A new suite of regulations aimed at standardizing environmental impact reporting for construction projects went into effect November 1, 2019.
The regulations include details on a new “National Unified Environmental Impact Credit Platform” (全国统一的环境影响评价信用平台), which the Ministry of Ecology and Environment (MEE) will use to track how closely construction units are complying with reporting guidelines. The MEE’s platform will also share information with China’s master social credit database.
The regulations take a stab at improving the quality and accuracy of environmental assessment reports by requiring that:
- Environmental impact assessments may only be conducted by qualified engineers and technical personnel
- Assessments may not be conducted by anyone with ties to the MEE (so as to avoid conflict of interest / corruption and falsification)
- Assessment reports may not be submitted by any company that is currently blacklisted for dishonesty.
- Submitted reports must be accompanied by complete and accurate data
The regs also define scoring and blacklisting systems for acts of dishonesty or non-compliance in environmental impact reporting. Basic details:
- All construction units / companies will establish a credit file in the Environmental Impact Assessment Credit Platform
- Scoring cycles last for 1 year from the date that the credit file is established
- Scores start at zero, and points are added for acts of dishonesty or non-compliance
- If the score reaches 10 within a scoring cycle, the company will receive a public warning, and may be subject to increased inspections.
- If the score reaches 20 within a scoring cycle, the company won’t be allowed to prepare or submit environmental assessment reports.
- If a company submits 10 impact assessments per scoring cycle, and has no records of dishonesty for two consecutive scoring cycles, they’ll enjoy fewer regulatory inspections.
Our take: Impact assessments can be carried out by construction units themselves, providing they have full-time staff that meets qualifications laid out in the regulations. If not, a third-party evaluator can be contracted to handle assessments.
In practice, what this means is that construction units with a history of misreporting lose the right to self-assess environmental compliance.
While these regulations apply specifically to construction projects, it’s not a big leap to imagine the MEE creating similar regulations for manufacturing and other polluting sectors.