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INCORPORATING CLEANER

PRODUCTION ANALYSIS INTO


ENVIRONMENTAL IMPACT
ASSESSMENT IN CHINA
Wenming Chen
China National Cleaner Production Center

Kimberley A. Warren
University of Hong Kong

Ning Duan
China National Cleaner Production Center

An environmental impact assessment (EIA) system was established in 1979 in


China. Although EIA was designed as a tool for pollution prevention, in
practice it has been based on end-of-pipe (EOP) treatment control since it
was first introduced. This approach has ensured an overwhelming focus by
enterprises on the use of EOP treatment, rather than pollution prevention, to
meet environmental standards, and it has produced a low rate of operation for
EOP facilities. The low operation rate for EOP facilities can be traced to the
traditional EIA system: it leads project proponents to develop large EOP
treatment facilities, but once the main production lines are put into operation,
proponents rarely have sufficient funds to operate the treatment facilities. This
paper analyzes problems that exist in the EIA system in China, and it describes
the Cleaner Production Index and Evaluation System, which is being proposed
by environmental authorities in China to evaluate EIA projects based on cleaner
production criteria. The paper also suggests how cleaner production analysis
can be integrated into the EIA system to improve it. 1999 Elsevier Science Inc.

Development of the EIA System in China


The evolution of Chinas environmental impact assessment (EIA) system
can be divided into four phases: preparation phase (19721979), preliminary
Address requests for reprints to: Wenming Chen, China National Cleaner Production Center, No. 8,
Dayangfang, Anwai, Beijing 100012, Peoples Republic of China.
ENVIRON IMPACT ASSESS REV 1999;19:457476
1999 Elsevier Science Inc. All rights reserved.
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PII S0195-9255(99)00023-2

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WENMING CHEN ET AL.

implementation phase (19791986), overall implementation phase (1986


1990), and intensification phase (1991present). The preparation phase
for EIA occurred during the 1970s, when environmental protection was
beginning in China. Because of serious pollution problems, some regions,
for example, Beijing, began to conduct environmental quality assessments
(EQAs) in the early 1970s.
In 1973, the technical team for A Study on Environmental Quality
Assessment for the Western Suburbs of Beijing was established. The study
focused on how to protect the environment of Beijing in the short and long
term. Nanjing City in Jiangsu Province and Maoming City in Guangdong
Province also conducted their own EQAs during this period. During the
preparation phase, environmental scholars in China also began research
on EIA. In 1977, the Chinese Academy of Sciences organized a seminar
on Regional Environmental Science to promote EQAs in large- and
medium-sized cities in China. After the seminar, EQAs were conducted in
some large cities (e.g., Shanghai, Tianjin, and Guangzhou) and for some
water basin regions (e.g., Songhua River, Tumeng River, and the West
Lake of Huangzhou City) (NEPA 1996).
The first clear requirement for EIA was contained in the first version of
Chinas basic environmental law, Environmental Protection Law of the
Peoples Republic of China (for trial implementation), issued in 1979. This
law established EIA as a compulsory environmental management program
(NEPA and the National Peoples Congress 1989), and it marked the beginning of the preliminary implementation phase (19791986). In 1981, the
State Planning Commission, State Construction Commission, State Economic and Trade Commission, and the Environmental Protection Committee of the State Council (1981) issued Management Procedures for Environmental Protection of Capital Construction Projects, which outlined
requirements for the EIA system. The first EIA conducted for a proposed
development project in China was the Environmental Impact Assessment
of Yongchuan Copper Mine. This EIA was carried out between 1979 and
1981, and it evaluated the impacts of the proposed mine on surface water
and air quality.
In 1986, the Chinese government modified the 1981 version of the Management Procedures for Environmental Protection of Capital Construction
Projects. (NEPA 1986). The new version more clearly defined the scope,
content, management limitations, and responsibilities linked to EIA. During the overall implementation phase (19861990), the National Environmental Protection Agency (NEPA, which was transformed into the State
Environmental Protection Administration, SEPA, in March 1998) and other
government bodies issued a number of administrative regulations related
to EIA, including procedures for issuing licenses to organizations qualified
to conduct EIAs (NEPA 1989). The rate of compliance with EIA was high
during the overall implementation phase: between 1986 and 1990, more
than 90% of medium and large construction projects conducted EIAs.

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Despite the EIA programs success during the overall implementation


phase, several key concerns were identified during this period. First, most
EIAs were conducted after projects had been sited and production processes had been designed. The relative timing of activities was such that
EIAs tended to focus on end-of-pipe (EOP) treatment and to neglect issues
related to alternative facility siting and cleaner production. Second, many
of the EIAs carried out during this period were of poor quality, and implementation of the EIAs and/or mitigation measures was low. Third, small
industrial projects, especially those involving township-and-village industrial enterprises (TVIEs), frequently avoided the EIA system. This lack of
participation was the result of an early focus of the EIA program on largeand medium-sized projects, thus enabling small-sized projects and TVIEs to
escape detailed scrutiny by local environmental protection bureaus (EPBs).
Local governments vested interests (i.e., ownership of TVIEs) in the development and success of rural enterprises also shielded TVIEs from environmental scrutiny and created de facto exemptions for TVIEs from EIA and
other regulatory requirements in the 1980s. In some cases, local governments applied intense pressure on local EPBs to approve projects involving TVIEs.
After 1990, two trends emerged concerning EIA in China. The first
relates to the specific content of the EIA. During the 1990s, the EIA
expanded in scope from assessments that primarily covered impacts of
industrial pollutant discharges to those that were broader and more ecological in nature. The second trend concerns what has come to be termed
regional environmental impact assessment. Whereas prior to 1990 EIAs
were mainly conducted for individual development projects, after 1990
EIAs also were required for entire regions. For example, EIAs have been
conducted for river basins and for entire industrial development areas (e.g.,
the Pudong area in Shanghai).
More recently, in November 1998 Chinas State Council approved a
revised version of the Management Procedures for Environmental Protection of Capital Construction Projects. The new guidelines (State Council
1998) contain specific provisions for cleaner production (Article 4), and they
state that all industrial construction projects should adopt low-polluting,
energy-saving CP technologies that reduce pollutant discharges. The revisions provide an implicit mandate for all large-, medium- and small-sized
industrial construction projects to include considerations related to cleaner
production (CP) in the context of EIA. Last, SEPA is currently considering
the application of strategic environmental assessment systems (CER
1999). Such systems move beyond EIAs for projects and apply EIA procedures to government economic and environmental policies.
EIA Process for Construction Projects in China
All new construction projects, expansions or renovations of existing facilities in China must comply with the Management Procedures for Environ-

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mental Protection of Capital Construction Projects to receive project approval from governmental agencies, such as planning or land management
departments. The guidelines establish an overall environmental management system for construction projects, which consists of five stages:

Project proposal
Project feasibility study
Project design
Project construction, and
Inspection and approval (of the completed project).

The first two stages of the system are part of the EIA regulatory process;
the latter three stages are carried out under the three synchronizations
program. This program stipulates that environmental protection measures
that are identified in the first two stages of the EIA management process
must be designed, constructed, and operated simultaneously with the design,
construction, and operation, respectively, of projects main facilities.
The project proposal stage is designed to provide a brief introduction to
the project, including facility siting issues and potential environment impacts. In the second stage, the project feasibility study, an EIA is carried
out. In theory, this suggests that project proponents carry out EIA analyses
prior to the design stage of their projects. However, in practice it is common
for project proponents to write their project proposals after decisions about
the projects location and final design have been made. Thus, major decisions regarding process technologies and plant design are made prior to
the feasibility study phase, i.e., before an EIA is carried out. As discussed
later, by bringing their completed plant and treatment facility designs to
the table at such an early stage, project proponents make it difficult for
alternative project designs (e.g., cleaner production technologies) or facility
locations to be considered and integrated into subsequent EIA analyses.

EIA Management Procedures


In China, the scope of the EIA, and the procedural requirements that
project proponents must satisfy, depend on the potential environmental
impacts of the project. In general, if the anticipated environmental impacts
are judged by environmental authorities to be significant, project proponents must complete a comprehensive EIA and submit an environmental
impact statement (EIS).1
If the projects environmental impacts are anticipated (through the project proposal) to be small, the procedural requirements for the EIA are
much simpler, with proponents typically only filling out a brief environmental impact form (EIF). The EIF contains the proposed projects location;
main products and raw materials, particularly toxic ones; water and energy
1
We follow translation of Sinkule and Ortolano (1995) of the Chinese phrase, baogao shu, as environmental impact statement; this phrase also can be literally translated as an environmental impact report.

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461

consumption; estimated total pollution discharges and main environmental


impacts; and pollution control measures, including treatment and recycling
and reuse measures.
Environmental authorities determine whether an EIS or EIF is required
through project classifications. New construction, expansion, and renovation projects in China are divided into three classes (A, B, and C) according
to their potential degree of environmental impacts. National and local
environmental protection agencies are in charge of the classification a
particular project receives. Class A means the project may cause significant
negative environmental impacts. For Class A projects, proponents must
prepare a comprehensive EIA analysis, the result of which is the filing of
an EIS with responsible environmental authorities. Class B projects may
cause limited unfavorable impacts to the environment. Class C projects do
not cause unfavorable impacts to the environment. For both Class B and
Class C projects, an EIF must be filled out and filed with relevant environmental agencies, but an EIS is not required. (However, if subsequent reviews of the EIF indicate that the pollution generation or toxic chemical
handling aspects of these projects is indeed significant, an EIA will be
required.)

Evaluation and Approval of EIAs


In China, the agency responsible for examining and approving an EIA is
determined based on the level of investment of a project. Only SEPA
(and its authorized representatives at the provincial and municipal levels)
approves EIAs for projects with investment levels greater than 200 million
yuan (about $24 million US). Provincial- and municipal-level EPBs review
projects requiring investments between 50 million and 200 million yuan, and
city-level EPBs evaluate EIAs for projects costing less than 50 million yuan.
As discussed earlier, to initiate the EIA process, a project proponent
must first submit a project proposal, which contains a preliminary analysis
of the estimated environmental impacts, to the responsible environmental
agency: SEPA or a provincial, municipal, or city EPB. The responsible
environmental agency reviews the project proposal, solicits comments from
its own staff and external sources (e.g., industry experts), and then schedules
a meeting with the project proponents to discuss their projects classification.
If the environmental agency classifies the project as Class B or Class C,
project proponents need only fill out an EIF. In the case of an EIF, the
project proponents are not obligated to use the services of a certified EIA
organization (e.g., an environmental institute or consulting company), but
may have their own staff (often with the assistance of local EPB staff)
complete the EIF.2
2
An EIA licensing system limits the number of institutes or companies that qualify as certified EIA
organizations in China. The authority to provide EIA certification rests with SEPA. Environmental institutes
or consulting companies submit an application (and often complete training courses) for EIA certification,
and SEPA evaluates the application, primarily based on the experience of the institute or company with

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If the project has been classified by the environmental agency as Class


A, the project proponents are obligated by law to hire a certified EIA
organization to assist them with the EIA analysis and submission of an
EIS. A contract is signed between the organization conducting the EIA
and project proponents, and the EIA is started. The organization conducting
the EIA prepares an outline of the EIA for the project and then submits
it to the responsible environmental agency (SEPA or an EPB) for review
and approval. When preparing the EIA outline for their clients, the certified
EIA organization is responsible for identifying the potential environmental
media to be impacted by the proposed project and the appropriate level
of analysis to be undertaken in the EIA. The organization preparing the
EIA accomplishes this by dividing the EIA into various individual impact
assessments based on the environmental elements (i.e., media) to be
impacted (e.g., an air EIA, a surface water EIA, a noise EIA, and so forth).
Technical guidelines prepared by NEPA (1993) provide a basis for determining the EIA classification for individual environmental elements.
Based on a combination of a projects anticipated discharge load and receiving waters, environmental elements of an EIA are classified as either Class
A, Class B, or Class C. The classification assigned to each element determines: (1) the prescribed level of impact analysis required (e.g., a highly
complex computer model simulation for air quality versus a simple estimation of total air pollutants emitted) for each element;3 and (2) the level of
monitoring and sampling (e.g., water quality) that must be undertaken as
part of the EIA.4 Class A elements of an EIA require the most detailed
evaluations, whereas Class B elements can be less detailed. The analysis
for Class C elements can be the least detailed.
Once the EIA outline has been submitted to the responsible environmental agency, a review meeting is convened to evaluate the content of the
proposed EIA outline and review the classification levels (Class A, Class
B, or Class C) of different EIA elements. After the review meeting is
EIA. SEPA also distinguishes in its EIA certification program between organizations that are legally
certified to conduct Class A project EIAs (i.e., more difficult and complex EIAs) versus Class B and Class
C project EIAs.
3
For example, according to national criteria, if a new construction project discharges wastewater to a
large-scale surface water body that is defined by national standards as a category I, II, or III zone, and
the proposed wastewater to be discharged from the project is more than 20,000 m3/d and contains at least
three kinds of pollutants, then the water element of the EIA is Class A. (In China, water bodies are divided
into five classes according to their end use and water quality protection goals, with Class I being of the
highest quality and Class V being of the poorest quality.) If a new construction project discharges
wastewater to a large-scale surface water body that is classified as category IV or V by the national
standards, and the wastewater to be discharged is more than 20,000 m3/d with at least three kinds of
pollutants, the water element of the EIA is Class B. Finally, if a new construction project discharges
wastewater to a small-scale surface water body, and the wastewater is between 200 and 1,000 m3/d with at
least three kinds of pollutants, the water element of the EIA is Class C.
4
For example, if a new construction project discharges less than 50,000 m3/d of wastewater to a largeor medium-sized lake, monitoring requirements are as follows: one sample is required for every 1 to 2.5
km2 for Class A, one sample per 1.5 to 3.5 km2 is needed for Class B, and one sample for every 2 to 4 km2
is required for Class C. (It should be noted that certain cities, such as Shanghai, apply stricter EIA
classification criteria than the national criteria just described.)

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463

completed, the organization conducting the EIA carries out the EIA and
submits the EIA report to the responsible environmental agency. The latter
organizes a second review meeting to evaluate the EIA report and decide
whether the project requires additional EOP treatment facilities to reduce
the projects environmental impacts, or whether the project should be
allowed to go forward.
The aforementioned two review meetings by SEPA or a local EPB play
a key role in controlling the quality of the EIA and the project. Participants
at these meetings include environmental agency staff and environmental
experts invited to participate in the reviews. Officials and invited experts
often focus strictly on the degree of environmental impact that a proposed
project may cause; however, they also may evaluate specific technical details
of the project, such as the type of production process selected.
Limitations of the Existing EIA System in China
Several serious limitations exist in the current EIA system in China. First,
EIA procedures and requirements, as defined in the Environmental Protection Law of the PRC (1989) and the Management Procedures for Environmental Protection of Capital Construction Projects (1986) do not specifically require the use of cleaner production. Although this situation has
improved with the November 1998 revisions to the management guidelines,
which now include CP provisions for some industry construction projects,
the effects of those revisions will not be felt immediately. The past regulatory climate continues to ensure that project proponents overwhelmingly
choose EOP treatment facilities to satisfy EIA requirements. This occurs
at all levels of investment.
Second, EIAs have primarily been conducted for large industrial projects;
most small industrial pollution sources have ignored EIA requirements.
Third, as discussed earlier, EIAs have often been conducted well into
the development stage of a construction project, long after project design
decisions have been made. The failure to conduct EIAs prior to the design
and facility siting phases of a development project makes it difficult to
integrate cleaner production approaches into the projects overall development. Last, the financial capabilities of enterprises have not been adequately accounted for in the EIA review process. As a result, enterprises that
cannot afford to operate treatment facilities continue to receive project
and EIA approvals.

EIA Policy and Regulatory Limitations Lead to Emphasis on


EOP Treatment
Because EIA regulations focus only on the environmental impacts created
from pollutants generated by a proposed project, the prevention of pollution
before it has been created has not traditionally been encouraged or inte-

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grated into Chinas EIA procedures. These regulations and policies often
assume that pollution will be created, and that the way to deal with it is
to require the purchase and use of EOP treatment facilities. This situation
encourages enterprises to view environmental protection (and EIA procedures) in terms of EOP treatmentto the great detriment of the promotion
of cleaner production concepts and methodologies in China.
Moreover, with regards to the evaluation and approval of EIAs, in the
past it has been the case that if a proposed project meets national and local
discharge standards, in general it will be approved. In other words, as long
as the project proponent installs sufficient EOP facilities to meet discharge
standardsregardless of whether the production technology selected is the
least polluting choicethe project is approved. For example, in China,
many old factories produce serious pollution. When proposals are submitted
to expand or renovate these factories, the EIAs must examine the pollutants
created by all production processes. The requirement that expanded renovated factories meet environmental standards often is satisfied by installing
sufficiently large EOP treatment facilities, rather than through technical
innovations or cleaner production measures.
The policy climate for EIA, however, is rapidly changing. EIA regulations
and procedures currently are being revised at both the national and local
levels in China (e.g., some new provisions require use of cutting-edge CP
technologies by firms in the industrialized provinces of southeast China),
and these policy changes are applying increasing pressure on enterprises
to incorporate CP options into their proposed projects.

Lack of Focus on Small Industrial Pollution Sources


From 1996 to 1997, the Chinese government closed more than 60,000 small,
seriously polluting industrial enterprises. This decision was based on the
current situation in China where small TVIEs are contributing significantly
to the nations total pollution discharges. For example, in 1996 TVIEs
generated more than 50% of Chinas pollution in terms of chemical oxygen
demand (COD).5
Pollution from small enterprises has become a major problem in China
for several reasons. First, many TVIEs do not participate in the current
EIA system; they dont submit EIA applications to SEPA or EPBs. Second,
even when small enterprises conduct EIAs, they frequently fail to install
the required EOP treatment facilities. Third, enforcement of environmental
requirements at TVIEs has been difficult, due to a lack of local EPB
resources and personnel. As a result, China does not have effective constraints on the development of small enterprises with poor technology, high
resource consumption, and high pollution generation.
5
Chemical oxygen demand (COD) is a measure of the organic content of wastewater. COD is determined
by using a chemical oxidizing substance to measure the amount of oxygen that would be needed to oxidize
a particular wastewaters organic content.

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EIAs Conducted in Feasibility Study Phase


The purpose of an EIA is to identify (and, thereby, eliminate or mitigate)
the environmental impacts of a proposed project before final facility and
siting designs are made by project proponents. However, it is typically the
case that EIAs in China are carried out during the feasibility stage of a
construction project, when production processes have already been selected
and alternative processes are no longer being considered. Without an assessment of environmental impacts or pollution sources prior to making final
facility design choices, technical decisions invariably do not consider how
design changes and cleaner production measures can be integrated into a
facilitys design to reduce or prevent pollution.
Case studies in China have shown that significant progress in eliminating
and reducing pollution can be achieved when top decisionmakers in a
company design (or redesign) facilities with cleaner production in mind
(MPRCEE 1997; Warren 1996). In addition to environmental benefits,
cleaner production measures may provide companies with attractive financial returns.

Firms Poor Management and Financial Burdens Constrain


EOP Treatment
Maintenance of production and treatment equipment in China often is
lax. According to industry sources, even new production equipment stops
functioning according to its original specifications within 3 years of purchase
because of a lack of proper maintenance. Poor maintenance extends to EOP
treatment facilities: only about one-third of the EOP treatment facilities in
China are functioning properly; the remaining two-thirds are either shut
down immediately after the facility has passed its final inspection, or are not
operated in accordance with original design specifications (MPRCEE 1997).
Poor maintenance practices are exacerbated by enterprises lack of funds
to cover operation and maintenance costs of their EOP treatment facilities.
This problem can be traced back to the EIA system: Why were construction
projects approved when project proponents could not afford the expense
of operating their treatment systems? The answer to this question is similar
to why poorly operating plants are not shut down today. Although the
number of enterprises with inadequate EOP treatment is huge, the potential
social problems from extensive plant closures (or rejection of applications
for new plants in a developing region) prevent the government from shutting
factories down.
Development of CP in China
CP is the continuous application of an integrated preventative environmental strategy applied for processes, products and services to raise ecoefficiency and reduce risks to humans and the environment (UNEP 1996).

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CP includes the use of non-toxic production processes, raw materials substitution, internal recycling, and energy efficiency measures.
Since 1992, with the assistance of the World Bank, the United Nations
Industrial Development Organization (UNIDO), the United Nations Environment Programme (UNEP), and other agencies, China has conducted
theoretical research, enterprise demonstration projects, and information
dissemination activities for cleaner production. These activities have been
part of an on-going project (referred to as the B-4 project) conducted
jointly with SEPA to fast-track the adoption of CP methods in China.
So far, remarkable progress has been made.
As part of the B-4 project, CP audits have been carried out in more than
200 enterprises in the following sectors: textiles, chemicals and petrochemicals, electroplating, pharmaceuticals, breweries, food and beverages, and
pulp and paper. The demonstration projects have shown that outstanding
economic and environmental benefits can be achieved by enterprises implementing CP technologies.6
In addition to sponsoring demonstration projects, the B-4 project supported the creation of the China National Cleaner Production Center
(CNCPC) in 1994. Provincial and sector-related cleaner production centers
were established through China in the mid and late 1990s. These national
and regional CP centers now function as the core strength for developing
and disseminating CP methods in China.
Moreover, through close exchange with foreign CP experts and continuous participation by many domestic enterprises, China has established its
own CP methodology system. This methodology has been accepted as the
standard for China by the CNCPC, regional and sector CP centers, and
academic and industrial organizations involved in CP work. These organizations have promoted the use of this CP methodology by enterprises in
China through publication of CP audit manuals and training materials for
enterprises. The following section elaborates on the CP methodology and
discusses how it will be integrated into procedures for EIA in China.
CP Index and Evaluation System in China
Based on research conducted by SEPA and the CNCPC on incorporating
cleaner production analysis into EIA, a CP Index and Evaluation System
(CPIES) was developed. In devising this system, SEPA and the CNCPC
consulted with environmental management staff at enterprises, and EIA
and CP experts in numerous Chinese organizations (e.g., universities). Staff
6
In general, with a very low investment, a typical enterprise participating in the B-4 project has reduced
its total amount of wastewater discharged by 10% to 20%, and its total pollutants generated by 8% to
15%. According to results from the B-4 project for 29 key enterprises, each 1,000 yuan ($120 US) investment
in CP reduced the amount of COD wastewater generated by 5.4 tons per year, and yielded annual average
economic benefits of 30,674 yuan ($3,696 US). The 29 enterprises invested a total of 0.78 million yuan
($93,976 US) to carry out no- and low-cost CP options. Economic benefits from some of these CP options in
individual factories led to annual economic benefits of up to 2.9 million yuan ($349,000 US) (CRAES 1996).

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467

at SEPA and CNCPC also reviewed data on CP audits in China and abroad,
and they conducted site visits to 100 enterprises to collect and analyze CP
results. These analyses revealed that enterprises needed a simple, easy-touse method to evaluate their existing and proposed products, production
processes, equipment, and technologies in terms of CP. The CPIES system
was developed to address this need, and the system will be applied to EIA
projects in China in an effort to decrease the time it takes to conduct CP
audits in enterprises.
The index and evaluation system is based on CP criteria, i.e., criteria
against which enterprises or EPB staff can measure and evaluate CP performance.7 As shown in Table 1, the CP criteria are divided into four main
categories: raw materials, products, resource use, and pollutant generation.
Raw materials criteria gauge the comprehensive environmental impact of
the extraction, processing, and utilization of raw materials in a production
process or product cycle. Products criteria analyze the environmental impacts of a products sale, distribution, consumption, and disposal. Resource
use criteria estimate the amounts of water, energy, and other resources
used during production of a single unit of product. Pollutant generation
criteria quantify the total and individual amounts of pollutants created in
producing a single unit of product. In effect, the CP criteria gauge the total
impact to the ecological environment of an enterprises single production
process or product line, or of entire production systems.
The CP criteria listed in Table 1 can be separated into two general
classes: qualitative criteria (raw materials criteria and product criteria) and
quantitative criteria (resource use criteria and pollutant generation criteria).
Different weighting (which CP and EIA experts in China are now evaluating) and scores in the final evaluation are assigned to qualitative and quantitative criteria, as shown in Tables 2 and 3. Note that lower marks on an
individual criterion correspond to more damaging environmental impacts.
Thus, when each of the individual marks is given a weight and the weighted
marks are summed to provide a total score, a higher score corresponds to
a cleaner project in terms of environmental impacts and CP performance.
The final evaluation of cleaner production is simple. Enterprises sum the
weighted scores for each criterion and compare their results with those
listed in Table 4. If the total score an enterprise receives is above 80, it
means, on average, the proposed construction project reaches an advanced
CP level. In other words, according to the present technological level the
process, product, project, or enterprise is clean. Scores between 70 and
80 indicate an advanced project, process, or enterprise in terms of CP,
and so on.
7
The CPIES and the principle of using criteria to assess and evaluate environmental performance was
based on the theory and practice of lifecycle assessment (LCA). The latter involves evaluating the effects
that a product has on the environment over the entire period of its lifecycle, from raw material extraction
to the ultimate disposal of the product.

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TABLE 1. Criteria for Cleaner Production Evaluation


CP Evaluation
Raw materials

Criterion
Toxicity

Ecological impact
Recoverability

Energy intensity

Reusability and
recyclability
Products

Sale and
distribution

Consumption

Product life
optimization

Disposal
Resource use

Fresh water
Energy
Others

Pollutant
generation

Wastewater

Waste gas

Solid waste

Meaning of Criterion
Degree of impact to ecological environment
caused by toxic component of the raw
materials
Degree of impact to ecological environment
caused by the extraction of raw materials
Degree to which raw materials can be
recovered to produce new raw materials
(e.g., chemical recovery)
Degree of energy consumption of
extracting and producing the raw
materials
Degree of reuse and recycling of raw
materials (which may cause secondary
environmental problems)
Degree of environmental impact from
product sale, transport, and distribution
(e.g., from factory to consumer retail
outlet)
Degree of impact caused by consumption
of products, including consumption of
energy and other products during
product use
Degree of product lifetime optimization,
including technical and aesthetic product
service life (e.g., length of acceptable
aesthetic appeal to consumers)
Degree of environmental impact caused by
product disposal after final use
Amount of fresh water consumption per
unit product
Amount of energy consumption per unit
product
Amount of other material consumption per
unit product
Amount of watewater generated per unit
product
Amount of main pollutants (e.g., heavy
metals) in wastewater per unit product
Amount of waste gas generated per unit
product
Amount of main pollutants in waste gas
per unit product
Amount of solid waste generated per unit
product
Amount of main pollutants in solid waste
per unit product

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TABLE 2. Marks for Qualitative and Quantitative CP Criteria


Type of Criteria
Qualitative criteria

Quantitative criteria

Values

Value Meaning

Range of
Marks

High
Medium
Low
Very clean
Clean
Ordinary
Poor
Very poor

Low environmental impact


Medium environmental impact
High environmental impact
Reaches advanced level internationally
Reaches advanced level domestically
Reaches average level domestically
Below average level domestically
Well below average level domestically

0.71.0
0.30.7
0.00.3
0.81.0
0.60.8
0.40.6
0.20.4
0.00.2

To use the CPIES, factories, EIA consultants, and local EPBs will need
detailed and accurate information on best CP practices and available technologies for any given industrial category. In addition to data supplied by
factories to local EPBs and other government units, information sources
for using the CPIES include industrial ministries, technical associations,
environmental agencies, international organizations, CP roundtables, and
companies specializing in CP.

TABLE 3. Weight Values for Individual Criteria


Criteria
Raw material

Products

Resource use

Pollutant generation
Total score

Weight Value
Toxicity
Ecological impact
Recoverability
Energy intensity
Reusability and recyclability
Subtotal
Sales and distribution
Consumption
Product life optimization
Disposal
Subtotal
Fresh water
Energy
Others
Subtotal

7
6
4
4
4
25
3
4
5
5
17
11
10
8
29a
29
100

a
The total weight value of the resource use and pollutants generated categories is 29 each. For resource
use, the weighting values in this table are often used during the CP analysis. However, for both categories,
the weights may vary, with apportionment of the total 29 points among each individual criterion being
determined on a case-by-case basis.

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Using CP Audit Methodologies in the EIA Process


CPIES provides enterprises with a quick and easy method of evaluating
production technologies and CP alternatives. In addition to CPIES, enterprises conducting EIAs also will need to use traditional CP audits, which
entail a more comprehensive analysis of CP performance and carry out CP
option generation and feasibility exercises. These audits and other CP
studies will be particularly important for renovations of existing enterprises.
When conducting CP analysis as part of an EIA, the CPIES can first
be applied to the factorys current processes, products, equipment, and
technologies. New technologies and systems proposed in renovation or
expansion plans then can be assessed in comparison to existing processes
(see case study following). Staff also can quantify the amount of pollutants
to be reduced by CP measures.
The use of CPIES will assist enterprises, EIA consultants, and EPBs
during the EIA process in identifying and preventing detrimental impacts to
the environment. For example, if an analysis based on the CPIES identified a
factorys proposed technology as being backward, a consultant carrying
out the EIA or an EPB evaluating it could suggest (or require) the choice
of cleaner and more efficient technologies. The process of using CPIES
would assist the factory in avoiding pollution and improving resource use,
thereby preventing (or reducing) the negative environmental impacts that
would have accompanied operation of the originally proposed technology.
The CPIES also represents a valuable tool for impact prediction. By
using the CPIES together with existing data on the environmental impacts
of particular processes, and previous experience with the technology in
China or abroad, EIA consultants and EPBs can obtain an early indication
of whether a proposed technology will be highly polluting and what its
likely environmental impacts will be. If the proposed technology would
result in significant environmental impacts, it could be rejected during the
EIA approval and evaluation process.
The CPIES also may enable enterprises to benchmark their CP performance against external performance standards. For example, enterprise
leaders at a paper factory in China might discover through a CPIES analysis
that, in comparison to other paper factories in China or to paper companies

TABLE 4. Final Evaluation Scores for CP Project, Process, or Enterprise


Total Score for Criteria

Interpretation

.80
7080
5570
4055
,40

Clean
Advanced
Ordinary
Backward
Elimination

CLEANER PRODUCTION ANALYSIS AND EIA

471

abroad, their own paper mill consumes a significantly higher amount of


raw materials per unit product. Identifying inefficient production is the first
step toward avoiding it and to eliminating its associated environmental and
economic costs.
Case Study of CPIES for the Suiping Pulp & Paper Mill
The Suiping Pulp & Paper Mill, located in the Huaihe River Basin in Henan
province, is used as a case study to illustrate the CPIES. The Suiping Pulp &
Paper Mill is a small enterprise; it had an output valued at about 1 million
yuan in 1996. The factor produces 17,000 tons of straw pulp and 6,500 tons
of wood pulp per year at full capacity. Because the Huaihe River had
serious pollution problems, in 1995 the Chinese government designated the
Huaihe River Basin a Key National Pollution Control Area. Several
hundred small pulp and paper enterprises in the basin were closed between
1996 and 1997, and significant pressure exists for the remaining pulp and
paper factories to improve their operations or be shut down.
Suiping Pulp & Paper Mill is a major pollution source in the Huaihe
River Basin. The mill was not equipped with an alkali recovery facility,
and wastewater was treated with a simple screening process and natural
precipitation. Treatment removed about 20% of the COD, and the treated
wastewater was discharged directly into the Huaihe river.
According to the Scheme of Prevention and Control of Pollution in the
Huaihe River Basin issued by the State Council (1997), any existing pulpmaking factory in the basin with a capacity below 50,000 tons annually
must either be closed down or increase its capacity to at least 50,000 tons
per year. In the latter case, the factorys wastewater discharge must meet
national and local standards. In response to the State Councils ruling,
Suiping Pulp & Paper Mill planned to expand its central pulp-making
process to a capacity of 37,000 tons of straw pulp and 13,000 tons of wood
pulp, for a total of 50,000 tons of pulp per year. The mill was required by
law to carry out an EIA for its proposed facility expansion project.
To test and verify the CPIES, staff at the CNCPC conducted a CP
assessment based on data provided by the Suiping Pulp & Paper Mill and
contained in the factorys EIA report for the proposed facility expansion
project (CRAES 1997). Data describing the existing and proposed straw
pulp-making processes were compared with benchmark data derived from
previous audit results for pulp and paper mills in China and other countries.8
Results of this application of the CPIES for Suiping Pulp & Paper Mill are
shown in Tables 5 and 6.
8
Results of previous CP audits in Chinese companies, carried out by CNCPC and enterprise staff (as
part of SEPA, B-4 project, and other CP research projects) are collected and stored in a database at
the CNCPC.

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WENMING CHEN ET AL.

TABLE 5. CPIES Analysis Results for Existing Straw Pulp (No Alkali Recovery) Process at Suiping Pulp & Paper Milla
CP Evaluation

Criterion

Raw materials

Toxicity
Ecological impact
Recoverability
Energy intensity
Reusability and
recyclability

High:
High:
High:
High:
High:

Sale and distribution


Consumption
Product life optimization
Disposal

High: 0.9
High: 0.9
Medium: 0.5
High: 0.7

Fresh water/unit product


Wheat straw/unit product
Alkaline/per unit product
Reuse of alkaline

Very poor: 0.0


Ordinary: 0.5
Clean: 0.75
Very poor: 0.0

Total wastewater

Very poor: 0.0

COD generated
BOD generated
Suspended solids

Very poor: 0.0


Very poor: 0.0
Very poor: 0.0

Subtotal
Products

Subtotal
Resource useb

Subtotal
Pollutant
generationc

Subtotal
Total score

Value: Marks
0.7
0.9
0.9
0.9
0.7

Weight

Marks

7
6
4
4
4

4.9
5.4
3.6
3.6
2.8

25
3
4
5
5
17
15
4
4
6
29
9

20.3
2.7
3.6
2.5
3.5
12.3
0.0
2.0
3.0
0.0
5.0
0

7
7
6
29

0
0
0
0
37.60

Source: CRAES (1996).


Resource use data do not include energy per unit product, because these data were unavailable from the
Suiping mill.
c
Chemical oxygen demand (COD), biochemical oxygen demand (BOD), and suspended solids are measures
characterizing wastewater releases to a receiving water body.
b

Because the existing and proposed processes use the same raw materials
and make the same products, the scores for raw materials and products
are identical. Results of applying the CPIES indicated that the existing
pulping process used by Suiping Pulp & Paper Mill had a score of only 37.6.
As Table 4 shows, any process with a score below 40 should be eliminated.
An assessment based on the CPIES was performed for the alkali pulp
recovery process proposed by the factory in its EIA report. The total score
for the proposed expansion project was 69.53, which is between 55 and 70
and thus corresponds to an ordinary level for pulp processes in China
today. The production process used in the proposed expansion project thus
is acceptable. However, the final score of 69.53 indicates that resource use
and pollutant generation aspects of the proposed new process could be
greatly improved.

473

CLEANER PRODUCTION ANALYSIS AND EIA

TABLE 6. Cleaner Production Analysis Final Scores for Existing Straw


Pulp Making (No Recovery) Process and Proposed New Straw Pulp-Making
Process with Alkali Recovery System at Suiping Pulp & Paper Mill

Scores for the old


process
Scores for the
proposed process

Raw
Materials

Products

Resource
Use

20.3

12.3

5.0

20.3

12.3

16.95

Pollutant
Generation
0
17.98

Total
37.60
69.53

The value of the CPIES is that its results would show that the proposed
pulp-making process is ordinary, meaning that it would result in notable
pollution discharges. Based on the factorys location and other factors,
managers at Suiping Mill or local EPB staff who are evaluating Suipings
EIA proposal could identify and predict that negative environmental impacts to local receiving waters would occur if the proposed technology were
approved. EPB staff could use these results to recommend to the factory
that to receive EIA approval, staff must reassess the proposed production
process and choose less-polluting, best available CP technologies. If the
Suiping Mill followed this recommendation and adopted additional CP
production methods, it could reduce the factorys resource use and pollution
levels, which were shown by the CP analysis to be high relative to advanced
pulp and paper mills in China and abroad.
Integrating CP into Chinas EIA System
Chinas environmental protection and economic development agencies can
use the EIA system to foster cleaner production and put an end to the
high input and low output problems that have characterized Chinese
industry for many years. CP analyses of the type done for the Suiping
Pulp & Paper Mill can help to identify industrial projects with backward
technologies, high resource and energy consumption, and serious pollution
problems. More generally, CPIES analyses could be used by local EPBs
to screen out small, poorly designed industrial projects that, in the past,
often have generated serious pollution and failed to meet standards because
of a shortage of funds to operate EOP treatment facilities.
How will cleaner production be incorporated into the existing EIA system
in China? Several possibilities exist, including EIA policy and procedural
changes and the application of cleaner production audits and the CPIES
as illustrated above for the Suiping Pulp & Paper Mill. The current EIA
system in China does not require enterprises to conduct a CP analysis or
audit during an EIA. Revisions in EIA regulations (and those of the related

474

WENMING CHEN ET AL.

three synchronizations program) to require project proponents to employ


the CPIES and select the least polluting and most efficient technologies
will go far towards reducing companies environmental impacts and improving their economic performance.9
As previously noted, the current EIA programs reliance on EOP treatment facilities has placed a financial burden on many of Chinas firms. And
firms with insufficient funds do not operate their treatment works; thus,
there are low operation rates for EOP treatment facilities. In contrast,
cleaner production focuses on improving the efficiency of products and
processes to reduce pollution generation. Frequently, CP is cheaper than
EOP treatment as a mechanism to reach environmental standards, and CP
may decrease production costs.
However, requiring firms (or EPBs) to use the CPIES may impose burdens. Currently, many factories and local EPBs in China lack the knowledge
of industrial best practices, particularly regarding advanced production
process and CP technologies. Moreover, some CP technologies require
larger initial capital investments than less expensive (but more polluting)
technologies proposed by some firms, especially TVIEs. These technical
and financial issues could diminish the attractiveness of using results from
the CPIES in the context of EIA. Last, requiring CP analyses will lengthen
the overall EIA process, which may be unacceptable to local governments
at a time when many of them have pledged to streamline approval processes
for businesses.
Measures can be taken to offset these disincentives to using the CPIES.
EPBs can give easier, faster, and more successful approval to EIAs that
choose CP over EOP treatment technologies. Preferential loans by banks
for CP projects and a revolving CP loan fund can be established to reduce
Chinese firms difficulties in financing large-scale CP expansion and renovation projects. Finally, increased enforcement by EPBs will ensure that
TVIEs participate in the EIA program and carry out requirements to
integrate CP into the EIA process.
Conclusions
Although the EIA system has been established for nearly 20 years in China
and has improved markedly during that time, serious limitations still exist.
Small industrial pollution sources continue to slip through the cracks of
the EIA regulatory system, and their pollution problems require urgent
9
EIA regulations could also be revised so that EIAs are moved to earlier stages of the project management
process, namely the project proposal phase. For companies, the CPIES (and more detailed CP audits) can
be completed during the EIA proposal stage. CP measures will also need to be synchronized with the
design, construction and operation of the plant, as part of the three synchronizations program. One
foreseeable issue to be addressed regarding CP policy changes is the potential for conflicts with other
environmental regulatory programs. Plans for the coordinated revision of the EIA and other programs,
such as the discharge fees system, are currently being evaluated and are slated for implementation over
the next five years (MPRCEE 1997).

CLEANER PRODUCTION ANALYSIS AND EIA

475

attention to avoid further declines in Chinas rural environmental quality.


Cleaner production provides an important means for addressing these problems, because CP is often less financially encumbering then EOP treatment,
and enterprises may derive economic benefits from its adoption.
Because the existing EIA system focuses primarily on the treatment of
pollutants after their generation, rather than on the prevention of pollutants
before they are created, it encourages enterprises to continue their reliance
on EOP treatment. Requirements to use the CPIES or a similar CP assessment process could be fully incorporated into EIA, and a first step in this
direction was taken with the State Councils 1998 revised Management
Procedures for Environmental Protection of Capital Construction Projects.
Thus, new emphasis by enterprises on CP and pollution prevention would
help China to improve the quality of new industrial projects and reduce
the economic burden EOP treatment places on enterprises.
The authors would like to acknowledge the United Nations Environment Programme and
the World Bank for their long-standing support of cleaner production in China. We would
also like to thank participating Chinese enterprises and staff of the China National Cleaner
Production Center for their hard work and effort in making current and past cleaner production
projects in China a success.

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