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Environmental Transparency in China: the First Annual Pollution Information Transparency Index (PITI) and Implications for Climate Change

Alex Wang

Posted July 30, 2009

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The First Annual Pollution Information Transparency Index

In partnership with the Institute of Public & Environmental Affairs (IPE), we launched a Pollution Information Transparency Index (PITI) last month on June 3rd.  This is China's first index to evaluate environmental information transparency in 113 cities around China.  We are now providing for the first time an English translation of our initial PITI findings.  

One of the central findings of our research concerns what we termed China's "All-Star Team." The point here is that if we look at the top performers in each category of transparency we evaluated, we find some Chinese cities that actually perform quite well.  The old saw that China's current level of development does not allow for good transparent governance, it turns out, is wrong.  China already has some cities that are capable of good information disclosure.  That said, most of the cities in our index are still at a very basic level of environmental disclosure.    

Implications for Climate Change

Why is this important?  There are many reasons here, but as climate focus gets ever more intense these days, there are two particular points worth highlighting. First, these findings present China with an opportunity to let the international community know that it is pushing forward and seeking to make progress on environmental information transparency.  And, second, through our index we now also have a rational (in Chinese terms "scientific") basis upon which to work to improve environmental transparency at the municipal level in China, where the rubber meets the road.  

This is more important than ever as we head toward the Copenhagen climate negotiations.  If we want an agreement (and if China is to have any chance at obtaining the technology and funding support it  seeks from developed nations), we need to begin closing the gaps, and there is no bigger gap than the one on verification and transparency re: emissions reductions.  This is as much a gap in trust, as it is a gap in capability.  As Julian Wong put it in a good post on recent Senate hearings re: US-China climate cooperation and the issue of MRV ('measurable, reportable and verifiable actions'), the question to China from U.S.-side skeptics now is "how can we believe you?"  At that Senate hearing, Elizabeth Economy of the Council on Foreign Relations states the prevalent belief in the West that MRV in China will be undermined by, among other things, " (1) weak implementation of and compliance with environmental law, (2) weak capacity to monitor pollution." Even Chinese experts acknowledge that these are key difficulties within the Chinese environmental governance system, and it would be a shame for this to block China from obtaining the support it needs, or becoming an excuse for the U.S. to stall aggressive moves forward on climate.

Our PITI evaluation shows that environmental transparency has perhaps gotten a better start in China than some would believe, but it also highlights that most cities in China indeed are still at the very preliminary stages of transparent environmental governance.  If we look at the recent US-China MOU on climate cooperation, we see that the items listed are primarily technological cooperation.  It is a tremendous mistake to leave governance cooperation and capacity building off the table.  This sort of cooperation won't be easy, but it is simply indispensible for building the understanding and trust necessary to moving forward on US-China (and multi-lateral) climate engagement.  This will need to be a two-way street as well.  The U.S. needs to make firm commitments to reduce greenhouse gases, and clearly measure and demonstrate those reductions.  Success on an ACES legislation that is not riddled with loopholes and escape hatches will be a critical first step.

PITI Announcement.  And with those points out of the way, without further ado, here is the English version of the PITI announcement we launched on June 3, 2009.  Detailed evaluation criteria can be found here (only in Chinese).

The China Pollution Information Transparency Index (PITI)

2008 First Annual Assessment Results for 113 Cities

Breaking the Ice on Environmental Open Information

June 3, 2009

China's State Council Government Open Information Regulations and Ministry of Environmental ProtectionEnvironmental 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. p>

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.




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sustainablejohnJul 30 2009 11:29 PM

congrats on the launch of this initiative!

Alex WangJul 30 2009 11:34 PM

Thanks, Sustainable John. Keep up the incredible work at The Beijing geothermal video is a classic.

loloJul 31 2009 06:13 AM is awesome!
Need more promotion to let people hear about this good thing though.
Keep up the good work!

Deborah SeligsohnAug 4 2009 11:47 PM

Alex, Congratulations to you and your team for this fantastic effort. As a developing country in the midst of rapid modernization it is not surprising that China still struggles with many aspects of environmental enforcement. But frankly, the results you present offer quite a bit of good news:

1. China’s 30-year history of reform and opening is based on the idea of learning from the best domestic models, pilots and experiments. The fact that some localities are doing much better than others means that the Chinese national government has great examples of what works, and it is likely we will see these used as environment and climate policies continue to be refined.

2. Many of these policies are new, and we also know that Chinese policy tends to be reviewed and reinforced after it is adopted. Your effort can help in that review. We know that localities don’t meet new targets right away, and that Central Government reviews and inspections force them to improve performance over time.

3. The fact that Eastern provinces are performing better than the national average is good news for the climate. While there are some energy intensive industries in the West, the reality is that the vast majority of China’s energy consumption occurs in its richest, most developed, most industrialized Eastern provinces. Thus, better enforcement there means better gains for controlling greenhouse gas emissions. We know this is happening, because China’s energy intensity numbers have continued to improve, and China is in fact exceeded its intensity goal in the first half of 2009.

4. The climate story differs from the local air pollution story – for pollutants with direct, local human health and ecosystem effects differentials in enforcement present a distinct problem – local people in cities with poor enforcement experience the effects directly. This is where the fact that China tends to use good examples to push others to improve lends hope, but where your data clearly illustrates how much work still needs to be done.

Thanks so much for sharing with us this excellent work.

Deborah Seligsohn
World Resources Institute

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