andsubmits the EIA report to the responsible environmental agency. The latterorganizes a second review meeting to evaluate the EIA report and decidewhether the project requires additional EOP treatment facilities to reducethe projects environmental impacts, or whether the project should beallowed to go forward.The aforementioned two review meetings by SEPA or a local EPB playa key role in controlling the quality of the EIA and the project. Participantsat these meetings include environmental agency staff and environmentalexperts invited to participate in the reviews. Officials and invited expertsoften focus strictly on the degree of environmental impact that a proposedproject may cause; however, they also may evaluate specific technical detailsof the project, such as the type of production process selected.Limitations of the Existing EIA System in ChinaSeveral serious limitations exist in the current EIA system in China. First,EIA procedures and requirements, as defined in the Environmental Protec-tion Law of the PRC (1989) and the Management Procedures for Environ-mental Protection of Capital Construction Projects (1986) do not specifi-cally require the use of cleaner production. Although this situation hasimproved with the November 1998 revisions to the management guidelines,which now include CP provisions for some industry construction projects,the effects of those revisions will not be felt immediately. The past regula-tory climate continues to ensure that project proponents overwhelminglychoose EOP treatment facilities to satisfy EIA requirements. This occursat all levels of investment.Second, EIAs have primarily been conducted for large industrial projects;most small industrial pollution sources have ignored EIA requirements.Third, as discussed earlier, EIAs have often been conducted well intothe development stage of a construction project, long after project designdecisions have been made. The failure to conduct EIAs prior to the designand facility siting phases of a development project makes it difficult tointegrate cleaner production approaches into the projects overall develop-ment. Last, the financial capabilities of enterprises have not been adequate-ly accounted for in the EIA review process. As a result, enterprises thatcannot afford to operate treatment facilities continue to receive projectand EIA approvals.EIA Policy and Regulatory Limitations Lead to Emphasis onEOP TreatmentBecause EIA regulations focus only on the environmental impacts createdfrom pollutants generated by a proposed project, the prevention of pollutionbefore it has been created has not traditionally been encouraged or inte-464 WENMING CHEN ET AL.grated into Chinas EIA procedures. These regulations and policies oftenassume that pollution will be created, and that the way to deal with it isto require the purchase and use of EOP treatment facilities. This situationencourages enterprises to view environmental protection (and EIA proce-dures) in terms of EOP treatmentto the great detriment of the promotionof cleaner production concepts and methodologies in China.Moreover, with regards to the evaluation and approval of EIAs, in thepast it has been the case that if a proposed project meets national and localdischarge standards, in general it will be approved. In other words, as longas the project proponent installs sufficient EOP facilities to meet dischargestandardsregardless of whether the production technology selected is theleast polluting choicethe project is approved. For example, in China,many old factories produce serious pollution. When proposals are submittedto expand or renovate these factories, the EIAs must examine the pollutantscreated by all production processes. The requirement that expanded reno-vated factories meet environmental standards often is satisfied by installingsufficiently large EOP treatment facilities, rather than through technicalinnovations or cleaner production measures.The policy climate for EIA, however, is rapidly changing. EIA regulationsand procedures currently are being revised at both the national and locallevels in China (e.g., some new provisions require use of cutting-edge CPtechnologies by firms in the industrialized provinces of southeast China),and these policy changes are applying increasing pressure on enterprisesto incorporate CP options into their proposed projects.Lack of Focus on Small Industrial Pollution SourcesFrom 1996 to 1997, the Chinese government closed more than 60,000 small,seriously polluting industrial enterprises. This decision was based on thecurrent situation in China where small TVIEs are contributing significantlyto the nations total pollution discharges. For example, in 1996 TVIEsgenerated more than 50% of Chinas pollution in terms of chemical oxygendemand (COD).5Pollution from small enterprises has become a major problem in Chinafor several reasons. First, many TVIEs do not participate in the currentEIA system; they dont submit EIA applications to SEPA or EPBs. Second,even when small enterprises conduct EIAs, they frequently fail to installthe required EOP treatment facilities. Third, enforcement of environmentalrequirements at TVIEs has been difficult, due to a lack of local EPBresources and personnel. As a result, China does not have effective con-straints on the development of small enterprises with poor technology, highresource consumption, and high pollution generation.5 Chemical oxygen demand (COD) is a measure of the organic content of wastewater. COD is determinedby using a chemical oxidizing substance to measure the amount of oxygen that would be needed to oxidizea particular wastewaters organic content.CLEANER PRODUCTION ANALYSIS AND EIA 465EIAs Conducted in Feasibility Study PhaseThe purpose of an EIA is to identify (and, thereby, eliminate or mitigate)the environmental impacts of a proposed project before final facility andsiting designs are made by project proponents. However, it is typically thecase that EIAs in China are carried out during the feasibility stage of aconstruction project, when production processes have already been selectedand alternative processes are no longer being considered. Without an assess-ment of environmental impacts or pollution sources prior to making finalfacility design choices, technical decisions invariably do not consider howdesign changes and cleaner production measures can be integrated into afacilitys design to reduce or prevent pollution.Case studies in China have shown that significant progress in eliminatingand reducing pollution can be achieved when top decisionmakers in acompany design (or redesign) facilities with cleaner production in mind(MPRCEE 1997; Warren 1996). In addition to environmental benefits,cleaner production measures may provide companies with attractive finan-cial returns.Firms Poor Management and Financial Burdens ConstrainEOP TreatmentMaintenance of production and treatment equipment in China often islax. According to industry sources, even new production equipment stopsfunctioning according to its original specifications within 3 years of purchasebecause of a lack of proper maintenance. Poor maintenance extends to EOPtreatment facilities: only about one-third of the EOP treatment facilities inChina are functioning properly; the remaining two-thirds are either shutdown immediately after the facility has passed its final inspection, or are notoperated in accordance with original design specifications (MPRCEE 1997).Poor maintenance practices are exacerbated by enterprises lack of fundsto cover operation and maintenance costs of their EOP treatment facilities.This problem can be traced back to the EIA system: Why were constructionprojects approved when project proponents could not afford the expenseof operating their treatment systems? The answer to this question is similarto why poorly operating plants are not shut down today. Although thenumber of enterprises with inadequate EOP treatment is huge, the potentialsocial problems from extensive plant closures (or rejection of applicationsfor new plants in a developing region) prevent the government from shuttingfactories down.Development of CP in ChinaCP is the continuous application of an integrated preventative environ-mental strategy applied for processes, products and services to raise eco-efficiency and reduce risks to humans and the environment (UNEP 1996).466 WENMING CHEN ET AL.CP includes the use of non-toxic production processes, raw materials substi-tution, internal recycling, and energy efficiency measures.Since 1992, with the assistance of the World Bank, the United NationsIndustrial Development Organization (UNIDO), the United Nations Envi-ronment Programme (UNEP), and other agencies, China has conductedtheoretical research, enterprise demonstration projects, and informationdissemination activities for cleaner production. These activities have beenpart of an on-going project (referred to as the B-4 project) conductedjointly with SEPA to fast-track the adoption of CP methods in China.So far, remarkable progress has been made.As part of the B-4 project, CP audits have been carried out in more than200 enterprises in the following sectors: textiles, chemicals and petrochemi-cals, electroplating, pharmaceuticals, breweries, food and beverages, andpulp and paper. The demonstration projects have shown that outstandingeconomic and environmental benefits can be achieved by enterprises imple-menting CP technologies.6In addition to sponsoring demonstration projects, the B-4 project sup-ported the creation of the China National Cleaner Production Center(CNCPC) in 1994. Provincial and sector-related cleaner production centerswere established through China in the mid and late 1990s. These nationaland regional CP centers now function as the core strength for developingand disseminating CP methods in China.Moreover, through close exchange with foreign CP experts and continu-ous participation by many domestic enterprises, China has established itsown CP methodology system. This methodology has been accepted as thestandard for China by the CNCPC, regional and sector CP centers, andacademic and industrial organizations involved in CP work. These organiza-tions have promoted the use of this CP methodology by enterprises inChina through publication of CP audit manuals and training materials forenterprises. The following section elaborates on the CP methodology anddiscusses how it will be integrated into procedures for EIA in China.CP Index and Evaluation System in ChinaBased on research conducted by SEPA and the CNCPC on incorporatingcleaner production analysis into EIA, a CP Index and Evaluation System(CPIES) was developed. In devising this system, SEPA and the CNCPCconsulted with environmental management staff at enterprises, and EIAand CP experts in numerous Chinese organizations (e.g., universities). Staff6 In general, with a very low investment, a typical enterprise participating in the B-4 project has reducedits total amount of wastewater discharged by 10% to 20%, and its total pollutants generated by 8% to15%. According to results from the B-4 project for 29 key enterprises, each 1,000 yuan ($120 US) investmentin CP reduced the amount of COD wastewater generated by 5.4 tons per year, and yielded annual averageeconomic benefits of 30,674 yuan ($3,696 US). The 29 enterprises invested a total of 0.78 million yuan($93,976 US) to carry out no- and low-cost CP options. Economic benefits from some of these CP options inindividual factories led to annual economic benefits of up to 2.9 million yuan ($349,000 US) (CRAES 1996).CLEANER PRODUCTION ANALYSIS AND EIA 467at SEPA and CNCPC also reviewed data on CP audits in China and abroad,and they conducted site visits to 100 enterprises to collect and analyze CPresults. These analyses revealed that enterprises needed a simple, easy-to-use method to evaluate their existing and proposed products, productionprocesses, equipment, and technologies in terms of CP. The CPIES systemwas developed to address this need, and the system will be applied to EIAprojects in China in an effort to decrease the time it takes to conduct CPaudits in enterprises.The index and evaluation system is based on CP criteria, i.e., criteriaagainst which enterprises or EPB staff can measure and evaluate CP perfor-mance.7 As shown in Table 1, the CP criteria are divided into four maincategories: raw materials, products, resource use, and pollutant generation.Raw materials criteria gauge the comprehensive environmental impact ofthe extraction, processing, and utilization of raw materials in a productionprocess or product cycle. Products criteria analyze the environmental im-pacts of a products sale, distribution, consumption, and disposal. Resourceuse criteria estimate the amounts of water, energy, and other resourcesused during production of a single unit of product. Pollutant generationcriteria quantify the total and individual amounts of pollutants created inproducing a single unit of product. In effect, the CP criteria gauge the totalimpact to the ecological environment of an enterprises single productionprocess or product line, or of entire production systems.The CP criteria listed in Table 1 can be separated into two generalclasses: qualitative criteria (raw materials criteria and product criteria) andquantitative criteria (resource use criteria and pollutant generation criteria).Different weighting (which CP and EIA experts in China are now evaluat-ing) and scores in the final evaluation are assigned to qualitative and quanti-tative criteria, as shown in Tables 2 and 3. Note that lower marks on anindividual criterion correspond to more damaging environmental impacts.Thus, when each of the individual marks is given a weight and the weightedmarks are summed to provide a total score, a higher score corresponds toa cleaner project in terms of environmental impacts and CP performance.The final evaluation of cleaner production is simple. Enterprises sum theweighted scores for each criterion and compare their results with thoselisted in Table 4. If the total score an enterprise receives is above 80, itmeans, on average, the proposed construction project reaches an advancedCP level. In other words, according to the present technological level theprocess, product, project, or enterprise is clean. Scores between 70 and80 indicate an advanced project, process, or enterprise in terms of CP,and so on.7 The CPIES and the principle of using criteria to assess and evaluate environmental performance wasbased on the theory and practice of lifecycle assessment (LCA). The latter involves evaluating the effectsthat a product has on the environment over the entire period of its lifecycle, from raw material extractionto the ultimate disposal of the product.468 WENMING CHEN ET AL.TABLE 1. Criteria for Cleaner Production EvaluationCP Evaluation Criterion Meaning of CriterionRaw materials Toxicity Degree of impact to ecological environmentcaused by toxic component of the rawmaterialsEcological impact Degree of impact to ecological environmentcaused by the extraction of raw materialsRecoverability Degree to which raw materials can berecovered to produce new raw materials(e.g., chemical recovery)Energy intensity Degree of energy consumption ofextracting and producing the rawmaterialsReusability and Degree of reuse and recycling of rawrecyclability materials (which may cause secondaryenvironmental problems)Products Sale and Degree of environmental impact fromdistribution product sale, transport, and distribution(e.g., from factory to consumer retailoutlet)Consumption Degree of impact caused by consumptionof products, including consumption ofenergy and other products duringproduct useProduct life Degree of product lifetime optimization,optimization including technical and aesthetic productservice life (e.g., length of acceptableaesthetic appeal to consumers)Disposal Degree of environmental impact caused byproduct disposal after final useResource use Fresh water Amount of fresh water consumption perunit productEnergy Amount of energy consumption per unitproductOthers Amount of other material consumption perunit productPollutant Wastewater Amount of watewater generated per unitgeneration productAmount of main pollutants (e.g., heavymetals) in wastewater per unit productWaste gas Amount of waste gas generated per unitproductAmount of main pollutants in waste gasper unit productSolid waste Amount of solid waste generated per unitproductAmount of main pollutants in solid wasteper unit productCLEANER PRODUCTION ANALYSIS AND EIA 469TABLE 2. Marks for Qualitative and Quantitative CP CriteriaRange ofType of Criteria Values Value Meaning MarksQualitative criteria High Low environmental impact 0.71.0Medium Medium environmental impact 0.30.7Low High environmental impact 0.00.3Quantitative criteria Very clean Reaches advanced level internationally 0.81.0Clean Reaches advanced level domestically 0.60.8Ordinary Reaches average level domestically 0.40.6Poor Below average level domestically 0.20.4Very poor Well below average level domestically 0.00.2To use the CPIES, factories, EIA consultants, and local EPBs will needdetailed and accurate information on best CP practices and available tech-nologies for any given industrial category. In addition to data supplied byfactories to local EPBs and other government units, information sourcesfor using the CPIES include industrial ministries, technical associations,environmental agencies, international organizations, CP roundtables, andcompanies specializing in CP.TABLE 3. Weight Values for Individual CriteriaCriteria Weight ValueRaw material Toxicity 7Ecological impact 6Recoverability 4Energy intensity 4Reusability and recyclability 4Subtotal 25Products Sales and distribution 3Consumption 4Product life optimization 5Disposal 5Subtotal 17Resource use Fresh water 11Energy 10Others 8Subtotal 29aPollutant generation 29Total score 100a The total weight value of the resource use and pollutants generated categories is 29 each. For resourceuse, the weighting values in this table are often used during the CP analysis. However, for both categories,the weights may vary, with apportionment of the total 29 points among each individual criterion beingdetermined on a case-by-case basis.470 WENMING CHEN ET AL.Using CP Audit Methodologies in the EIA ProcessCPIES provides enterprises with a quick and easy method of evaluatingproduction technologies and CP alternatives. In addition to CPIES, enter-prises conducting EIAs also will need to use traditional CP audits, whichentail a more comprehensive analysis of CP performance and carry out CPoption generation and feasibility exercises. These audits and other CPstudies will be particularly important for renovations of existing enterprises.When conducting CP analysis as part of an EIA, the CPIES can firstbe applied to the factorys current processes, products, equipment, andtechnologies. New technologies and systems proposed in renovation orexpansion plans then can be assessed in comparison to existing processes(see case study following). Staff also can quantify the amount of pollutantsto be reduced by CP measures.The use of CPIES will assist enterprises, EIA consultants, and EPBsduring the EIA process in identifying and preventing detrimental impacts tothe environment. For example, if an analysis based on the CPIES identified afactorys proposed technology as being backward, a consultant carryingout the EIA or an EPB evaluating it could suggest (or require) the choiceof cleaner and more efficient technologies. The process of using CPIESwould assist the factory in avoiding pollution and improving resource use,thereby preventing (or reducing) the negative environmental impacts thatwould have accompanied operation of the originally proposed technology.The CPIES also represents a valuable tool for impact prediction. Byusing the CPIES together with existing data on the environmental impactsof particular processes, and previous experience with the technology inChina or abroad, EIA consultants and EPBs can obtain an early indicationof whether a proposed technology will be highly polluting and what itslikely environmental impacts will be. If the proposed technology wouldresult in significant environmental impacts, it could be rejected during theEIA approval and evaluation process.The CPIES also may enable enterprises to benchmark their CP perfor-mance against external performance standards. For example, enterpriseleaders at a paper factory in China might discover through a CPIES analysisthat, in comparison to other paper factories in China or to paper companiesTABLE 4. Final Evaluation Scores for CP Project, Process, or EnterpriseTotal Score for Criteria Interpretation.80 Clean7080 Advanced5570 Ordinary4055 Backward,40 EliminationCLEANER PRODUCTION ANALYSIS AND EIA 471abroad, their own paper mill consumes a significantly higher amount ofraw materials per unit product. Identifying inefficient production is the firststep toward avoiding it and to eliminating its associated environmental andeconomic costs.Case Study of CPIES for the Suiping Pulp & Paper MillThe Suiping Pulp & Paper Mill, located in the Huaihe River Basin in Henanprovince, is used as a case study to illustrate the CPIES. The Suiping Pulp &Paper Mill is a small enterprise; it had an output valued at about 1 millionyuan in 1996. The factor produces 17,000 tons of straw pulp and 6,500 tonsof wood pulp per year at full capacity. Because the Huaihe River hadserious pollution problems, in 1995 the Chinese government designated theHuaihe River Basin a Key National Pollution Control Area. Severalhundred small pulp and paper enterprises in the basin were closed between1996 and 1997, and significant pressure exists for the remaining pulp andpaper factories to improve their operations or be shut down.Suiping Pulp & Paper Mill is a major pollution source in the HuaiheRiver Basin. The mill was not equipped with an alkali recovery facility,and wastewater was treated with a simple screening process and naturalprecipitation. Treatment removed about 20% of the COD, and the treatedwastewater was discharged directly into the Huaihe river.According to the Scheme of Prevention and Control of Pollution in theHuaihe River Basin issued by the State Council (1997), any existing pulp-making factory in the basin with a capacity below 50,000 tons annuallymust either be closed down or increase its capacity to at least 50,000 tonsper year. In the latter case, the factorys wastewater discharge must meetnational and local standards. In response to the State Councils ruling,Suiping Pulp & Paper Mill planned to expand its central pulp-makingprocess to a capacity of 37,000 tons of straw pulp and 13,000 tons of woodpulp, for a total of 50,000 tons of pulp per year. The mill was required bylaw to carry out an EIA for its proposed facility expansion project.To test and verify the CPIES, staff at the CNCPC conducted a CPassessment based on data provided by the Suiping Pulp & Paper Mill andcontained in the factorys EIA report for the proposed facility expansionproject (CRAES 1997). Data describing the existing and proposed strawpulp-making processes were compared with benchmark data derived fromprevious audit results for pulp and paper mills in China and other countries.8Results of this application of the CPIES for Suiping Pulp & Paper Mill areshown in Tables 5 and 6.8 Results of previous CP audits in Chinese companies, carried out by CNCPC and enterprise staff (aspart of SEPA, B-4 project, and other CP research projects) are collected and stored in a database atthe CNCPC.472 WENMING CHEN ET AL.TABLE 5. CPIES Analysis Results for Existing Straw Pulp (No Alkali Re-covery) Process at Suiping Pulp & Paper MillaCP Evaluation Criterion Value: Marks Weight MarksRaw materials Toxicity High: 0.7 7 4.9Ecological impact High: 0.9 6 5.4Recoverability High: 0.9 4 3.6Energy intensity High: 0.9 4 3.6Reusability and High: 0.7 4 2.8recyclabilitySubtotal 25 20.3Products Sale and distribution High: 0.9 3 2.7Consumption High: 0.9 4 3.6Product life optimization Medium: 0.5 5 2.5Disposal High: 0.7 5 3.5Subtotal 17 12.3Resource useb Fresh water/unit product Very poor: 0.0 15 0.0Wheat straw/unit product Ordinary: 0.5 4 2.0Alkaline/per unit product Clean: 0.75 4 3.0Reuse of alkaline Very poor: 0.0 6 0.0Subtotal 29 5.0Pollutant Total wastewater Very poor: 0.0 9 0generationcCOD generated Very poor: 0.0 7 0BOD generated Very poor: 0.0 7 0Suspended solids Very poor: 0.0 6 0Subtotal 29 0Total score 37.60a Source: CRAES (1996).b Resource use data do not include energy per unit product, because these data were unavailable from theSuiping mill.c Chemical oxygen demand (COD), biochemical oxygen demand (BOD), and suspended solids are measurescharacterizing wastewater releases to a receiving water body.Because the existing and proposed processes use the same raw materialsand make the same products, the scores for raw materials and productsare identical. Results of applying the CPIES indicated that the existingpulping process used by Suiping Pulp & Paper Mill had a score of only 37.6.As Table 4 shows, any process with a score below 40 should be eliminated.An assessment based on the CPIES was performed for the alkali pulprecovery process proposed by the factory in its EIA report. The total scorefor the proposed expansion project was 69.53, which is between 55 and 70and thus corresponds to an ordinary level for pulp processes in Chinatoday. The production process used in the proposed expansion project thusis acceptable. However, the final score of 69.53 indicates that resource useand pollutant generation aspects of the proposed new process could begreatly improved.CLEANER PRODUCTION ANALYSIS AND EIA 473TABLE 6. Cleaner Production Analysis Final Scores for Existing StrawPulp Making (No Recovery) Process and Proposed New Straw Pulp-MakingProcess with Alkali Recovery System at Suiping Pulp & Paper MillRaw Resource PollutantMaterials Products Use Generation TotalScores for the oldprocess 20.3 12.3 5.0 0 37.60Scores for theproposed process 20.3 12.3 16.95 17.98 69.53The value of the CPIES is that its results would show that the proposedpulp-making process is ordinary, meaning that it would result in notablepollution discharges. Based on the factorys location and other factors,managers at Suiping Mill or local EPB staff who are evaluating SuipingsEIA proposal could identify and predict that negative environmental im-pacts to local receiving waters would occur if the proposed technology wereapproved. EPB staff could use these results to recommend to the factorythat to receive EIA approval, staff must reassess the proposed productionprocess and choose less-polluting, best available CP technologies. If theSuiping Mill followed this recommendation and adopted additional CPproduction methods, it could reduce the factorys resource use and pollutionlevels, which were shown by the CP analysis to be high relative to advancedpulp and paper mills in China and abroad.Integrating CP into Chinas EIA SystemChinas environmental protection and economic development agencies canuse the EIA system to foster cleaner production and put an end to thehigh input and low output problems that have characterized Chineseindustry for many years. CP analyses of the type done for the SuipingPulp & Paper Mill can help to identify industrial projects with backwardtechnologies, high resource and energy consumption, and serious pollutionproblems. More generally, CPIES analyses could be used by local EPBsto screen out small, poorly designed industrial projects that, in the past,often have generated serious pollution and failed to meet standards becauseof a shortage of funds to operate EOP treatment facilities.How will cleaner production be incorporated into the existing EIA systemin China? Several possibilities exist, including EIA policy and proceduralchanges and the application of cleaner production audits and the CPIESas illustrated above for the Suiping Pulp & Paper Mill. The current EIAsystem in China does not require enterprises to conduct a CP analysis oraudit during an EIA. Revisions in EIA regulations (and those of the related474 WENMING CHEN ET AL.three synchronizations program) to require project proponents to employthe CPIES and select the least polluting and most efficient technologieswill go far towards reducing companies environmental impacts and improv-ing their economic performance.9As previously noted, the current EIA programs reliance on EOP treat-ment facilities has placed a financial burden on many of Chinas firms. Andfirms with insufficient funds do not operate their treatment works; thus,there are low operation rates for EOP treatment facilities. In contrast,cleaner production focuses on improving the efficiency of products andprocesses to reduce pollution generation. Frequently, CP is cheaper thanEOP treatment as a mechanism to reach environmental standards, and CPmay decrease production costs.However, requiring firms (or EPBs) to use the CPIES may impose bur-dens. Currently, many factories and local EPBs in China lack the knowledgeof industrial best practices, particularly regarding advanced productionprocess and CP technologies. Moreover, some CP technologies requirelarger initial capital investments than less expensive (but more polluting)technologies proposed by some firms, especially TVIEs. These technicaland financial issues could diminish the attractiveness of using results fromthe CPIES in the context of EIA. Last, requiring CP analyses will lengthenthe overall EIA process, which may be unacceptable to local governmentsat a time when many of them have pledged to streamline approval processesfor businesses.Measures can be taken to offset these disincentives to using the CPIES.EPBs can give easier, faster, and more successful approval to EIAs thatchoose CP over EOP treatment technologies. Preferential loans by banksfor CP projects and a revolving CP loan fund can be established to reduceChinese firms difficulties in financing large-scale CP expansion and renova-tion projects. Finally, increased enforcement by EPBs will ensure thatTVIEs participate in the EIA program and carry out requirements tointegrate CP into the EIA process.ConclusionsAlthough the EIA system has been established for nearly 20 years in Chinaand has improved markedly during that time, serious limitations still exist.Small industrial pollution sources continue to slip through the cracks ofthe EIA regulatory system, and their pollution problems require urgent9 EIA regulations could also be revised so that EIAs are moved to earlier stages of the project managementprocess, namely the project proposal phase. For companies, the CPIES (and more detailed CP audits) canbe completed during the EIA proposal stage. CP measures will also need to be synchronized with thedesign, construction and operation of the plant, as part of the three synchronizations program. Oneforeseeable issue to be addressed regarding CP policy changes is the potential for conflicts with otherenvironmental regulatory programs. Plans for the coordinated revision of the EIA and other programs,such as the discharge fees system, are currently being evaluated and are slated for implementation overthe next five years (MPRCEE 1997).CLEANER PRODUCTION ANALYSIS AND EIA 475attention to avoid further declines in Chinas rural environmental quality.Cleaner production provides an important means for addressing these prob-lems, because CP is often less financially encumbering then EOP treatment,and enterprises may derive economic benefits from its adoption.Because the existing EIA system focuses primarily on the treatment ofpollutants after their generation, rather than on the prevention of pollutantsbefore they are created, it encourages enterprises to continue their relianceon EOP treatment. Requirements to use the CPIES or a similar CP assess-ment process could be fully incorporated into EIA, and a first step in thisdirection was taken with the State Councils 1998 revised ManagementProcedures for Environmental Protection of Capital Construction Projects.Thus, new emphasis by enterprises on CP and pollution prevention wouldhelp China to improve the quality of new industrial projects and reducethe economic burden EOP treatment places on enterprises.The authors would like to acknowledge the United Nations Environment Programme andthe World Bank for their long-standing support of cleaner production in China. We wouldalso like to thank participating Chinese enterprises and staff of the China National CleanerProduction Center for their hard work and effort in making current and past cleaner productionprojects in China a success.ReferencesCER (China Environmental Review). 1999. Vol. II, Issue 2, December 1998January1999. London: Asia Environmental Trading, Ltd.CRAES (Chinese Research Academy of Environmental Sciences). 1996. TechnicalResearch Report of Promoting Cleaner Production in China (B-4 sub-project).Unpublished technical report.CRAES (Chinese Research Academy of Environmental Sciences). 1997. Environ-mental Impact Assessment Report for the Extension Engineering of SuipingPulp & Paper Mill. Unpublished report.MPRCEE (Modern Policy Research Center for Environment and Economy). 1997.Sub-reports of Policy Research on Promoting Cleaner Production in China. B-4project Research Group. Unpublished report.NEPA (National Environmental Protection Agency). 1996. Training Material forEnvironmental Impact Assessment. Unpublished training material. Beijing:NEPA.NEPA and the National Peoples Congress. 1989. Environmental Protection Lawof the Peoples Republic of China. In The Handbook for Environmental Lawsand Enforcement (1997). Beijing: China Environmental Science Press.NEPA. 1989. Management Procedures for EIA Certification of Construction Proj-ects. In The Handbook for Environmental Laws and Enforcement (1997). Beijing:China Environmental Science Press.476 WENMING CHEN ET AL.NEPA. 1993. Technical Guidelines for Environmental Impact Assessment. Regula-tion HJ/T 2.1-2.3-93. Beijing: China Environmental Science Press.Sinkule, B. Ortolano, L. (1995). Implementing Environmental Policy in China.Westport, CT: Praeger.State Planning Commission, State Construction Commission, State Economic andTrade Commission, and Environmental Protection Committee of the State Coun-cil. 1981 (trial) and 1986 (modified). Management Procedures for EnvironmentalProtection of Capital Construction Projects. In The Handbook for EnvironmentalLaws and Enforcement (1997). Beijing: China Environmental Science Press.State Council. 1997. Scheme of Prevention and Control of Pollution in the HuaiheRiver Basin. State Council Circular, Beijing, China.State Council. 1998. Management Procedures for Environmental Protection ofCapital Construction Projects. Regulation No. 253. Beijing: China EnvironmentalScience Press.UNEP IE. 1996. Cleaner Production Programme. Unpublished brochure. Paris:UNEP IE.Warren, K.A. 1996. Going Green in China: An Organization Theory Perspectiveon Pollution Prevention in Chinese Electroplating Firms. Ph.D. dissertation, De-partment of Civil and Environmental Engineering, Stanford University, Stan-ford, CA.

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