Thoughts on the reform of the total pollutant emission control system during the 13th Five-Year Plan period

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Theoretically, total emission control can only be applied to pollutants that have a homogeneous impact on environmental quality and end-users, such as sulfur dioxide, which causes acid rain, and carbon dioxide, which contributes to the greenhouse effect. In practice, the total emission control implemented in our country is a directive control model that sets five-year reduction targets for the emissions of key pollutants, which are then allocated downward to local levels, with assessments conducted on an annual basis. At present, total pollutant emission control has become an important environmental legal system in China. Over the past 10 years, total emission control has played a positive and effective role in reducing pollutant emissions, curbing environmental degradation, and establishing a **responsibility system for environmental protection goals. However, the current total emission control system also has many problems. In particular, as public demand for environmental quality in terms of people’s livelihoods continues to rise, it is imperative to reform the total emission control system during the 13th Five-Year Plan period so that it aligns with the goal of improving environmental quality. Analysis of the evolution of total pollutant emission control: The Third National Environmental Protection Conference in 1988 proposed the simultaneous implementation of concentration control and total amount control. In August 1996, the \"Decisions of the State Council on Several Issues Concerning Environmental Protection\" mentioned for the first time the need to implement total control over pollutant emissions, to establish a system of total control indicators and a mechanism for regular public reporting, marking a shift in China’s pollutant emission management from concentration control alone to a combination of both concentration control and total control. Since its establishment, China’s total emission control system has gone through four five-year plans, evolving through continuous exploration and gradual development, with evident results in its implementation. “The total emission control system was officially put into effect during the Ninth Five-Year Plan period. Through the \"Ninth Five-Year Plan for Total Emission Control of Major Pollutants Nationwide,\" China set a goal of reducing the total emissions of 12 pollutants, including dust, sulfur dioxide, particulate matter, chemical oxygen demand, petroleum compounds, **, arsenic, mercury, lead, cadmium, hexavalent chromium, and industrial solid waste, by 10% to 15%. It also established the assessment target of \"one control and two compliance standards,\" meaning that by the year 2000, the country should achieve overall control over pollutant emissions, while 47 key cities should meet the environmental standards for their respective areas, and industrial enterprises across the country should comply with the pollutant emission regulations. With an average annual GDP growth rate of 8.3%, the emission reduction targets were largely achieved. However, during this period, the environmental situation in our country underwent significant changes. Environmental pollution increased at a rapid pace alongside the growth of GDP, which not only led to a comprehensive deterioration of the environmental conditions in the 1990s but also resulted in the accumulation of numerous environmental problems. “The overall control targets for the 15th plan period were essentially unmet. The faster-than-expected economic growth and structural changes were things that were not anticipated when formulating the Tenth Five-Year Plan for National Economic and Social Development; the gap between environmental protection and economic development is widening. “During the 15th Five-Year Plan period, China’s emissions of industrial waste gas and wastewater, as well as the generation of solid waste, entered a phase of rapid growth, with annual growth rates reaching 22%, 8.5%, and 17% respectively. Although targets were set to reduce emissions of sulfur dioxide, dust (soot and industrial dust), chemical oxygen demand, ammonia nitrogen, and industrial solid waste by 10%–20%, these five total emission control targets were not achieved; in essence, there was a total amount specified but no actual control, meaning the goals were essentially unmet. “During the 11th Five-Year Plan period, total emission control was raised to a **strategic level**, and China’s environmental protection policies shifted from relying on soft constraints to those based on hard constraints. Among them, sulfur dioxide and chemical oxygen demand are two indicators representing \"rigid constraints\"; it is planned that by 2010, their emissions will be reduced by 10% compared to the 2005 levels. During this period, significant innovations were made in terms of system design, management models, and implementation methods to control the total amount involved; these innovations overcame the limitations posed by systems that imposed limits on quantities. With the effective support of three key measures, three systems, and nine regulatory frameworks, both chemical oxygen demand and sulfur dioxide emissions were reduced beyond the set targets. “The total emission controls during the 12th Five-Year Plan period were further expanded and optimized. Taking into account factors such as environmental quality characteristics, key priorities for different stages, existing foundations, as well as technical and economic aspects, ammonia nitrogen and nitrogen oxides were included as mandatory control targets on top of the controls already in place for sulfur dioxide and chemical oxygen demand during the 11th Five-Year Plan period. Meanwhile, agricultural sources and motor vehicles were brought under control as well. By the end of 2014, the reduction targets for chemical oxygen demand and sulfur dioxide had been met ahead of schedule under the 12th Five-Year Plan; the target for ammonia nitrogen was nearly achieved, while the reduction of nitrogen oxides exceeded the scheduled progress. **“The total emission control measures during the 12th Five-Year Plan period were effective. During this period, China developed a relatively systematic framework for guiding and managing pollution reduction throughout the entire process, achieving significant results. Such measures played a positive role in promoting the construction of environmental protection infrastructure, accelerating industrial structure transformation, and enhancing basic environmental protection capabilities. Total emission control became the core focus of environmental protection at the local level; it not only contributed to improving environmental quality but also served as an important tool for restructuring the economy, changing development patterns, and benefiting people’s livelihoods. The total amount of pollutants discharged has decreased significantly, leading to an improvement in environmental quality. Despite the ongoing socioeconomic development and the continuous rise in key economic indicators as well as energy and resource consumption, the emissions of the four major pollutants across the country have been largely brought under control, resulting in varying degrees of improvement in environmental quality. By the end of 2014, the total national emissions of chemical oxygen demand, ammonia nitrogen, sulfur dioxide, and nitrogen oxides were 22.946 million tons, 2.385 million tons, 19.744 million tons, and 20.78 million tons respectively, representing decreases of 10.1%, 9.8%, 12.9%, and 8.6% compared to 2010. Among these, the targets for reducing chemical oxygen demand and sulfur dioxide were met ahead of schedule; the target for ammonia nitrogen was nearly achieved, while the reduction in nitrogen oxide emissions exceeded the scheduled goals. Satellite remote sensing data show that between 2010 and 2014, the annual average concentrations of sulfur dioxide in East China and North China (including Beijing, Tianjin, Hebei, Shanxi, Shandong, Henan, Anhui, Jiangsu, Zhejiang, Hubei, Shanghai, and Liaoning), South China (mainly the Pearl River Delta region), and Southwest China (mainly the Chengdu-Chongqing urban agglomeration and surrounding areas) decreased by 1.34%, 55.98%, and 48.47% respectively ； Nitrogen oxides decreased by 6.66%, 23.49%, and 1.61% respectively; the significant reduction in the emissions of these two air pollutants helped to mitigate the upward trend in PM2.5 pollution. The average annual concentrations of chemical oxygen demand and ammonia nitrogen at the nationally monitored surface water sites dropped by 17.0% and 38.1% respectively, which played a positive role in improving the environmental quality of China. Pollution control facilities have seen significant development, resulting in a marked improvement in emission reduction capabilities. During the 12th Five-Year Plan period, building on the successful experience gained during the 11th Five-Year Plan in terms of overall emission reduction, further historic breakthroughs were achieved in the construction of pollution control facilities. By 2014, the total installed capacity of desulfurization facilities in coal-fired power plants across the country reached 800 million kilowatts, with this proportion rising from 12% in 2005 to 95% of the total installed capacity of coal-fired power plants ； The total installed capacity of denitration facilities reached 690 million kilowatts, with their share increasing from 2% to 82%. Denitration has been implemented for a clinker production capacity of 650 million tons, with the proportion of denitration capacity increasing from 0% to 83%. Desulfurization of a 120,000-square-meter sintering machine was carried out, achieving a desulfurization rate of 81%. More than 3,000 new and upgraded industrial wastewater treatment facilities have been built across the country, resulting in a significant increase in the rate of industrial wastewater discharged in compliance with standards ； 2,829 new urban sewage treatment plants were added, bringing the total sewage treatment capacity to 36 million tons per day; the daily processing capacity for the harmless treatment of municipal solid waste reached 105,000 tons. The rates of urban sewage treatment and the harmless treatment of municipal solid waste exceeded 89% and 90%, respectively ； More than 40,000 large-scale livestock and poultry farms have upgraded their waste treatment and resource utilization facilities, resulting in an increase of about 5% in chemical oxygen demand removal efficiency and about 20% in ammonia nitrogen removal efficiency. The large-scale construction of pollution control facilities provides a strong guarantee for achieving emission reduction targets. Structural adjustments have yielded significant results, with a marked reduction in pollution emissions. A mechanism to drive down pollution levels has been established; through measures such as phasing out smaller enterprises in favor of larger ones, reducing emissions through substitution, and setting deadlines for elimination, efforts have been made to accelerate the adjustment of the economic and industrial structures, thereby forcing a large number of enterprises with high energy consumption and high emission levels to withdraw from the market. “In the first four years of the 12th Five-Year Plan, approximately 26 million kilowatts of small thermal power units were phased out, 80 million tons of steel production was reduced, and 300 million tons of cement production was cut back. Additionally, 3,184 paper manufacturing enterprises and 1,467 printing and dyeing enterprises were closed down. In 2014, thermal power units with a capacity of over 300,000 kilowatts accounted for 77% of the total in the country, and the standard coal consumption per unit of electricity generated decreased by 10 grams per kilowatt-hour ； The energy consumption per unit of GDP across the country is 0.89 tons of standard coal per 10,000 yuan, a decrease of 13.45% compared to 2010 ； The chemical oxygen demand and ammonia nitrogen emission loads per unit of industrial output in the national papermaking industry decreased by 35.9% and 40.7%, respectively. Strengthening the main responsibilities and establishing a **target responsibility system** – during the 12th Five-Year Plan period, an assessment system centered on **target responsibilities** facilitated strong progress in emission reduction efforts. The State Council authorized the Ministry of Environmental Protection to sign agreements on targets for reducing the total emissions of major pollutants with provincial governments, the five major power generation groups, CNPC, Sinopec, and Shenhua Group. These agreements clearly stipulate the emission reduction targets and measures. All provinces across the country have broken down and assigned their environmental protection goals and tasks to various levels of government, thereby ensuring that all emission reduction measures are implemented in an orderly and effective manner. Three major problems with total quantity control: Although progress has been made in reducing total emissions, under the current environmental protection strategies and amid public concern over livelihood issues, total quantity control also presents a series of problems that urgently require improvement and reform. In general, it is mainly manifested in the following three aspects. First, there is a lack of synchronization between overall emission reduction and quality improvement. The current design of pollution reduction systems is primarily based on the existing environmental management infrastructure and capabilities; the range of control factors is limited, and the control methods are singular. The control objectives and plans are not effectively linked to environmental capacity, making it impossible to address the needs for improving environmental quality in various regions in a scientific and effective manner. On a macro level, it is difficult to clarify the contribution of total quantity control to the improvement of local environmental quality. As a result, this creates the illusion among the public that the overall emission control targets are being met year after year, even though environmental quality continues to deteriorate. Second, the total quantity control system lacks coordination and integration with the existing pollution source management system. Effective control of pollution sources is the core task of total emission control. However, due to the lack of a standardized and rigorous permit system for emissions, the requirements imposed by the total emission control system on pollution sources cannot be effectively integrated with other policy tools such as environmental impact assessments, emission standards, and emission fees. This prevents the creation of a cohesive regulatory framework, resulting in increased administrative costs without corresponding improvements in effectiveness. In most areas, the total emission control targets have not been specifically assigned to key pollution sources. For some emission sources and polluting enterprises, the requirements of total emission control are often lower than those set by emission standards. Third, there is a lack of capacity in terms of total amount control and pollution reduction technologies. Overall, the current environmental management capabilities are insufficient to address the challenges of pollution reduction. Firstly, the statistical methodology system is not yet perfect; small sources and non-road mobile sources that are not monitored have not been included in the statistical system. Secondly, the scope, frequency, and parameters of pollution source monitoring still do not meet the requirements for quantitative and detailed management of total emissions; moreover, the monitoring and evaluation methods in some systems are not yet perfect, failing to reflect the pollution discharge status of these sources in a timely, comprehensive, and accurate manner. Once again, environmental supervision capabilities are insufficient; in some areas, the assessment of pollution reduction efforts is superficial, the assignment of reduction targets and the enforcement of related responsibilities are inadequate, there is a lack of environmental protection resources at the local level, and follow-up actions are not properly carried out. “Accelerated institutional reform is urgently needed for total emission control during the 13th Five-Year Plan period. This period is crucial for curbing the increase in pollutant emissions, achieving overall emission reductions, and improving environmental quality; it imposes higher demands on the design of emission reduction systems, emission reduction technologies, the effectiveness of environmental supervision, and the use of various policy tools. Therefore, it is recommended that, building on the work done during the 12th Five-Year Plan period, significant efforts be made in the top-level design of emission reduction policies during the 13th Five-Year Plan period, involving choices and innovations, in order to gradually implement reforms in the following five areas. Accelerate the establishment of a total emission control system aimed at improving environmental quality. An environmental management approach that focuses on improving environmental quality and meeting human health needs can better reflect the efficiency and effectiveness of source control and emission reduction, and this represents the ultimate goal of environmental management in China. As an important measure for improving environmental quality, total emission control should see the expansion and refinement of relevant approaches and technical methods during the 13th Five-Year Plan period, with a gradual shift from a pollution reduction model driven by tasks based on the current state of environmental quality to a control model oriented toward environmental quality goals. In areas heavily polluted, it is necessary to actively establish a relationship between total emissions and environmental quality, using environmental quality as a guiding criterion to determine the emission reduction targets, indicators, and control measures for the 13th Five-Year Plan, thereby achieving precise and scientific emission reductions ； In areas where the quality of the atmospheric and aquatic environments is close to meeting the standards, it is possible to implement technically and economically feasible total quantity controls in the near term, on the premise that environmental quality continues to improve. We should actively explore the establishment of a reduction system at the **region (stream) area–industry level**. There are significant spatial differences in environmental issues in China; due to variations in energy structures, economic structures, and levels of development, different regions face distinct environmental pressures. The total emission control measures during the 13th Five-Year Plan period should build upon national-level controls while enhancing their specificity and effectiveness. By taking into account the differences in resource and environmental conditions as well as environmental function requirements across various regions, targeted measures should be implemented. For areas with severe environmental pollution, regional total emission controls should be enforced based on the needs for improving environmental quality, adopting a \"one region, one strategy\" approach to establish regional total emission factors, control targets, and implementation mechanisms. Furthermore, implementing total quantity controls on inefficient and highly polluting industries is not only crucial for achieving the overall goal of controlling the total amount of major pollutants, but it also facilitates strategic adjustments in the industrial structure and optimizes regional development patterns; it represents an effective means of using pollution reduction to drive economic transformation. The system of total quantity control for enterprises and institutions is implemented through licenses. As efforts to enforce total quantity control progress, the need for more precise and quantitative management in this area has become increasingly evident in China, and it has gradually emerged as the key approach to controlling point source pollution emissions. “Building on this foundation, the 13th Five-Year Plan should further strengthen the management of point source and fixed sources of pollution. Focusing on industrial pollution sources, a total emission control system for enterprises and institutions should be established to ensure that such controls are targeted at the enterprise level. The total emission targets for enterprises and institutions, as well as requirements regarding energy consumption, concentration limits, and pollution control measures, which are determined based on the needs to improve environmental quality, should be formalized through emission permits. The management of pollution reduction targets should be elevated to a systematic approach that covers the entire process of pollutant emissions by enterprises and institutions, and the primary responsibility of enterprises for reducing emissions should be further strengthened in order to create a comprehensive and effective management system that addresses both symptoms and root causes. Establish a comprehensive evaluation and assessment system centered on environmental quality. The mechanism for assessing overall emission reductions is currently a significant aspect that is widely criticized by local authorities as well as experts and scholars. It is recommended that the Ministry of Environmental Protection intensify reforms, streamline the relationships among existing environmental management assessment systems, integrate various evaluation and assessment mechanisms within the environmental protection framework, and establish a comprehensive assessment system centered on environmental quality performance. Total amount control assessments should be regarded as one of the key indicators in quality assessments, and a total amount assessment approach that includes data verification, evaluation of key projects, and assessment of the work process should be developed to promote local efforts in preventing air and water pollution. Effective measures should be taken to accelerate the disclosure of information on environmental quality and pollution sources; the assessment system should include greater public participation, with particular emphasis on the weight given to public satisfaction, in order to address the significant disparity between \"official\" assessments and what the public perceives. At the same time, the current allocation of central financial funds for environmental protection should be strictly linked to performance evaluations of environmental quality, in order to improve the environmental performance and economic efficiency in reducing the total amount of pollutants. Establish a total quantity control system based on multiple measures and collaborative governance. International experience as well as local practices show that combining legal, economic, technical means along with necessary administrative approaches, and adopting a governance model involving governments, enterprises, and the public, is an effective way to achieve environmental goals. “During the 13th Five-Year Plan period, China’s total volume control should move away from the traditional model dominated by a single approach and driven by administrative orders, so as to reflect the modern environmental governance concept of multiple measures and joint governance by various stakeholders. While maintaining the effectiveness of command-and-control policies, it is necessary to coordinate the relationships among emission trading, emission fees, comprehensive environmental protection electricity prices, contract-based emission reduction services, ecological environment compensation, and total emission control systems. A market-based emission reduction mechanism should be gradually established, and a range of economic policies and technical measures as well as other incentive-based policies should be employed to motivate enterprises to reduce their emissions. On the premise of being responsible for environmental quality at all levels, an implementation mechanism should be established in which enterprises assume primary responsibility, social organizations participate in accordance with the law, and the news media exert oversight through public opinion. Build a solid scientific and technological support system. During the 13th Five-Year Plan period, China should further strengthen the scientific and technological support and guidance role in total quantity control. First, it is necessary to intensify basic research on the theories and management systems related to total quantity control, improve the level of scientific decision-making, address the issue of lack of technical support in the implementation of total quantity control, and enhance the effectiveness of environmental management. Second, accelerate the development of pollution reduction technologies suitable for China’s national conditions, continuously increase the contribution of technological progress to pollution reduction, and minimize pollutants generated during the production process. Third, it is necessary to further break through the bottlenecks in environmental management related to total quantity control, and improve methods such as online monitoring of pollution sources, automatic verification of emission reduction data, and national environmental statistics on pollution sources, so as to provide support for advancing more refined and quantitative management of total quantity control in the future.