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Feel free to share your insights on the approval (filing) process for new construction, renovation, and expansion projects

2022-09-28View Original

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The last edit to this post was made by Shutong on 2023-6-16 at 00:27. I’ll share an experience related to project registration; the general situation is as follows: In 2020, there were institutional reforms in my area, and the documents required for approving projects were previously issued by the local development and reform departments. Later, it became the responsibility of the administrative approval departments to handle project registration, and the subsequent project documents came to be called “XX Project Registration Certificates”. Coincidentally, the original project approval documents had been issued by the development and reform departments, but after those documents were issued, this responsibility was transferred to the administrative approval bureau – that’s the background. The original registration documents state: “The investment for this project is XX, of which the capital contribution accounts for 100%.” The problem lies in this percentage. According to relevant investment regulations, capital contribution refers to the funds that the project owner must invest in the construction of the project; such funds can be considered as the project owner’s own capital ; Relevant regulations require that the capital funds used for project construction must be no less than 30% of the investment amount ; To reduce financial pressure, most companies opt to fund part of the construction with their own capital, while borrowing the remaining amount for the project ; It is precisely this 100% proportion that prevents the project from obtaining loans from financial institutions ; **With the shift in institutional functions, it is no longer possible to modify the project approval documents, which poses a significant problem for companies ; Still regarding this project, for projects involving the chemical industry, when implementing the principle of simultaneous implementation of three requirements, they are generally divided into hazardous chemical construction projects and non-hazardous chemical construction projects (some refer to them as ordinary chemical projects; in the author’s view, these refer to those enterprises that do not need to obtain special permits) ; Under this premise, the implementation of the \"three simultaneities\" principle involves two documents: one is Order No. 36 issued by the former State Administration of Work Safety (later revised by Order No. 77), namely the \"Measures for the Supervision and Management of Safety Facilities in Construction Projects in Accordance with the Principle of Three Simultaneities\", and the other is Order No. 45 issued by the same authority (later revised by Order No. 79), namely the \"Measures for the Supervision and Management of Safety in Construction Projects Involving Hazardous Chemicals\". It is likely that everyone has encountered difficulties in determining which of these documents applies to a given project ; That’s exactly the problem: which category does the project fall into? The reason is that the documentation submitted for approval did not specify phased construction of the project. However, the review experts considered it to be a hazardous chemicals construction project, and no details regarding phased construction were provided at the time of project approval; in reality, the construction was carried out in phases ; Again, it is due to the **change in institutional functions** that it is no longer possible to modify the project approval documents, which poses a significant problem for companies. As for resolving the issues that arise later, that’s not the main point. The two problems mentioned above are both present in the same registration document, and they ultimately have a significant impact on the company’s construction efforts. I’m just trying to stimulate some discussion here; I welcome everyone to share any ‘incidents’ they encountered during the approval (registration) process for new, modified, or expanded projects, just for fun ; The main goal is to gain experience, enrich one’s own experiences, and solve practical problems. Thank you; please point out any mistakes!

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