China's State Council Government Open Information Regulations and Ministry of Environmental Protection Environmental Information Disclosure Measures went into effect on May 1, 2008. These regulations are major milestones for environmental governance in China. The Institute of Public & Environmental Affairs (IPE) and the Natural Resources Defense Council (NRDC) have developed a Pollution Information Transparency Index (PITI) in order to carry out a systematic assessment of the first year of implementation for these regulations. Utilizing the PITI methodology, which evaluates government disclosure of pollution information, we have completed an initial assessment of pollution information disclosure in 113 Chinese cities for 2008.
Of the 113 cities, 110 are key state environmental protection cities, including Harbin, Jinan, Shijiazhuang, Changsha, Guangzhou, Chengdu, and Urumqi. The cities are located throughout China’s eastern, central, and western regions. Through an analysis of 8 specific metrics, including records of violations of rules and standards, results of environmental petition and complaint cases, and disclosures upon request, we have made an assessment of the level of pollution information disclosure in each city and formulated corresponding scores and rankings.
Progress has Been Made, but Most Cities are Still Only at the Beginning Stages of Environmental Information Disclosure Implementation
This initial assessment shows that many regions in China have made progress in environmental information transparency. Of those cities that have been most proactive, Shanghai, Ningbo, Taiyuan, and Wuhan have begun to make systematic disclosure of violations by corporations. Cities such as Beijing, Chongqing, Fuzhou, and Jiaozuo demonstrated good initial performance in the disclosure of information on the handling of petitions and complaint cases. Hefei, Qingdao, Kunming, and Zhengzhou have been the most responsive to requests for information disclosure.
The initial results from this first year of implementation show that the overall level of environmental transparency is still very basic. Out of a possible 100 points, slightly more than 60 points represent requirements under Chinese law. Additional points are granted on factors that help to meet the practical needs of the public. Of the 113 cities assessed, only four scored above 60 points, 32 cities scored under 20 points, and the average score of all 113 cities was barely over 30 points.
We Observe a Relationship between the Level of Economic Development and Degree of Information Disclosure, but this Relationship is not Absolute
The initial results also show that there are significant regional differences in the degree of disclosure. In general, the eastern provinces outperform the central provinces, while the central provinces outperform the western provinces of China. Fifty-six cities in eastern China have an average PITI score of 36.07 points, while the average PITI score of the 34 cities in central China is only 27.71 points. Among 23 cities in western China, the average is 22.60 points.
We see a relationship between the level of economic development and the level of pollution information disclosure in these cities. However, from further detailed analysis we observe that this relationship is not absolute. Among the central and western cities with rather low levels of disclosure, Wuhan, Chongqing, and Taiyuan distinguish themselves as exceptions to the trend. In the eastern part of China, where in general the disclosure level is high, there are several underperformers. These include Zhanjiang, Benxi, and Tai'an.
If the performances of Guangdong Province and Jiangsu Province - both of which are in developed coastal regions and bases for export oriented industry - are compared, we can see that the 9 assessed cities in Jiangsu Province had an average per capita GDP of RMB 39,846 in 2007 and an average PITI score of 43.54, while the 9 assessed cities in Guangdong province had an average per capita GDP of RMB 45,590 and an average PITI score of 34.28.
Some Cities with Higher Levels of Emissions Intensity and Poorer Air Quality Exhibit a Low Degree of Pollution Information Disclosure
Some cities with high levels of emissions per unit of GDP scored lower in the PITI assessment. By using pollution discharged per 10,000 RMB of industrial output in the year 2007 as a variable, we can see that certain cities in eastern, central, and western China with high discharge levels, such as Shizuishan, Baoji, Xiangtan, Yibin, Luzhou, Benxi, Kaifeng, and Zaozhuang, demonstrated extremely limited disclosure levels.
It is also worth noting that some of the cities with the worst air quality scored quite low on environmental disclosure as well. If we introduce the average concentration level of air pollutants in 2005 as a variable, we can see that cities like Lanzhou, Zhuzhou, Datong, Linfen, Yangquan, Baotou, Yueyang, and Panzhihua have high concentration levels of sulfur dioxide and/or PM 10, and a very limited level of pollution information disclosure.
Many Barriers Exist to Obtaining Pollution Information via Request
In order to assess disclosure upon request, which is required by the Environmental Information Disclosure Measures, in September 2008 we filed requests for information with all of the 113 assessed cities. We requested a list of polluters that had received administrative punishment, as well as a list of local complaints and how they were handled. These are both categories of information that environmental protection bureaus are required to disclose actively. Nonetheless, eighty-six cities did not fulfill our requests. The reasons they gave included:"such data should not be disclosed," "disclosing such information would reveal corporate secrets," and "this request can only be handled with an introduction letter from superior governmental agencies." Some said that it would not be good to disclose the information because they are focused on maintaining growth. The employees of some city offices hung up the phone when our staff asked for this information, and in 16 cities a contact person from which to request this information could not be found.
There is no doubt that PITI has revealed gaps in environmental information transparency. We hope that PITI can serve as a tool to promote constructive solutions to these gaps. One of the important goals of this assessment is to identify the most successful models of disclosure developed in various cities and facilitate their dissemination to other cities across China. Based on the practices of the top-scoring cities, we believe that it is fully possible to achieve similar results throughout China.
China's Four Province-Level Municipalities can Learn from Each Other's Best Practices
For example, if we compare the rankings of four major municipalities - Beijing, Shanghai, Chongqing, and Tianjin - we can see that the first three rank relatively highly while the last, Tianjin, ranks considerably lower. Further detailed analysis shows that Shanghai has been the pioneer in systemic disclosure of violations through daily monitoring and supervision, while Chongqing and Beijing have an established system to disclose the results of their handling of public petition and complaints cases. All three have actively responded to requests for information. Tianjin could learn from these three cities in their respective areas of expertise in order to improve its performance.
Nonetheless, Shanghai, Beijing, and Chongqing exhibit performance that is far from perfect. Further detailed analysis shows that all three cities have had obvious shortcomings in performance, with their scores falling below less-developed cities like Ningbo, Hefei, Fuzhou, and Wuhan that have demonstrated a more balanced performance across major disclosure metrics. For instance, Shanghai has a clear gap in its disclosure of results of handling petition and complaints cases. In a city with roughly 18 million residents, we could find only seven responses to complaints over pollution related environmental issues. Likewise, the disclosure of standards violated is not done in a comprehensive and systematic way in either Chongqing or Beijing. Shanghai, Chongqing and Beijing could learn much from each other through information sharing if they want to improve overall performance.
Innovation can be Found in Unexpected Places beyond China's Major Cities
It is not only major municipalities that have employed innovative solutions to disclose pollution data. Weihai in Shandong Province, for example, was the first city anywhere in China to publicly post hourly data transmitted from online monitoring systems installed in major pollution sources. Another city, Changzhou in Jiangsu Province, uses local media as a platform to publish violations by companies. In Zhejiang Province, Taizhou has shown extremely comprehensive disclosure of violations, and Huzhou provides both the discharge volume and pollutant type when it publishes fee notices. Major cities in Liaoning Province, such as Shenyang, have created a search function on local environmental protection bureau websites, so as to make information more accessible to the public. In response to our request for information, the city of Hefei in Anhui Province published its list of violators on its website to maintain compliance and allow public access.
China's "All-Star Team" of Cities Demonstrates That Effective Pollution Information Disclosure is Possible Right Now
After thorough analysis, we identified the top scorers in each of the eight indicators, assembling an "all-star team." When added together, these top eight scorers reach 89.5 points, a level that can be taken as a key measuring point. This demonstrates that, even at China’s current stage of economic development, a relatively high level of information disclosure is possible.
Environmental Transparency is a Critical Tool in the Fight against Pollution
International practice has proved that expansion of environmental transparency is helpful to pollution reduction. There is an increasing understanding that environmental transparency can play a uniquely important role in overcoming barriers like local protectionism, weak enforcement, and the low cost of violations - eventually leading to improved environmental stewardship in China. The very fact that environmental groups can conduct an assessment like PITI shows the historic progress made in China with regards to public participation and environmental transparency. Through this assessment we can see that environmental transparency has come a long way in one year. However we can also see great potential for improvement. We would like to work together with environmental agencies and other stakeholders to promote the expansion of environmental transparency, which we believe to be an imperative in China's quest for sustainable development.
