Not approved! Environmental impact assessment for 4 billion cubic meters of coal-to-natural gas project in Inner Mongolia rejected

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On September 1, the **Ministry of Environmental Protection issued an environmental impact assessment approval document (Letter No. 1314 from the Environmental Assessment Department), denying approval for the environmental impact report related to Inner Mongolia Huaxing New Energy Co., Ltd.’s project to produce 4 billion cubic meters per year of coal-based natural gas. It also lists several issues existing in project environmental assessment (see below). On July 24, 2017, the **Ministry of Environmental Protection officially began reviewing the environmental impact assessment documents for Inner Mongolia Huaxing New Energy Co., Ltd.’s coal-to-natural gas project with an annual production capacity of 4 billion cubic meters. On May 19, the **Ministry of Environmental Protection officially accepted the environmental impact assessment documents for Inner Mongolia Huaxing New Energy Co., Ltd.’s coal-to-natural gas project with a capacity of 4 billion Nm3 per year. On January 20, 2014, the 4 billion Nm3/year coal-to-natural gas project of Inner Mongolia Huaxing New Energy Co., Ltd. received the reply from the General Office of the **Development and Reform Commission titled \"Reply on the Preliminary Work for the Coal-to-Natural Gas Pilot Project of Inner Mongolia Huaxing New Energy Co., Ltd.\" (Document No. Fa Gai Ban Neng Yuan 188), which approved the initiation of the preliminary work for this project. In 2016, the **Ministry of Environmental Protection approved the environmental impact assessment applications for CNOOC’s Datong project in Shanxi, the Suxin Hefeng project in Xinjiang, the Beikong Jingtai project in Inner Mongolia, and the Xintian project in Ili, Xinjiang. Notice on the Refusal to Approve the Environmental Impact Assessment Report for Inner Mongolia Huaxing New Energy Co., Ltd.’s 4 billion cubic meters per year coal-to-natural gas project. Inner Mongolia Huaxing New Energy Co., Ltd.: We have received your company’s application regarding the review of the Environmental Impact Assessment Report for Inner Mongolia Huaxing New Energy Co., Ltd.’s 4 billion cubic meters per year coal-to-natural gas project (Inner Mongolia Huaxing [2017] No. 7). Upon review, the project and its environmental impact report have the following main issues: First, the project is located in the Shanghai Miao Energy and Chemical Industry Base in Ejin Horo Front Banner, in the western part of Ordos City, adjacent to the Ningdong Energy and Chemical Industry Base in Ningxia. The degree of regional development in this area is high, and the situation regarding joint air pollution control across different regions is severe. In 2016, the annual average concentration of inhalable particulate matter (PM10) did not meet the **environmental air quality standards, with a exceedance rate of 24%. The maximum daily average concentration of the characteristic pollutant benzo[a]pyrene also exceeded the standard by 99.6%. The measures proposed in the report for reducing regional air pollutants involve upgrades to boilers to ensure compliance with standards; however, no measures were suggested to reduce benzo[a]pyrene levels. As a result, these measures are insufficient to meet the requirements for improving regional environmental air quality. 　　II. According to the environmental impact report, the project requires a total amount of 2,804.39 tons per year of sulfur dioxide; however, 840.78 tons per year of this amount comes from alternative sources that have not been assigned to specific companies. For nitrogen oxides, the required total amount is 2,955.64 tons per year, but 325.21 tons per year of this amount also has no identified alternative source. The report states that the amount of volatile organic compounds to be reduced through substitution comes from shutting down two coking plants, but it lacks specific calculation methods and feasibility analyses. The above issues are not in compliance with the requirements of the Interim Measures for the Review and Management of Total Emission Limits for Major Pollutants in Construction Projects. 　　III. The coal pulverization pressurized gasification process intended for use in this project has a low level of clean production; it results in high emissions of pollutants in the form of wastewater and waste gas, and its operational stability is poor. To date, there are no successful examples of its long-term, stable operation. The report does not provide sufficient discussion on the effectiveness and feasibility of using clay as a barrier material in wastewater retention tanks; there is insufficient evidence to support the stable operation of the wastewater treatment facilities and the reliability of preventing wastewater from leaking out, posing significant environmental risks. 　　IV. According to calculations, the project requires the treatment of 115,400 tons of hazardous waste per year, of which 28,000 tons are to be incinerated and 87,400 tons are to be landfilled. However, the hazardous waste treatment facility at the Shanghaimiao Energy and Chemical Complex, which serves this project, has an annual processing capacity of only 94,000 tons – 17,000 tons to be incinerated and 77,000 tons to be landfilled. The processing capacity of this facility is not sufficient to meet the project’s needs, and it is therefore not possible to ensure proper treatment of the hazardous waste. 　　In light of the above issues, our department has decided not to approve the environmental impact assessment report for this project. Article 25 of the Environmental Impact Assessment Law of the People’s Republic of China stipulates that if the environmental impact report for a construction project is not approved following its review, the construction unit shall not commence construction. Our department has entrusted the Environmental Protection Department of Inner Mongolia Autonomous Region and the North China Environmental Protection Inspection Center to carry out supervision and inspection. 　　If your company is not satisfied with the decision contained in this notice, it may apply for administrative reconsideration to our department within 60 days from the date of receipt of this notice, or it may file an administrative lawsuit in accordance with the law within 6 months from the date of receipt of this notice. General Office of the Ministry of Environmental Protection