Local Environmental Policy Implementation:

Water Pollution Prevention and Control in Guangzhou

by

Yun Xin Cao

Doctor of Philosophy in Public Administration

2022

Faculty of Social Sciences

University of Macau
 Local Environmental Policy Implementation:

Water Pollution Prevention and Control in Guangzhou

by

Yun Xin Cao

SUPERVISOR: Prof. Bryan Chiew Siang Ho

CO-SUPERVISOR: Prof. Emer. Bo Long Liu

DEPARTMENT: Department of Government and Public Administration

Doctor of Philosophy in Public Administration

2022

Faculty of Social Sciences

University of Macau
Author’s right 2022 by

CAO, Yunxin
 Acknowledgments

My high appreciation goes to my supervisors, Prof. Emer. Bolong Liu and Prof.

Bryan Chiew Siang Ho. Throughout my years of study at the University of Macau,

they have guided me in my studies and helped me in my life. Let alone they have spent

numerous weekends and nights reading and commenting on my dissertation. To me,

my supervisors are both teachers and friends. I am also grateful to Prof. Tak-Wing

NGO and Prof. Bruce Kam Kwan KWONG for their insightful suggestions during my

thesis proposal assessment. Thanks to Prof. Lianjiang Li for his invaluable comments

in the midst of his busy schedule. In particular, I have had the opportunity to take two

courses of Prof. Tak-Wing NGO. His articulate and meticulous logic in the course has

always inspired me to be a good teacher and researcher. My special thanks also go to

Claudy Lio and Vivian Vong for their ongoing assistance during my PhD study.

I would also like to thank my interviewees, especially Haixuan Ye, Tian Xiao,

Jiayi Zhang and Zhijian Lu from the ENGOs. They helped me conduct field works and

put me in touch with officials and individuals who could be interviewed.

I am deeply grateful to my family. I am indebted to my parents for their nurturing

and unconditional support over the past years. Thanks to my husband, who supported

me financially and shared in the household chores after I decided to quit my job to

complete the PhD thesis. Finally, I would like to thank my lovely two-year-old son.

Despite the difficulties of writing my thesis and raising a baby at the same time, his

smile has been inspiring me to overcome all the difficulties.

i
 Abstract

Since the opening up and reform in 1978, China’s rapid economic growth has

been achieved at the expense of the environment. Before 2000, the Chinese state was

focused on solving water crisis and the problems of water scarcity. After 2000, water

quality is a grave concern and the focus is on water pollution prevention and control

(WPPC). The ideas of ecological civilization, implying a symbiosis of the economy

and the environment, were enshrined in the Party Constitution in 2012. Plans and

efforts began to be directed at WPPC in the 11th Five-Year-Plan (2006-2010) and

especially so after the 18th Party Congress in 2012.

Environmental protection demands huge investment but with a significant time

lag between inputs and outcomes. Implementation process is highly complex and

challenging with many actors from the public and private sectors as well as society.

Local cadres are used to prioritizing economic development when GDP growth rate is

the most important indicator for promotion. Tension arises when they are urged to

implement environmental policies. Overlapping functions of governmental

departments in economics and environment also posed as obstacles to implementation.

Forced to bear the financial burden for environmental protection, they tend to protect

local interests and avoid implementation. As such, before 2006, the divergence of

interest in the principal-agent relationships between higher-level governments (i.e. the

center and the province) and lower-level governments (below the province), and

among lower-level governments in regard to environmental protection led to conflict

of interest. When policy ambiguity was high as well, symbolic implementation was

ii
the norm as policies were either not implemented or poorly implemented.

The present study takes into account recent advances in governance studies on

the importance of policy implementation as a formative stage of the policy process. It

adopts Richard Matland’s ambiguity-conflict model to account for the relations of

structure and agency via four different implementation modes in terms of policy

characteristics and their levels of policy ambiguity and conflict, which reflect the

workings of principal-agent relationships, environmental laws and plans as well as

policy tools being employed by different levels of government to tackle environmental

problems on the ground. These implementation modes shed light not only on the

importance of agency, i.e. the capacity of individuals to fulfill their potential, which is

predominant in environmental governance studies on China that emphasize the role of

non-state actors in civil society and environmental non-governmental organizations.

They also relate agency to structure in terms of the implementation arrangements and

the mutual influence of structures and power, given the core of public policy being

top-down by governments in reality. Based on documentary research, fieldwork and

participation as well as interviews, the research shows the relations and interactions of

structure and agency that bring about different WPPC implementation outcomes

before and after 2012 in Guangzhou.

The 2008 WPPC in Guangzhou began with a political implementation mode with

low policy ambiguity and high conflict initially. As implementation proceeded, the

inadequacy of a single indicator for measuring water quality led to a high level of

policy ambiguity. Implementing WPPC could be justified politically and economically

iii
when Guangzhou was hosting the 2010 Asian Games soon; this had alleviated conflicts

due to the divergent interests of local governments. As policy ambiguity became high

and conflict was low, a political implementation mode slid into an experimental

implementation mode. Implementation outcomes, however, were unsatisfactory

despite Guangzhou’s impressive economic and organizational capacities through

command-and-control instruments, reorganization and financial inputs. Although local

governments were offered some economic incentives and political incentives, the

central government’s capacity for policy enforcement was weak without an effective

monitoring system. Without nodality tools such as the skillful handling of information

for persuasion and channels for public participation, the application of policy tools was

incomplete. The link between cadre performance assessment and WPPC was tenuous.

As a result, the 2008 WPPC failed to tackle the root causes of water pollution and the

improvement made to water quality was short-lived.

Before the 2016 WPPC, the Guangzhou government made WPPC a top priority

and opted to develop a sustainable economic development model when it was made a

pilot city for water ecological civilization. Its own action plan complied with the action

plan for WPPC formulated by the central government in 2015 with clearer objectives

and low policy ambiguity. A working mechanism, comprising of central inspection

groups supplemented by River Chiefs headed by local leading cadres that permeated

hierarchy and networks, brings about public participation and information disclosure.

It has, therefore, built and sustained an effective monitoring system that strengthened

the central government’s capacity in policy enforcement. In addition, the central

iv
government has also improved the incentives for local governments so as to encourage

compliance with central directives. As conflicts are increasingly minimized, the

convergence of interest between the central government and local governments

enhances the potential of administrative implementation for WPPC.

Keywords: WPPC, Matland’s ambiguity-conflict model, principal-agent relationships,

implementation mode, political implementation, experimental implementation,

administrative implementation

v
 Declaration
I declare that the thesis here submitted is original except for the source materials

explicitly acknowledged and that this thesis as a whole, or any part of this thesis has

not been previously submitted for the same degree or for a different degree.

I also acknowledge that I have read and understood the Rules on Handling Student

Academic Dishonestly and the Regulations of the Student Discipline of the University

of Macau.

vi
 Table of Contents

Acknowledgments ......................................................................................................... i

Abstract ........................................................................................................................ ii

Declaration .................................................................................................................. vi

Lists of Tables and Figures......................................................................................... xii

List of Abbreviations ................................................................................................ xvii

Chapter 1 Introduction ................................................................................................ 1

1.1 Research Background............................................................................................. 1

1.1.1 Environmental Problems in China ........................................................ 1

1.1.2 Chinese Government’s Response and Local Challenge ........................ 2

1.1.3 China’s Water Crisis as an Environmental Challenge ........................... 6

1.1.4 Reasons for Choosing Guangzhou City as a Case Study ...................... 9

1.2 Literature Review ................................................................................................. 12

1.2.1 Localism, Local Interests and Environmental Politics in China ......... 12

1.2.2 Factors Affecting Local Environmental Policy Implementation......... 16

1.3 Research Questions, Hypotheses and Theoretical Implications .......................... 35

1.3.1 Research Questions ............................................................................. 35

1.3.2 Hypotheses and Theoretical Implications .......................................... 36

1.4 Contribution of the Thesis ................................................................................... 39

1.4.1 Theoretical Construct .......................................................................... 39

1.4.2 Major Findings .................................................................................... 41

1.4.3 Argument ............................................................................................. 48

vii
1.5 Methodology and Limitations .............................................................................. 49

1.6 Chapter Layout ..................................................................................................... 53

Chapter 2 Studying Implementation: Synthesis, Instruments and Principal-Agent

Relationship ................................................................................................................ 55

2.1 Policy Implementation ......................................................................................... 55

2.1.1 Models of Policy Implementation ....................................................... 56

2.1.2 Actors in Policy Implementation ......................................................... 68

2.1.3 Choice of Policy Tools and Instruments.............................................. 69

2.1.4 Criteria for Successful Implementation............................................... 76

2.2 Principal-Agent Theory ........................................................................................ 79

2.2.1 Principal-Agent Model in Economics ................................................. 81

2.2.2 Principal-Agent Framework in the Public Sector ............................... 84

2.3 The Application of Theories in this Study............................................................ 88

Chapter 3 Formulating and Legitimating WPPC Policies at the Center .................... 94

3.1 Roles of Party and State Organs in WPPC ........................................................... 97

3.1.1 Change in the CCP’s Attitude towards Environmental Protection ...... 98

3.1.2 The Role of NPC, 2014 EPL and WPPCL ........................................ 108

3.1.3 The Role of the State Council and Government Reorganization ...... 119

3.2 WPPC Policy Characteristics and the Emergence of Political Implementation

................................................................................................................ 123

3.2.1 Policy Characteristics and Emerging Political Implementation Before

2012 ............................................................................................................ 124

viii
 3.2.2 Reducing Ambiguity and Alleviating Conflict in WPPC Policy after

2012 ............................................................................................................ 131

Chapter 4 Implementing and Managing WPPC in Guangzhou (2008-2010) .......... 140

4.1 Water Environment in Guangzhou ..................................................................... 142

4.1.1 General Situation............................................................................... 142

4.1.2 History of Managing Water Pollution Control in Guangzhou .......... 143

4.2 Major Actors in Guangzhou’s WPPC Policy Implementation ........................... 146

4.2.1 The Party Secretary of the Party Committee..................................... 146

4.2.2 The Reorganization of Guangzhou Water Authority and Guangzhou

Ecology and Environmental Bureau .......................................................... 150

4.2.3 Other Government Departments involved in WPPC Works ............. 155

4.3 Actors, Policy Tools, Implementation Modes and Outcomes of 2008 WPPC

................................................................................................................ 158

4.3.1 The 2008 WPPC Objectives .............................................................. 159

4.3.2 The 2008 Work Plan, Actors and Responsibilities ............................ 160

4.3.3 From Political Implementation to Experimental Implementation .... 163

4.3.4 Policy Tools and Rationale ................................................................ 166

4.3.5 Assessment of 2008 WPPC Implementation Outcomes ................... 170

Chapter 5 Implementing and Managing WPPC in Guangzhou (2016-2020) .......... 177

5.1 Objectives of the 2016 GZAPWPPC ................................................................. 179

5.2 Roles and Conflicts: Government, Civil Society and the Market ...................... 181

5.2.1 Leading Officials and Departments in the 2016 WPPC .................... 181

ix
 5.2.2 Civil Society ...................................................................................... 186

5.2.3 Market ............................................................................................... 188

5.2.4 Conflicts in the 2016 WPPC ............................................................. 189

5.3 Mechanism for Ensuring Compliance ................................................................ 194

5.3.1 Two Important Systems for Ensuring Compliance ........................... 194

5.3.2 Intergovernmental Relationships and Interactions: RCS, CIEEP and

Civil Society ............................................................................................... 200

5.4 A More Complete Application of Policy Tools ................................................. 218

5.4.1 Managing Enterprises, Cadres and the Public ................................... 218

5.4.2 Uncovering and Managing the Root Causes of Pollution ................. 220

5.5 The Outputs and Outcomes of 2016 WPPC ...................................................... 222

5.5.1 Formal Transposition and Practical Application as Policy Outputs .. 222

5.5.2 The Outcomes of the 2016 WPPC .................................................... 230

Chapter 6 Principal-Agent Relationships in WPPC: An Interests-Incentives-

Information (3I) Framework .................................................................................... 235

6.1 Divergence or Convergence of Interests?........................................................... 237

6.1.1 The Divergence of Interests in Environmental Protection ................ 237

6.1.2 Guangzhou’s Convergence with the Central Government’s Interest 240

6.2 Incentives for Dealing with Divergent Interests................................................. 243

6.2.1 Political Incentives in Environmental Policy Implementation .......... 243

6.2.2 Economic Incentives in Environmental Policy Implementation ....... 250

6.2.3 Moral Incentives in Environmental Policy Implementation ............. 257

x
6.3 Information: A Working Mechanism and a Monitoring System ........................ 264

6.4 The Combined Impact of Interests-Incentives-Information (3I) on WPPC ....... 271

6.4.1 The Impact of 3I on the 2008 WPPC in Guangzhou......................... 271

6.4.2 The Impact of 3I on 2016 WPPC in Guangzhou .............................. 274

Chapter 7 Conclusion ............................................................................................... 280

7.1 Research Questions, Design and Significance ................................................... 283

7.2 Research Findings and Contribution .................................................................. 287

7.3 Future Research Outlook.................................................................................... 294

Reference.................................................................................................................. 298

Appendices ............................................................................................................... 351

xi
 Lists of Tables and Figures

Tables

Table 1 China’s EPI Rank and Score from 2006-2018 ............................................. 1

Table 2 Key Targets of 11th -13th FYPs on Environment Protection ....................... 3

Table 3 Incidents of Environmental Pollution and Destruction in China 2001-2010 9

Table 4 A Schematic Overview of the Factors for Analyzing the Shift in Guangzhou’s

WPPC Implementation Modes .................................................................. 44

Table 5 Interviews ................................................................................................... 51

Table 6 Four Implementation Processes of Ambiguity-Conflict Model ................. 67

Table 7 Policy Classification by Governance Principles......................................... 71

Table 8 Environmental Policy Tools ....................................................................... 75

Table 9 Criteria for Measuring Implementation Success ........................................ 79

Table 10 The Central Leading Groups .................................................................... 99

Table 11 Contents Related to Environmental Protection in GCDR Meetings ...... 101

Table 12 Contents Related to Environmental Protection in CCDR Meetings ...... 103

Table 13 Statements on Water Environment Protection in the Reports of the PC 107

Table 14 Main Environmental Laws in China....................................................... 109

Table 15 Revised Contents of WPPCL in the Two Deliberations ......................... 120

Table 16 Central Policy Framework of WPPC before 2012 ................................. 125

Table 17 Objectives in WPPC Plan of Liaohe River Basin .................................. 126

Table 18 Central Policy Framework of Water Environment Protection after 2012

................................................................................................................ 132

xii
Table 19 Main Objectives and Indices Proposed by the APWPPC ...................... 133

Table 20 Chronicles of Water Pollution Control in Guangzhou ........................... 144

Table 21 The Main Responsibilities of GZWA Related to WPPC ........................ 153

Table 22 Organization Structure of GZEBB ......................................................... 155

Table 23 Water Pollution Control Objectives of Guangzhou from 2008 to 2010 . 160

Table 24 Environmental Policy Tools Adopted in the Notice ............................... 168

Table 25 Main Objectives and Indices of GZAPWPPC ....................................... 179

Table 26 Accountability in the Central Environmental Protection Inspection

2015-2017 .............................................................................................. 185

Table 27 List of PPP Projects for Water Pollution Control in Guangzhou .... 189

Table 28 Guangzhou’s Key Tasks for WPPC Arranged by Guangdong Government

in 2018 .................................................................................................... 201

Table 29 CIGEEP’s Inspections in Guangdong Province 2016-2021 ................... 204

Table 30 Ten General River Chief Decrees of Guangzhou ................................... 206

Table 31 Communications between New Life and WPPC Related Departments

2013-2018 ............................................................................................... 215

Table 32 Main Policy Tools Adopted in the “Four Cleansing” Movement .......... 221

Table 33 Policy Tools Used in Managing Sewage Pollutant Discharge ............... 222

Table 34 Provision of Incentives for WPPC of Guangzhou.................................. 227

Table 35 Monitoring and Enforcement for WPPC of Guangzhou ........................ 228

Table 36 Outcomes of WPPC in Guangzhou 2017-2020 ...................................... 230

Table 37 Proportion of Water Quality Categories at National Examination and

xiii
 Monitoring Sections in Guangzhou ........................................................ 232

Table 38 Remediation of Black and Odorous Water Bodies (BOWB) in Guangzhou

2018-2020 ............................................................................................... 232

Table 39 The Interests of Central Government and Local Government in Environme-

ntal Protection at Different Times ........................................................... 238

Table 40 Key Targets of 11th -13th FYPs on Water Environment Protection ...... 245

Table 41 Main Environmental Protection Indicators (EPI) in 11th and 12th EPFYP

................................................................................................................ 246

Table 42 Main Indicators of 13th EPFYP .............................................................. 247

Table 43 Central Government Expenditure on Environmental Protection (EP) 2007-

2020 ........................................................................................................ 251

Table 44 Central Government Earmarked Transfers on Water Environment Manage-

ment (WEM) .......................................................................................... 252

Table 45 Excerpts from Xi Jinping’ s Speech on Ecological Civilization ............ 265

Table 46 Background to the Implementation of Environmental Policies by Central

Government ............................................................................................ 269

xiv
Figures

Figure 1 The Use of Water in China 2000-2016 ....................................................... 7

Figure 2 Waste Water Discharge in China ................................................................ 8

Figure 3 COD Discharge and Ammonia Nitrogen Discharge in China .................... 8

Figure 4 Waste Water Discharge in 4 Provinces from 2011-2016 .......................... 10

Figure 5 Waste Water Untreated in 4 Provinces from 2011-2016 ........................... 10

Figure 6 Ambiguity-Conflict Matrix: Policy Implementation Processes ............... 62

Figure 7 Application of Theories in Each Chapter ................................................. 93

Figure 8 Overall Plan for Building Ecological Civilization ................................. 137

Figure 9 The GZWA under “Tiao-Kuai” Relationship.......................................... 152

Figure 10 Historical Evolution of Guangzhou Ecology and Environment Bureau

................................................................................................................ 154

Figure 11 Operation Mechanism of 2008 Water Pollution Control in Guangzhou

................................................................................................................ 163

Figure 12 Guangzhou Centralized Drinking Water Sources Quality .................... 171

Figure 13 Water Quality of Main Rivers in Build-up Areas of Guangzhou 2013-2016

................................................................................................................ 173

Figure 14 Public Reporting Channels for WPPC in Guangzhou .......................... 188

Figure 15 Operation of 2016 WPPC in Guangzhou.............................................. 202

Figure 16 Seven-level RCS of Guangzhou ........................................................... 209

Figure 17 Guangzhou River Chief Training App .................................................. 210

Figure 18 Guangzhou River Chiefs Billboard ...................................................... 218

xv
Figure 19 The Share of Expenditure Between the Central Government and Local

Governments 2007-2020 in Environmental Protection .......................... 256

Figure 20 Real-Time Data from State-Controlled Monitoring Sections in Guangzhou

............................................................................................................. 278

Figure 21 WeChat Account for Public Participation in Urban Water Environment

............................................................................................................. 280

Figure 22 Weekly Report on Public Participation in the Urban Water Environment

......................................................................................................... 280

xvi
 List of Abbreviations

APWPPC Action Plan for Water Pollution Prevention and Control

BOWB Black and Odorous Water Bodies

CC Central Committee

CCDR Committee on Comprehensively Deepening Reforms

CCP Chinese Communist Party

CIEEP Central Inspection on Ecological and Environmental

Protection

CIGEEP Central Inspection Group on Ecological and Environmental

Protection

CLEEP Central-Level Expenditure on Environment Protection

CLGs Central Leading Groups

COD Chemical Oxygen Demand

CPES Cadre Performance Evaluation System

CPPCCGZC Chinese People’s Political Consultative Conference

Guangzhou Committee

CTPEP Central Transfer Payments on Environment Protection

DSMICCDR Decision on Several Major Issues Concerning

Comprehensively Deepening Reform

ENGOs Environmental Non-Government Organizations

EPB Environmental Protection Bureau

EPFYP Environmental Protection Five Year Plan

xvii
EPI Environmental Protection Index

EPIP (Trial) Environmental Protection Inspection Plan (Trial)

EPL Environmental Protection Law

EPOGZMPG Environmental Protection Office of Guangzhou

Municipal People’s government

EPOGZRC Environmental Protection Office of Guangzhou

Revolutionary Committee

ERPC Environment and Resources Protection Committee

ESER Energy Savings and Emissions Reduction

FYP Five Year Plan

GCDR Group on Comprehensively Deepening Reforms

GDAPWPPC Guangdong Action Plan for Water Pollution Prevention and

Control

GDEED Guangdong Ecology and Environment Department

GDEPD Guangdong Environment Protection Department

GDHURD Guangdong Housing and Urban-Rural Development

Department

GDRCSO Guangdong River Chief System Office

GDWRD Guangdong Water Resources Department

GESECSR Group for Economic System and Ecological Civilization

System Reform

GOCCCCP General Office of the Central Committee of the CCP

xviii
GOSC General Office of the State Council

GRPGZ Guidance on River Patrol in Guangzhou

GZAPWPPC Guangzhou Action Plan for Water Pollution Prevention and

Control

GZARAB Guangzhou Agriculture and Rural Affairs Bureau

GZCC Guangzhou Construction Commission

GZDRC Guangzhou Development and Reform Commission

GZDWA Guangzhou District Water Authority

GZEEB Guangzhou Ecology and Environment Bureau

GZEEB Guangzhou Ecology and Environment Bureau

GZEPB Guangzhou Environmental Protection Bureau

GZEPLGO Guangzhou Environmental Protection Leading Group Office

GZETC Guangzhou Economic and Trade Commission

GZIITB Guangzhou Industry and Information Technology Bureau

GZMRRIDA Guangzhou Measures of Reward for Reporting of Illegal

Drainage Acts

GZPC Guangzhou People’s Congress

GZRCSO Guangzhou River Chief System Office

GZWA Guangzhou Water Authority

GZWIG Guangzhou Water Investment Group Co. Ltd

GZWRB Guangzhou Water Resources Bureau

MA Ministry of Agriculture

xix
MAPGLCEED Measures on Accountability of the Party and Government

Leading Cadres for Ecological Environment Damage

MARA Ministry of Agriculture and Rural Affairs

MC Ministry of Construction

MCTBOWB Model Cities for the Treatment of Black and Odorous Water

Bodies

MEE Ministry of Ecology and Environment

MEP Ministry of Environment Protection

MF Ministry of Finance

MHURD Ministry of Housing and Urban-Rural Development

MIIT Ministry of Industry and Information Technology

MLR Ministry of Land and Resources

MWR Ministry of Water Resources

NASWQMRTDDS National Automatic Surface Water Quality Monitoring Real-

time Data Dissemination System

NATO Nodality, Authority, Treasure and Organization

NDRC National Development and Reform Commission

NPC National People’s Congress

NSA National School of Administration

OABEC Opinions on Accelerating the Building of Ecological

Civilization

OAWEMGZ Opinions on Accountability for Water Environment

xx
 Management in Guangzhou

OFIRCS Opinions on the Full Implementation of the River Chief

System

OISWRMS Opinions on Implementing the Strictest Water Resources

Management System

OPRECS Overall Plan for the Reform of Ecological Civilization

System

ORCs Official River Chiefs

PC (National) Party Congress

PLS Prizes in Lieu of Subsidies

PPP Public-Private Partnership

RCS River Chief System

SEPA State Environmental Protection Administration

SETC State Economic and Trade Commission

SOD Scientific Outlook on Development

SRCs Social River Chiefs

TRS Target Responsibility System

WEM Water Environment Management

WPPC Water Pollution Prevention and Control

WPPCL Water Pollution Prevention and Control Law

3I Interests-Incentives-Information

xxi
 Chapter 1 Introduction

1.1 Research Background

1.1.1 Environmental Problems in China

Since the opening up and reform of China in 1978, she has kept a high-speed

growth momentum for more than four decades. The impressive growth is, however,

achieved at the expense of the environment. The seriousness of environment

degradation has caught the attention of the Chinese government, the domestic public

and the international community. According to the 2018 Environmental Performance

Index (EPI) 1 provided jointly by Yale University and Columbia University in

collaboration with the World Economic Forum, China has consistently ranked low in

the two dimensions of environmental health and ecosystem vitality (see Table 1 below).

Table 1

China’s EPI Rank and Score from 2006-2018

Country Year EPI Rank Total Number of State
2006 94 133
2012 116 132
China 2014 118 178
2016 109 180
2018 120 180
Note. Yale Center for Environmental Law & Policy.
https://epi.envirocenter.yale.edu/.

China’s EPI ranked 116 out of 132 countries in 2012, 118 out of 178 countries in

2014, then 109 and 120 out of 180 countries in 2016 and 2018 respectively (see Table

1 above). Although there were some improvements in the past years, China’s

1
The Environmental Performance Index (EPI) ranks how well countries perform on high-priority environmental
issues in two broad policy areas: protection of human health from environmental harm and protection of
ecosystems.
1
environmental performance was only better than India, lagged much behind the other

main emerging economies (such as Russia and Brazil), Asian neighbors - whether

democracies or authoritarian states (such as Thailand, Indonesia, and Vietnam) - let

alone the Western developed countries.

Environmental problems not only threaten people’s health and economic

development, they also pose an acute political challenge to governance (Chen, 2009;

Economy, 2004; Saich, 2015). Since 2012, main industrial clusters like Beijing-

Tianjin-Hebei region and the Yangtze River Delta have fallen victim to heavy smog

sporadically. The extensive use of coal led to air pollution, which is further exacerbated

by the increase in automobiles. In January 2013, a choking smog in Beijing showed

just how debilitating air pollution could be. But water pollution and scarcity are “an

even greater problem” (Saich, 2015, p.346). In 2007, the massive bloom of blue algae

in Lake Taihu, the source of water supply for Wuxi city in Jiangsu Province, brought

about a drinking water crisis. Bottled water in stores and supermarkets was snapped

up, leaving approximately two million people without drinking water for at least a

week (Xie, 2008). And in March 2013, farmers upstream in Zhejiang province

slaughtered more than 16,000 diseased pigs and simply dumped them in a nearby

waterway that finally flowed into Shanghai’s Huangpu River. The then Ministry of

Environmental Protection reported that one-fifth of farmland was polluted due to the

overuse of chemicals. Such water is neither fit for human consumption nor industrial

use. Worst of all, there are as many as 450 “cancer villages” across China (Saich, 2015).

1.1.2 Chinese Government’s Response and Local Challenge

2
 The central government has apparently realized the need to deal with

environmental problems for sustainable development. The main targets in various Five

Years Plans (FYPs) related to environmental protection have become stricter in the

past fifteen years. After 1978, the emphasis of the 6th FYP (1981-1985) to the 9th FYP

(1996-2000) was mainly on institutional reform and economic development.

Environmental protection only became the focus after the 10th FYP (2001-2005).

Subsequently, the 11th FYP (2006-2010) first created obligatory and anticipatory

indicators to clarify the responsibility of governments at different levels. Energy

consumption per unit of GDP, water use in industry, major pollutant emissions and

forest coverage were some examples of obligatory indicators (see Table 2 below).2 On

this basis, the 12th FYP (2011-2016) included other binding targets on CO2 emission,

non-fossil energy consumption. The 13th FYP (2016-2020) further added indicators for

air quality and surface water quality. This shows that the Chinese government began

working seriously towards environmental protection and sustainable development

after 2006.

Table 2

Key Targets of 11th -13th FYPs on Environment Protection

Type of
FYP Key Targets on Environment Protection
Target
-Energy consumption per unit of GDP to be reduced by 20%; Obligatory
-Water use per unit of value-added industrial output to be Obligatory
11th
reduced by 30%;
FYP
-Aggregate major pollutant emissions to be reduced by 10%; Obligatory
-Forest coverage rate to rise to 20%. Obligatory
12th -Energy consumption per unit of GDP to be reduced by 16%; Obligatory

2
Obligatory targets, also called as binding targets, fulfilling which is nominally required for a cadre to gain
performance reward every year and promotion in his or her political career.
3
 FYP -Non-fossil energy to account for 11.4% of primary energy Obligatory
consumption;
-Water use per unit of industrial value-added output to be Obligatory
reduced by 30%;
-CO2 emissions per unit of GDP to be reduced by 17%; Obligatory
-Forest coverage rate to rise to 21.66% and forest stock to be Obligatory
increased by 600million m3;
-Aggregate major pollutant emissions reduction (%) Obligatory
·Chemical oxygen demand (COD): 8%
·Sulfur dioxide: 8%
·Ammonia nitrogen:10%
·Nitrogen oxides: 10%.
-Energy consumption per unit of GDP to be reduced by 15%; Obligatory
-Non-fossil energy to account for 15% of primary energy Obligatory
consumption;
-Water use per RMB10,000 GDP to be reduced by 23%; Obligatory
-CO2 emissions per unit of GDP to be reduced by 18%; Obligatory
-Forest coverage rate to rise to 23.04% and forest stock to be Obligatory
increased by 1.4 billion m3;
-Air quality Obligatory
·Days of good or excellent air quality in cities at and above
13th
the prefectural level to be over 80%；
FYP
·PM2.5 intensity in cities at and above the prefectural level
missing the target to be reduced by 18%
-Surface water quality of Grade III or better to be over 70% and Obligatory
worse than Grade V to be less than 5%;
-Aggregate major pollutant emissions reduction (%) Obligatory
·Chemical oxygen demand (COD): 10%
·Sulfur dioxide: 15%
·Ammonia nitrogen:10%
·Nitrogen oxides: 15%.
Note. Central Compilation & Translation Bureau (2016).

In addition to these macro-goals set in the FYPs, the central government has

developed an extensive environmental protection agency network and adopted a

number of policies and regulations that if observed will go a long way to ameliorating

environmental degradation. After years of lobbying and during the March 1998

National People’s Congress (NPC), the environment protection administration was

upgraded to ministerial status and a decade later renamed the Ministry of

4
Environmental Protection (MEP) in March 2008. Again, in 2018, MEP was replaced

by the Ministry of Ecology and Environment (MEE). The National Development and

Reform Commission (NDRC), the Ministry of Land and Resources (MLR), and other

ministries and commissions were linked up with the newly established MEE to pursue

environmental protection goals.

On 1 January 2015, a new Environmental Protection Law (EPL) came into effect.

It addresses air, water and soil pollutions and gives the relevant authorities greater

enforcement power, including imposing heavy fines and holding offenders in detention

for up to 15 days. Importantly, the law permits legally registered social organizations

to initiate litigation in the name of public interest. To have greater transparency, local

governments are instructed to release information on pollution. The details of the EPL

were formulated at the national level and then passed down to provincial governments

and its equivalents (autonomous regions and municipalities directly under the central

government) that further allocate targets to their prefectures, counties and townships

(Saich, 2015). Thus, the compliance and cooperation of sub-national governments are

very critical for fulfilling those key targets set by the central government.

Commitment to pursuing environmental protection means the central government

is trying to slow down environmental degradation (Economy, 2004; OECD, 2007). But

China is a big country with a large population and serious regional disparities socially,

politically and economically. The interests of local governments may not be in line

with that of the central government’s (He & Kong, 2011; Zhou & Lian, 2011; Chan

et.al, 1995; Li & Higgins, 2013). Despite national ambitions and numerous new

5
initiatives provided by Beijing, a substantial environmental policy implementation gap

exists. Thus, an obvious paradox often noticed by researchers, according to past

records, is that the ambitious goals and regulations for environmental protection set by

the central government too often failed due to problems in local implementation

(Kostka & Mol, 2013).

The divergence of interests between the center and the localities may bring about

quite different implementation outcomes. Non-implementation, poor-implementation

or selective-implementation are possible as far the enforcement of environmental

policies and regulations in China is concerned (Van Rooij, 2006a; Greenpeace, 2011;

O’Brien & Li, 1999). Yet, there were some successful cases of implementation, such

as the fulfillment of the energy intensity reduction goal in the 11th FYP of Shanxi

Province (Kostka & Hobbs, 2012), methanol fuel-switching in Shanxi Province

(Kostka & Hobbs, 2013) and water pollution control of Taihu lake in Jiangsu Province

in 2007 (Sun, 2009). This implies that environmental policy implementation is much

like implementation of other policies in China, unevenly spread out across the country.

This warrants the interest and attention to environmental protection in context and

from a local perspective as well, not just with what happens at the top.

1.1.3 China’s Water Crisis as an Environmental Challenge

Water crisis due to water shortage or pollution is a much more worrisome

environmental problem than others to China’s leaders because of its implications for

public’s access to clean drinking water, public health and economic growth (Economy,

2004; Saich, 2015). Currently, agriculture has the largest share of using water resources

6
in China (see Figure1). Industry water usage is kept at a stable level, while household

and service usage of water resources have been increasing in the past years.

Figure 1

The Use of Water in China 2000-2016

unit:100million cu.m
7000.0
6000.0
5000.0
4000.0
3000.0
2000.0
1000.0
0.0

Total Amount of Water Use Agriculture Use

Industry Use Household and Service Use

Note. China Statistical Yearbook on Environment 2017

Two-thirds of China’s 669 cities are confronted with water shortage problems.

China’s per capita availability of renewable water resources is about a quarter of the

world’s average, but water consumption per unit of Gross Domestic Product (GDP) is

three times the world’s average because of a water-intensive industrial structure,

outdated technologies, low reuse rate, and wastefulness (Chinese Academy of Social

Sciences, 2008). Besides, industrialization, urbanization and rapid population growth

have taken their toll on China’s already scarce fresh water resources. Half of China’s

major rivers and around 40 percent of important lakes are polluted. In 2014, waste

water discharge from industries and households was almost twice as much as that in

2000. Although there was a slight decline in industrial discharge, household discharge

increased dramatically and accounted for over 70 per cent of the waste water discharge.

7
At the same time, Chemical Oxygen Demand (COD) and Ammonia Nitrogen

Discharge in waste water showed a growing trend and outbroke after 2010 (see Figure

2 and Figure 3 below).

Figure 2

Waste Water Discharge in China

unit:100 million tons

800
600
400
200
0

Wast Water Discharge Industrial Discharge

Household Discharge

Note. National Bureau of Statistics & Ministry of Environment Protection (2017).

Figure 3

COD Discharge and Ammonia Nitrogen Discharge in China

unit:10,000 tons
3000.0
2500.0
2000.0
1500.0
1000.0
500.0
0.0

COD Discharge Ammonia Nitrogen Discharge

Note. National Bureau of Statistics & Ministry of Environment Protection (2017).

According to the data in the China Statistical Yearbook on Environment 2002-

2011, water pollution incidents accounted for most environmental emergencies from

2001 to 2010 (see Table 3 below).

8
Table 3

Incidents of Environmental Pollution and Destruction in China 2001-20103

Number of Water Air Solid Waste

Year Others
Incidents Pollution Pollution Pollution

2001 1842 1096 576 39 131

2002 1921 1097 597 109 118
2003 1843 1042 654 50 91
2004 1441 753 569 47 72
2005 1406 693 538 48 127
2006 842 482 232 45 83
2007 - - - - -
2008 474 198 141 45 90
2009 418 116 130 55 117
2010 420 135 157 3 124
Note. National Bureau of Statistics & Ministry of Environment Protection (2002-2011).

1.1.4 Reasons for Choosing Guangzhou City as a Case Study

In view of the seriousness of water pollution in China, this research focuses on

local governments’ policy implementation pertaining to water pollution prevention and

control (WPPC). In spite of centralized policy-making, idiosyncratic local

implementation of environmental policies is prevalent. This is partly due to drastic

regional disparity in economic development, social and natural conditions (Li &

Higgins, 2013). This research has chosen Guangzhou city in Guangdong Province as

a case study on local governments’ implementation of WPPC policy for the following

reasons.

3
Note: After 2011, incidents of environmental pollution were no longer listed based on the incident
types but the degree of pollution, namely extraordinary serious, serious, comparatively serious and
ordinary incidents.

9
 Firstly, Guangdong Province is an important economic growth engine. Most

importantly, Guangzhou is one of the four first-tier cities in China, i.e. Shanghai,

Beijing, Guangzhou and Shenzhen in terms of size and per capita GDP. Some of its

main industries, such as textile and ceramics often bring about serious water pollution.

The volume of waste water discharge is much higher than other provinces (see Figure

4 below). Although Guangdong has built many wastewater treatment plants with

efficient treatment capacity, untreated waste water is still more than other provinces,

such as Jiangsu, Shandong and Zhejiang which are almost at the same level of

economic development (see Figure 5 below).4

Figure 4

Waste Water Discharge in 4 Provinces from 2011-2016

Unit: 10,000 cu.m

800000
700000
600000 671363 689202
636504 652251
615166
500000 606268
400000
396336 412277 427570
300000 377869 388975 393453
295243 302131 320102
200000 265465 277438 281135 250146 269386 277096
214355 221437 235798
100000
0
2011 2012 2013 2014 2015 2016

Guangdong Jiangsu Shandong Zhejiang

Note. National Bureau of Statistics & Ministry of Environment Protection (2012-

2017).

Figure 5

Waste Water Untreated in 4 Provinces from 2011-2016

4 Guangdong, Jiangsu, Shandong and Zhejiang were the first to the fourth in GDP ranking list from 2011-2016.
10
 Unit: 10,000 cu.m
140000 126661
120000
100000
80000 71772
49985 55133
60000 42657 41429
38083 36216
40000 31956 27686 30917
25269 25907
23302 2507021691 23142
18117 16023 14247 13960 12790 16920
12146
20000
0
2011 2012 2013 2014 2015 2016

Guangdong Jiangsu Shandong Zhejiang

Note. Adapted from National Bureau of Statistics & Ministry of Environment

Protection (2012-2017).

In 2016, the Ministry of Housing and Urban-Rural Development (MHRUD) and

the then MEP jointly published the results of their inspections on the entire country’s

black and odorous water bodies in 295 cities at prefecture level and above. 1,811 black

and odorous water bodies were found in 216 cities, among which Guangdong Province

had the largest number of black and odorous water bodies (242). Guangzhou and

Shenzhen, two first-tier cities in Guangdong Province, had the most black and odorous

water bodies, reaching 35 and 43 respectively (Ministry of Housing and Rural-Urban

Development, 2016). Guangdong is confronted with the challenge of striking a balance

between economic development and environmental protection.

In April 2015, the State Council published the Action Plan for Water Pollution

Prevention and Control (APWPPC). One of the key indices is to control within 10 per

cent the quantity of black and odorous water bodies in built-up areas in cities at

prefecture level and above. Later in December 2016, the central government released

a document to establish the “River Chief System” (He zhang zhi）nationwide by the

end of 2018. River Chief System (RCS) is a management system for rivers and lakes

11
and is linked to the accountability system of water environmental governance, namely

the performance evaluation of top leading cadres. Only leading cadres in the four tiers

of party and government organizations (provinces, municipalities, counties and

townships) can take on the position of a river chief.

Guangzhou has made significant progress in WPPC in recent years due to

pressure from the central government. In 2018, Guangzhou was listed as one of the

demonstration cities for the treatment of black-odor water bodies; it received RMB

600 million from the central government for implementing WPPC policy (Liu, 2018).

In 2020, Baiyun District in Guangzhou’s outstanding performance in WPPC won itself

a reward of RMR 10 million from the General Office of the State Council of Further

Strengthening Supervisory Inspection-based Incentives (Guangzhou Daily, 2020).

Therefore, Guangzhou’s impressive performance deserves further attention and

explanation, given the challenge of policy implementation at the local level.

1.2 Literature Review

As mentioned above, water resources in China are unevenly distributed. Local

governments are confronted with different social and natural conditions when

implementing water-related policies. The following will review studies related to the

role played by local governments in Chinese politics vis-à-vis the implementation and

enforcement of environmental policies.

1.2.1 Localism, Local Interests and Environmental Politics in China

Divergence between the central government’s national environmental policies

and the actual outcomes at the local level makes up the environmental policy

12
implementation gap (Kostaka & Mol, 2013). Such an implementation gap could be

identified in China and other countries (Knill & Lenschow, 2000; Scheberle, 2004).

However, the causes vary across different political systems.

Payne (1995) claimed that democracy is good for environmental protection. The

concept of “environmental democracy” is characterized by a participatory and

ecologically rational form of collective decision-making (Mason, 2012). Others, such

as Beeson (2010), put forward the concept of “environmental authoritarianism”,

whereby an authoritarian regime could better deal with environmental degradation by

effectively preventing individuals from unsustainable behavior. Whether these two

types of regimes work or not is contentious (Josephson, 2004; Purdy, 2010). In the

case of China, it is often taken as an example of environmental authoritarianism

(Beeson, 2010; Gilley, 2012; Moore, 2014). One of the prominent features in

environmental authoritarianism is that the government plays a domineering role in

environmental protection. Environmental governance uses and depends heavily on

top-down command-and-control instruments (Kostka, 2014).

In the existing literature on China’s environmental politics, the major obstacle to

environmental governance lies at the local level (Economy, 2004; Van Rooij, 2006a).

Two influential theories have pointed to the significance of local governments in policy

implementation even during the time of China’s planned economy. Shue (1988)

depicted China’s bottom-level governmental organizations as a cellular structure in

which each village was a relatively small, complete, self-sufficient and self-contained

unit. The level of inter-village contact was low; instead, most villages were vertically

13
integrated with higher-level government organs. Although counties and villages were

administrative organs, township and village cadres were simply not obedient agents.

Instead, they were the guardians of local interests and capable of modifying or even

resisting central policies when local interests hanged in the balance. The checks and

balances between rural communities and the state administrative authorities were

related to China’s longstanding tradition of gentry (shen shi) autonomy. Then, Chinese

local governments had their own independent stance of “localism” in spite of a highly

centralized regime.

The other influential theory is the M-form hypothesis on China’s planned

economy proposed by Qian and Xu (1993) who took after the former Soviet Union’s

planned economy as a U-form system in which the central and local governments were

in a relationship of vertical planning and management. In pre-reform China, the

planned economy was described as an M-form structure composed of a series of multi-

layer and multi-regional management organizations with similar structures and

functions, namely the “kuai-kuai (pieces) economy”. Even in a highly centralized,

planned economic system, the local economy enjoyed a certain degree of autonomy.

In the reform era, there was considerable administrative and financial

decentralization such that the power of local governments was further strengthened as

economic growth was promoted by the state. Hence, Qian and Weingast (1997) put

forward the famous Chinese-style fiscal federalism theory. Some scholars, however,

pointed to the rationality of decentralization in strengthening the performance

legitimacy of the party despite political risk (Kostka, 2014; Cao, 2011). According to

14
Cao (2011), the central government controls the power to govern officials through their

appointment, supervision, reward and punishment, while local governments are

responsible for governing the people. This “vertically decentralized authoritarianism”

system reduces the political risk of the central government as political risk is dispersed

and the degree of centralizing state power is spontaneously adjusted; this has

contributed to the long-term stability of the political system. For Cai (2008), the

Chinese political system is not only authoritarian, but resilient as well. The multiple

levels of authority help in reducing uncertainty by granting conditional autonomy to

lower-level governments. Taking food safety supervision as an example, through

decentralization, the central government transferred high social risk to local

governments (Cao & Zhou, 2013). In environmental protection, the same applies to

controlling water pollution in rivers, which is transboundary and of high political risk.

In his research on local government, Zhou (2017) pointed to the illusion of treating

local governments as faithful agents of China’s highly centralized political system in

policy implementation. As Qian and Xu (1993) asserted, even before the economic

reforms in the late 1970s, China was more decentralized than the Soviet Union. The

so-called planned economy should be more accurately described as a “locally planned

economic system” (Zhou, 2017, p.11). With economic reforms, administrative

decentralization and the establishment of Special Economic Zones (SEZs) greatly

expanded the role of local governments in spearheading economic development. But

this does not mean that local governments are obliged to act in complete obedience to

the directives of the central government, given its distance, localism and autonomy as

15
perennial features historically.

1.2.2 Factors Affecting Local Environmental Policy Implementation

In China, the central government and local governments differed in functional

roles, objectives and constraints. The central government is more concerned with

macroeconomic control and balancing social welfare at the national level, while local

governments often pay more attention to securing finance and resources to develop the

economy and provide social welfare at the local level (Yu, 2011). Thus, the motivation

and resulting behavior of local officials are not necessarily in line with the central

government’s intention for achieving environmental protection or public interest (Li

& Higgins, 2013). Its political will and institutional capacity for solving environmental

problems are crucial for environmental protection outcomes, which are tied to the

orientation of individual officials, structural and contextual factors in the political

system as well as local economic conditions (Li & Higgins, 2013). Research on local

governments’ implementation of environmental policy should consider the internal

operation of bureaucracy, official incentives and other aspects within the purview of

central-local relations (Tang, 2016). Two perspectives – structural and process – are

helpful for understanding factors effecting local environmental policy implementation.

1. Structural Perspective

For Lieberthal and Lampton (1992), the Chinese political system is termed

“fragmented authoritarianism”, whereby authorities at the lower rungs of the Chinese

political system are fragmented and disjointed. Structurally, China’s bureaucratic

ranking system, when combined with the functional division of authority among

16
various bureaucracies, produced a situation in which negotiation among an array of

bodies is necessary and no single body has authority over the others. As Lieberthal and

Oksenberg (1988) explained, “The reform happened in 1980s contributed to the

fragmentation of authorities’ decision making procedurally, which made the central-

local relations neither in terms of central dominance nor provincial autonomy, but a

complex interdependence and bargaining relationship” (pp.352-353). There are

definitely rooms for negotiation between the two parties (Shirk, 1993). Besides, it is

difficult for the central government to move a single step forward without the support

of local governments (Zhou, 2017).

Under centralized policy implementation, some scholars have attributed local

governments’ implementation outcomes of environmental policies to the political will

of the central government. Through the setting of targets based on indicators for

environmental protection and sustainable development, the central government

assesses the promotion prospects of local officials (Sun et.al, 2014). After the 10th FYP,

local governments came to realize the change in the central government’s attitude

towards environmental protection and feel the pressure from the top (He & Kong,

2011). Ran (2013) has come up with the terms “hierarchical pressure (cengji jiaya)”

or “pressure-type system (yalixing tizhi)” to explain the enforcement of environmental

policies at the sub-national level. The pressure-type system refers to a task-based

management model in which higher-level governments break down and assign tasks

to lower-level governments in the hope that they complete these tasks within schedule

(Rong, 1998).

17
 In inter-governmental relationships, the “similarity of responsibility structure

(zhize tonggou)” refers to governments along the line of the vertical hierarchy having

highly identical structures in terms of function, responsibility and institutional set-up

(Zhu & Zhang, 2005). Cadres one-level-down the hierarchy are being managed by

superiors directly above (xiaguan yiji). This has resulted in cadres being

hyperresponsive to their immediate superiors at the expense of other interests. In

O’Brien and Li’s study (1999), cadres in rural areas had to obey directives from their

bosses one level up. Such an organizational arrangement might have helped to fulfill

targets under the pressure-type system when heads of local administration at all levels

compete for promotion at the same hierarchical level across different regions (Zhou,

2010). The evaluation criteria of higher-level governments could be indicators on

economic growth or other measurable criteria. Yet, those in support of the centralized

implementation model argued that the central government’s political will does not

fully determine the outcomes of environmental policy implementation, which also

depend on persuasion skills and the central capacity to build consensus with local

governments. After all, the latter may be passive implementers of central’s

environmental policies. Such a perspective might explain the important role played by

the central government, but fails to explain the uneven implementation of

environmental policies under the pressure-type system.

In 1980s, the Chinese Communist Party (CCP) began to reconstruct highly

centralized planned institution in order to “streamline administration and

decentralization” (Zhou, 2010, p.98). Since then, local governments have had more

18
administrative discretion. As such, some scholars presented a decentralized policy

implementation or provincialism approach (kuaikuai zhuanzheng), which included

views such as Chinese-style federalism (Qian & Weingast, 1997), developmental state

and entrepreneurial state (Qi, 1992; Walder, 1995). Local governments have been

perceived as rational agents pursuing economic interests and implementing national

policies selectively in accordance with their own interests (O’Brien & Li,1999;

Economy, 2004; Anselin, 2001; Rauscher, 2005; Van Rooij, 2006a; Eaton & Kostka,

2014). Local officials are obsessed with developing the economy rather than protecting

the environment; this being the root cause of poorly implemented environmental

policies (Mol & Carter, 2006). The divergence between “centralized policy

implementation” and “decentralized policy implementation” has impacted on

implementation outcomes (Xue & Yang, 2011).

Economic competition between local governments has led to their unwillingness

to increase fiscal expenditure for pollution control because of the positive externalities

of environmental governance (Anselin, 2001). To compete for investment from

enterprises, local governments lower their environmental standards (Rauscher 2005).

In Wu et.al study (2013), local governments preferred investment in transport facilities

to environmental protection infrastructures as the former brought about financial

revenue and growth in GDP. While the 2000 survey in Zhan et.al study (2013) showed

positive association between the support of the central government and perceived

enforcement effectiveness, the support of central government was no longer a

significant factor in the 2006 survey. Perceived enforcement effectiveness was, instead,

19
positively associated with the support of local governments and their collaboration

with other government units. Besides, time horizon is also a critical element insofar as

local governments’ interests are concerned. There are significant downsides to local

leaders changing office every three to four years (Eaton & Kostka, 2014). Officials

with a short time horizon are more likely to choose the path of least resistance in

selecting quick and low-quality approaches when implementing environmental

policies.

Nevertheless, Ran (2013) has rejected the decentralization premise and argued

that the central government in fact wields substantial power; shortcomings in

environmental policy implementation are due to formal constraints and deficiency in

the incentives offered by the central government. When incentives in regard to local

environmental policy implementation are perversely structured, they lead to non-

implementation or poor implementation. As such, we should not study local authorities

alone and lose sight of the context within a multi-level hierarchy (Zhou, 2014). In other

words, the behavior of local officials in inter-governmental relationships are essential

for understanding the nature of local environmental policy implementation. This has

led to an interest in a mixed model that takes into account a fiscal decentralized model

and a political centralized model when studying implementation at the local level.

Local governments have enough discretion in fiscal power and administrative authority.

Yet, the central government is still able to control and hold the behavior of local

governments accountable through the cadre management system.

For Landry (2008) and Xu (2011), inter-governmental relations in China

20
embrace political centralization and economic decentralization. Administrative

subcontracting (xingzheng fabaozhi) and territory management (shudi guanli) are the

main features of this model (Zhou L.A., 2014). The theoretical basis for such a mixed

model is principal-agent theory, in which the central government is regarded as the

principal with the formal authority (including the authority of appointment,

supervision and monitoring, instruction and approval) and residual control rights (such

as veto power without restriction and the right to intervene when necessary). Local

governments are the agents with considerable discretion and de facto power to do

things in their own ways through subcontracting (Zhou L.A., 2014).

Under the analytical framework of principal and agent, the effectiveness of

environmental policy enforcement is determined by three critical elements — the

interests between the central government and local governments, incentives adopted

by the central government and the availability of information for supervision and

monitoring. The effects of political incentives for the promotion of environmental

protection became the focus of empirical studies. The concept “political tournament”

points to

a competition for promotion opportunities among local leaders at the same

hierarchical level and in different regions. The system and its evaluation criteria

are designed by higher-level governments using evaluation indicators that could

be the growth rates of local economies as well as other measurable criteria. (Zhou,

2010, p.65).

When the criteria for evaluating the performance of local officials in political

21
tournaments are more oriented towards the economy rather than the environment,

environmental policy implementation is destined for failure (Qi & Zhang, 2014; Yang

et al., 2008).

Local governments as agents in administrative subcontracting enjoy considerable

discretion and control over information and their disclosure to higher level

governments (Zhou L.A., 2014). Scholars have doubted the validity and authenticity

of China’s environmental information, especially so when indicators do not match

specification and data are being tampered (Andrews, 2008; Gong & Qi, 2014); these

have been the reasons for the failure of China’s environmental policies (Mol, 2009). If

means of effective monitoring were available and the central government had ready

access to information, Chinese leaders would choose the decentralization of power,

without having to worry about abuse or corruption (Zhou, 2010). This means a strong

capacity on the part of the central government in supervision and control of

administrative agencies. Without such a monitoring system, the principal (central

government) could only examine or assess the effectiveness of environmental policies

based on the final outputs and outcomes.

The structural perspective tends to emphasize the importance of formal

institutions and formal authority and their effects on local environmental policy

implementation. However, field research on China’s environmental politics and local

implementation has gradually uncovered the black box of China’s governmental

activities. Local governments perform differently even if they are in the same province

facing similar formal institutions and structures (Tang, 2016). Although the central

22
government tries to improve the environment and put pressure on local governments

through the cadre or target responsibility system, local governments could still give

priority to those tasks that meet local interests first, be it economic or political interests.

Local governments tend to ignore tasks that lack clearly quantifiable targets. Therefore,

local environmental policy implementation is not dominated by either the central

government or local governments, nor is it just a simple division of administrative

power and economic power. It is an interactive or game process in central-local

relations. Hence, the following reviews the process perspective for illuminating the

nuanced interactions between the central government and local governments.

2. Process perspective

From a process perspective, local environmental policy implementation includes

individual officials and their communication, interaction and games in governments at

different levels. Such a perspective takes into consideration the divergence of interests

between the central government and local governments in principal-agent relationships,

incentive compatibility and problems of information asymmetry. The outcomes or

effectiveness of environmental policies, thus, depends on local governments’ choice

of tactics dictated by their interests, response to external incentives and the information

within their control.

E.Bardach’s Implementation Game (1977) analyzed public policy

implementation on the basis of benefit game. Besides, public choice theory has put

forward the premise that individuals in the political arena are as rational, in terms of

their interest preference, as those in the market. Instead of being regarded as motivated

23
only by the public interest, individual bureaucrats and politicians tend to maximize

their own interests in terms of power, prestige, security and income (Mueller, 1989).

According to Ding (2004), policy implementation is by nature a kind of game based

on actors’ interests because the action of policy-implementers is often driven by

interests, given that a policy itself is embedded with interest preference. Thus, the

divergence of interests and conflicts of interest between the central government and

local governments could lead to poor implementation or failed implementation.

The disparity in economic conditions might be one of the most important factors

that affects the interests of local officials. For example, local officials often have close

ties with business leaders and indeed could be partners of local factories over the years

since the reform took off (Ran, 2013). Controlling polluting factories partly owned by

local governments becomes problematic. Li and Higgins (2013) found that in better-

developed regions, local governments have had more resources at their disposal and a

greater capacity to protect the environment. Besides, in Li’s (2011) comparative case

study of the World Bank led pilot environmental information disclosure program in

Hohhot and Zhenjiang, Hohhot depended on a single dairy company for its tax revenue;

this particular company enjoyed overwhelming bargaining power and was able to

block environmental information from being published.

As pointed out above, Ran’s research (2013) showed that the political, financial

or moral incentives set by the central government for environmental policy

implementation at the local level are perversely structured, which resulted in non-

implementation or poor implementation. In China, political incentives are to a large

24
extent concerned with the promotion of local officials. Unlike their counterparts in the

economic related departments, such as the Development and Reform Commission, the

Foreign Investment Bureau, and the Construction Bureau, EPB officials have had less

opportunity for promotion (Kostka, 2013). The cadre management system, which is

crucial for the advancement of local officials proved to have a negative effect on the

enforcement of greening targets. For a long period of time, the Cadre Performance

Evaluation System (CPES) had regarded the full implementation of environmental

policies as a “soft target” with no veto power in regard to the promotion of local

officials (Heimer, 2006). Elevating environmental protection objectives to hard targets

with veto power would better encourage effective implementation.

Manipulation of statistical data or collusion among local governments remain

serious problems. Research has shown that data manipulation has become routine for

local cadres due to pressures from upper-level officials as well as their own interests

for promotion and economic gains (Cai, 2000; Chen, 2010). Looking into the

institutional logic behind the behavior of data manipulation or collusion of local

governments, Zhou’s research (2010) showed that when output level is less elastic to

an employee’s efforts, an increase in the intensity of incentives will induce the

employee to distort his or her performance to “meet” policy targets. This has partly

explained why cadre performance evaluation failed to produce the desired behavior or

even induced results that ran counter to the intended targets. The manipulation of data

remains unabated when there is a lack of effective mechanism to deter manipulation.

Local officials do not just pay attention to political incentives. They also calculate

25
their own costs and benefits (Ran, 2013). In her field research, Ran (2013) found that

the central government did not financially motivate local governments to implement

environmental policies due to its limited environmental budget. In contrast, non-

implementation or poor implementation of environmental policies conferred more

financial rewards for local officials who focused more on economic development.

Local governments also lacked moral incentives to implement environmental policies

when doing so did not bolster their self-esteem, generate admiration or even approval

from others within the current political system; hence, failing to do so did not generate

a sense of guilt in local officials.

Nevertheless, there were also some successful cases in the enforcement of

environmental policy implementation. For example, in 2010, Shanxi achieved an

energy intensity reduction goal of 25 per cent, which was higher than the national

target of 20 per cent. According to Kostka and Hobbs (2012), local officials’ interests

and incentives were instrumental in bringing about such a policy outcome. Energy

saving and emission reduction (ESER) policy was especially pressing for Shanxi

province, which had a high level of coal production and large proportion of energy-

intensive enterprises. Implementing the ESER policy was very difficult, given the

mono-industrial structure of the province and the adverse impact on employment

opportunity. With the strong intervention of the central government, local officials and

enterprise managers, realizing that their promotion or economic interests were at stake,

re-aligned their political and economic interests through interest bundling and policy

bundling. Thus, policies were re-framed according to local interests in order to bring

26
about successful implementation of pollution control.

Methanol automobile fuel development is another example of local government’

success in implementing environmental policies (Kostka & Hobbs, 2013).5 In the case

of methanol fuel-switching, local governments’ actions were not necessarily at odd

with the interests of the center, most of which involved methanol fuel business in

Shaanxi and Shanxi provinces’ locally-based coal production. They actively created

and managed local methanol programs at the provincial and municipal level in spite of

the national de-emphasis on methanol automobiles and the absence of subsidies from

the central government. On this basis, local governments with embedded interests

accounted for the proactive, managerial support of methanol business in many locales

by developing local methanol standards, creating subsidy programs, and establishing

formal and informal incentives for businesses to join pilot programs. The case of

methanol fuel demonstrated how local governments with strong, embedded interests

filled in the national-level policy vacuum on this issue.

Tang and Chen (2017) differentiate eight types of environmental policy

implementation under the framework of motivation-incentive-information. When the

motivation of local governments is low, it has an adverse effect on implementation

outcome. Unless the central government is able to provide incentives with appropriate

supervision as demonstrated in Kostka and Hobbs’ analysis (2012) of energy intensity

reduction in Shanxi province, the motivation of local governments to implement policy

will be low and manipulation of data is prevalent (Cai, 2000; Chen, 2010). As a result,

5
Note: methanol is one of the ramifications of coal and fertilizer production, which can be used as an alternative
energy for automobile.
27
collusion among local governments at different levels (Zhou, 2010), bargaining

between higher-level governments and lower-level governments (Zhou & Lian, 2011)

or campaign-style governance (Liu, 2004; Liu, 2017) to deal with environmental

policy implementation will come to the fore. In contrast, when the motivation of local

governments is high, they may adopt different measures in response to the central

government’s incentives despite the problems of information asymmetry. Local

governments may be proactive or innovative in environmental policy implementation.

In complying with the directives of the central government, local governments will

seek to maximize its interests whether implementation outcome as a whole is

satisfactory or not.

3. Civil Society, Environmental Governance in China and the Issues of Structure

and Agency

Structural and process perspectives attempt to understand and explain how the

Chinese Party state responded to environmental challenges through its governing

structures, regulatory setting, key agencies, policy making and implementation, and

law enforcement. Another important stream of China’s environmental politics has

moved away from the role of the state to the role of civil society, such as various

environmental activism, public awareness of environment protection, and public

participation in environmental policy implementation.

The Expanded Role of Chinese Civil Society in Environmental Protection.

The rapid development of non-governmental, voluntary citizens’ environmental

associations and groups has been one of the most important changes in China’s

28
political system over the past two decades. Wang and He (2004) even referred to it as

“China’s associational revolution” because of the impressive momentum of social

activism and self-mobilization, which included various forms of collective action by

citizens, ranging from spontaneous protests by pollution victims to organized public

campaigns against specific government or business construction projects (Wu, 2009).

These studies described the origin, characteristics, development of ENGOs (Brettell,

2000; Schwartz, 2004; Yang, 2005; Zhan & Tang, 2013; Dai et al., 2017). ENGOs and

their actions have been used by scholars to study state-society relations in China (Lu,

2007; Saich, 2000; Sun & Zhao, 2008; Ma, 2005; Zhang & Barr, 2013; Turiel et al.,

2017).

Increasing public awareness of environmental protection is also an important

aspect. Relevant national research institutions, private consulting teams, local NGOs

and academics have conducted surveys of public environmental awareness at the

national and local levels (Tong, 2007; Wong, 2003; Wong & Chan, 1996; Lee, 2005;

Yang, 2002). According to Lee (2005), at least 28 surveys of public environmental

awareness and attitude were conducted in China from 1990 to 2002, among these four

were nationwide surveys. Besides, public complaint system, as a formal institutional

channel for public participation, has also attracted scholarly attention (Warwick &

Ortolano, 2007; Van Rooij, 2006b; Tilt, 2007; Brettell, 2001; Mol, 2009; Kostka, 2022).

With the institutional reforms of environmental protection authorities, new

participatory mechanisms such as public hearing in Environmental Impact Assessment

Law, regulations related to public dissemination of environmental information,

29
environmental litigation stipulated in the 2014 Environmental Protection Law have

opened new space for citizen to participate in the environmental issues (Zhu & Ru,

2008; Li, 2004; Zhu et al., 2022). Therefore, the role of civil society has expanded in

China’s environmental policy implementation.

Environmental Governance in the Chinese Context and the Issues of

Structure and Agency. How does the expanded role of civil society discussed above

fit into the current literature on environmental governance when it is applied to the

Chinese context?

According to Chhotray and Stroker (2009), “[G]overnance is concerned with the

practice of making collective decisions” (p.214). As such, the formulation and

implementation of a policy may involve actors from the state and other actors from

communities, businesses, and NGOs (Lemos & Agrawal, 2006). Thus, environmental

governance is synonymous with collective interventions aimed at changing incentives,

knowledge, institutions, decision making, and behavior related to environment

protection (Lemos & Agrawal, 2006). Davidson and Frickel (2004) defined

environmental governance broadly as “attempts by governing bodies or combinations

thereof to alleviate recognized environmental dilemmas” (p.471). Six predominant

conceptual perspectives were used to analyze the state-society relations in

environmental governance in the past years. These are pluralism, agency capture,

ecological Marxism, social constructionism, ecological modernization, and global

environmentalism.

The pluralist perspective has often been applied to the study of environmental

30
governance system (O'Neill et al., 2013). Most of them have been devoted to

evaluating formulations and outcomes of particular environmental policies, guided by

the prerequisite that public policy is an outcome of competing interests and limited

resources, and that the appropriate role of government institutions is to provide a fair

framework within which these actors in social decision-making processes play out

(Young, 1981; O'Neill et al., 2013). In other words, these studies attempt to solve the

problem that how government institutions aggregate the multiple competing interests

in the environmental field to produce effective policy.

Application of agency capture theory in environmental governance is a particular

strand of research that focuses on environmental and natural resource bureaucracies.

Scholars define capture in a variety of ways. According to Stigler (1971), this is the

ability of the regulated industry to secure rents by using regulations to create entry

barriers to a market; “the control of agency policy decision-making by a sub-

population of individuals or organizations outside of the agency” (Yackee, 2014, p.

296); or “…responsiveness to the desires of the industry or groups being regulated”

(Barkow, 2010, p. 21). Despite a lack of agreement, Rex (2020) believed two common

themes run through these definitions: “the key actors are regulators and regulated

industries, and regulators who fail to uphold the public interest do so after successful

pressure from business interests” (p.2). Researchers criticized that agency agendas

became driven by industry constituents, leading to counterproductive policy results in

natural resource management (Davidson & Frickel, 2004).

Since the 1980s, Neo-Marxist theorists have argued that capitalist states brought

31
about environmental degradation (Bunker, 1985; Schnaiberg & Gould, 1994). They

explored the role of the state in environmental protection in a more comprehensive or

macro-theoretical manner. Whereas, ecological modernization has sought to explain

the means by which the environmental problematic has informed institutional

transformations in industrialized countries (Frijns et al., 2000). The accumulation and

internalization of environmental costs will become a significant theme in the reform

of existing political-economic structures due to advances in environmental sciences

and technologies (Buttel, 1998; Spaargaren & Mol, 1992; Mol, 1996). And for social

constructionists, they are concerned with “how people assign meaning to their world”

(Hannigan, 1995, p.33). Environmental social constructionists have turned their

attention to the processes of environmental claim-making, that is, how social and

political understandings of environmental problems are crafted, contested, and

legitimated (Buttel & Taylor, 1992; Hannigan, 1995). Finally, scholars supporting

global environmentalism have focused on the potential for global environmental

problems, and particularly the internationalization of environmental politics, to

encourage environmental state building at the nation-state level.

Most of these studies in environmental governance based on the above six

theories have been conducted in Western industrialized countries, which are different

from China in terms of political system, culture, and socio-economic development.

These theories may provide partial explanation in regard to certain aspects of

environmental policy making or implementation in China. For examples, the

phenomena of agency capture frequently occurred in China before 2012, China’s

32
environmental degradation due to capitalist investments, and the Chinese state’s

hegemonic control over environmental discourse as environmental social construction.

As a typical case of environmental authoritarianism, the Chinese Party state plays a

strong interventionist role in environmental protection. The registration and operation

of ENGOs are largely under the supervision and control of the government; many of

them are even semi-official organizations (Yang, 2005). In the edited volume China’s

Embedded Activism, Ho and Edmonds (2007) have had reservations about the

fundamental transformation in Chinese politics credited to the efforts of Chinese

NGOs. For them, environmental activism has “resourcefully adapted to, rather than

opposed to, the political conditions of its era” (Ho & Edmonds, 2007, p.331).

Civil society in China may play an important role in environmental pollution

control, but essentially it is a political game between the central government and local

governments. For example, the central government tries to get more local

environmental information from the public through the central inspection system, but

local governments can get such information ahead of the central government by setting

up social river chiefs and rewarding the public for reporting. As Lemos and Agrawal

(2006) proposed, “less powerful organizations and individuals may come to exercise

greater voice, there is also room for cynicism that decentralization policies have

typically been motivated by powerful state actors to enhance their own political

positions” (p.305).

Finally, environmental governance not only involves a plurality of participants,

but also advocates greater use of market- and voluntary-based instruments, rather than

33
relying solely on hierarchically organized, regulatory control ways by government

(Lemos & Agrawal, 2006). Ironically, market failures often occur in public goods such

as environment due to externalities and free rider problem. In China, emissions trading

markets, environmental taxes and subsidies are not well developed. The government

lacks the necessary institutions and sound infrastructure to support these market-based

instruments.

Studies in environmental governance and its application to the Chinese context

might tilt the focus towards agency, i.e. how the capacity of the individuals permit

them to have the power and resources to fulfill their potential. Such a capacity, however,

cannot be easily detached from issues related to structure, for examples institutions

and organizational structures that constrain as well as empower state and non-state

actors. Most importantly, recent advances in governance studies have highlighted the

importance of institutions and organizational structures in policy implementation,

which is the formative stage in the policy process itself (Sager & Gofen, 2022). Sager

and Gofen (2022) have pointed out the gap in the implementation literature when

implementation arrangements as structures influencing, and influenced by, power have

been overlooked. They called for future research into studying how mutual influence

of structures and power can be better accounted for in polity of implementation:

vertical and horizontal cooperation in multilevel settings, public–private arrangements,

and organizational identities. Therefore, the present research seeks to strike a balance

between a structural perspective and a process perspective by means of a theoretical

framework that takes into account the role of structure and agency in local

34
environmental policy implementation. While the complementary role of Chinese civil

society in environmental protection is acknowledged, its importance cannot replace

the mutual influence of structures and power that permeated agency in Chinese

authoritarian system or Chinese authoritarian environmentalism in different degrees

across time and space.

1.3 Research Questions, Hypotheses and Theoretical Implications

1.3.1 Research Questions

Guangzhou was a city with serious water pollution before the promulgation of

APWPPC in 2015. 21.4 per cent of Guangzhou’s rivers and lakes were severely

polluted. 48 of 53 creeks were below Class V water quality and 35 of them were

supervised by the State Council (Guangzhou Ecology and Environment Bureau

[GZEEB], 2015). After the 11th FYP (2006-2010), the central government has been

emphasizing the importance of tackling water pollution. Since then, action plans and

control measures have been issued to reverse the serious water pollution problems in

the past decade. Yet, Guangzhou stood out among other cities when it eliminated 35

black and odorous water bodies in 2018. By 2019, all 147 black and odorous water

bodies in the national regulatory platform were also eliminated.

The current research on water pollution prevention and control (WPPC) in

Guangzhou raises the following questions:

(1) What were the reasons for Guangzhou’s past failures in WPPC?

(2) What are the factors or conditions instrumental for Guangzhou’s relative

success in WPPC after 2015?

35
 (3) If implementation made a difference, what are the factors and conditions

instrumental for implementation deficits or implementation success?

(4) Which aspects of Guangzhou’s WPPC still fall short of achieving the

expected policy objectives of eliminating water pollution in the city?

1.3.2 Hypotheses and Theoretical Implications

Matland’s (1995) ambiguity-conflict model of implementation is a synthesis of

top-down approach and bottom-up approaches in implementation studies. Ambiguity

and conflict are indicators of the characteristics or features of a policy itself in terms

of the level of policy ambiguity and the level of conflict during implementation with a

matrix of four distinctive types or modes of policy implementation (see chapter two

for details). In administrative implementation, such a mode of implementation exhibits

a low level in policy ambiguity and conflict; whereas in political implementation, a

low level of policy ambiguity and a high level of conflict. Symbolic implementation

implies an implementation mode with a high level in policy ambiguity and conflict; in

experimental implementation, a low level of ambiguity and a low level of conflict. The

conventional view of China’s environmental policy implementation has been, in

general, symbolic. Although this might help policy makers in the central government

in obtaining the legitimate support of the public and the international community,

deviation from policy objectives during implementation at the local level is quite

common (Ran, 2015; Zhang et.al, 2007).

The unevenness in development across the country and the implementation of

WPPC policy across different regions implies that smooth top-down implementation

36
or administrative implementation according to the intent of the central government is

unlikely to be the case. Since Mao’s era, the Chinese state has implemented various

reforms by means of experimentation in designated demonstration sites. Hence, the

present research hypothesizes, firstly, that in the case of WPPC policy implementation,

it has straddled along a continuum with four different types or modes of

implementation. The divergence of interests and conflicts of interest between the

central government and local governments tend to be the case in symbolic

implementation and political implementation, whereby the level of conflict is high.

Secondly, the policy features or characteristics of WPPC policies have been

transforming from a high level of policy ambiguity and conflict (symbolic

implementation) to either a high level of ambiguity and a low level of conflict

(experimental implementation) or a low level of ambiguity and a high level of conflict

(political implementation) when the central government strengthened its intent and

support for local environmental protection.

It is essential for us to take into account the interests of local officials and relevant

departments in WPPC policy implementation as well as how local governments

respond to the incentives from upper-level governments (i.e. the center and the

province). Thus, the dynamics of principal-agent relationships between the center and

local in relation to the center’s device or manipulation of interests and incentives, and

the control of information are the focus of the current study (see chapter six). The

present study starts from a structural perspective (see chapter three) when the

formulation and legitimation of environmental laws and policies are carried out by the

37
center (chapter three). The formal transposition of environmental laws and policies

takes place in the local context and the practical application of policies, likewise, have

to tackle environmental problems according to local interests and needs.

The dynamics of central-local relations in WPPC policy implementation from a

principal-agent perspective is gradually uncovered through a process perspective as

well (see chapter four to six). In the process, the analysis seeks to explain how interests

between different parties at different levels of government diverge or converge, which

are to a large extent dependence on the capacity of the central government in

overcoming the problems of information asymmetry, i.e. securing valid and reliable

environmental data for making relevant laws and effective monitoring of local

governments and officials in WPPC policy implementation. Coercive measures by

means of authority tools and organization tools, though necessary, are by no means

sufficient to elicit compliance. The provision of incentives—political, economic and

moral—will be necessary for eliciting compliance from local governments (see

chapter four, five and six).

Therefore, the second hypothesis is: when interests of local officials override the

incentives to tackle water pollution problems, the divergent interests of local

governments inevitably lead to WPPC implementation deficits or failure. As a result,

the root causes of water pollution remain unresolved. In order to overcome the

divergence of interests between the central government and local governments in

environmental protection, the central government has to possess the capacity to acquire

valid and reliable environmental information as well as hold leading cadres in local

38
governments accountable for implementation through a working mechanism and

effective environmental monitoring system.

1.4 Contribution of the Thesis

This research has attempted to contribute to the study of local environmental

policy implementation in China through the theoretical construct of this study, major

findings and argument.

1.4.1 Theoretical Construct

This study has adopted Richard Matland’s ambiguity-conflict model for studying

implementation at the local level because it synthesized top-down and bottom-up

approaches in implementation. The model offers a matrix of four different modes of

implementation—administrative, political, experimental, symbolic— in terms of two

dimensions according to the levels of policy ambiguity and conflict, i.e. high or low.

Administrative implementation is high challenging, even if it is not impossible (see

chapter two). Given China’s authoritarian environmentalism, Matland’s model

provides a framework that offers rooms for tracking the interplay and interdependency

between political power at the center and the local level. Historically, the dynamics

and strength of local power in response to power from the center tended to transform

policy characteristics intended by the center as policies were being distilled in the local

context. As the Chinese saying goes, “there are policies from the top and so are

strategies from below” (shang you zhengce, xia you duice)”. One possibility is the

selective implementation of policies by local cadres and governments as pointed out

by O’Brien and Li; the other, local governments collude to defy central directives when

39
they perceive their interests are at stake.

The process of WPPC policy implementation is highly complex, involving many

actors from the public and private sectors as well as society. To investigate the behavior

of actors in this complex and interactive process within an institutional setting made

up of an authoritarian political system and intricate organizational structures, the

principal-agent theory coupled with the choice of policy tools provide an analytical

framework that bridges the gaps between structure and agency in environmental policy

implementation. Implementation gap is an inevitable result of the structure of politico-

administrative institutions in modern states. The principal-agent perspective, on the

one hand, reflects the role of agency within a particular institutional setting and

political structure, on the other hand, reflects on how structural influence and power

are played out in the politics of implementation and the process of tackling

implementation gaps. Despite the authoritarian role of the central government, local

governments still enjoy discretion in local affairs. Hence, the principal-agent

relationship implicit in Matland’s model is given a prominent position to illuminate

the working of interests, incentives and information between higher-level governments

(i.e. at the center and province) and lower-level governments (below the province) as

well as among lower-level governments (i.e. country, township and village levels).

Thus, reasons for the divergence of interests between the central government and local

governments and whether the divergent interests of local governments could be

overcome are the focal points in this research on the implementation of WPPC policies

before and after 2012 in Guangzhou.

40
 Inasmuch as the overcoming of divergent interests of local governments depends

on interests, incentives and information, policy tools at the disposal of local

governments are pertinent not just for local governments but for the central

government as well. Hence, the interdependency between the central and the local has

to be strong enough to bring about satisfactory or successful implementation. In the

case of the central government, it has to have an accurate picture of the performance

of local governments in implementing WPPC policies. Otherwise, it may not perceive

the limits of coercion and the need to enforce policy implementation through

persuasion or incentives that are attractive for local governments. From the perspective

of local governments, it is important that such incentives are congruent with local

interests. In other words, local governments have to perceive environmental protection

not as contradicting economic development, but supporting and even essential for

economic development. This is the case with Guangzhou, a designated pilot city for

building water ecological civilization. Thus, it has not only taken WPPC

implementation seriously, but has endeavored to develop a sustainable model for

economic development. It is along this line of thinking that Figure 7 in chapter two

has presented the flow linking the interactions between structure and process as well

as factors and conditions that bring about satisfactory or unsatisfactory implementation

outcomes of WPPC policies before and after 2012 in Guangzhou.

1.4.2 Major Findings

Until the 17th Party Congress in 2007, environmental policy implementation in

China was to a greater extent symbolic, i.e. a high level in policy ambiguity and

41
conflict. As mentioned above, not all cases of environmental policy implementation

failed. There were some successful cases although these cases also revealed the passive

stance then taken by the central government vis-à-vis local governments in tackling

environmental problems, in particular, before 2012; the Tiahu lake incident is a good

example.

When environmental policies are highly ambiguous, the means and goals tend to

be unclear or incompatible. Local governments’ divergent interests tend to protect

local interests and give priority to developing the economy, instead of environmental

protection. Conflict intensifies when the policy tools being used by local governments

are largely authority tools, i.e. command-and-control instruments, such as heavy fines

and forceful closing down of industries and businesses. From a principal-agent

perspective, this strains the relationships between the central government and local

governments. To overcome the divergent interests of local governments and ensure

compliance, the central government has to offer attractive incentives, improve its

capacity in information gathering, engage in persuasion and make effective use of

information and technology in monitoring the performance of local governments, and

enforcing implementation according to central directives (see chapter six).

From a structural perspective, the central government began putting a stronger

emphasis on environmental protection after 2006 (see chapter three). After the 17th

Party Congress and the release of the 12th FYP (2006-2010), a political implementation

mode had gradually emerged due to the change in the CCP’s attitude and awareness

about the importance and the need to protect the environment for sustainable

42
development. Thus, environmental policy implementation became more complex and

engendered different possibilities or modes of implementation.

The findings in this study show that in the implementation of WPPC policies in

different time periods, i.e. before 2012 and after 2012, even in a particular region, the

mode of implementation may not necessary be a single mode and may embrace more

than one mode in the process (see Table 4 below). This is instructive for understanding

the complex process of environmental policy implementation, which involves

interactions and coordination between and among multiple actors and organizations

from the public and private sectors as well as society.

The 2008 WPPC in Guangzhou failed in spite of considerable investment and

resources pending the 2010 Asian Games (see chapter four). The formal transposition

of policy in terms of timeliness, completeness and integration was inadequate and the

practical application limited as well due to the constrained time-frame set for achieving

the WPPC objectives by the central government. Implementation straddled along two

different modes, from a political to an experimental mode. During this period, the

divergence of interests between the central government and local governments led to

a high level of conflict when implementing WPPC policies across the country.

Although policy ambiguity appeared on the surface to be low initially because of the

dependence on a single indicator (i.e. COD quota) for measuring water quality, it

became highly ambiguous as implementation proceeded.

43
Table 4

A Schematic Overview of the Factors for Analyzing the Shift in Guangzhou’s WPPC

Implementation Modes

Guangzhou 2008-2010 WPPC 2016-2020 WPPC

Implementation
Experimental Political Administrative
Mode
Ambiguity High Low Low
Conflict Low High Low
Duration Short-term Long-term
Formal Transposition Low Moderate High
Practical Application Low Moderate High
Policy tools Applied
(a) Organization tools Yes Yes
(b) Authority tools Yes Yes
(c) Treasure tools Yes Yes
(d) Nodality tools No Yes
Principal-agent
relationship
(a) Interests Divergence Converging Convergence
(b) Incentives
Political incentives Perversed structure Less perversed Attractive
Economic incentives Insufficent More input Sufficient
Moral incentives Weak Moderate Moderate
(c) Information Asymmetrical Less asymmetrical Less asymmetrical
Note. Compiled by the author.

Implementation deficits occurred when nodality tools or nodality-based policy

instruments, such as information and public participation, were missing in spite of the

application of authority tools, organization tools and treasure tools. The lack of

nodality tools undermined the capacity of the central government to acquire pertinent

information on the environment or have an accurate picture of the performance of local

governments in WPPC. The 2008 WPPC, therefore, also points to the central

government’s weak capacity in policy enforcement in terms of information, personnel

44
and resources. Information asymmetry and the lack of technological innovation

coupled with the deficiencies in policy instruments led to implementation deficits.

In terms of incentives, political incentives were perversely structured when local

officials were not being held accountable for implementation outcomes. As for

economic incentives, the Guangzhou government invested RMB48.615 billion.

Moreover, Guangzhou was privileged to host the 2010 Asian Games. This could have,

to a certain extent, mitigated the divergent interests of local governments, even though

the moral incentives to carry out WPPC was weak when cadre assessment was not

strongly linked to performance in water governance. Nevertheless, government

departments at different levels worked in unison to complete WPPC tasks when

environmental protection was perceived to be congruent with economic development;

WPPC was pursued for the sake of local interests. Hence, conflict, instead of being

high as in political implementation, turned out to be low. The implementation of WPPC

policy was forced on Guangzhou in a highly constrained form to meet the deadline of

the 2010 Asian Games. As a result, a political implementation mode slid into an

experimental mode. As an experimental implementation in itself (a high level of

ambiguity and a low level of conflict), it offered precious lessons to be learned on what

was missing in the process.

In the 2016 WPPC in Guangzhou, the unprecedented achievements in

implementation outcomes offered hopeful signs of political implementation

potentially shifting towards administrative implementation. In the latter, the levels of

policy ambiguity and conflict are both low. This implies that the central government’s

45
capacity in ensuring compliance through the deployment of resources, personnel and

information to achieve WPPC objectives at the local level has become stronger. This

is partly due to Guangzhou’s intention to develop an economically sustainable

development model, one that takes environmental protection seriously, in this case

WPPC, when it was designated a pilot city for water ecological civilization in 2013.

As divergent interests were overcome, the principal-agent relationships between the

central government and local governments are moving towards convergence of

interests.

The 2015 Action Plan for Water Pollution Prevention and Control (APWPPC)

issued by the central government has guided the Guangzhou government with clearer

objectives. Through formal transposition, the latter came up with the Guangzhou

Action Plan for Water Pollution Prevention and Control (GZAPWPPC). While

nodality tools were absent in the 2008 WPPC, they became crucial in the 2016 WPPC

in expanding the positive impacts due to the application of authority tools, organization

tools and treasure tools.

The Central Inspection (Group) on Ecological and Environmental Protection

(CIEEP) or CIGEEP functions as both an instrument of authority tools and nodality

tools. The CIEEP imposes pressure on provincial governments to achieve WPPC goals

by engaging the public in reporting environmental problems that failed to be addressed

by local governments. These reports provided valid and reliable information essential

to building an efficient and effective monitoring system. The River Chief System (RCS)

has also complemented the work of CIEEP. Similar to the CIEEP, the RCS is an

46
outcome of applying organization tools and also functions as an instrument of authority

tools and nodality tools. But RCS reaches out to lower-level governments and the

public below the provincial level. Both systems hold local leaders accountable for

WPPC and webbed into a working mechanism that emphasizes social inclusion and

provides alternative channels for interaction, communication and coordination. Such

a mechanism alleviates conflicts as well. In the process, a more complete

implementation and monitoring system for achieving WPPC has emerged

incrementally. Advanced communication technology has been used to enhance the

functions of nodality tools, i.e. public participation and information disclosure.

The application of nodality tools through the CIGEEP and the RCS has come up

with a working mechanism that permeated hierarchy and networks in order to build

and sustain an efficient and effective monitoring system. It has strengthened the

capacity of the central government in securing valid and reliable environmental

information, overcome problems of information asymmetry, allowed the central

government not only to assess but to persuade and encourage local leading cadres and

governments to perform well in WPPC. Political incentives have become less

perversely structured when local leading officials are now held accountable for

implementation outcomes. Economic incentives have improved even though local

governments still bear substantial burden in financing projects for environmental

protection. And moral incentives have been strengthened with persuasion from the

center in terms of Chinese leaders’ speeches on environmental protection and trainings

in party schools and colleges that help to raise the knowledge and expertise of leading

47
cadres in environmental protection (see chapter five and chapter six).

Unlike the 2008 WPPC, the 2016 WPPC has produced a long-term impact on

water quality when the focus is on tackling the root causes of water pollution. It has

been greatly supported by investment and the building of infrastructures, such as

sewage treatment facilities, pipe networks etc., through the provision of goods and

services by public enterprises, which was inadequate in the 2008 WPPC. But the harsh

application of authority-based instruments exerted a high price on local economy in

urban towns and villages when industries that failed to meet environmental standards

were forcefully closed down; this simultaneously obliterated the dependency of local

communities on those industries for their source of income and livelihood. It remains

quite a challenge to balance the goals of economic development and environmental

protection, to close up the divergence of interests between the central government and

local governments (i.e. the Guangzhou government and lower-level governments) and

among lower-level governments as well, given the need to balance the interests of local

governments with the interests of industries and enterprises.

1.4.3 Argument

Guangzhou’s case has shown that economic and organizational capacities of

government are essential and even necessary for implementing WPPC, but they are

not sufficient to bring about satisfactory or successful implementation. The 2008

WPPC implementation outcomes were unsatisfactory despite Guangzhou’s impressive

economic and organizational capacities through command-and-control instruments

and reorganization. Although local governments were offered some economic

48
incentives and political incentives, the central government’s capacity for policy

enforcement was weak without an effective monitoring system. Without nodality tools

such as the skillful handling of information and public participation, the application of

policy tools was incomplete. Hence, the 2016 WPPC implementation outcomes shed

light on the importance of nodality tools, such as the importance of information and

public participation, and reflected the limitations of authority tools, organization tools

and treasure tools for ensuring satisfactory implementation outcomes. This points to

the importance of balancing coercive and non-coercive incentives on the part of the

central government on the one hand, and on the other, sensitivity toward the perception

of local governments about the congruency between environmental protection and

economic development in serving local interests inasmuch as it serves the interests of

the central government. Otherwise, divergent interests of local governments may

undermine the central intent and efforts at implementing WPPC.

1.5 Methodology and Limitations

The research design adopts a case-study approach by means of a qualitative

method to study and compare two WPPC implementations in Guangzhou city. Case

study makes possible the thick description of local institutions, institutional change

and behavioral change of local actors by combining static description with dynamic

process tracking (Yin, 2014). Thus, the selection of a case is critical in this study. Given

the shortcomings of past research and the subject of this study, this case should meet

at least two criteria. One is that in a region itself, there could be multiple experiences

when implementing a particular environmental policy and that the effects of

49
implementation may vary over time as well. The other one is the central government’s

perception of an environmental policy and those measures adopted may evolve and

change with time. The case of the Guangzhou government’s two experiences in WPPC

is meaningful, given these two criteria. The Guangzhou government implemented

WPPC policies in 2008 and 2016 and the effectiveness of implementation varied

significantly. At the same time, the central government’s attitude towards WPPC and

related policies have been evolving and changing over the past decade. Such a case

provides a dynamic perspective to explore factors or conditions influencing

implementation outcomes over time.

Field research was used to gather detailed information on the two WPPC

implementations in Guangzhou (see Table 5 below on interviews). This includes going

through information on the attitudes of Guangzhou government officials towards

WPPC, possible conflicts of interest, and the involvement of social organizations and

the public. The author had conducted fieldwork in Guangzhou. From January to March

2018, the author participated in the Social River Chief (minjian hezhang) project of

Guangzhou New Life Environmental Protection Association. From July to August

2018, the author participated in the summer activities of Liuxi River Ecological

Protection Center. Through environmental protection organizations, the author came

into contact with people living near the creeks, relevant government officials, social

river chiefs and other stakeholders or participants of river patrolling. During field

research, the author was also a participant-observer involved in the daily river patrols

with members of environmental protection organizations, participation in the hearings

50
and symposiums organized by the Water Authority in each district of Guangzhou,

public forums of residents along the river, and training sessions for social river chiefs.

Documentary research was also used to collect relevant academic work, official

documents and data, which included a review on academic research work related to

the implementation studies of local governments, studies on China’s environmental

politics and policy, and related material in the internet and magazines as well as the

official or ENGOs’ documents classified as “internal document (neibu ziliao)”.

Table 5

Interviews
Time Interviewee Position Interview Content
Official in Guangzhou The process of water
August 16,
G1 Water Authority pollution control in 2008
2018
(GZWA) and 2016
Staff in Guangzhou
March 22,
G2 Environmental Key issues in 2008 WPPC
2019
Monitoring Center
August 21, Official in the The establishment of
2018; Government Guangzhou River Guangzhou River Chief
G3
October Officials Chief System Office System (RCS), difficulties
12, 2020 (GZRCSO) and countermeasures
November Successful Experience of
G4 Official in GZWA
26, 2020 2016 WPPC in Guangzhou
Grid staff of Yaotian
August 26, Village in Xintang
G5 A grid staff’s daily work
2019 Town, Zengcheng
District, Guangzhou
Basic conditions of Bai
August 5- Villager of Bai Shan Shan Village;
V1
8, 2018 Village, Guangzhou Sources of income for
villagers
Baishan
Background of Baishan
Village
The assistant of the Village;
August, 10 V2 Head of Baishan Implementation of the
village RCS in the village

51
 Implementation of the
August 26, The assistant of the RCS in the village;
V3
2018 Baishan Village Clerk Tourism development in
Baishan Village
Background of Bai Shan
August 20, Village official of village;
V4
2018 Baishan village Implementation of the
RCS in the village
Background of Liuxi River
Ecological Protection
Staff of the Liuxi Center;
August 10-
E1 River Ecological Its function for WPPC in
15, 2018
Protection Center Baishan village;
Its interaction with Bai
Shan village committee.
ENGOs
Director of the Liuxi Baishan village’s change
July 15,
E2 River Ecological in WPPC and economic
2019
Protection Center structure
January 3; RCS and SRC
March 10; implementation;
E3 Staff of the New Life
August 20, New Life’ interaction with
2018 community and GZRCSO
SRCs’ responsibility;
August 5, Social River
S1 SRCs in Guangzhou Their interactions with
2018 Chiefs
governments
The difference between the
Guangzhou government’s
July 20, Journalist in Southern
Journalist J1 two water pollution
2019 Metropolitan News
treatments in 2008 and
2016
Staff in Party School
May 16, Curriculum for Guangzhou
C1 of the Guangzhou
2020 Cadre party cadre training
Committee of CCP
Training
Curriculum for non-party
June 2, Institutions Staff in Guangzhou
C2 cadre training in
2020 Institute of Socialism
Guangzhou
Note. Compiled by the author.

My research is limiting in two aspects. Firstly, there is a lack of suitable cases for

horizontal comparison. This study has compared longitudinally the differences in the

implementation of WPPC policies in Guangzhou during two different periods before

52
and after 2012. The main factors influencing implementation outcomes come from

both the central government’s decisions and the interests of local governments. In

addition, the open public opinion environment and developed social organizations in

Guangzhou as well as the lessons drawn from failed implementation of WPPC policies

in the past, especially the 2008 WPPC, have helped to a certain extent in bringing about

better implementation outcomes in the 2016 WPPC. Without some horizontal

comparison, it is difficult to conclude in this study those factors that might be more

influential or essential as cases in other regions or cities may not be compatible or

suitable for comparison in view of the idiosyncrasies of local conditions, socially,

environmentally, and economically in different provinces. Secondly, another limitation

is that this study has not dwelt much into the role of enterprises and the market in

WPPC. The concluding chapter has highlighted this for further research into WPPC

policy implementation in Guangzhou or elsewhere.

1.6 Chapter Layout

This chapter has provided an overview of the present study. Chapter two outlines

and explains the theoretical framework for analysis in this thesis, which takes into

account implementation approaches, actors, policy tools and instruments, principal-

agent relationships and the four implementation modes in Matland’s (1995) ambiguity-

conflict model.

Chapter three introduces the policy formulation and legitimation of

environmental protection and WPPC policies from a structural perspective to show the

change in the attitude of the central government towards tackling environmental

53
problems vis-à-vis water pollution and the shift towards a political implementation

mode using the implementation of WPPC in Liaohe river as a case in point.

To understand WPPC policy implementation at the local level, chapter four and

chapter five analyze the implementation processes and evaluate the implementation

outcomes in Guangzhou before and after 2012. Chapter four focuses on the

implementation of WPPC policy in Guangzhou from 2008 to 2010; chapter five, the

implementation of WPPC policy from 2016 to 2020.

Chapter six explains the reasons behind satisfactory or unsatisfactory

implementation outcomes in the two WPPCs carried out in Guangzhou from a

principal-agent perspective and an interests-incentives-information (3I) framework. It

elucidates the interplay and interdependency of the central government and local

governments in implementing WPPC policies over time and the changes in

implementation outcomes in relation to the changes in the behavior of local

governments in terms of interests, incentives and information.

Last but not least, chapter seven provides a brief summary of the present study

and the implications for further research.

54
 Chapter 2 Studying Implementation: Synthesis, Instruments and

Principal-Agent Relationship

Although a structural perspective serves as the background to the formulation of

China’s environmental policy at the center (see Chapter three), this research is an

attempt to study the implementation of environmental policies by Chinese local

governments from a process perspective. Nevertheless, the present study takes into

account the interactions between the central government and local governments in

environmental policy implementation before investigating the behavior of local actors

through factors such as policy tools and instruments, interests, incentives and

information that affect their motivation and inclinations towards environmental policy

implementation. This chapter lays out the theoretical framework for this study. Firstly,

it reviews different approaches or models in implementation studies and some attempts

at synthesis. Secondly, it introduces and explains the rationale for using Matland’s

(1995) model on ambiguity-conflict in this study. Thirdly, to enrich the application of

Matland’s model (1995), a discussion on the choice of policy tools or instruments vis-

à-vis environmental policy tools and the principal-agent theory elaborates how they

set the stage for theoretical application in the empirical studies on WPPC policy

implementation in Guangzhou in chapter four, five and six of this thesis.

2.1 Policy Implementation

Policy implementation is one of the stages in the policy-making process. It

connects the policy makers with the beneficiaries, who are mediated by the policy

deliverers. Implementation is concerned with transforming policy outputs into policy

55
outcomes (Knill & Tosum, 2012). This definition is straightforward at first glance, but

empirical analysis shows that it is a complicated process encompassing various actions

by public and private actors (Van Meter & Van Horn, 1975). It is anything but a

straightforward task to achieve the desired policy goals and outcomes in practice. Most

importantly, the specific interests of actors are likely to influence and affect policy

outcomes.

2.1.1 Models of Policy Implementation

1.Top-down Models of Policy Implementation and Criticism

The diversity of activities is reflected in the theoretical perspectives used to

describe and explain policy implementation. According to Knill and Tosun (2012),

“[T]he traditional approach is characterized by a top-down perspective, which

concentrates on policy outputs and investigates the extent to which the intended

objectives have been achieved over time and why” (p.152). In Pressman and

Wildavsky’s classic study (1973), they pointed out that deviation from policy goals

may occur during the implementation phase. Their study was based on a top-down

approach in implementation (Van Meter & Van Horn, 1975; Sabatier & Mazmanian,

1980). Such an approach clearly distinguished the stages of policy formulation and

implementation (Hill, 2009). It compared policy targets and the extent of

implementation. The extent in which targets are achieved served as one of the

important indicators for successful implementation. Effective implementation

corresponds to a good match between policy objectives and outcomes.

Sabatier and Mazmanian (1980) have illustrated the logic of the top-down

56
approach by means of a four-step model. First, it involves the extent to which the

actions of implementing officials and target groups are consistent with the objectives

and procedures outlined in a policy. Second, this concerns the extent in which the

objectives could be attained over time. Thirdly, it involves the evaluation of main

elements affecting policy outcomes. Finally, it analyses whether and how to

reformulate policies according to experience. Although the top-down approach has

produced some interesting insights into the implementation process, it has also been

met with three criticisms (Matland, 1995).

Firstly, the top-down approach or perspective takes statutory language or policy

output as the starting point. As Matland (1995) asserted, it “fails to consider the

significance of actions taken earlier in the policy-making process” (p.147). Secondly,

top-downers tend to see implementation as a purely administrative process and ignore

the political aspect. However, bureaucratic actors may not be “Weberian” in nature and

might pursue their own interests in accordance with the argument put forward by

Niskanen (1971) and other theorists of public choice (Mueller, 2003). Finally, top-

down models have been criticized for their exclusion of local actors and the particular

conditions of implementation at the “street level” (Matland, 1995).

2.Bottom-up Models of Policy Implementation and Criticism

Subsequent policy implementation research takes a “bottom-up” approach, which

analyses the multitude of actors who interact at the operational level of a particular

policy. The bottom-up models considered effective implementation in a process-

oriented manner and abandoned the division between policy formulation and

57
implementation (Berman, 1978; Lipsky, 1980; Hjern & Porter, 1981; Hjern, 1982). For

Knill and Tosun (2012), “policy objectives and instruments are no longer defined as

benchmarks to be reached; instead, it is expected that they may undergo modifications

during the process of implementation” (p.155). Implementers have discretion to adjust

policy according to particular or local requirements and changes in the perception of

policy problems. Hence, “effective implementation is not measured by the attainment

of a certain centrally defined objective, but judged by the extent to which the perceived

outcomes correspond with the preferences of the actors involved” (Knill & Tosun,

2012, p.155). The key question in evaluating the success of implementation is the

extent to which a given policy allows for a process of learning, capacity building and

support building to address issues associated with it in a decentralized manner,

consistent with the interests of the actors involved (Wilson, 1989; Schneider & Ingram,

1997).

The most extensive empirical work within the bottom-up tradition has been that

of Benny Hjern (1982) and his colleagues (Hjern & Hull, 1985; Hull & Hjern, 1987).

Hjern’s tactic is to study a policy problem and ask microlevel actors about their goals,

activities, problems and contacts. Hjern (1982) found that central initiatives are often

not well adapted to local conditions. The success of a program depends to a large extent

on the skills of individuals in adapting policy to local conditions; central activities

influence the implementation of a project to a limited extent (Hjern, 1982; Hjern &

Hull, 1985).

The precise description of the complexities of the implementation process

58
inherent in the bottom-up approach also introduces problems related to the evaluation

of success (Knill & Tosun, 2012). Since effective implementation is measured based

on the extent in which goals have been achieved by considering specific conditions

“on the ground”, rather than a comparison between initial goals and actual

achievements, it is difficult to make a general comparative assessment of effectiveness

(Knill & Lenschow, 2000). In addition, “two criticisms of bottom-up models appear

with some consistency—one normative, one methodological” (Matland, 1995, pp.149-

150). The normative criticism pointed to policy control being exercised by actors

whose power derived from their accountability to sovereign voters in a democratic

system. However, street-level bureaucrats who have considerable discretion in their

interactions with clients do not possess such democratic or electoral power. Thus, local

implementers should be subject to central control. Flexibility and autonomy may lower

performance and the achievement of official goals when the goals of the policy

formulators and implementers differ greatly. The second criticism is that bottom-up

models tend to overemphasize the extent of local autonomy. Deviation in actions could

be explained largely by differences at the local level, yet central actors could

effectively affect policy outcomes by exercising control through the institutional

structure, available resources and the access to an implementing arena.

3. Hybrid Models of Policy Implementation

In view of the criticisms on top-down and bottom-up models, there have been

attempts to synthesize the two approaches. Some researchers proposed different ways

of synthesizing these two approaches, while others searched for conditions in which

59
one approach is more appropriate than the other (Elmore, 1985; Goggin et al. 1990;

Sabatier, 1986; Matland, 1995; O’Toole, 2003). Elmore (1985)’s suggestion of forward

and backward mapping was an early attempt at synthesis. Goggin et al. (1990)

presented a communications model of intergovernmental policy implementation by

describing three kinds of variables that affect state implementation. Sabatier (1986)

has argued that policies operate within parameters (socioeconomic conditions, legal

instruments, and the basic government structure) most easily identified with a top-

down approach. However, substantial actions involving advocacy coalitions by public

and private organizations and actors should be given due attention.

The hybrid model of policy implementation advanced by Matland (1995) is

particularly insightful. Matland’s model analyses the policy ambiguity and conflict

levels of policies to determine whether a top-down or a bottom-up approach is more

appropriate for explaining a particular mode of implementation. In reviewing the

implementation literature, it is apparent that top-downers and bottom-uppers choose

to study different types of policies. Top-downers tend to choose policies that are rather

clearly defined. Bottom-uppers study policies inherently with a greater degree of

uncertainty. Thus, building an effective model of implementation requires careful

evaluation of policy characteristics. Matland put forward levels of ambiguity and

conflict (high and low) as the two dimensions for analyzing and explaining the

characteristics that reflect four different modes of implementation in a continuum, in

which shift in implementation mode is possible.

Policy ambiguity refers to “a lack of clarity of goals and/or means of achieving

60
them” (Knill & Tosun, 2012, p.157). The level of ambiguity inherent in a policy

directly affects the implementation process in significant ways. It influences the ability

of superiors to monitor activities, taking into account the likelihood that the policy is

uniformly understood across the many implementation sites, the probability that local

contextual factors play a significant role, and the degree to which relevant actors vary

sharply across implementation sites. Policy conflict points to “the difference between

the most preferred outcome of an implementation agency and the output that the

agency has to implement” (Knill & Tosun, 2012, p.157). The level of policy conflict

has a number of important effects. Policy conflict directly affects the ease of access to

the implementation process. When the level of conflict is low, access is relatively easy;

barriers to entry are higher when the level of conflict is high. Intensity also rises with

conflict levels. The conception of these two dimensions as being high or low gives

way to four ideal-typical implementation processes: administrative, political,

experimental and symbolic (see Figure 6 below).

Administrative Implementation. In administrative implementation, policy

features exhibit low levels of ambiguity and conflict. Under this circumstance, goals

and means for solving the existing problem are known. Low level of ambiguity implies

the active participation of actors during implementation. As participants keep stable

over time, they will develop standard operating procedures to speed up their work.

Meanwhile, the transparency of technology makes clear which resources are required

and how to procure these resources. The central principle in such a constellation is

outcomes are determined by resources. Matland compared such implementation

61
process to a machine. At the top of the machine is a central authority who has the

information, resources, and sanction capabilities to help enact the desired policy.

Therefore, the system is relatively closed to environmental factors. The isolation from

outside influence, together with the programmed nature of policy, leads to relatively

unified outcomes at the micro-level.

Figure 6

Ambiguity-Conflict Matrix: Policy Implementation Processes

Note. Matland (1995).

When the level of conflict is low, normative compliance mechanism is generally

sufficient. Etzioni (1961) proposes three types of mechanism for gaining compliance

from an actor: normative, coercive, and remunerative. A normative mechanism induces

compliance through a jointly held goal or the legitimacy of the person such as a

superior in a hierarchy requesting action. A coercive mechanism acquires compliance

by threatening sanctions for the failure of an action. A remunerative mechanism

includes sufficient incentives, often additional resources, to make the desired course

62
of action attractive to the agent. Failure occurs largely because of technical problems:

the machine sputters. This mainly includes misunderstanding, poor coordination,

insufficient resources, insufficient time to use the correct technology, or the lack of an

effective monitoring strategy to control and sanction deviant behavior. In general, the

implementation process becomes dominated by technocratic questions of compliance

and follow-up when a policy is characterized by a high degree of consensus and the

ways for reaching the policy target are known. This description is quite similar to that

in the traditional top-down approach.

Political Implementation. A low level of ambiguity and a high level of conflict

are typical characteristics of a policy in political implementation. In such a

constellation, actors often have clearly defined goals, though dissent occurs when

goals are incompatible or conflicts occur over the means for achieving them. Therefore,

the central principle in political implementation is that implementation outcomes are

decided by power or bargaining. In some cases, one actor or a coalition of actors have

sufficient power to force their will on other participants. In other cases, some actors

resort to bargaining to reach an agreement. This also clearly indicates the top-down

logic underlying the implementation process.

As Matland (1995) pointed out, compliance is not automatically forthcoming.

Coercive and remunerative mechanisms will be more useful than others under this

condition. Coercive mechanisms are most effective when the desired outcomes are

easily monitored and the coercing principal controls resources essential to the agent.

The greater the authority to require an agent’s action, the more likely it is that the agent

63
will comply with the principal’s requests. However, many actors or agents have

independent bases of power. If their interests are not in line with the principal, they

could refuse to participate without having their own interests threatened. In spite of

strong sanctions, states and municipalities could still exhibit a surprising degree of

independence (Ingram, 1977). The principal-agent problems in political

implementation could lead to the failure of compliance despite the use of coercive

mechanism. Under these conditions, activities are directed toward reaching an

agreement through bargaining. Such a system is more open to outside influences than

that of administrative implementation.

Matland (1995) believes that descriptions proposed by the newer top-down

models come closest to capturing the essence of the implementation process under

these conditions. As Matland (1995) describes,

The traditional public administration models and the earliest top-down models

took an administrative view of what is essentially a political problem; they failed

to identify the sources of implementation barriers. The more sophisticated top-

down models, which were developed partially in response to the failings of

standard public administration teachings, emphasize political factors. (p.165)

Experimental implementation. The remaining two implementation processes

are related to the bottom-up approach. Experimental implementation refers to a

situation when a policy exhibits a high level of ambiguity and a low level of conflict.

Policy outcomes of such implementation depend largely on the active involvement of

actors. Hence, the central principle is that contextual conditions dominate the process.

64
Outcomes depend heavily on the resources and those actors present in the environment,

which are likely to vary from context to context. Given the emphasis on the relevance

of contextual conditions and the role of chance, policy outcomes are hard to predict.

In view of the high level of ambiguity, implementation outcomes differ from site

to site. The constellation of actors participating, the pressures on the actors, the

perceptions of the policy, available resources and possible programmatic activities

vary widely across different policy settings. Policies, in which both goals and means

are not that clear, naturally fall into the category of experimental implementation.

Besides, policies with clear and widely supported goals but with unclear means of

implementation take on experimental characteristics as well. Implementing such

policies, however, may lead to the development of entirely new capabilities. But there

may be limited accountability as mini-fiefdoms find leaders pursuing their own

interests, not the public interest.

Another feature of experimental implementation is the low level of conflict,

which is likely to open up arena for a large number of actors to participate and to

provide those with intense interest substantial resources and opportunities to mold

policy significantly. Such opportunities may be excellent for bureaucratic

entrepreneurs to be creative in their solutions for dealing with local needs. The

implementation process is more open to environmental influences than the other types

of implementation process. Program mutations arise as different organizations

implement different policies in different environments. These mutations can be seen

as natural experiments, and it is important for policy designers to actively use them to

65
enhance their knowledge of change processes within the policy area, with a strong

emphasis on formative evaluations (Mohr, 1988).

Symbolic implementation. Symbolic implementation is often reflected in a

policy with a high level of ambiguity and a high level of conflict. At first glance, it

seems implausible that a policy could have a high level of ambiguity and yet be

conflictual. After all, many scholars have suggested making a policy more ambiguous

in order to diminish conflict. Nevertheless, policies with such characteristics do exist.

According to Matland (1995), policies that invoke highly salient symbols often

produce a high level of conflict even when the policy is vague. They play an important

role in confirming new goals, in reaffirming a commitment to old goals, or in

emphasizing important values and principles (Olsen, 1970). The high level of conflict

structures the way resolutions are developed. And the high level of ambiguity results

in outcomes that vary from site to site. The central principle is that local level

coalitional strength determines the outcome when coalitions of actors at the local level

always control the available resources. However, the power of various actor coalitions

is again determined by contextual conditions. The preferences of actors’ groups are

likely to be based on their professional training. Among groups trained in different

ways, there will be disagreement over proposals for policy implementation, leading to

long battles and significant delay in attaining outcomes.

In short, Matland’s ambiguity-conflict model presented four types (modes) of

implementation as summarized in the Table 6 below.

66
 Table 6

Four Implementation Processes of Ambiguity-Conflict Model

Type Administrative Political Experimental Symbolic

Description Implementation Implementation Implementation Implementation
Low ambiguity Low ambiguity High ambiguity High ambiguity
Attribution
Low conflict High conflict Low conflict High conflict
Outcomes are determined
Outcomes are determined Outcomes are determined Contextual conditions
Central Principle by local level coalitional
by resources by power dominate the process
strength

67
67
The process should not be
Mechanism for Coercive and Coercive mechanisms,
Normative mechanisms forced into an artificially
Compliance remunerative mechanisms Bargaining techniques
constrained form
Similar to political
More open to More open to
Openness of the implementation,
Relatively closed to environmental influences environmental influences
Implementation except those
outside influence than administrative than other forms of
System environmental influences
implementation implementation
exist at the microlevel

Evaluation Summative evaluation Summative evaluation Formative evaluation Formative evaluation

Appropriateness of More sophisticated top- Neither top-down nor

Top-down approach Bottom-up approach
Approaches down approach bottom-up appropriate
Note. Adapted from Matland (1995).
2.1.2 Actors in Policy Implementation

No matter which model is adopted to describe the implementation process, the

ultimate operation should be completed by specific actors involved in the system. In

most polities, policy implementation is mainly carried out by bureaucrats at different

levels. Bureaucracy with its intra- and inter-organizational conflicts consists of a

significant number of actors vying to be determinants of policy implementation

(Howlett et al., 2003). At the central level, there are various national ministries with

different functions (economic development, environment protection, defense, etc.),

which form the critical executive departments. Although ministries located at the

center play a significant role in policy implementation, national policy is also

implemented by those public entities at the local level. According to Saich (2015),

“[W]hile the central government in China proclaims many policies to improve public

service provision, counties and townships have to fund and provide most of the

services” (p.121). In many cases, policies are not implemented by either the central

government or local governments. They are implemented by multiple organizations,

located at different levels of government. In this context, “implementation involves

collaborative efforts and brings inter-organizational relations to the fore” (Knill &

Tosun, 2012, p.150). Hall and O’Toole (2000) have pointed out that a considerable

share of legislation requires multiorganizational structures. Therefore, the functioning

of inter-organizational networks is crucial to achieving effective coordination. Such

networks are relatively stable structures in which individuals and organizations act in

different situations dependent on the contributions of others (Hanf & O’Toole, 1992).

68
 Bureaucracies could have more or less decisional discretion, depending on the

specific policy to be implemented. When different bureaucratic agencies at different

levels of government (national, state, provincial and local) participate in implementing

a policy, their embedded interests, ambitions and traditions are likely to affect the

implementation process and shape its outcomes (Bardach, 1977; Elmore, 1978).

Bureaucracies might have a greater leeway in interpreting policy outputs if it is

characterized by vague policy contents or goals. As an example, sustainable

development is a very broad concept that involves ecological, social and economic

dimensions. In such cases, a bureaucracy could certainly shape public policy when

providing an operational definition of vague policy objectives. As Knill and Tosun

(2012) asserted, “policy outputs characterized by vagueness, inconsistency and

complexity have higher chances of being implemented inconsistently” (p.151). Policy

implementation is no trivial activity as it involves multiple actors located in different

public agencies who may or may not have the same preferences when implementing a

given policy.

2.1.3 Choice of Policy Tools and Instruments

The choice of policy tools and instruments may affect the effectiveness of

implementation (Bressers & Klok, 1988; Linder & Peters, 1989; Howlett, 1991; Knill

& Lenschow, 2000; May, 2003). Policy implementation involves applying one or more

of the policy instruments to the resolution of problems. Although implementation

process may fit a top-down, bottom-up or mixed model, a government may choose one

or several tools in its toolbox (Hood, 1986; Linder & Peters, 1991).

69
1. Policy Tools

The study of policy instruments by public policy scholars began with Harold

Lasswell’s insights into the subject in his 1936 work, Politics: Who Gets What, When,

How. According to Howlett et al. (2003), the study of policy tools has moved from

simple description of each tool to the classification schemes for different categories of

tools as well as reasons behind their use by governments. This section, therefore,

introduces a parsimonious approach of classifying policies based on governance

principles - the NATO scheme - proposed by Hood (1986; cf. Hood & Margetts, 2007;

Knill & Tosun). In Hood’s (1986) NATO scheme, the four governance principles are

nodality, authority, treasure and organization (see Table 7 below). The four principles

are further differentiated in terms of basic resource, governance logic and typical

instruments (Hood & Margetts, 2007).

Information is the basic resource for nodality as the governance principle. Here,

the governance logic is indirect, in that governments seek to “change the beliefs and

perceptions of public and private actors, hence changing individual or collective

behavior in order to achieve political objectives” (Knill & Tosun, 2012, p.22).

Nodality-based instruments include using data and information for education, advice,

recommendation and persuasion (Vedung, 1998, as cited in Knill & Tosun, 2012).

Information campaign is the commonly used nodality-based instrument. Nodality-

based instruments are relatively low cost in terms of application and implementation

and is a good starting point for addressing problems without clear solutions (Knill &

Tosun, 2012). Even if a better instrument is found, suasion can be changed or

70
abandoned without much difficulty (Stanbury & Fulton, 1984). The weakness of

nodality tools lies in “their often limited and uncertain effectiveness” (Knill & Tosun,

2012, p.23).

Table 7

Policy Classification by Governance Principles

Governance Nodality Authority Treasure Organization
principle
Basic Information Law Money Structures and
resource capacity
Governance Indirect Direct Indirect Provision of
logic stimulation of prescription stimulation of public good or
behavioral of behavioral behavioral service by the
change through rules change through state or public
information and financial enterprise
persuasion incentives
Typical Information Prohibitions Taxes Direct
instruments campaigns Bans User charges provision
Suasion Permits Grants Public
Research Standards Tax deductions companies
inquiries Government
reorganization
Note. Adapted from Hood and Margetts (2007), Howlett et al. (2003).

Law is the basic resource for authority as the governance principle (Knill & Tosun,

2012). Authority means “the legitimacy of legal or official power and gives to the

government the ability to force societal actors to follow legal rules” (Knill & Tosun,

2012, p.23). Authority-based governance logic aims to use its instruments to directly

prescribe the behavior of individual or institutions within the legal conditions in which

they operate. Command-and-control instruments are used to demand, forbid, guarantee

and judge whether rules should be followed by negative sanctions (Knill & Tosun,

2012). Authority-based instruments, however, might occur in more cooperative forms,

71
i.e. entailing a more or less far-reaching participation by, and delegation of power to,

private actors (Knill & Lehmkuhl, 2002). Regulations constitute the most feasible

governance option and one that can hardly be substituted with other approaches in the

field of risky or dangerous sectors (such as nuclear safety) (Holzinger et al., 2006). It

is politically appealing when the public expects quick and definite action on the part

of the government (Mitnick, 1980, as cited in Howlett et al., 2003). Furthermore, from

the perspective of governments, “they have only minor budgetary implications” (Knill

& Tosun, 2012, p.24). Assuming that legal rules are effectively implemented,

authority-based instruments may produce high predictability of policy effects. There

are, however, some disadvantages when using authority-based instruments. Regulation

“generally entails high costs with regard to controlling and monitoring their proper

enforcement” (Knill & Tosun, 2012, p.24). Also, regulations can, at times, affect

innovation and technological progress because there are no incentives for policy

addressees to go beyond legal requirements (Holzinger et al., 2006). As Laffont and

Tirole (1991) pointed out, there might be a danger of regulatory capture. This is likely

to happen “when the design of regulatory rules requires detailed scientific and

technical information” (Knill & Tosun, 2012, p.24).

Money as the basic resource for treasure as the governance principle involves “all

forms of financial transfers to individuals, firms, and organizations from governments

or from other individuals, firms, and organizations under government direction”

(Howlett et al., p.108). Treasure-based instruments may be positive or negative

financial incentives. Grants are offered to individuals or organizations in order to

72
stimulate them to produce more of a certain good or service. Other treasure-based

instruments include tax incentives, i.e. deductions, special rates or exclusion,

government loans at an interest rate below the market rate, and financial disincentives,

such as taxes and user charges (Howlett et al., 2003). Such instruments are easier to

implement than command-and-control or regulatory instruments as individual

participants could decide for themselves how to respond to the financial incentives by

taking into account changing local and sectoral circumstances. By allowing target

groups to devise appropriate responses, financial incentives may encourage innovation

on their part. As economic tools, they are often politically more acceptable when

benefits are relatively concentrated in certain societal groups and the costs are spread

across all taxpayers (Wilson, 1974). These tools, however, strongly affect the public

budget. It is also difficult to gather information on how much subsidies would be

required to induce a desired behavior. Given the indirect nature of subsidies, there is

often a time lag before the intended effects become apparent. This makes them an

inappropriate instrument to use in times of crisis.

Organization as a governance principle is concerned with the “reliance on formal

organizational structures in order to achieve policy objectives” (Knill & Tosun, 2012,

p.25). Instead of waiting for the private sector or non-governmental organizations to

do something, governments often directly provide public goods or services through its

employees and funding from the public treasury (Mayntz, 1979; Leman, 2002).

Organization-based instruments include direct provision, public or state-owned

enterprises, market creation, and government reorganization (Howlett et al., 2003).

73
These provisions avoid problems associated with indirect provision which entails

discussion, negotiations and concerns with the problem of non-compliance. The direct

provision of public goods by the state itself could do away with the intermediary steps

to directly or indirectly influence target group behavior (Knill & Tosun, 2012). Public

enterprises and government reorganizations, however, engender certain problems too.

Taxpayers’ monies may be use to compensate the poor performance of such enterprises

and to avoid bankruptcy (Knill & Tosun, 2012). In addition, political conflicts may

affect the provision of public goods and services when political demands arising out

of elections are considered more important than serving the public interest. Moreover,

principal–agent problems “might emerge in the sense that the management of public

enterprises, i.e. the agent, can pursue different objectives than its political principals,

i.e. the government” (Knill & Tosun, 2012, p.26).

2. Environmental Policy Tools

Environmental policy tools are the specific ways and means people adopt to solve

environmental problems or achieve certain environmental policy goals (Yang, 2016).

They are the bridge to achieve the goals of environmental policy. According to the

World Bank’s 1997 Annual Report, environmental policy tools could be classified into

four categories: “using markets, creating markets, using environmental regulations and

engaging the public” (World Bank, 1997, p.6). The following elaborates on the affinity

between Hood’s NATO scheme and the World Bank’s scheme on environmental policy

tools (see Table 8 below).

74
Table 8

Environmental Policy Tools

Using
Engaging the
Using Markets Creating Markets Environmental
Public
(Treasure) (Organization) Regulations
(Nodaltiy)
(Authority)
Subsidy
Property right/
reduction Standards Public participation
decentralization
Environmental Information
Tradable permits/right Bans
taxes disclosure
User fees International offset
Permits and quotas -
systems
Deposit-refund
- - -
systems
Targeted
- - -
subsidies
Note. World Bank (1997).

In the World Bank’s scheme, the category of engaging the public include

environmental policy tools such as information disclosure and public participation.

The former “allow consumers to make more informed choices and demand more

environmentally friendly goods and services” (World Bank, 1997, p.14). While the

latter is concerned with activities to secure and make use of reliable information for

environmental protection through public discussion about environmental assessments

of major projects as well as establishing new partnerships between governments,

NGOs, trade unions and community groups. These policy instruments perfectly

mirrored nodality-based instruments, which try to make use of information to stimulate

behavioral change indirectly through suasion.

The use of environmental regulations in the World Bank’s scheme is similarly

concerned with the use of authority-based instruments put forward in Hood’s NATO

75
scheme as well. Command-and-control instruments such as standard, ban, permits and

quotas are often favored by policymakers as they promise certainty of outcome (World

Bank, 1997), notwithstanding the high costs of monitoring and enforcement work.

The category on using market in the World Bank’s scheme consists of treasure-

based instruments found in Hood’s NATO scheme, namely subsidy reduction,

environmental taxes and user fees, which serve to stimulate behavioral change directly

through financial incentives

Last but not least, the category on creating market did not emphasize much about

organization-based instruments, i.e. direct provision, public enterprises and

government reorganization, found in Hood’s NATO scheme so that the state or public

enterprises could directly provide goods and services. However, creating market itself

as a category in the World Bank’s scheme is related, to a large extent, with

organization-based instruments. Those “creating market” instruments listed in the

World Bank’s scheme—property right/decentralization, tradable permit/right and

international offset system—are applicable to addressing environmental problems

associated with air pollution.

2.1.4 Criteria for Successful Implementation

According to Knill and Tosun (2012), “the assessment of implementation is not

only affected by the analytical perspective adopted, but also by the criteria that are

applied” (p.158). Comparing to bottom-up models, top-down models are clearly more

suitable for comparing and assessing policy goals and actual implementation. Based

on the logic of top-down models, some scholars have suggested distinguishing

76
between formal transposition and practical application (Knill & Lenschow, 1998;

Weale et al., 2000; Winter, 2003; Knill, 2006; Hartlapp & Falkner, 2009; Robichau &

Lynn, 2009).

Formal transposition “focuses on the entirety of the specific provisions of a given

public policy and their incorporation into the existing legal and administrative system”

(Knill & Tosun, 2012, p.158). In this context, bureaucrats must ensure that the work is

done in a complete manner and within the time frame set by the legal act when a policy

is adopted. In other words, this stage tries to ensure the implementability of policy in

the sense that it can actually be put into practice. Policy-makers, however, sometimes

adopt detailed and specific laws, while at other times they formulate general and vague

laws that leave the bureaucrats with considerable discretion to fill in the policy details

(Huber & Shipan, 2002).

Practical application refers to “the actual putting into practice of a policy” (Knill

& Tosun, 2012, p.159). It comprises different activities depending on the content of a

policy. In some cases, it means the provision of services defined by legislation. For

example, the provision of education, health care or job opportunities by a government

reflects the practical application of related public policies. During implementation,

policy addressees or implementers have to modify their behavior so as to fulfill the

obligations stemming from a public policy. Ideally, organizations and individuals

targeted by the legislation voluntarily comply with it (Knill & Tosun, 2012). As non-

compliance might occur, enforcement measures are required. Governments may first

choose policy instruments with non-coercive measures to elicit compliance. For

77
instance, making an appeal to policy implementers to provide information about a

policy. In general, compliance is forthcoming when organizations and individuals

targeted by the policy believe that it is legitimate. After all, non-compliance is widely

perceived as socially unacceptable. In most cases, when command-and-control

instruments are employed, practical application involves monitoring and enforcement

activities.

As Knill and Tosun (2012) highlighted, “monitoring is about surveillance,

increased transparency and information gathering as to how well the target group

actually complies with the requirements of a given public policy” (p.160). This may

include requesting compliance reports or carrying out announced or unannounced on-

site inspections. When non-compliance is detected, enforcement is the next step taken

to ensure that non-compliance is stopped and remedial measures are taken. Measures

available to implementers include prohibition notices, suspension of operational

licenses, injunctions and the carrying out of remedial works (Knill & Tosun, 2012).

Either of the two dimensions, formal transposition and practical application, may

be adopted to effectively assess implementation (Knill & Tosun, 2012). Formal

transposition is particularly promising for the analytical insights into policies that are

intersectoral and required collaborative efforts by many different organizations.

Whereas, practical application though complex with various assessment activities,

certainly offers a better understanding of the more substantive aspects of public policy

that go beyond what is written in the law book. Therefore, empirical studies generate

insights into either how well implementers provide a certain service or by what means

78
they seek to induce the target population to change their behavior. Table 9 summarizes

the focus and criteria of these two dimensions.

Table 9

Criteria for Measuring Implementation Success

Focus Criteria
Formal Legal and administrative ·Time frame
transposition provisions for the ·Completeness
transposition of requirements ·Correct integration
to the existing legal and into the regulatory
administrative system context

Practical Organizational and ·Provision of policy-

application administrative related services
structures and procedures ·Provision of non-
coercive incentives
for compliance
·Monitoring and
enforcement
Note. Knill and Tosun (2012, p.160).

2.2 Principal-Agent Theory

The gaps between legislative or political intent and administrative practice are

often cited as a major reason for policy failure (Kerr, 1976). These gaps are regarded

as the inevitable result of the structure of politico-administrative institutions in modern

states as decision-makers delegate responsibility for implementation to officials at the

lower level directly or indirectly under their control. The principal-agent problems in

policy implementation, “arise from the common practice in most countries, set out

above, whereby general laws passed by the political branches of government are put

into effect through detailed regulations created by administrative agencies charged

with implementing the law” (Howlett et al., 2003, p.191).

79
 This institutional arrangement provides a particular perspective to explain the

gaps in implementation from a principal-agent relationship. An inherent problem

between politicians and administrators is how to secure the agent’s compliance.

Administrators always have their own understanding, interests and resources that may

stand in the way of policies conceived by decision-makers. Howlett et al. (2003) have

pointed out that “this structural problem is compounded by several other difficulties

built into such systems” (p.191).

Implementation involves not one but multiple government agencies. Policy

implementation increasingly takes place in complex ‘inter-organizational’ contexts,

whereby the creation of another layer of specialized administrative agencies designed

specifically for coordination is necessary (Mayntz, 1993; Rogers & Whetton, 1982).

The nature of a problem itself also affects programs designed for implementation in

several ways (Howlett et al., 2003). Policy decisions involve different degrees of

technical difficulties, some of which are more intractable than others. For example,

closing down an illegal casino or opening a new school in a new neighborhood is

specific single decision rather unproblematic and routine in practice. However,

pollution as a public problem is rooted in many causes; programs designed to address

those causes are normally expected to fall short of their objectives. In addition, “the

nature of the affected target group is also an issue” (Howlett et al., 2003, p.192). The

size of the target group and the extent of the behavioral change the policy requires of

the target group are both key determinants of the level of difficulty in implementation.

In addition, administrative discretion in the implementation process is also affected by

80
the social, economic, technological, and political contexts (Hutter & Manning, 1990).

Changes in social and economic conditions may affect the interpretation of a problem

and how ongoing programs are implemented. The availability of new technology may

increase the probability of efficient or effective implementation. Variation in political

circumstances may also lead to changes in the way policies are implemented. As a

great deal of discretion is often placed in the hands of administrators, this may

exacerbate the principal-agent dilemmas.

2.2.1 Principal-Agent Model in Economics

The principal-agent problem was first proposed by economists to explain the

incentive problem and decision making within firms. The incentive problem arises out

of the division of labor, delegation and information, which are inevitable in any

organization, whether in the public sector or the private sector. As Laffont & Martimort

(2002) noted, “the division of labor and exchange induce the need for delegation” (p.7).

Thus, the kernel of principal-agent problem is how to get the agent to act in the best

interest of the principal, or how to construct optimal incentive structures that would

govern the principal’s and agent’s behavior in their best interest (Ross, 1973; Jensen

& Meckling, 1976).

A principal-agent relationship has several notable characteristics. First and

foremost, the principal and the agent may have conflicting interests. As Kiewiet and

McCubbins (1991) put it,

There is almost always some conflict between the interests of those who delegate

authority (principals) and the agents to whom they delegate it. Agents behave

81
 opportunistically, pursuing their own interests subject only to the constraints

imposed by their relationship with the principal. The opportunism ... is a

ubiquitous feature of the human experience. (p.5)

The main problem is how to recognize conflicts and design an incentive structure

that best reconciles conflicting interests.

Information asymmetry exists between the parties involved. When a principal

delegates a task to an agent, the agent may get access to information that is not

available to the principal. As Laffont and Martimort (2002) explain,

The exact opportunity cost of this task, the precise technology used, and how good

the matching is between the agent’s intrinsic ability and this technology are all

examples of pieces of information that may become private knowledge of the

agent. (p.28)

This puts the agent in a strategically advantageous position in the relationship with the

principal. It allows the agent to use delegated authority to advance its own interests

rather than those of the principal. Adverse selection and moral hazard are possible

consequences of asymmetric information.

The principal-agent relationship incurs transaction costs. The persistence of

problems of information asymmetry and the almost unobservable possibility of

shirking or non-compliance by agents can be detrimental to the interests of principals

(Moe, 1984). This hidden information and the hidden actions of agents may create

agency’s losses in the principal-agent relationship. The principal or a third party has to

pay a price to observe or monitor the actions of agents. Albeit principals can use

82
various means, such as screening and monitoring agents, to minimize losses due to

adverse selection and moral hazard, these means also impose some cost on the

principal. There are inevitably transaction costs associated with the principal-agent

relationship.

Principal-agent theory assumes that both principals and agents are rational and

always act in their own interests (Zou, 1989). Rationality, as commonly agreed,

requires that both principals and agents have consistent preferences. That is, their

preference rankings should be non-contradictory and transitive. Moreover, they would

adopt optimal strategies to maximize their utility (or expected utility in the case of

uncertainty). In principal-agent relationships, both principals and agents respond

rationally to the incentive structure and take actions that are in their best interest given

the constraints of the environment.

In general, conflicting interests and informational asymmetry between principals

and agents lead to the principal-agent problem. If the two parties’ objectives are exactly

the same, then no matter how asymmetric information is, agents will always care about

the interests of principals as much as their own. Then, it becomes meaningless to

incentivize agents. Secondly, if an agent’s behavior could be completely observed by

the principal in spite of the conflicts of interest between the two, the solution of how

to incentivize the agent is also very simple. The principal only needs to give

corresponding remuneration according to the agent’s efforts.

Kiewiet and McCubbins (1984) have proposed four measures for a principal to

minimize agency’s losses. First, a principal could design a contract to delegate tasks

83
and responsibilities as well as to specify a corresponding schedule of compensation in

such a way that an agent is motivated to best serve the principal’s interests. In case of

non-compliance, there should be credible and negative payoffs for the agent. Second,

a principal could use screening and selection mechanisms to select the most suitable

agent before entering into a contractual relationship. Third, a principal could require

an agent to report relevant information to minimize hidden action. Supplementing the

reporting requirements, a principal could also oversee an agent by direct “police patrol”

or by third-party “fire alarm”. Lastly, a principal could set up institutional checks or

veto subgroups to prevent an agent from taking actions that the former considers

undesirable. These four types of measures can help a principal minimize agency’s

losses. Yet, principals would still incur transaction costs as a result of taking such

measures.

2.2.2 Principal-Agent Framework in the Public Sector

In a well-ordered society, the public sector will provide a fairly large set of public

services, a decent set of social security programs and a fair amount of public regulation

of the private sector (Lane, 2005). The public sector contains the general government

sector plus all bureaus and agencies, including the central bank. Public enterprises are

sometimes placed in the public sector and sometimes in the private sector, if organized

as joint-stock firms (Lane, 2005). Lane’s description of the public sector consists of

three subsectors: the government sector, public enterprises and monetary authority.

The government sector has received most attention from scholars in the field of public

management. This is concerned with how a government organizes its employees into

84
teams for service provision, transfer payments and regulatory tasks. Public

administration or management is conducted within a political setting where the goals

and means of activities are politically decided, including the execution of public

policies. From a principal-agent perspective, public management can be regarded as a

nexus of contracts between principals and agents at various levels of government (Lane,

2005).

According to Lane (2005), there are at least four kinds of principal-agent

relationships in a traditional public sector: “governance of the bureau; governance of

social security; governance of the public enterprises; and making of monetary policy”

(p.3). There are, however, some problems with applying principal-agent theory in

public management. Hughes (2012) has argued that the application of principal-agent

theory to the public sector leads to disturbing comparison of accountability with the

private sector. In the public context, it is difficult to determine who the principals are,

or to find out what they really want. “The principal - the owners - of the public service

may be the public as a whole, but its interests are so diffuse that effective control of

agents — politicians and public managers — is unlikely to be effective” (Hughes, 2012,

p.13). If principals have no adequate means of making sure that agents carry out their

directives, agents are less likely to perform. As Hughes (2012) puts it, “if there is an

agency problem in the private sector, it is likely to be worse in the public sector” (p.13).

In the public sector, the policy implementation phase is often rife with principal-

agent problems. As Knill and Tosun (2012) point out, “principal-agent theories

constitute an important starting point for the explanation of implementation deficits”

85
(p.163). The difference in policy objectives and actual implementation is caused by

the configuration of modern political-administrative system, which is characterized by

the delegation of competencies to subordinate administrative authorities. This

delegation is particularly relevant with regard to the difference between the tasks of

policy formulation (usually taking place within central ministries) and the

implementation of these policies (often delegated to agencies at the subnational or

local level) (Howlett et al., 2009). Delegation brings with it the problem of

bureaucratic drift. This problem is further exacerbated by two factors (Knill & Tosun,

2012). High organizational complexity increases the number of agents and the levels

of government that are involved in the implementation process and hence increases the

potential for bureaucratic drift (Schnapp, 2000; Hammond & Knott, 1996). In addition,

high scientific or technical complexity of underlying policy problem increases the

opportunities for different interpretations of policy objectives by principals and agents

(Knill & Tosun, 2012). The more specialized knowledge is needed to implement a

public policy, the more likely implementers possess an information advantage over the

policymakers, which facilitates deviation from the original policy objectives.

Politicians could control the bureaucracy and the way it implements public policy

in two ways. Firstly, through formal oversight, the parliament directly monitors an

agency’s behavior to gain the information it needed to correct undesirable behavior

(Aberbach, 1990). This mainly takes place in the context of committee hearings and

investigations (Meier, 2000). For instance, Anderson (2010) noticed that “members of

Congress or Parliament in the United States and United Kingdom are often involved

86
in ‘casework’, which involves dealing with issues that occur to citizens during the

implementation phase of a policy” (p.219). Such cases typically involve the

unsatisfactory provision of certain services or infrastructures.

Secondly, statutory control permits the executive or the legislature to design an

agency’s structure and processes in favor of some policies over others. As Bawn (1997)

asserts, “[W]hile oversight occurs after the bureaucratic actors have implemented a

policy, statutory controls are established before they act” (p.102). There are two forms

of statutory control: those designed around “fire alarms” and those around “stacked

decks”. Fire alarms are “a system in which the parliament establishes rules and

informal practices that enable individual citizens and interest groups to examine

administrative decisions and to ‘raise the alarm’ should they disagree strongly with

specific decisions” (McCubbins & Schwartz, 1984, p.427). Alternatively, legislation

that delegates policy decisions to an agency may specify in great detail how the agency

decisions are to be made. McCubbins et al. (1987) have argued that legislators could

strategically design agency structure and processes to “stack the deck” in favor of those

groups that the legislators want to help.

So far, we have only discussed ways of controlling administrative agencies.

However, Newton and van Deth (2010) have pointed to additional possibilities for

reducing the risk of a bureaucratic drift:

Firstly, politicians can appoint bureaucrats on the grounds of political

considerations such as their ideological proximity to the party or parties to which

the government and/or the parliamentary majority belongs. Secondly, the potential

87
 of bureaucratic drift could be reduced by training bureaucrats in a manner that

develops a professional ethos of public service. Thirdly, financial control could be

used as one form of oversight. Fourthly, an increasing share of open government

might help to reduce delegation problems. The authors have also suggested the

employment of “sunshine laws”, requiring administrative agencies to do their

work in public through open meetings. Finally, maladministration might be

reduced through the presence of ombudsmen. (pp.124-5)

It should be noted that most of the points mentioned above included assumptions

about the behavior of bureaucrats that corresponds more to Niskanen’s view than

Weber’s. While the former emphasized the tendency of bureaucrats to maximize their

self-interest, the latter expected bureaucrats to be guided by their professional ethos

and to behave in ways that serve their political masters.

2.3 The Application of Theories in this Study

According to Matland (1995), building an effective model of implementation

requires a careful evaluation of policy characteristics. The birth and characteristics of

a policy determine the direction of policy implementation to a certain extent, having

an effect on the behavior of participants and their choice of policy tools.

Since 1998, the State Council has made a series of plans to deal with water

pollution in important basins and lakes such as Taihu Lake and Huaihe River. However,

a national action plan for WPPC was not available until 2015. Therefore, chapter three

of this study will, first of all, introduce the formulation and legitimation of WPPC

policies by the central government for local governments since 1998. Matland’s

88
ambiguity-conflict model will be used to analyze the characteristics of WPPC policies

issued by the central government before and after 2012. These characteristics include,

among others, the extent of ambiguity in the policy objectives and the means conceived

and justified to achieve those objectives as well as the extent of conflict in the policy

implementation process. Such policy features and its concomitant mode of

implementation to a large extent have reflected a change in the attitude and orientation

of the central government about environmental protection and in preventing and

controlling water pollution in particular.

Chapter four and chapter five describe and explain the implementation processes

of WPPC policies at the local level and evaluate implementation outcomes in two

periods (i.e. 2008 to 2010 and 2016 to 2020), mainly taking Guangzhou as the case for

analysis. Both chapters analyze the characteristics of Guangzhou’s WPPC policies for

2008-2010 and 2016-2020 respectively from the perspectives of policy goal setting,

actors involved in WPPC implementation, the choice of policy tools and operation

mechanisms. Goal setting addresses the extent of policy ambiguity, while actors and

operation mechanisms are concerned with conflict analysis. Matland’s model will be

used to analyze the implementation modes of Guangzhou’s WPPC policies in two

different periods.

In a specific implementation mode, local governments are more inclined to

choose certain environmental policy tools and instruments to achieve their policy

objectives, which may be command-and-control tools, market-driven tools as well as

the use of information and public participation tools. Governments sometimes choose

89
one tool, and more often they use two or three tools at the same time. Did the policy

tools chosen by the Guangzhou government in the two different periods make a

difference to implementation outcomes? The choice of policy tools and instruments

according to Hood’s NATO scheme, where applicable in relation to the World Banks’s

scheme, will be discussed in the analysis.

The implementation of WPPC policies in Guangzhou involves many participants.

In a highly complex environment, participants come from different government

departments, environmental non-government organizations (ENGOs), the public,

public and private enterprises, etc., which lead to the use of different policy tools and

instruments with differing outcomes and implementation modes. The outcomes of the

two WPPC implementations in Guangzhou will be evaluated in terms of formal

transposition and practical application over two different periods. Formal transposition

examines the relevance and completeness of policies within a specified time frame and

whether they are well integrated with the regulatory context. The three criteria of

timing, completeness and integration with the legal and administration systems are set

forth in Table 9 above. Did the Guangzhou government provide relevant policies

within a specified time frame? Were contents of the policies issued by the Guangzhou

government complete? Are these contents general and vague or detailed and specific?

Were these policies well integrated into the existing legal and administrative systems?

As far as practical application is concerned, the provision of policy-related

services, the provision of non-coercive incentives for compliance as well as monitoring

and enforcement as coercive measures are related to the three criteria used to assess

90
the actual implementation of policies (see Table 9 above). Hence, chapter four and

chapter five critically examine whether the Guangzhou government and related

agencies provided policy-related services when implementing WPPC policies in the

two periods respectively. It will also examine non-coercive incentives and coercive

measures that were put in place to deal with disobedience or non-compliance.

As pointed out above, some scholars have long considered environmental policy

implementation in China as being largely symbolic (Ran, 2014; Shimiliaowa & Wang,

2011). In Matland’s ambiguity-conflict framework, this means that implementation is

characterized by high levels of policy ambiguity and conflict. However, chapter four

and chapter five will show that the modes of local implementation in regard to the

implementation of WPPC policies in Guangzhou are non-singular, complex, dynamic

and non-static. Implementation moves along a continuum where political

implementation may shift or slide either towards experimentation implementation or

administrative implementation as well. Although political implementation involves a

low level of policy ambiguity and a high level of policy conflict, the central principle

is that implementation outcomes are decided by power. As compliance is not

automatically forthcoming for such a policy implementation mode, implicit in the

different mechanisms for compliance put forward by Matland are potentially different

types of principal-agent relationships. Coercive mechanisms are most effective when

the desired outcomes are easily monitored by the coercing principals who control

incentives and resources essential to the agents. Conversely, if agents are not in good

relationship with principals and have independent bases of power, then bargaining or

91
negotiation is a more suitable mechanism for obedience or compliance.

In his explanation of political implementation, Matland mentioned some

important factors, such as the alignment of goals between principals and agents,

principals’ control over key resources essential to agents, and the extent in which

policy implementation could be well monitored and enforced. These correspond to the

three key factors in the principal-agent theory— interests, incentives and information–

discussed above. Therefore, principal-agent theory can be a useful analytical

framework for studying political implementation. Besides, China’s central-local

relations essentially parallel principal-agent relationships. Therefore, Chapter six will

analyze the behavioral changes of local governments in Guangzhou in the

implementation of WPPC policies from a principal-agent perspective and assess the

reasons for the failure or success of WPPC policy implementation in the two periods.

Figure 7 presents the conceptual framework, relating the interrelationship between all

the concepts and theories used in this study and their application in each chapter.

92
Figure 7

Application of Theories in Each Chapter

Note. Compiled by the author.

93
 Chapter 3 Formulating and Legitimating WPPC Policies at the Center

Environment is a typical public good in which governments are held responsible

for dealing with its externalities.6 Public demands for governments to play a leading

role in environmental governance did not appear until the large-scale industrial

pollution in modern society (Hughes, 2006). Although discussion in books such as

Silent Spring (Carson, 1962) and The Limits to Growth (Meadows et al., 1972)

greatly popularized the awareness of environmental protection in Western societies, it

was not until the 1970s that environmental issues attracted the attention of

governments (Hughes, 2006). Large-scale environmental movements in Western

countries drove their governments to respond to public environmental demands

(Hughes, 2006). The United Nations Conference on Human Environment held in

Stockholm in 1972 is a symbol, whereby the international community began to jointly

deal with environmental problems challenging human survival. The Declaration on

Human Environment in that conference defined the responsibilities of states in

environmental protection for the first time (United Nations, 1973).

Then, China was still a closed state undergoing a cultural revolution. Pollution

was considered a by-product of capitalism. Nevertheless, it sent a large delegation to

attend the conference in Stockholm (Qu, 2010). China’s top policy makers came to

recognize the state of serious environmental problems in the world. In August 1973,

the State Council and the State Family Planning Commission held the first National

6
Paul A. Samuelson (1954) defined public goods in the article named The Pure Theory of Public Expenditure.
He argued that public goods is collective consumption goods which all enjoy in common in the sense that each
individual’s consumption of such a good leads to no subtraction from any other individual’s consumption of that
good.
94
Conference on Environmental Protection (Qu, 2010). After the meeting, the State

Council promulgated the Provisions on the Protection and Improvement of the

Environment (Trial Draft), which was an important milestone towards making

environmental protection an official agenda. In 1979, the Standing Committee of the

National People’s Congress promulgated the first Environmental Protection Law of the

People’s Republic of China (Trial) (Qu, 2010).

Policy formulation takes place within a particular institutional setting. Although

the current research uses a process perspective to study the dynamics of local

environmental implementation, this chapter gives due emphasis to a structural

perspective to understand the formulation and legitimation of China’s environmental

policies vis-à-vis WPPC policies. Such a perspective is necessary for enunciating the

implications of principal-agent relationships and the mode of implementation that was

being advanced the Chinese Communist Party (CCP). While the conventional view of

environmental policy implementation in China as largely symbolic still holds for

reasons that will be explained below, a political implementation mode for water

environmental protection has gradually emerged in the early 21st century (i.e. 2002).

This is due to the CCP’s awareness of environmental protection as an institutional issue

as well with serious implications for sustainable development (Chen, 2009). Such an

awareness has led to a change in the CCP’s attitude in its policy formulation and

legitimation of environmental policies; in this study, WPPC policies in particular.

The first section of this chapter, therefore, begins with a discussion of the context

for the formulation and legitimation of China’s environmental policies by relating it to

95
the authoritative role of Party and state organs. This is followed by a discussion of how

environmental laws, policies and action plans concerning WPPC policy

implementation gradually reign in local governments as responsible agents for

implementation outputs and outcomes. Before 2000, environmental protection

agencies were solely the responsible agents. After the reorganization of Ministry of

Environment Protection (MEP) in 2018, Ministry of Ecology and Environment (MEE)

is responsible for environmental protection (Xie, 2019). The 12th NPC in 2012 had

clarified the roles and responsibilities of local governments in environmental

protection at the provincial level and below. Concrete targets and indicators for

improving water quality were also put forward in the 2014 Environmental Protection

Law (EPL) (Standing Committee of the National People’s Congress [SCNPC], 2014),

the Action Plan for Water Pollution Prevention and Control (APWPPC) (State Council,

2015), and the Water Pollution Prevention and Control Law (WPPCL) (SCNPC, 2017),

which increasingly left little room for policy ambiguity. The level of conflict, however,

is likely to be high, in view of the financial burdens on local governments and the

challenge of balancing economic development and environmental protection.

Environmental policy implementation, in all likelihood, is more likely symbolic, in

mainly but not restricted to economically less developed regions, when local

governments could escape from the reach of the state or are debt-ridden due to over-

investment of “face projects” and corruption issues. Thus, the levels of policy

ambiguity and conflict are both high.

Not all cases of environmental policy implementation in China, however, are

96
symbolic. Section two, firstly, looks into the WPPC policy characteristics and points

the emergence of a political implementation mode in WPPC even before 2012. The

case of Liaohe River Basin is used as an example to elucidate the problems leading to

poor implementation. Secondly, the discussion dwells into the CCP goals of building

ecological civilization and its implications to the mode of implementation for WPPC

by pointing to the need to adopt effective measures and mechanisms for reducing

policy ambiguity and alleviating conflict.

3.1 Roles of Party and State Organs in WPPC

The central government, in a narrow sense, refers to the State Council which is

the highest state administrative organ. 7 However, the CCP has always assumed a

domineering role in policy formulation and legitimation (Zhu, 2008). The legislature—

the National People’s Congress (NPC)—has a role to play as well. In general, the

central government encompasses the Central Committee (CC) of the CCP, the State

Council and the NPC. Zhu (2008) summarized such a system as a “6 +1+ 2” with the

CC of the CCP and the Political Bureau or Politburo as the core, given that Party and

government are indivisible with the former in a dominant position in the Chinese

political system. The top of the Party pyramid is the National Party Congress (here

after PC),8 which in theory convenes once every five years (Saich, 2015). However, a

large number of delegates meeting over a short period of time means rarely anything

7 The organizational structure of the State Council mentions that the State Council of the People’s Republic of
China, the Central People’s Government, is the executive organ of the highest organ of state power and the
highest organ of state administration. http://www.gov.cn/guowuyuan/index.htm.
8 As the abbreviation for National Party Congress and National People’s Congress are both NPC, to avoid

confusion, the expression Party Congress is used when referring to the National Party Congress. In Tony Saich’s
(2015) book Governance and Politics of China, the expression Party Congress is also used.
97
of importance will be seriously debated.9 It has an important symbolic role in some

aspects (Saich, 2015). When the PC is not in session, the CC of the CCP is, in theory,

the leading body of the Party. It meets more frequently, usually once a year in plenary

session. But its size (205 full members and 171 alternatives at the 18th PC) again

indicates that it is not truly a decision-making body in the Party.

In reality, decision-making power lies in the 18 to 25 Politburo members and its

Standing Committee (seven to nine members) in particular (Saich, 2015). They are the

most important Party organs in the decision-making process. When the CC is not in

session, the Politburo and its Standing Committee exercise significant functions and

power. According to Ran (2015), “China’s environmental policy-making system is a

limited pluralism under the control of the CCP” (p.40). The Standing Committee of

the Politburo on behalf of the Party formulates and legitimates macro and abstract

environmental ideas and strategies. The State Council and the NPC are responsible for

transforming the Party’s abstract will into specific laws, regulations and action plans

through certain procedures (Ran, 2015).

3.1.1 Change in the CCP’s Attitude towards Environmental Protection

The Standing Committee and the Politburo are supported in their works by a

number of Central Leading Groups (CLGs) (Saich, 2015). “[T]hey are usually headed

by a Standing Committee member and they serve both to help implement decisions by

coordinating work across the system and to funnel information and research back to

the Standing Committee of the Politburo” (Saich, 2015, p.96). The CLGs cover a range

9 For example, 2,270 delegates selected attended 18th PC from 8 Nov.,2012 to 14 Nov., 2012.
98
of issues such as foreign affairs, Taiwan, Hong Kong-Macao, finance and economics,

propaganda, security, party building and so on. Some of them are permanent, while

others are temporary. Their establishment, revocation and the arrangement of their

leaders usually reflect the concerns of the central government in key policy areas

(SHAW, 2005). After continuous adjustments, the CLGs mainly consist of six

categories: organization and personnel, propaganda, politics and law, finance and

economy, united front of foreign affairs, party building and party affairs (see Table 10

below). When CLGs were established in the 1950s, there was no leading group

specifically responsible for environmental protection (Ran, 2015). Zhuang (2016) has

pointed out that environmental protection, then, was not yet considered that important

by the CCP.

Table 10

The Central Leading Groups

Six Main Categories of CLGs Name of CLGs

Organization and Personnel Central Coordination Group on Personnel
Work
Propaganda Group on Propaganda and Ideological Work
Politics and Law Central Tibet Work Coordination Group
Central Xinjiang Work Coordination Group
Finance and Economy Group on Finance and Economy
Group on Rural Work
United Front Work Group on Foreign Affairs
Group on Taiwan Affairs
Central Hong Kong-Macao Work
Coordination Group
Party Building and Party Group for Party Building Work
Affairs Group on Inspection Work
Group on the Party’s Mass Line Education
and Practice.

99
Note. Adapted from the online information.10

The situation, however, changed with the 18th PC in 2013. Several new CLGs

were set up at the Third Plenum in November 2013, one of which is the Group on

Comprehensively Deepening Reforms (GCDR) headed by the General Secretary Xi

Jinping (Saich, 2015). This Group consists of six sub-groups which are mainly

responsible for system reform in various fields. The Group for Economic System and

Ecological Civilization System Reform (GESECSR) is also one of them. Its functions

include the formulation of major strategies, policies and overall plans for the

construction of ecological civilization system (Qiu, 2014). After the third plenary

session of the 19th PC (2017), the GCDR was upgraded as the Committee on

Comprehensively Deepening Reforms (CCDR). 11 This means that the deliberative

and coordinating body for system reform has changed from a periodic working

mechanism to a fixed one, with comprehensive functions, stable operation and sound

organization (Wan, 2018).

A number of guiding opinions and action plans on ecological protection have been

approved by GCDR and CCDR (see Table 11 and Table 12 below). By 2020, the

GCDR had held a total of 39 meetings, in which 16 meetings were related to

environmental protection. Of the 17 meetings CCDR held, eight were related to

environmental protection. 12
The contents of these meetings included the overall plan

10 The media summarized 18 leading groups of the Central Committee; Xi Jinping served as the leader of four
groups. Available at http://www.ce.cn/xwzx/gnsz/szyw/201406/23/t20140623_3016850.shtml; The number of
leading groups are more than 22, Xi served as the leader of four groups. Available at
http://news.china.com.cn/2015-07/31/content_36190622.htm.
11
The details of the reform can be found in the Program for Deepening the Reform of Party and State Institutions
(CC of the CCP, 2018). Available at http://www.gov.cn/zhengce/2018-03/21/content_5276191.htm#1.
12
The number and content of the GCDR and CCDR meetings can be found in Table 11 and Table 12 and in the
online information. Available at http://www.scopsr.gov.cn/zlzx/sgzhy/index_1.html.
100
of ecological civilization system reform, environmental monitoring, assessment and

accountability of cadres, improvement of ecological compensation mechanism,

construction of ecological civilization experimental area, protection schemes for rivers,

lakes, wetlands, coastlines and forests (see Table 11 and Table 12). Hence, the central

government has attached greater importance to environmental protection since the 18th

PC in 2012.

Table 11

Contents Related to Environmental Protection in GCDR Meetings

Meetings of the 18th GCDR
Time Meeting Meeting Contents on Ecological Protection
Jan.22, Establishing six special groups under the GCDR, including the
1st meeting
2014 GESECSR.
The meeting reviewed and approved the Report on Major
Reform of the Group for Economic System and Ecological
Feb.28, nd
2 meeting Civilization System Reform (Guanyu jingji tizhi he shengtai
2014
wenming tizhi gaige zhuanxiang xiaozu zhongda gaige de
huibao).
The meeting reviewed and approved the Environmental
Protection Supervision Program (Trial Implementation)
(Huanjing baohu ducha fang’an (shixing)), the Ecology and
Environment Monitoring Network Construction Plan (Shengtai
huanjing jiance wangluo jianshe fang’an), Pilot Program on the
th
Jul.1, 14 Audit of Leading Cadres' Natural Resources Assets after
2015 meeting Leaving Their Posts (Kaizhan lingdao ganbu ziran ziyuan
zichan liren shenji shidian fang’an), and Measures for
Investigating the Responsibility of the Party and Government
Leading Cadres for Ecology and Environment Damage (Trial
Implementation) (Dangzheng lingdao ganbu shengtai huanjing
sunhai zeren zhuijiu banfa (shixing)).
Listened to the report of the GESECSR on the implementation
Feb.23, 21st
of Overall Plan for the Reform of the Ecological Civilization”
2016 meeting
System.
The meeting reviewed and approved Opinions on Improving the
Mar.22 22nd
Compensation Mechanism of Ecological Protection (Guanyu
, 2016 meeting
jianquan shengtai baohu buchang jizhi de yijian).
th
Jun.27, 25 The meeting reviewed and approved Opinions on the

101
2016 meeting Establishment of A Unified and Standardized National
Ecological Civilization Experimental Zone (Guanyu sheli tongyi
guifan de guojia shengtai wenming shiyanqu de yijian), and
Implementation Plan of National Ecological Civilization
Experimental Zone (Fujian) (Guojia shengtai wenming
shiyanqu (Fujian) shishi fang’an)).
The meeting reviewed and approved Guiding Opinions on the
Pilot Reform of Vertical Management System of Monitoring,
Jul.22, 26th Supervision and Law Enforcement of Environmental Protection
2016 meeting Institutions below the Provincial Level (Guanyu shengyixia
huanbao jigou jiance jiancha zhifa chuizhi guanli zhidu gaige
shidian gongzuo de zhidao yijian).
The meeting reviewed and approved Measures for Compilation
and Implementation of Negative List of Industrial Access in Key
Ecological Function Zones (Zhongdian shengtai gongnengqu
chanye zhunru fumian qingdan bianzhi shishi banfa),
Aug.30 27th Evaluation Method of Ecological Civilization Construction
, 2016 meeting Objective (Shengtai wenming jianshe mubiao pingjia kaohe
banfa), Report on carrying out pilot reform of eco-
environmental damage compensation system in some provinces
(Guanyu zai bufen shengfen kaizhan shengtai huanjing sunhai
peichang zhidu gaige shidian de baogao).
The meeting reviewed and approved Opinions on the
Oct.11, 28th
Implementation of the River Chief System in An All-round Way
2016 meeting
(Guanyu quanmian tuixing hezhangzhi de yijian).
The meeting reviewed and approved Some Opinions on
Delimiting and Strictly Observing Ecological Protection Red
Line (Guanyu huading bing yanshou shengtai baohu hongxian
Nov.1, 29th
de ruogan yijian), Wetland Protection and Restoration System
2016 meeting
Scheme (Shidi baohu xiufu zhidu fang’an), and Coastal Line
Protection and Utilization Management Measures (Hai’anxian
baohu yu liyong guanli banfan).
Review the supervision report on the implementation of the
Mar.24 33rd
reform in the areas of people's livelihood such as the river chief
, 2017 meeting
system
The meeting reviewed and approved Implementation Plan on
Forbidding Foreign Garbage to Enter China and Promoting the
Apr.18, 34th
Reform of Solid Waste Import Management System (Jinzhi
2017 meeting
yanglaji rujing tuijin guti feiwu jinkou guanli zhidu gaige shishi
fang’an).
The meeting reviewed and approved Some Opinions on
May
35th Establishing A Long-term Monitoring and Early Warning
23,
meeting Mechanism for Resources and Environment Carrying Capacity
2017
(Guanyu jianli ziyuan huanjing chengzai nengli jiance yujing

102
 changxiao jizhi de ruogan yijian), Opinions on Deepening
Environmental Monitoring Reform and Improving the Quality
of Environmental Monitoring Data (Guanyu shenhua huanjing
jiance gaige tigao huanjing jiance shuju zhiliang de yijian), and
Pilot Scheme for Cross-regional Environmental Protection
Organizations (Kuadiqu huanbao jigou shidian fang’an).
The meeting reviewed and approved Interim Provisions on
Audit of Leading Cadres' Natural Resources Assets Leaving
Office (Lingdao ganbu ziran ziyuan zichan liren shenji zanxing
guiding), Implementation Plan of National Ecological
Civilization Experimental Zone (Jiangxi) (Guojia shengtai
Jun.26, 36th wenming shiyanqu (Jiangxi) shishi fang’an)), Implementation
2017 meeting Plan of National Ecological Civilization Experimental Zone
(Guizhou) (Guojia shengtai wenming shiyanqu (Guizhou) shishi
fang’an)). Review the Report on the Promotion and
Construction of the National Ecological Civilization
Experimental Zone (Fujian) (Guojia shengtai wenming
shiyanqu (Fujian) tuijin jianshe qingkuang baogao)).
The meeting reviewed and approved Reform Plan of
Aug.29 38th
Compensation System for Ecology and Environment Damage
, 2017 meeting
(Shengtai huanjing sunhai peichang zhidu gaige fang’an).
Meetings of the 19th GCDR
The meeting reviewed and approved Three Year Action Plan for
Rural Human Settlement Environment Improvement (Nongcun
Nov.20
1 meeting renju huanjing zhengzhi sannian xingdong fang’an), Guiding
st
, 2017
Opinions on Implementing Lake Chief System (Guanyu zai hupo
shishi huzhangzhi de zhidao yijian).
Note. Meetings of the GCDR. http://www.scopsr.gov.cn/zlzx/sgzhy/index_1.html .

Table 12

Contents Related to Environmental Protection in CCDR Meetings

Time Meeting Meeting Contents on Ecological Protection
The meeting reviewed and approved Guiding Opinions on the
Construction of Market-oriented Green Technology Innovation
System (Guanyu goujian shichang daoxiang de lvse jishu
Jan.23, chuangxin tixi de zhidao yijian), Natural Forest Protection and
6th meeting
2019 Restoration System Plan (Tianranlin baohu xiufu zhidu
fang’an), and Implementation Plan of National Ecological
Civilization Experimental Zone (Hainan) (Guojia shengtai
wenming shiyanqu (Hainan) shishi fang’an)).
May.3 The meeting reviewed and approved Opinions on Carrying Out
th
0, 8 meeting Comprehensive Reform Pilot Project of Energy Revolution in
2019 Shanxi Province (Guanyu zai Shanxi kaizhan nengyuan geming
103
 zonghe gaige shidian de yijian).
The meeting reviewed and approved General Plan for Creating
th
Sept.1 10 Green life (Lvse shenghuo chuangjian xingdong zongti
0, 2019 meeting fang’an), Opinions on Further Strengthening Plastic Pollution
Control (Guanyu jinyibu jiaqiang suliao wuran zhili de yijian).
The meeting reviewed and approved Guidance on the
Nov.27 11th
Construction of Modern Environmental Governance System
, 2019 meeting
(Guanyu goujian xiandai huanjing zhili tixi de zhidao yijian).
The meeting reviewed and approved General Plan for Major
Projects of National Important Ecosystem Protection and
Apr.28 13th
Restoration (2021-2035) (Quanguo zhongyao shengtai xitong
, 2020 meeting
baohu he xiufu zhongda gongcheng zongti guihua (2021-
2035)).
The meeting reviewed and approved Some Opinions on Pushing
Sept.2, 15th
Ahead with Garbage Sorting (Guanyu jinyibu tuijin shenghuo
2020 meeting
laji fenlei gongzuo de ruogan yijian).
The meeting reviewed and approved Opinions on
Nov.3, 16th
Comprehensively Implementing Forest Chief System (Guanyu
2020 meeting
quanmian tuixing linzhangzhi de yijian).
The meeting reviewed and approved Reform Program for the
Dec.31 17th
Legal Disclosure System of Environmental Information
,2020 meeting
(Huanjing xinxi yifa pilu zhidu gaige fang’an)
Note. Meetings of the CCDR. http://www.scopsr.gov.cn/zlzx/sgzhy/index.html.

The CCP’s change in attitude towards environmental issues was also reflected in

the PC’s reports. Such a change could also be outlined in three stages (Ran, 2015; Yu

& Liu, 2012). Details on the changes in the CCP’s understanding of environmental

protection are summarized in Table A1 in Appendix A.

The first stage lasted from 1982 to 1992 (Yu & Liu, 2012). The word “ecology”

was used for the first time in the report of the 12th PC in 1982 (Hu, 1982). At that time,

the Party’s understanding of environmental protection was combined with controlling

population size and solving food shortage problems (Liu, 2008). Food and clothing,

then, were the main concerns. In the report of the 13th PC (1987), population and

environmental problems were put together in discussion (Zhao, 1987). Initially, the

104
CCP thought that environmental pollution was an outcome of economic development.

Thus, the report proposed for the first time that it was necessary to combat

environmental pollution and strengthen the protection of ecological environment in

parallel with economic development. At this stage, the CCP did not address issues

related to water pollution.

From 1992 to 2002, the CCP’s understanding of environmental protection entered

the second stage, in which environmental protection was meant to serve the needs of

economic development (Yu & Liu, 2012). In the report of the 14th PC in 1992, it was

formally stated that “environmental protection is a basic state policy” (Jiang, 1992). In

1997, the “Sustainable Development Strategy” was explicitly proposed in the report

of the 15th PC. It acknowledged for the first time that enormous pressure on resources

and the environment caused by population growth and economic development was one

of the deficiencies in the work of the CCP (Jiang, 1997). It was at this stage that the

CCP became concerned with issues related to water scarcity and sought ways to

improve water use efficiency.

In the third stage from 2002 to 2012, the CCP began to recognize that the

environmental issues were not simply a matter of population, resources or agriculture,

but an institutional issue as well (Yu & Liu, 2012). In the report of the 16th PC, the

CCP proposed a comprehensive reform of the economic system to address the

contradictions between the environment and economic development (Jiang, 2002).

Institutional reform was further expressed in the report of the 17th PC in the “Scientific

Outlook on Development (SOD)” (Hu, 2007). It advocated adhering to a people-

105
centered, comprehensive, coordinated and sustainable development. The SOD was an

attempt by the CCP to systematically address challenges posed by environmental

issues to stability and the legitimacy of the regime. In terms of environmental

protection in regard to water, the report of the 17th PC (2007) not only proposed

increasing the efficiency of water resource use, but increasing investment for WPPC

(Hu, 2007).

After the 18th PC in 2012, the CCP entered the fourth stage in its understanding

of environmental protection. Environmental protection has since occupied a relatively

independent position in the policy agenda. In the report of the 18th PC, the CCP

introduced the concept of ecological civilization (Hu, 2012). As pointed out by the

former General Secretary Hu Jintao, “We must give prominence to the construction of

ecological civilization, and integrate it into all aspects and processes of economic,

political, cultural and social construction” (Hu, 2012). This is precisely the “five-in-

one” overall layout by the CCP in the new era. 13 In other words, environmental

protection will be as important as economic, political, cultural and social constructions.

The report of the 19th PC in 2017 further emphasized the construction and reform of

ecological civilization system (Xi, 2017). Later, General Secretary Xi Jinping

reiterated that, “We should strengthen the overall design and organizational leadership

of the construction of ecological civilization, set up institutions for the management of

state-owned natural resources assets and the supervision of natural ecology, and

improve the ecological and environmental management system” (Xi, 2017). In terms

13
The “five-in-one” overall layout refers to the promotion of economic, political, cultural, social and ecological
civilization as constructions in a comprehensive manner.
106
of water protection, the reports of the 18th and 19th PC focused more on WPPC as well

as water conservation. The report of 18th PC emphasized the reduction of major

pollutants by means of WPPC and water resources management (Hu, 2012). In the 19th

PC, it further emphasized the acceleration of WPPC and promoted the management

system for rivers and lakes (Xi, 2017).

Table 13 below presents the ideas of the CCP regarding water protection since the

14th PC. In general, from the 14th PC in 1992 to the 16th PC in 2002, the CCP was

mainly concerned with problems of water scarcity, water use efficiency and the

construction of ambitious water-related projects (Jiang, 1992, 1997, 2002). Since the

17th PC in 2007, the CCP has been paying more attention to WPPC (Hu, 2007, 2012).

During the 19th PC in 2017, the CCP put greater emphasis on the establishment of a

water protection system for maintaining a good water environment in the long term

(Xi, 2017).

Table 13

Statements on Water Environment Protection in the Reports of the PC

PC Statement related to water environment protection
14th PC Protect and make rational use of water resources.
Strictly implement the laws on water and marine
15th PC protection...control environmental pollution...conserve water and
soil.
Solve the problem of water shortage in some areas as soon as
16th PC
possible.
Protect water resource and improve the utilization
17th PC efficiency...increase investment on the prevention and control of
water pollution.
Decrease the total emissions of major pollutants significantly...Save
18th PC water resources...Strengthen water pollution prevention and
control...Improve water resources management system.
19th PC Coordinate the management of...rivers...lakes...speed up the

107
 prevention and control of water pollution...implement
comprehensive management of watershed environment and
offshore area.
Note. Adapted from the reports of PC.
http://cpc.people.com.cn/GB/64162/64168/index.html.

The revised Party Constitution of the 17th PC in 2007 stated that “the CCP leads

the people in building a resource-intensive and environment-friendly society” (The

17th National Party Congress of the CCP, 2007). The Party Constitution adopted at the

18th PC in 2012 also stated that “the CCP leads the people in building a socialist

ecological civilization” (The 18th National Party Congress of the CCP, 2012). Hence,

the CCP’s leadership over the country has gone beyond the political, ideological,

organizational and economic aspects. Now it includes the leadership in environmental

protection. The NPC and the State Council have formulated a series of environmental

laws, regulations and action plans under the guidance of the CCP’s philosophy in

different stages.

3.1.2 The Role of NPC, 2014 EPL and WPPCL

The making of WPPC Law and policies depends on a relatively holistic planning

system at the central level. At the top is the CCP who is the “architect” of

environmental political discourse. Such a political discourse has been changing with

the deepening of the CCP’s awareness of environmental protection. The NPC and the

State Council are two important bodies that translate the abstract will of the CCP into

laws, regulations and action plans for WPPC (Ran, 2015). The following discusses the

role of NPC in the formulation and legitimation of the 2014 Environmental Protection

Law (hereafter 2014 EPL) and WPPC Law (hereafter WPPCL).

108
 As the highest legislature in the Chinese political system, the NPC and its

Standing Committee are responsible for transforming the Party’s political discourse on

environmental protection into specific national laws. Although China’s environmental

legislation system includes the central level (NPC) and the local level (Local People’s

Congress), the NPC at the central level plays a leading role in the formulation and

revision of laws due to the boundary characteristics of environmental problems (Liu,

2004).

The NPC has ten specialized committees. The Environment and Resources

Protection Committee (ERPC) was established in 1994 (National People’s Congress

[NPC], 2020a). It is responsible for studying, deliberating and drafting environmental

related laws concerned with the prevention of environmental pollution, ecological and

environmental protection, and natural resources protection (NPC, 2020b). Since the

adoption of Environmental Protection Law (for Trial Implementation) in 1979, the

NPC and its Standing Committee have passed more than 20 laws related to

environmental protection (see Table 14 below). Most of the environmental protection

laws adopted before 2000 had not been revised for more than 10 years. With the strong

emphasis on the importance of environmental protection in the 18th PC and 19th PC,

many of these laws were revised successively. Among the revised laws, the 2014 EPL

and the Water Pollution Prevention and Control Law (WPPCL) have had the greatest

impact in tackling water pollution.

Table 14

Main Environmental Laws in China

109
 Name of Law Date of Formulation and Revision
Formulated and put into trial use on Sept. 13, 1979.
Environmental Protection
Adopted on Dec. 26, 1989.
Law
Revised on Apr. 24, 2014.
Adopted on Oct. 28, 2002.
Environmental Impact
Revised for the first time on July 2, 2016.
Assessment Law
Revised for the second time on December 29, 2018.
Adopted on September 5, 1987.
Air Pollution Prevention and Revised on August 29, 1995.
Control Law Revised for the first time on April 29, 2000.
Revised for the second time on August 29, 2015.
Adopted on May 11, 1984.
Water Pollution Prevention Revised for the first time on May 15, 1996.
and Control Law Revised for the second time on February 28, 2008.
Revised for the third time on June 27, 2017.
Adopted on October 30, 1995.
Solid Waste Pollution
Revised for the first time on December 29, 2004.
Prevention and Control Law
Revised for the second time on April 29, 2020.
Radioactive Pollution
Adopted on June 28, 2003.
Prevention and Control Law
Adopted on August 23, 1982.
Marine Environment Revised for the first time on December 25, 1999.
Protection Law Revised for the second time on December 28, 2013.
Revised for the third time on November 4, 2017.
Environmental Noise Adopted on October 29, 1996.
Pollution Law Revised on December 29, 2018.
Note. Sort out according to the policy documents of MEE.
http://www.mee.gov.cn/zcwj/.

1. Revision and the 2014 EPL

The revised EPL was passed at the 8th meeting of the 12th NPC Standing

Committee in April 2014 (hereafter 2014 EPL) (Gu & Luo, 2014). Prior to this, China

had been using the EPL passed in 1989 (hereafter 1989 EPL), which lagged behind the

needs of economic and social development. It was least effective in terms of law

enforcement (Wang, 2012). 14

The 2014 EPL was adopted after two consultations

14
Many NPC deputies believed that the 1989 EPL, has the characteristics of a planned economy and did not
dovetail with individual laws enacted later (such as the air pollution prevention and control law). From 1995 to
2012, a total of 2,474 NPC deputies raised 78 motions to amend the 1989 EPL (Wang, 2012).
110
with the public and four deliberations by the Standing Committee of the NPC. In an

extremely rare move, the then MEP proposed 34 amendments to the first review of the

EPL in its official website (Wang, 2012). The revision process reflected a political

game between the legislature and the environmental authorities and social forces.

There were revisions in five aspects (Standing Committee of the NPC, 2014).

Firstly, the phrase “to promote the development of socialist modernization” became

“to promote the construction of ecological civilization and sustainable economic and

social development” in the 2014 EPL. The amendment aimed to change the situation

of developing the economy at the expense of the environment and resources. Secondly,

the right on environmental public interest litigation was a new and most contested issue

during the law drafting (Liu, 2015). The initial draft of 2014 EPL did not even mention

such an issue. During the second deliberation, it was suggested that only the All-China

Environment Federation and the provincial Environmental Protection Federation

could file public interest litigation. By the third deliberation, social organizations

registered with the Ministry of Civil Affairs are granted the right to environmental

public interest litigation. In the fourth and final deliberation, such a right is extended

to social nonprofit organizations registered with the Civil Affairs Departments at or

above the city with districts (see Article 58 of 2014 EPL). Several hundred eligible

NGOs, but not individual citizens, are qualified to initiate environmental public

interest litigation.

Thirdly, the 2014 EPL expanded the environmental management functions of

local governments, while also strengthened their accountability in fulfilling

111
environmental protection responsibilities (Liu, 2015; Zhang et al., 2015). For example,

local governments are permitted to formulate local environmental quality standards

that are stricter than the national ones and are required to establish a data sharing

mechanism to strengthen the management of environmental monitoring. In addition,

environmental protection authorities are given the power of administrative seizure,

detention and continuous daily penalties.15 These newly added regulations make the

role of environmental protection authorities more prominent in environmental

governance. The 2014 EPL stipulated that local governments are responsible for the

environmental quality within their jurisdictions (see Article 6,8,9,10 of the 2014 EPL).

In areas that have failed to meet standards on expiration, the 2014 EPL stipulated the

“restriction of new projects approvals” (see Article 44 of 2014 EPL). The law also

required local governments to report their performance to the People’s Congress at the

same level and accept the latter’s supervision (see Article 27 of 2014 EPL). In addition,

administrative sanction, such as resignation, applies to leading cadres in local

governments and relevant government staff who have neglected to perform their

environmental protection duties (see Article 68 of 2014 EPL). Hence, environmental

protection agencies are no longer sole agents responsible for policy outcomes. Local

governments have to take into account environmental impact assessment when

planning economic and social development as they are ultimately responsible for the

quality of the local environment.

Fourthly, other than conventional environmental regulatory tools in the 1989 EPL,

15 The 2014 EPL deviates from caps on fines and only one-time penalties, and introduces a more severe
daily penalty system as long as environmental violation continues and with no maximum (see Article 59 of 2014
EPL).
112
the 2014 EPL has provided a legal basis for market-based instruments in improving

the environmental performance of industries (Zhang et al, 2015). Goods and services

like ecological compensation system (Article 31 of 2014 EPL), environmental liability

insurance (Article 52 of 2014 EPL) and green credit (Article 54 of 2014 EPL) are

required to be provided by the state or public enterprises; these are examples of

organization tools or tools of creating market in the World Banks’s scheme. While

environmental taxes (Article 43 of 2014 EPL) as a type of negative financial incentive

is an example of a type of treasure tool or using market in the World Bank’s scheme.

Lastly, the 1989 EPL did not include public participation and environmental

information disclosure, but the 2014 EPL aimed to strengthen and institutionalize

public participation and information disclosure (Zhang et al., 2015), which are

important in environmental governance. These are policy tools for engaging the public

in the World Bank’s scheme and nodality tools concerned with the use of information

by the state in Hood’s NATO’ scheme (ref. chapter two). Thus, government agencies

at county level and above are required to publicize information and data on

environmental quality, management and supervision (see Article 53, 54 of 2014 EPL).

Industrial polluters have to make public detailed information on pollution discharge,

construction and operation of environmental facilities public (see Article 55 of 2014

EPL). Environmental performance evaluations of local environmental agencies (and

their principals) and industries shall be published (see Article 54 of 2014 EPL).

Violations of environmental regulations should be recorded in the credit archive of

organizations/individuals. This is a system-in-the-making that can be used for the

113
promotion and demotion of local officials. The revised content of the 2014 EPL

reflected the transformation of China’s environmental governance from a unitary

government ruling to multi-participation led by government. Environmental

governance is supposed to be a benign interaction among responsible governments,

law-abiding enterprises and active citizens.

2. Revision of the WPPCL in 2017

On June 27, 2017, China’s top legislature passed the revised WPPCL (hereafter

the 2017 WPPCL). The 2017 WPPCL is closely connected with the 2014 EPL. It gives

due consideration to the problems pointed out in the Inspection Report on WPPCL

Enforcement 2015 (2015 nian Jiancha shuiwuran fangzhifa shishi qingkuang baogao)

of the NPC Standing Committee (Guo, 2015) and the Action Plan for Water Pollution

Prevention and Control (APWPPC) (State Council, 2015). The NPC Standing

Committee and relevant ministries made thorough preparation when revising the

WPPCL. 16
The added contents included the WPPC responsibilities of local

governments, joint prevention and control of watershed pollution, supervision and

management of WPPC, guarantee of drinking water safety, WPPC in key areas,

punishment of illegal activities and so forth (SCNPC, 2017).

First Deliberation of Revised WPPCL (Draft). The 25th meeting of the

Standing Committee of the 12th NPC in Beijing on December 20, 2016 carried out the

first review of the revised WPPCL (Draft) (hereafter the Revision Draft) submitted by

16
In 2015, the NPC Standing Committee carried out law enforcement inspection on the WPPCL. Subsequently, a
law enforcement inspection report was conducted and a special inquiry (zhuanti xunwen) on WPPC was carried
out at the 16th meeting of the Standing Committee of NPC held in August. The then Vice Premier Wang Yang led
13 leading cadres from 10 departments to answer inquiries from the NPC Standing Committee.
114
the State Council.17 The Revision Draft in the first deliberation mainly concerned six

aspects.18

First, to hold local governments responsible for WPPC, the Revision Draft added

the provision that if the water environment quality improvement targets set in the

WPPC plan are not met, the relevant municipal and county-level governments shall

formulate a plan for reaching the standard within a time limit...local governments can

put forward standards stricter than the national water pollutant discharge ones within

their jurisdictions (Ding, 2016). This is consistent with the provisions of Article 28 and

Article 16 in the 2014 EPL.19

Second, to strengthen the joint WPPC and ecological protection for the watershed,

the Revision Draft proposed that environmental protection departments under the State

Council shall, together with relevant departments and provincial governments,

establish a linkage and coordination mechanism for water environment protection of

major rivers and lakes (Ding, 2016).

Third, to improve the supervision and management system of WPPC, the

Revision Draft proposed three measures, which include the improvement of relevant

provisions for pollutant discharge permit, improvement of environmental monitoring

system and clarification concerning the self-monitoring obligations of pollutant

17
See the special report on first reviews of the amendment of the WPPCL by the Standing Committee of the
NPC. http://www.npc.gov.cn/zgrdw/npc/lfzt/rlyw/node_31814.htm.
18
These six aspects were interpreted by Ding Ming (2016), who was the Deputy Director of the Bills Office of
the Environment and Resources Committee of the National People’s Congress.
19
Article 28 of the 2014 EPL: the relevant local governments of key areas and river basins that fail to meet the
national environmental quality standards shall formulate plans to meet the standards within a time limit and take
measures to meet the standards on time.
Article 16 of the 2014 EPL: the governments of provinces, autonomous regions and municipalities directly under
the central government may formulate local pollutant discharge standards for items not specified in the national
pollutant discharge standards; For items already specified in the national pollutant discharge standards, local
pollutant discharge standards can be stricter than the national ones.
115
discharge units, and establishing a list of toxic and harmful water pollutants. These

three measures allow for a full process monitoring of water pollutant discharge (Ding,

2016).

Fourth, WPPC measures in key areas such as industrial effluent, groundwater,

agriculture and rural sewage shall be strengthened. Fifth, the drinking water safety

guarantee system shall be strengthened as well. The Opinions on Accelerating the

Building of Ecological Civilization (OABEC) and the APWPPC all proposed to

“strengthen the whole process management of water supply and ensure the safety of

drinking water” (Central Committee of the CCP [CC of the CCP] & State Council,

2015).

Sixth, enterprises that break the law on pollutant discharge will face increased

penalties. The Water Pollution Prevention and Control Law (2008) (hereafter the 2008

WPPCL) only imposed a fine of not less than twice and not more than five times the

pollutant discharge charges for units discharging pollutants in excess of the standard

and/or in excess of the total amount (Standing Committee of the NPC, 2008). In

practice, such penalties did not create a strong deterrent for enterprises (Ding, 2016).

In order to keep pace with the 2014 EPL, the Revision Daft suggested that the

department in charge of environmental protection at or above the county level may

order the enterprises to make corrections, restrict production or suspend production for

rectification. Fines of more than RMB 100,000 or less than RMB 1 million shall be

charged for serious violations and such enterprises could be shut down (Ding, 2016).

Second Deliberation of Revised WPPCL (Draft). On June 22, 2017, the 28th

116
meeting of the Standing Committee of the 12th NPC deliberated the Revision Draft for

the second time.20 The added relevant contents included the River Chief System (RCS)

and modified contents on the safe disposal of sludge, agricultural non-point source

pollution, punishment for illegal acts pertaining to water environment and so forth

(Gao, 2017).

Since the general office of the CC of the CCP and the general office of the State

Council issued the Opinions on the Full Implementation of the River Chief System

(OFIRCS) in December 2016, some members from the NPC Standing Committee,

environmental protection departments, and the public demanded that the draft should

reflect the relevant contents of the RCS as well (Gao, 2017). Thus, a provision was

added in the draft for a second review.

Some sludge contains toxic and harmful substances, which will cause new

pollution if not handled properly. With more and more sludge being generated from

the increasing rate in centralized urban sewage treatment, the draft proposed that

The operating unit of the centralized urban wastewater treatment facility or the

sludge treatment and disposal unit shall safely treat and dispose of sludge to ensure

that the treated and disposed sludge meets national standards and record the

destination of the sludge. (Gao, 2017)

To deal with the impact of agricultural non-point source pollution, the draft

suggested that

Agricultural departments and other relevant departments of local governments at

20
See the special report on second review of the amendment of the WPPCL by the Standing Committee of the
NPC. http://www.npc.gov.cn/zgrdw/npc/lfzt/rlyw/node_31814.htm.
117
 or above the county level should promote soil testing and fertilization techniques

and high-efficiency, low-toxicity and low-residue pesticides, and governments

where livestock and poultry are scattered should organize farmers to collect

livestock and poultry manure and sewage for centralized treatment and utilization.

(Gao, 2017)

Finally, to punish illegal acts pertaining to water environment, the draft proposed

revision in the following two aspects. One aspect is to increase the legal liability for

any violations due to the misrepresentation of monitoring data, failure to build

groundwater quality monitoring wells and failure to use double-layered oil tanks in

underground tanks (Wang, 2017). The other is to increase fines for illegal discharge of

oil, acid and alkali into water. If the situation is serious, it shall be reported to the

government with the power to cease operation (Wang, 2017).

The 2017 WPPCL was adopted in the 28th meeting of the Standing Committee of

the 12th NPC on June 27, 2017 and became effective on January 1, 2018. 21
After two

deliberations by the NPC Standing Committee, the new WPPCL aimed at

strengthening the responsibilities of local governments, improving the system of

pollutant discharge permit, guaranteeing drinking water safety, preventing and

controlling groundwater pollution, jointly preventing and controlling water pollution

in cross-regional river basins, and increasing penalties and so on. All these changes

served to ensure that the targets are clear and implementable. The content of the revised

WPPCL is helpful in transforming the concept of ecological civilization into

21
See the special report on second review of the amendment of the WPPCL by the Standing Committee of the
NPC. http://www.npc.gov.cn/zgrdw/npc/lfzt/rlyw/node_31814.htm.
118
implementable measures for water environmental protection; it is highly consistent

with the content and the policy instruments listed in the 2014 EPL and documents

related to the construction of ecological civilization issued by the CC of the CCP (see

Table 15 below).

3.1.3 The Role of the State Council and Government Reorganization

As the highest administrative organ in China, the State Council and its sub-

agencies are jointly responsible for making the abstract environmental political

discourse of the CCP concrete and operational through administrative regulations and

action plans (Zhu, 2008). There are more than 50 environment related administrative

regulations promulgated by the State Council (Ran, 2015), including a series of

specific policy tools and regulatory measures to facilitate the implementation of

environmental policies. These include environmental impact assessment system, three

simultaneities (san tong shi), pollution-discharge charge system (paiwu shoufei zhidu),

pollutant discharge declaration-registration-permit system (paiwu shenbao dengji he

xuke zhidu), environmental protection target responsibility system (huanbao mubiao

zerenzhi), total amount control, regional/watershed restricted approval system

(quyu/liuyu xianpi zhidu), emissions trading (pilot) and so forth (Yang, 2016). Some

of these measures are aimed at individuals or enterprises, while others at the market or

local governments. These policy tools are mainly command-and-control instruments.

119
 Table 15

Revised Contents of WPPCL in the Two Deliberations

1st 2nd Relevant Articles in
Revised Contents Basis for Revision
Review Review the 2017 WPPCL
Local governments’ responsibility on Article 16, 26and 28 of the 2014 EPL Article 4, 6, 14
√
water environment protection
Joint prevention and control of water Article 20 of the 2014 EPL Article 13, 16
√
pollution and ecological protection
Supervision and management system of Article 17,18, 30, 44 and 45 of the 2014 Article 10, 20,
√
water pollution prevention and control EPL 21,25, 29, 32
Water pollution prevention and control Guiding Opinions on Promoting Article 44, 45,
√

120
measures in key areas Ecological Civilization 53,54,55,56, 59
Drinking water safety guarantee system Opinions on Accelerating the Building Article 63-73
√
of Ecological Civilization; APWPPC

120
Set up strict legal liability √ Article 59, 60 of the 2014 EPL Article 83
River Chief System Opinions on the Full Implementation of Article 5
√
the River Chief System
Sludge treatment and disposal √ - Article51, 88
Agricultural non-point source pollution Article 33,49 of the 2014 EPL Article 52, 53, 55,
√
56
Further strengthen the punishment of Article 59, 60 of the 2014 EPL Article82, 83,94
√
illegal acts
Note. Compiled by the author.
Some economic tools (i.e. treasure-based instruments) may be positive and negative

financial incentives, but not legally binding on policy addressees and voluntary on

their part. As for nodality tools, public participation and information disclosure were

not included till 2012. In general, the central government is quite dependent on

command-and-control instruments in environmental governance, in which authority as

the principle of governance (as stated in Hood’s NATO scheme, ref. chapter two) is

comparatively prominent. This was also the case in the field of WPPC before 2012.

In the past, the government depended on environment and resources indicators in

the FYP for national economic and social development. After the promulgation of the

FYP, the State Council and its subordinate environment related departments

formulated specific environmental policies to achieve these targets. During the 11th

FYP from 2006 to 2010, the central government had assessed the performance of local

governments through those legally binding indicators. As a goal, the FYP attempted to

reduce total major pollutants by 10 per cent (see Table 2 in Chapter 1). For WPPC, a

capped chemical oxygen demand (COD) quota was the binding indicator.22 During

the 12th FYP from 2011 to 2015, six binding indicators were set up as a response to

serious environmental and energy problems. Decreasing COD by eight per cent and

ammonia nitrogen by ten per cent were two important indicators for WPPC (see Table

2). In the 13th FYP (2016-2020), eight more environmental binding indicators were

added, which include the proportion of surface water quality reaching worse than Class

22
Chemical oxygen demand (COD), is the amount of oxidant consumed when a certain strong oxidant is used to
treat a water sample under certain conditions. It is an indicator of how much reducing substances are in the water
(the reducing substances in water include various organic substances, nitrites, sulfides, ferrous salts, etc., but the
main one is organic substances). Therefore, COD is often used as an indicator to measure the amount of organic
substances in the water. The greater the COD, the more polluted the water body is by organic matter.
121
V or better than Class III (see Table 2).

Although the indicators for WPPC do not appear to be complex, they actually

involve many sectors. The sources of water pollution are mainly industrial pollution,

domestic pollution and agricultural pollution. Therefore, the MEE and the Ministry of

Water Resources (MWR) have to cooperate with other agencies in WPPC works. They

work with the National Development and Reform Commission (NDRC) on economic

development, with the Ministry of Industry and Information Technology (MIIT) and

the Ministry of Housing and Urban-Rural Development (MHURD) on urban

construction, and with the Ministry of Agriculture and Rural Affairs (MARA) on rural

development. 23

Given the traditionally weak position of environmental authorities, the power to

develop plans related to WPPC was scattered among various departments (Chen, 2009;

Ran, 2015). The dispersal of power as a phenomenon was prominent in the 1989 EPL.

The law stipulated that state marine, public security, transport, railway authorities can

implement supervision and management of environmental pollution prevention and

control (Standing Committee of the NPC, 1989, Article 7). As a result, there were

problems of bull management, overlapping responsibilities, unclear authority and

responsibility in WPPC. Nevertheless, Wu (2009) noticed that, “environmental

protection is a compound issue area ... not exclusive to China but for most states,

environmental governance in its entirety spreads out across a number of sectors and

corresponding institutions” (p.388). In the case of China, the fragmentation of water

23
The above sectors involved in WPPC can refer to the division of labor in the APWPPC (State Council, 2015).

122
pollution prevention and control is not typical of China’s political system. The key

question, then, is whether there is a mechanism that can well coordinate cooperation

among multiple sectors. Before the 18th PC in 2012, it lacked such an effective

mechanism in the field of WPPC.

After 18th PC, the central government has taken at least two measures to improve

this situation. First, compared with the 1989 EPL, the 2014 EPL stipulated that the

department in charge of environmental protection under the State Council shall

exercise unified supervision and management on environmental protection nationwide

(Standing Committee of the NPC, 2014, Article 10). This ruled out the power of other

departments to meddle in unified supervision and management. Second, the MEP was

upgraded and renamed the Ministry of Ecology and Environment in 2018 (see Table

A3 in Appendix A for the evolution of China’s environmental protection authority).

Consequently, the power concerned with environment protection has been redefined

and divided. Environmental functions that were once scattered among the NDRC, the

Ministry of Land and Resources (MLR), the MWR, the Ministry of Agriculture and

the State Oceanic Administration were transferred to the MEE (CC of the CCP, 2018).

These two measures have established the leadership of the MEE in environmental

protection, facilitating the coordination and cooperation between and among other

state authorities or agencies.

3.2 WPPC Policy Characteristics and the Emergence of Political Implementation

The system of formulating WPPC policies at the central level is relatively well

developed. Yet the implementation outcomes of these policies at the local level are

123
widely questioned (Ran, 2013; Kostka & Mol, 2013). The characteristics of a policy

may affect the results of policy implementation (Matland, 1995). The following lists

and analyzes the features and changes in WPPC policy characteristics for

implementation before and after 2012.

3.2.1 Policy Characteristics and Emerging Political Implementation Before 2012

Before 2012, most of the documents on WPPC were put forward by ministries

and commissions, such as MEP (SEPA), NDRC (SDPC) and MWR (see Table A2 in

Appendix A for the WPPC documents issued by the central government). Upon

approval by the State Council, these documents were distributed to the relevant local

governments as well as departments under the State Council.

From 1998 to 2011, the State Council successively approved WPPC plans for Tai

Lake, Liao River, Hai River, Huai River. Most of the plans were first proposed by the

then State Environmental Protection Administration (SEPA), the MWR and the NDRC

(see Table A2). These plans were distributed to the relevant departments and provincial

governments where the rivers are located. Since its establishment in 1998, SEPA had

asked the State Council for instructions on a series of WPPC plans such as Tai Lake,

Liao River and Huai River. The contents included the prevention and control of

industrial pollution or agricultural non-point source pollution, industrial structure

adjustment, urban sewage treatment, accountability and fund-raising (SEPA, 2003).

However, these WPPC policies issued before 2012 were only for some provinces and

cities, and were not systematic in content. Besides, these policies lacked the necessary

institutional safeguards for implementation, which were particularly evident in regard

124
to the assessment and accountability of local governments (SEPA, 2003; GOSC, 1999).

Table 16

Central Policy Framework of WPPC before 2012

CCP NPC State Council
Sustainable
Political development;
discourse The scientific outlook
on development.
1989EPL;
Water Environmental Protection
1996WPPCL;
Laws
2008WPPCL.
WPPC plans for Tai
Lake, Liao River, Hai
River, Huai River,
Dianchi Lake, Wei
Water Environmental Protection Regulations and
River and Songhua
Tools River;
National groundwater
pollution prevention
and control plan.
Note. Compiled by the author.
Table 16 above summarized the policy framework for WPPC before 2012. The

CC of the CCP put forward the ideas of sustainable development and SOD in the

reports of the PC, but it did not issue specific documents on the overall plan for

environmental protection (see Table A2). In terms of the NPC, environmental

protection law then still followed the 1989 EPL, and the WPPCL formulated in 1984

was revised in 1996 and 2008 (Standing Committee of the NPC, 2008). The State

Council and its subordinates then successively issued WPPC plans for Taihu Lake,

Liao River, Hai River, Huai River, Dianchi Lake, Wei River and Songhua River as well

as national groundwater pollution prevention and control (see Table A2). The plans for

other rivers and lakes issued during this period were similar in content. 24 Their main

24 Relevant documents for WPPC are available at http://www.gov.cn/zhengce/content/2010-

125
objectives were concerned with the water quality of urban centralized drinking water

sources as well as water quality in river basins or lakes. These plans focused on

controlling COD discharge in industrial wastewater and urban domestic sewage.

Besides COD discharge, the plan for Taihu Lake had included the discharge of total

phosphorus and total nitrogen (SEPA, 2003; State Council, 1998).

1. WPPC in Liaohe River Basin and Policy Ambiguity

In symbolic implementation, implementation outcomes depend on the local

context and local actors as policy ambiguity and policy conflict are both high (Matland,

1995). Ambiguity may be a kind of compromise in the process of decision-making

when conflict is high among participants (Matland, 1995). Ambiguity of policy

objectives or means may lead to implementation deficits or failure. However, policy

ambiguity was not the cause for implementation deficits in all cases of WPPC

implementation before 2012. Even then, not all cases of environmental policy

implementation were symbolic. The case of WPPC policy implementation in Liaohe

River, which had adopted the indicators in the WPPC plan set forth by the central

government, is elucidated below to show the emergence of political implementation

for WPPC policy implementation before 2012 (see Table 17 below).

In both the Nineth FYP from 1996 to 2000 and the Tenth FYP from 2001 to 2005

for WPPC of Liaohe River Basin, implementation targets were clearly set (SEPA,

2003). In the plan, two types of water bodies were expected to meet different standards

and the discharge of pollutant COD was also clearly specified (see Table 17 below).

11/14/content_5175.htm, http://www.gov.cn/zhengce/content/2010-11/19/content_5185.htm.
126
Therefore, the goals for the WPPC plan were, at face value, relatively clear and

unambiguous.

Table 17

Objectives in WPPC Plan of Liaohe River Basin

Main Indicators 2000 2005
Water quality of Meet class II Not be less than class III
urban centralized
drinking water
sources
Water quality in Not lower than Class V The water quality of the 45
the river basin monitoring sections were
regulated separately
Maximum Inner Mongolia: 29,000 tons Inner Mongolia: 26,434.7tons
allowable COD Liaoning: 207,300 tons Liaoning: 268,472.3 tons
discharge in Three Jilin: 34,900 tons Jilin: 40,922.5 tons
Provinces

Note. Adapted from SEPA (2003).

Six key projects were proposed in the Plan to achieve those objectives, which

included drinking water source protection, rural well drilling, industrial pollution

prevention and control, urban sewage treatment plant construction, water environment

improvement and ecological protection, and water quality monitoring system

construction and water environment investigation. Each project specified the number

of completions and planned investment amounts in different provinces (SEPA, 2003).

In terms of fund-raising, local governments at all levels bore a total investment of

RMB 18.847 billion for Liaohe River Basin with appropriate support from the state

during the Tenth FYP (2002-2007), in which the responsibility of supervision fell on

provincial environmental protection bureaus (SEPA, 2003). The plan’s accountability

system stated that

127
The discipline inspection and supervision departments of the environmental protection

bureaus of the three provinces and regions, shall take the initiative to report the

environmental protection law enforcement and supervision to the provincial and

regional supervision departments ... seriously investigate and deal with those who do

not implement the Reply of the State Council or even violate laws and disciplines,

according to the Party discipline and government discipline. (SEPA, 2003, p.47)

2. WPPC in Liaohe River Basin and Policy Conflict

Matland (1995) has pointed out that policy conflict will exist when more than one

organization sees a policy as directly relevant to its own interests and when these

organizations have incongruous views. Such differences can occur in either the

professed goals of a policy or the programs planned to implement the policy. Goal

setting and the division of institutional functions are two aspects of importance to

WPPC policies.

From the perspective of goal setting, conflict between environmental protection

and economic development came to the fore. Since the reform and opening up,

environmental protection was considered anathema to economic development, with

the latter being of central importance. 25 The central government had accorded

environmental protection lower priority than economic development. Article 1 of the

1989 EPL reflected such a conflict between protecting the environment and continuing

economic development: “[T]his Law is formulated for the purpose of protecting and

improving people’s environment and the ecological environment, preventing and

25
This is illustrated by the content of the reports of successive Party Congresses and the FYPs. See Table A1 in
Appendix A for a list of changes in the CCP’s attitude to environmental issues.
128
controlling pollution and other public hazards, safeguarding human health and

facilitating the development of socialist modernization” (Standing Committee of the

NPC, 1989).

In the WPPC of Liaohe River Basin, the central government tried to change the

situation of water pollution within a short period with several strict targets. When

governments continued to give priority to economic development, allocating the

responsibility for environmental protection to some traditional, development-oriented

departments led to functional conflicts within the bureaucracy. Although NDRC is

supposed to be responsible for clean energy and issues related to climate change, its

core works are concerned with macroeconomic development, planning and

supervision (NDRC, n.d.). The construction of hydropower stations and dams is more

in line with the interests of MWR, which is responsible for the protection of water

resources and the development and utilization of water resources (MWR, n.d.). The

rapid expansion of hydropower projects in ecologically fragile areas such as Yunnan

Province is closely related to the interests of water resource departments (Mertha,

2008). Although Ministry of Agriculture (MA) is mainly responsible for

environmental pollution problems in agriculture and rural areas, it attached greater

importance to grain production, increasing farmers’ income and the development of

township enterprises (MA, 2017.). The agricultural department is worried that strict

environmental standards for pesticides and fertilizers may affect agricultural output,

farmers’ income and even the country’s food security (Ran, 2015).

The WPPC plan of Liaohe River Basin is an epitome of all WPPC plans before

129
2012. Its implementation outcomes were unsatisfactory in practice. The Ninth FYP

(1996-2000) for WPPC in Liaohe River Basin stipulated that the water quality of the

whole basin should not be worse than Class V, water quality of urban centralized

drinking water sources should meet class II standard, while the total COD discharge

of the three provinces should be controlled at 271,200 tons by 2000 (SEPA, 2003).

However, information from SEPA (2003) showed that proportion of water quality

worse than Class V was 51.9 per cent, the standard rate of drinking water quality was

only 62.5 per cent, and the total COD discharge reached 583,300 tons. In addition,

more than half of the industrial pollution source treatment projects failed to meet the

requirements of technical transformation and cleaner production, only one tenth of the

urban sewage treatment projects were completed, and most of the well drilling projects

had not even started. Of the 1,730 wells, only four well drilling projects were

completed (SEPA, 2003).

In political implementation, “successful implementation depends on either having

sufficient power to force one’s will on the other participants or having sufficient

resources to be able to bargain an agreement on means. Coercive and remunerative

mechanisms will predominate” (Matland, 1995, p.164). Although policy ambiguity

was relatively low in the case of WPPC in Liaohe River Basin, conflict in

implementation was very high. In the Tenth FYP (2002-2007) for the WPPC in the

Liaohe River Basin, 12 departments at the central level, including SEPA, SDPC, State

Economic and Trade Commission (SETC), MWR, Ministry of Construction (MC)

were involved (SEPA, 2003). Given SEPA’s weak position among many departments,

130
implementation turned out to be unsatisfactory despite SEPA’s supervisory and

coordinating role. As an effective mechanism for ensuring the accountability of

environmental protection was still lacking, the WPPC policy in Liaohe was poorly

implemented. Obviously, the central government did not have sufficient power or

resources to force local governments to comply with its will at this stage. As coercive

and remunerative mechanisms were inadequate in WPPC policy implementation

before 2012, poor implementation by local governments was the norm, rather than

exception even though implementation might be less than symbolic.

3.2.2 Reducing Ambiguity and Alleviating Conflict in WPPC Policy after 2012

After 2012, the CCP began to promote environmental protection rigorously.

Tackling water pollution became a priority. For the first time, the ideas of constructing

ecological civilization were reported in the PC (Hu, 2012). Meanwhile, the CC of the

CCP issued three documents as an overall plan.26 The Standing Committee of the NPC

revised the 1989 EPL in 2014 and the 2008 WPPCL in 2017. Several important

documents on environmental protection for water were issued by the State Council and

released together with the CC, for example, the documents on RCS (General Office

of the Central Committee of the CCP & General Office of the State Council

[GOCCCCP & GOSC], 2016). With greater attention from the central government,

WPPC policy after 2012 has become more systematic and complete in guiding

ideology, action plan, prevention and control regulations as well as institutional

26
The three documents are: Decision on Several Major Issues Concerning Comprehensively Deepening Reform
(CC of the CCP, 2013); Opinions on Accelerating the Building of Ecological Civilization (CC of the CCP & State
Council, 2015a); Overall Plan for the Reform of Ecological Civilization System (CC of the CCP & State Council,
2015b).
131
guarantee (see Table 18 below).

Table 18

Central Policy Framework of Water Environment Protection after 2012

State
CCP NPC
Council
Idea:ecological civilization
Documents:
⑴Decision on Several Major Issues
Concerning Comprehensively
Deepening Reform (Guanyu quanmian
shenhua gaige ruogan zhongda wenti de
jueding);
Political
⑵Opinions on Accelerating the
discourse
Building of Ecological Civilization
(Guanyu jiakuai tuijin shengtai
wenming jianshe de yijian)
⑶Overall Plan for the Reform of
Ecological Civilization System
(Shengtai wenming tizhi gaige zongti
fang’an)
2014EPL;
Water Environmental Protection Laws
2017WPPCL.
OISWRMS;
Water Environmental Protection Regulations and Tools APWPPC;
OFIRCS.
Source: compiled by the author.

In 2012, the State Council issued the first national document on water resources

management Opinions on Implementing the Strictest Water Resources Management

System (OISWRMS). Later, the State Council issued two important documents:

APWPPC in 2015 and OFIRCS in 2016 (see Table 18 above). APWPPC proposed ten

measures to guide local governments in WPPC for the first time (State Council, 2015).

OFIRCS was jointly issued by the general office of the CC and the general office of

the State Council to strengthen the accountability of local governments and ensure the

132
full implementation of the APWPPC (See Table A2 in Appendix A for main WPPC

documents issued by the State Council).

1. APWPPC and Reducing Policy Ambiguity

In the APWPPC, exact objectives and systemic measures have been put forward

for implementing WPPC (see Table 19 below), which is supposed to be “led by

governments, implemented by enterprises, driven by market, participated by the public”

(State Council, 2015). The five aspects of water pollution are: polluted river basins,

black and odorous water bodies in built-up areas in cities, centralized drinking water

source, groundwater and offshore areas. The control of pollutant discharge includes

industrial pollution, urban domestic pollution, agricultural and rural pollution as well

as ship and port pollution (State Council, 2015).

Table 19

Main Objectives and Indices Proposed by the APWPPC

Deadline Objectives
2020 The national water environment
quality will be periodically
improved.
Heavily polluted water bodies
dramatically will be reduced.
Drinking water safety guarantee
continuously will be improved.
Groundwater overexploitation
will be strictly controlled,
groundwater pollution will
preliminarily be controlled.
Key Indices
The overall proportion of water quality
of seven basins being above average
(reaching or exceeding Class Ⅲ) will be
70% or above.
Quantity of black and odorous water
bodies in built-up areas in cities at
prefecture level and above will be
controlled within 10%.
The overall proportion of centralized
drinking water source quality in cities at
prefecture level and above reaching or
exceeding Class Ⅲ will be larger than
93%.
The proportion of extremely poor
groundwater quality nationwide will be
controlled around 15%.

133
 Environmental quality in offshore
areas becomes better.
Water ecological environment in
Beijing-Tianjin-Hebei Region,
Yangtze River Delta, Pearl River
Delta and other areas will be
improved.
Note. State Council (2015).
The proportion of above average (Class
I and II) water quality in offshore areas
will reach about 70%.
The proportion of unusable (below
Class V) water sections in Beijing-
Tianjin-Hebei Region will be about
15% lower, and efforts should be made
to eliminate unusable water bodies in
the Yangtze River Delta and Pearl River
Delta.

In the APWPPC, there are ten measures and a total 35 actions to achieve the stated

goals (see Table A4 in Appendix A for the targets, measures and actions in APWPPC).

These ten measures are: the overall control of pollutant discharge, promoting

transformation and updating of economic structure, water resources saving and

conservation, strengthening sci-tech support and so forth. Each measure covers three

to four specific action plans, completion time and standards as well as the division of

labor in different departments (State Council, 2015). For example, prevention and

control of industrial pollution as the first plan in the overall control of pollutant

discharge involves specific means, such as “to close down ten categories of small

enterprises”, completion time “before the end of 2016” and stipulated division of labor

to be “led by MEP, MIIT, MLR and implementation by local governments at different

levels” (State Council, 2015). Compared with the policy before 2012, the current

WPPC policy has clearer objectives, specific measures, relatively clear division of

labor; this has greatly reduced the level of policy ambiguity.

2. Building a Mechanism to Deal with Conflicts

Giving priority to environmental protection at the central level does not mean a

134
decrease in conflict. On the contrary, it may lead to the escalation in conflict. Before

the 18th PC in 2012, the CCP put forward the ideas of sustainable development and

SOD. However, the legislation, policy tools and institutional guarantee did not keep

up with those ideas. Implementing WPPC might have been regarded as symbolic by

some local governments even though the central government had tried to make

implementation politically imperative. After all, local governments were not held

accountable for failing to achieve WPPC goals. After the 18th PC, the central

government has proposed the strengthening of performance assessment and

accountability system and issued Measures on Accountability of the Party and

Government Leading Cadres for Ecological Environment Damage (for Trial)

(Dangzheng lingdao ganbu shengtai huanjing sunhai zeren zhuijiu banfa (shixing),

MAPGLCEED) (Central Committee of the CCP & State Council, 2015c). The central

government has also promoted the implementation of River Chief System and Lake

Chief System across the country. 27

Conflicts tend to be reflected in the divergence of interests between the central

government and local governments. One of the typical cases is the demolition of illegal

villas in Qinling Mountains (CCTV, 2019). From May 2014 to July 2018, General

Secretary Xi Jinping had instructed the destruction of villas illegally built in Qinling

Mountains for six times. However, local governments did not carry out the central

government’s directives and were indifferent to the instructions. Besides, the illegal

27
See the two documents issued by central government.: Opinions on the Full Implementation of the River Chief
System (GOCCCCP & GOSC, 2016); Guidance on the Implementation of the Lake Chief System (GOCCCCP &
GOSC, 2018).
135
filling of Qiandao Lake drinking water reserve, the shrinking of Kelamayi reserve in

Xinjiang Province to give way to coal mines, and the private cofferdams of Dongting

Lake in Hunan province all reflected the escalation of conflicts between the local and

central authorities on environmental protection issues. On the one hand, the central

government has highly advocated environmental protection. On the other hand, local

governments have for many years benefitted from environmental damage. As Matland

(1995) said, “compliance is not automatically forthcoming” (p.163). Successful

implementation, such as the case of Qinling illegal villas, was in the end due to the

strong intervention of the central government (CCTV, 2019).

The central government’s stance and attitude toward environmental protection

has become stronger after 2012. Although economic development is still a top priority,

the CCP believes that environmental pollution has to be urgently dealt with if China

were to develop sustainably (Hu, 2012; Xi, 2017; The 18th National Party Congress of

the CCP, 2012). The revision of the Party Statute and the statement in the reports of

the 18th and 19th PC have clearly demonstrated that the CCP’s change in attitude

towards environment protection. Besides, the CC of the CCP has successively issued

important documents on the overall layout of ecological civilization. These are:

Decision on Several Major Issues Concerning Comprehensively Deepening Reform

(DSMICCDR), Opinions on Accelerating the Building of Ecological Civilization

(OABEC), and Overall Plan for the Reform of Ecological Civilization System

(OPRECS). In DSMICCDR, Articles 51-54 consist of four principles for developing

ecological civilization. OABEC is about the overall requirement of building ecological

136
civilization. OPRECS has put forward constructing nine systems to realize long-term

ecological protection.

Figure 8

Overall Plan for Building Ecological Civilization

Note. Compiled by the author.

Although these three documents aimed at different aspects of building ecological

civilization, the contents are highly unified on how to build ecological civilization

(Central Committee of the CCP & State Council, 2015a, 2015b). The core of ecological

civilization construction is to improve the property rights system of natural resources

and assets. After finding out how much natural resources China has, the overall

environmental planning and land development can be effectively carried out. In the

process of development, on the one hand, it needs to pay attention to the control and

economical use of natural resources. Endowing natural resources with value,

137
improving the ecological compensation system and establishing the corresponding

market mechanism are means for saving natural resource. On the other hand, it has to

prevent and control environmental pollution through the joint participation of

government, market and society. The establishment and implementation of all these

systems and measures highly depend on governments at all levels to perform their

environmental functions well; this is also about improving the performance assessment

and accountability system of ecological civilization (See Figure 8 above for the overall

idea of building an ecological civilization).

The release of a series of documents on the construction of ecological civilization

has made local governments keenly aware that environmental protection is one of the

most important policies on the central policy agenda. The objectives listed in the

APWPPC are relatively complete, systematic and operational. It is unlike the water

pollution targets set before 2012 when local governments had to self-finance and

achieve policy goals within a short period of time. Before 2012, conflicts between the

central and the local were partly mitigated due to the relatively weak stance of the

central government towards environmental protection. Functional conflicts between

central departments were often alleviated through the Ministerial Joint Meeting on

Environment (Huanjing buji lianxi huiyi). However, such an approach was not

appropriate and effective due to the weak position of the environmental protection

authorities then. In general, a corresponding conflict resolution mechanism had not

been established by the central government before 2012.

Conflicts among various central departments are unavoidable when the APWPPC

138
enlisted as many as 12 leading departments in various actions, not to mention the

participating departments. After the 18th PC, the central government has taken two

measures to manage conflicts during the implementation of WPPC policy. Firstly, the

RCS has been promoted nationwide. This means that the responsibility for WPPC

implementation outcomes falls on the shoulders of leading cadres in the Party and

government. In addition, it has also issued MAPGLCEED (for Trial) to provide

clarification pertaining to the object, situation and methods for accountability. As

Matland (1995) claims, “[T]he greater the implementer’s authority to require agent

action, the more likely it is that agents will comply with the principal’s requests”

(p.164). The central government has attempted to ensure compliance from local

governments by emphasizing the accountability of main leading cadres, thereby

reducing conflicts among different parties. Besides, the leadership position of

environmental protection departments in WPPC has been strengthened to reduce

conflicts between and among departments.

The characteristics of a policy are likely to affect implementation outcomes.

Differences in the characteristics of WPPC policies hold certain implications for

implementation outcomes. Chapter four and chapter five look further into the

dynamics of implementing WPPC policies in two different periods before 2012 and

after 2012, using Guangzhou as a case study for implementation at the local level.

139
 Chapter 4 Implementing and Managing WPPC in Guangzhou (2008-2010)

In line with the analysis on the implementation of Liaohe River Basin in the

previous chapter, the management of the 2008 Guangzhou WPPC policy

implementation during the same period had also embraced a political implementation

mode, whereby the level of policy ambiguity was low and the level of conflict during

implementation was high. Conflict tends to be high in most places because

implementing WPPC policy inherently embraced the tension between economic

development and environmental protection at the local level. But this was not the case

with Guangzhou in 2008 as it was about to host the Asian Games in 2010. The

implementation and management of WPPC was, therefore, justified on economic

ground. Economically, Guangzhou benefited from hosting such an event as the event’s

popularity also raised the prestige of the city among other first-tier cities in China. 28

Similar to the implementation in Liaohe River Basin, the formal transposition of

WPPC policy in Guangzhou then closely followed the central government’s policy

directives before 2012, among which the emphasis on a single indicator, i.e. reducing

COD discharge quota was prominent (see Table 2 for the indicators in 11th FYP).

Unlike Liaohe River Basin, the central government did not come up with a plan for

implementing WPPC in the Pearl River Basin. As implementation proceeded, the

inadequacy and incompatibility of a single indicator with regard to the ambitious

28
According to the research by the Guangzhou Statistics Bureau, the 2010 Asian Games increased Guangzhou’s
total agricultural output by RMB 405 million. It brought Guangzhou a total income of RMB 2.3 billion from tourism
and gave a strong impetus to the construction of its tourism software and hardware environment. Guangzhou had
accelerated the process of metro construction, forming a network of 235.7 km of metro lines by the opening of the
Asian Games. The metro had given a boost to the construction and sale of commercial premises and the surrounding
residential and office buildings along its lines (Project Group of Guangzhou Statistics Bureau, 2011).
140
policy objectives stipulated in the Work Plan on Sewage Treatment and River

Comprehensive Management in Guangzhou (hereafter the 2008 Work Plan)

(Guangzhou Government, 2008a) came to the fore. Instead of being low, policy

ambiguity increasingly became high. Conflict turned out to be low in part due to the

imminent 2010 Asian Games. The Guangzhou government invested RMB 48.615

billion to accomplish WPPC objectives within a year and a half in order to be ready

for the 2010 Asian Games (Guangzhou Government, 2008a). Major leading

departments efficiently coordinated WPPC works among other participating

departments. In the process, a political implementation mode inadvertently slid into an

experimental implementation mode, whereby policy ambiguity was high and conflict

was low.

This chapter begins with a discussion of the context in regard to the water

environment and pollution in Guangzhou in early 2000, followed by an elaboration on

the leadership and accountability mechanism established for managing the 2008

WPPC policy implementation. The efforts at reorganization (i.e. organization-based

tools) and imposition of command-and-control instruments (i.e. authority-based tools)

backed up with monetary input (i.e. treasure tools) are discussed in the next section,

which also introduces the major actors in managing WPPC works. The final section

discusses the roles and interactions among different actors. The practical application

of policy, though impressive, was inadequate. Basic infrastructures, such as the

construction of sewage treatment plants and laying of pipe networks, fell short of

requirements. Water quality did not improve in the long run. Without an effective

141
monitoring system for acquiring valid and reliable environmental information, the use

of appropriate technology in building infrastructures and public participation,

implementation outcomes were less than satisfactory. In sliding from a political

implementation mode to an experimental implementation mode, it, nevertheless,

offered significant lessons for implementing and managing WPPC in the future.

4.1 Water Environment in Guangzhou

4.1.1 General Situation

Guangzhou is a city of water with over 2,000 years of history. 1,368 rivers formed

a vast network in the Pearl River as the mainstream flows through the city (Guangzhou

Water Authority [GZWA], 2020a). It is the political, economic, and cultural center of

Southern China. A megacity with more than 15 million residents. Guangzhou’s

contribution ranks firmly in the forefront of China’s economy. In the past four decades,

rapid downtown expansion had ceaselessly eroded lands, rivers and creeks (GZWA,

2020a). Many rivers and creeks were polluted; some even disappeared. Water pollution

seriously contaminated urban villages (Cheng zhong cun). Residents in urban villages

claimed that sewage from septic tanks was released into rivers and creeks. With

increased number of cars and factories, unpleasant odors from polluted rivers and

creeks continued for more than a decade (GZWA, 2020a). Nevertheless, Guangzhou

has managed to control industrial effluent discharge after years of water pollution

control. Annually, there is downward trend in the discharge of industrial wastewater

and main pollutants. Domestic sewage discharge, however, has increased year on year

with urban expansion and population growth. Agricultural non-point source pollution

142
has become one of the main sources of water pollution due to the improper use of

pesticides and fertilizers (Zhang et al., 2016). In general, industrial sewage, domestic

sewage and agricultural sewage are the three major sources of pollution affecting the

water quality of Guangzhou’s rivers.

There is also a gap between urban water supply and water demand in Guangzhou.

Demand for water in Guangzhou has been increasing at the rate of 10 per cent annually.

The demand for water was 4.0×106 m3 in 1996 and reached 6.0×106 m3 in 2010, while

urban water supply only increased at the rate of 6.8 per cent (Zhang et al., 2016).

Besides, Guangzhou also has limited potential for the development and utilization of

water resources. In 1995, the utilization rate of water resources reached 80.8 per cent

(Zhang et al., 2016). To achieve sustainable development, Guangzhou must solve the

water problems, among which surface water pollution and water ecosystem

degradation are the most prominent.

4.1.2 History of Managing Water Pollution Control in Guangzhou

According to the Guangzhou Environmental Quality Reports 1999-2001, water

pollution in Guangzhou around 2000 was very serious due to the industrial wastewater

and domestic sewage discharge in the Pearl River segment (Guangzhou Ecology and

Environment Bureau [GZEEB], 2003a, 2003b, 2003c). Although the comprehensive

treatment of urban environment showed a decreasing trend for industrial waste

discharge, industrial pollutants remain a grave concern. In addition, huge amount of

domestic sewage discharge and the lag in the construction of urban domestic sewage

treatment facilities had affected the effectiveness of water pollution treatment as well

143
(GZEEB, 2003b). The rivers and lakes in urban areas were seriously polluted by

petroleum and organic pollutants, and most of the water quality was inferior to the

Class V surface water standard (GZEEB, 2003a, 2003b, 2003c). The 19 urban rivers

and creeks had basically become the sewage receiving channels for urban sewage,

where the domestic sewage of residents along the coast was directly discharged into

the rivers. In many hotels and restaurants, the sewage from the catering service

industry was discharged into the rivers (GZEEB, 2003b). In such a serious situation,

Li Changchun, the then Secretary of the Guangdong Provincial Party Committee, set

the WPPC goals for Guangzhou since 1998: the prevention and control of water

pollution should “achieve initial results by 2003, not to be black and odorous by 2005,

and become clean river by 2010” (GZEEB, 2003a). Table 20 shows chronicles of water

pollution control in Guangzhou.

Table 20

Chronicles of Water Pollution Control in Guangzhou

Year Chronicles of Water Pollution Control

· Guangzhou opened the prelude to the large-scale water pollution control by the
1997 start of the second phase of the sewage treatment system in Da Tang Sha and the
first phase of the Liede Sewage Treatment System.
· Guangzhou put forward three phased goals of “achieving initial results by 2003,
1998 not to be black and odorous by 2005 and making the river clean by 2010” for
comprehensive improvement of water quality of the Pearl River.
· Guangzhou started the project of “green mountains and waters, blue sky and
2003
clear water”.

144
 · Guangzhou Water Authority was established.
· Then mayor Zhang Guangning proposed to fundamentally improve the water
environment of Guangzhou before the 2010 Asian Games.
2008 · Guangzhou established the Guangzhou Water Investment Group Co. Ltd
(GZWIG), and started the reform of the water investment and finance system of
Guangzhou.
· Guangzhou government issued the Work Plan for Sewage Treatment and
Comprehensive Treatment of Rivers.
· Guangzhou had been identified as a pilot city for the construction of water
ecological civilization by the MWR.
2013 · Guangzhou comprehensively carried out water pollution control once again,
and formulated the Guangzhou Work Plan for Implementing the Action Plan for
Cleaner Water in Southern Guangdong.
· Promoted the Action Plan for Clearer Water in Southern Guangdong focusing
on the protection of Liuxi River.
· Guangzhou Liuxi River Basin Protection Regulations was issued.
2014
· The Work Plan for the Comprehensive Improvement of Water Environment in
Liuxi River Basin and the Construction Plan for the Treatment Projects for Liuxi
River and other Guangzhou Foshan Cross-boundary Rivers were formulated.
· Guangzhou government issued a Circular on Comprehensively Carrying out
2015
the Water Environment Improvement of the Liuxi River Basin.
Note. Adapted from Guangzhou Environmental Quality Report 1999-2015.
http://sthjj.gz.gov.cn/zwgk/hjgb/index_5.html.

Table 20 above has listed attempts at water pollution control in past decades.

Every initiation in Guangzhou is closely related to the central government’s directives.

After the 15th Party Congress in 1997, Guangzhou opened the prelude to water

pollution control. After the 16th Party Congress in 2002, Guangzhou started the project

of “Green Mountains and Waters, Blue Sky and Clear Water”. Next, Guangzhou

reformed its water authority and issued the Work Plan for Sewage Treatment and

Comprehensive Treatment of Rivers after the 17th Party Congress in 2007. Guangzhou

is designated a pilot city for water ecological construction with a series of plans after

the 18th Party Congress in 2012. Of particular significance was the investment of RMB

48.615 billion in 2008 by the Guangzhou government to manage the city’s water

145
environment and control pollution in 121 rivers and creeks before the Asian Games on

June 30, 2010 (Guangzhou Government, 2008). In the history of water pollution

control in Guangzhou, this was the largest investment and most extensive control ever

imposed, besides the WPPC launched in 2016. The following discusses and analyses

the WPPC launched in 2008 (hereafter 2008 WPPC). For the purpose of comparison,

the next chapter will analyze the WPPC launched in 2016.

4.2 Major Actors in Guangzhou’s WPPC Policy Implementation

Based on information acquired during field research and official documents of

local governments, four types of participants were involved in implementing and

managing the works of 2008 WPPC: The Party Secretary of the Party Committee, the

head of the city (county, district) as the first person in charge of local environmental

policy implementation, officials from bureaus concerned with environmental

protection and water affairs, and officials from the local Development and Reform

Commission and other government departments.

4.2.1 The Party Secretary of the Party Committee

In the Chinese polity, the Party Secretary of a Party Committee is the most

influential and authoritative leader in the local Party branch, leading the organization,

engaging in propaganda work and united front activities and other affairs. The Party

Secretary enjoys considerable discretionary power in her or his disposal and makes

decisions directly affecting the daily operation of the government in many ways

(Zhuang, 2016). Such discretionary power includes the right to preside over meetings,

to come up with and coordinate an overall plan, to inspect and supervise, to comment

146
and summarize, to issue documents and to approve or veto matters (Wu, 2008).

According to Ran (2015), “the power of a Party Secretary in environmental protection

affairs include setting goals and strategies, setting an agenda, managing personnel

issues and conflict mediation” (p.66). In the field research, the author witnessed the

role of the Party Secretary as indispensable when it comes to initiating policies and

mediating conflicts.

In general, a Party Secretary has to formulate strategies for local social and

economic development within the purview of the central government’s directives and

instructions (Wu, 2008). The extent of a Party Secretary’s understanding or

interpretation of these directives and instructions is reflected in the Party Secretary’s

priority in regard to various developmental goals and strategies. In the case of

Guangzhou, municipal Party Secretaries regarded local economic development as a

top priority even though they may differ on developmental strategies. More than four

decades of rapid economic growth signals the achievements of municipal Party

Secretaries as well as the obstacles in implementing environmental policies.

In presiding over the local Standing Committee of the Party Committee, the Party

Secretary sets the content and form of discussion topics and makes decision after

discussion. In theory, the collective leadership of the Standing Committee should be

implemented and major decisions should be made based on the casting of votes by

every member in the Standing Committee. However, in practice, collective leadership

often gives way to the Party Secretary’s preference because she or he is imbued with

considerable power in regard to major decisions on personnel issues (Wu, 2008).

147
According to the Regulations on the Selection and Appointment of Party and

Government Leading Cadres, the selection criteria for cadres are morality, ability,

diligence, performance and honesty (CC of the CCP, 2019). Since the Party Secretary

enjoys discretionary power without oversight or checks and balances, she or he retains

the power to change or adjust a motion, to recommend a nomination and to have the

final say in the decision-making process (Ran, 2015). Therefore, when Party

Secretaries select officials at the lower level, even if there is nothing concerned with

corruption, they prefer to choose subordinate cadres who are politically loyal and

supportive of their strategic goals and policy priorities. Leaders of local environmental

protection departments, including directors and deputy directors, are selected and

appointed by the local Party Committee under the strong influence and control of Party

Secretaries. For better developmental prospect, leaders of environment related

departments usually choose to consciously implement the will of the Party Secretary,

even when it comes into conflict with environmental protection issues (Ran, 2013).

Managing WPPC policy implementation often requires the cooperation of many

local government departments. When conflicts arise and an institutionalized inter-

departmental communication mechanism is lacking, “finding the leader” is the most

common way of inter-departmental communication (Ran, 2015). When conflicts arise

during the implementation process, a Party Secretary’s ability in conflict mediation

and conflict resolution will have an impact on the pace and progress of implementation

(Wu, 2008). Thus, Party Secretaries play an instrumental role in conflict mediation.

4.2.2 Head of City

148
 In 2005, the State Council issued the Decision on Implementing the Scientific

Outlook of Development and Strengthening Environmental Protection, which

stipulated that “the main leaders of local governments and relevant departments are

responsible for environmental protection in their respective administrative regions and

systems”. In 2006, China State Environmental Protection Administration (SEPA)

formulated the Rules for the Implementation of Quantitative Assessment Indicators for

Comprehensive Improvement of Urban Environment. It was clearly stated that “the

chief executive should be the first person responsible for environmental protection

within her/his jurisdiction”. Since 2006, the Mayor of a city (county, district) as the

executive head of a local government at the same level should be the first person

responsible for environmental protection in her or his administrative region in

accordance with relevant laws and regulations. The Mayor’s role as the first

responsible person in the local environmental policy implementation is embodied in

three aspects: issuing the target responsibility statement on environmental protection

(huanbao mubiao zerenshu), dictating the closing down of polluting enterprises, and

arranging the budget and financial expenditure for environmental protection (Liu,

2018; Ran, 2014; Ran, 2015).

It should be noted that the right to order the closing down of polluting enterprises

by a local chief executive is the most important administrative punishment belonging

to one of the end-of-pipe policy tools in environmental governance (Ran, 2015). Under

the current environmental legal framework, the closing down of any polluting

enterprises must be approved by a local government at or above the county level. In

149
other words, without the approval of the chief executive of a local government, the

environmental protection department has no right to close any polluting enterprises

(see Article 83 of 2017 WPPCL for reference).

4.2.2 The Reorganization of Guangzhou Water Authority and Guangzhou

Ecology and Environmental Bureau

Local governments are expected to execute policies according to the intent of the

central government. They interpret the political discourse, laws and policies of the

central government before setting up a local implementation system through formal

transposition (Saich, 2015). Van Meter and Van Horn (1975) have pointed out that the

characteristics of an implementation system are one of the important variables on

policy outcome. Local governments are not a unified executive agency, but composed

of a variety of actors (Ran, 2015). And water pollution control is a comprehensive and

complex project involving the cooperation of many governmental agencies. Confusion

in the division of labor and overlapping functions are problematic and detrimental to

WPPC implementation. Therefore, overcoming the fragmentation of an

implementation system is crucial to realizing multi-sectors cooperation (Zhao & Cai，

2020).

1. Organization and Functions of Guangzhou Water Authority (GZWA)

The Guangzhou government has announced to the public that GZWA is mainly

responsible for the planning and construction of WPPC, while Guangzhou Ecology

and Environment Bureau (GZEEB) undertakes the supervision, management and

150
implementation of WPPC policy.29 GZWA was formally established on January 15,

2008, replacing the Guangzhou Water Resources Bureau (GZWRB) established in

1972. In order to improve the overall planning and efficiency of water related affairs,

the Guangzhou government has formulated the Work Plan for the Reform of Water

Management System in Guangzhou, which finally gave birth to the GZWA, a landmark

department involves with WPPC works in Guangzhou (Guo, 2008). The newly

established GZWA assumed the functions of water affairs management in a unified

way. It not only performs all the functions undertaken by the original GZWRB, but is

also responsible for urban and rural flood control, water supply, drainage and sewage

treatment, groundwater management, water planning and water saving formerly

undertaken by other government departments in Guangzhou (Guo, 2008). In this way,

all water related affairs in Guangzhou are managed by the GZWA.

The GZWA is in the “Tiao-Kuai” relationship30 of Chinese political system. It is under

the leadership of the Guangzhou Party Committee and the Guangzhou government in

terms of personnel and funding, and receives business guidance from the relevant

departments at higher levels (See Figure 9 below). Due to the integration of several

businesses into GZWA, its corresponding parent departments mainly include

Guangdong Water Resources Department (GDWR), Guangdong Ecology and

Environment Department (GDEED) and Guangdong Housing and Urban-Rural

Development Department (GDHURD). The organizational structure of GZWA can be

29
For details, please refer to the list of powers and responsibilities of government departments in Guangzhou.
Available at https://www.gdzwfw.gov.cn/portal/affairs-public-duty-list?region=440100&deptCode=007485821.
30
Tiao-tiao system means the higher-level department is expected to provide professional guidance for lower-
level governments, while in the kuai-kuai system the comprehensive local government at the same level allocates
the manpower, funds, and materials to the functional departments (ZhouLi’an, 2010, p.158).
151
divided into internal organizations and subordinate units, with some changes over the

years, although the core functions of these have not changed much.

Figure 9

The GZWA under “Tiao-Kuai” Relationship

State Council

MEE, MWR, MHURD Provincial Government

Business Guidance

GDEE, GDWR, GDHURD Municipal Government

Business Guidance

GZWA District Governments

Business Guidance

GZDWA

GDEE, GDWR, GDHURD Provincial Government

Municipal Government

Municipal Party Committee

GZWA

Note. Compiled by the author. GZDWA stands for Guangzhou District Water Authority.

The main responsibilities of GZWA can be roughly divided into core functions

and peripheral functions. The core functions generally refer to some administrative

functions undertaken by GZWA, usually without inter-department cooperation, while

peripheral functions involve some administrative functions in cooperation with other

departments (See Table 21 below on the responsibilities of GZWA related to WPPC).

152
Table 21

The Main Responsibilities of GZWA Related to WPPC

Duty Content of Duties
Category
To implement the national, provincial and municipal laws, regulations
and rules on water affairs, and draft local water administrative
regulations and rules.
To ensure the proper development and utilization of water resources.
To be responsible for water conservation
To be responsible for the supervision and administration of rivers, lakes,
reservoirs and other rivers and lakes in the whole city, and to organize
the implementation of the management, comprehensive utilization and
Core
protection of water areas and their shorelines, estuaries and tidal flats.
Functions
To be responsible for water supply / drainage industry management.
To formulate the investment scale, direction and municipal financial
fund plan of water fixed assets and guide the implementation,
supervision and management.
To be responsible for the construction and management of water
projects.
To be responsible for water science and technology exchange and
cooperation
To guide and supervise the operation and management of water
conservancy facilities.
To guide the reform of water conservancy management system.
Peripheral
To guide water administration supervision and water administration law
functions
enforcement; To undertake the investigation and treatment of major and
cross regional water related violations; Coordinate and arbitrate disputes
over cross-regional water affairs.
Note. GZWA (2019).

2. Organization and Functions of GZEEB

In early 2013, “Invite the Director of Environmental Protection Bureau (EPB) to

swim in the river” became a social media buzzword. 31 In view of public’s

dissatisfaction with environmental pollution, daring the director of environmental

protection to swim in the river was an intuitive test of measuring the water quality of

31
Netizens asked the director of environmental protection to swim in the river, the director responded: not at the
moment (Wangyou qing huanbao juzhang xiahe youyong, juzhang huiying: muqian zhenbuxing).
http://news.sohu.com/20130626/n379863459.shtml.
153
local major rivers. Some studies have pointed out that the weak position of

environmental protection departments in local governments was reflected in their

inability to fulfill their statutory duties, which was one of the reasons for the deviation

in environmental policy implementation (Li & Zusman, 2006). However, the weak

position of EPB has been strengthened in recent years. Guangzhou’s environmental

protection authority had grown from a Leading Group Office of Three Wastes

Treatment in the 1970s to an independent government department, Guangzhou

Environmental Protection Bureau (GZEPB) in 1995. GZEPB was later renamed and

reorganized as GZEEB in 2019. It has been greatly enhanced in terms of personnel,

funding, technology and power (see Figure 10 below).

Figure 10

Historical Evolution of Guangzhou Ecology and Environment Bureau

⚫ May 1972 Guangzhou "Three Wastes" Governance Leading Group Office was established.
⚫ Sept. 1973 Guangzhou Environmental Protection Leading Group Office (GZEPLGO) was
established.
⚫ June 1974 GZEPLGO was renamed as the Environmental Protection Office of Guangzhou
Revolutionary Committee (EPOGZRC).
⚫ Sept. 1981 EPOGZRC was renamed as the Environmental Protection Office of Guangzhou
Municipal People’s government (EPOGZMPG).
⚫ June 1984 Guangzhou Municipal People's government decided to establish the Guangzhou
Environmental Protection Commission (GZEPC).
⚫ Oct. 1995 The government reform determined that the Environmental Protection Bureau
was established independently, and EPOGZMPG was renamed Guangzhou
Environmental Protection Bureau.
⚫ Jan. 2019 Guangzhou Ecology and Environment Bureau was listed, and the former
Guangzhou Environmental Protection Bureau was withdrawn.

Note. GZEEB. (n.d.-a).

Like GZWA, GZEEB is also in the “Tiao-Kuai” structure of Chinese political

154
system. It is under the leadership of the Guangzhou government in terms of personnel

and funding, but receives instructions and guidance from environmental protection

departments further up the hierarchy (i.e. the provincial level). There are regional

differences in the organization and functions of local EEBs. Different from some cities,

the vertical management of GZEEB at the municipal level means that the district EEB

is an agency under GZEEB. The organization structure of GZEEB also includes

internal institutions and directly affiliated units (see Table 22 below, only the

institutions related to WPPC are listed). GZEEB also focuses on the macro-planning

of environmental protection, supervision and law enforcement.

Table 22

Organization Structure of GZEBB

Internal Institutions Subordinate units
Policy and Regulation Department Guangzhou Environmental Technology
Center
Water and Marine Ecological Guangzhou Ecology and Environment
Environment Department Monitoring Center
Environmental Impact Assessment and Guangzhou Academy of Environmental
Emission Management Department Protection
Ecological Environment Monitoring and Guangzhou Environmental Protection
Technology Department Publicity and Education Center
Ecological Environment Supervision
-
Department
Publicity, Education, Exchange and
-
Cooperation Department
Note. GZEBB. (n.d.-b).

4.2.3 Other Government Departments involved in WPPC Works

In addition to the participation of water affairs and environmental protection

departments, there are many other departments involved in works related to WPPC.

This has to do with the complexity of WPPC itself. Other than the improvement of

155
water quality of rivers and lakes, they also work closely on local economic

development, engineering construction, rural affairs and so forth. Such a local

multisectoral participation corresponds to the central multisectoral participation. As

counterparts, they work together and undertake tasks issued by their superiors.

Therefore, the following will introduce the functions of Guangzhou Development and

Reform Commission (GZDRC), Guangzhou Industry and Information Technology

Bureau (GZIITB) and other departments related to WPPC works.

1. Guangzhou Development and Reform Commission (GZDRC)

GZDRC is a comprehensive department responsible for macroeconomic

development planning and regulation under the leadership of the Guangzhou

government. Its institutional functions also include certain environmental protection

functions, such as “promoting sustainable development strategy, coordinating work on

energy conservation, emission reduction, leading the formulation of relevant plans and

policies as well as low-carbon city construction” (Guangzhou Development and

Reform Commission [GZDRC], 2022, see twelfth duty). In theory, the advantage of

giving the GZDRC some environmental protection functions is that it is responsible

for the overall strategy of economic development and industrial restructuring, which

potentially prevents environmental pollution and ecological damage at the source of

project planning and construction. Among the 28 internal institutions of GZDRC, three

of them are related to environmental protection. The Comprehensive Economic

System Reform Department undertakes the daily task of the special group on the

reform of the municipal economic system and ecological civilization system. The

156
Industrial Development Department promotes the “retreat from secondary industry to

tertiary industry (Tui’er jinsan)” and the Resource Conservation and Environmental

Climate Department is responsible for the comprehensive analysis of major issues

concerned with coordinating socio-economic development and the environment,

taking into account the impact of climate change. 32

2. Guangzhou Industry and Information Technology Bureau (GZIITB)

GZIITB is formerly Guangzhou Industry and Information Technology

Commission. Under the leadership of Guangzhou government, it manages industry

and information technology. In terms of environmental responsibilities, GZIITB

manages the development of circular economy in industrial enterprises, clean

production, energy conservation and emission reduction of enterprises (Guangzhou

Industry and Information Technology Bureau [GZIITB], 2022, see eleventh duty of

GZIITB).

To many who think that WPPC works fall within the jurisdiction of GZEPB or

GZWA, the public is less aware of the functions of GZIITB in environmental

protection. The fact is large scale energy consumption and industrial production

discharge affects the quality of water environment. Among the 78 measures in

Guangzhou Action Plan for Water Pollution Prevention and Control (GZAPWPPC),

GZIITB is in charge of leading five measures, while participating in the other 28

measures. Therefore, whether the GZIITB effectively implements the supervision and

management functions of energy conservation and emission reduction of industrial

32
For details, please refer to the internal structure of the Guangzhou Development and Reform Commission.
Available at http://fgw.gz.gov.cn/gkmlpt/content/8/8193/post_8193327.html#476.

157
enterprises is crucial to the quality of water environment.

3. Guangzhou Agriculture and Rural Affairs Bureau

Before the institutional reform in 2018, the predecessor of Guangzhou

Agriculture and Rural Affairs Bureau (GZARAB) was Guangzhou Agriculture Bureau.

According to GZAPWPPC, GZARAB is involved in eight leading measures and

nineteen participating measures (Guangzhou Government, 2016). The environmental

functions of GZARAB include the following three aspects. The first is to ensure the

prevention and control of agricultural and rural pollution, including the control of

livestock and poultry breeding and agricultural non-point source pollution, and the

adjustment and optimization of the planting structure and layout. The second is

accelerating the promotion of agricultural water conservation, construction of

farmland water conservancy projects, constructing better drainage and irrigation

project system, and improving the infrastructure conditions of farmland water

conservancy. And the third is promoting a healthy aquatic ecology that protects aquatic

organisms. These tasks are reflected in the eighth duty of the responsibilities of

GZARAB (Guangzhou Agriculture and Rural Affairs Bureau [GZARAB], 2021).

In addition to these five leading departments (GZWA, GZEEB, GZDRC, GZIITB

and GZARAB) in WPPC works, there are also the Forestry and Landscape Bureau,

the Planning and Natural Resources Bureau, the Urban Management Commission, and

the Science and Technology Innovation Bureau that cooperate and work on various

projects.

4.3 Actors, Policy Tools, Implementation Modes and Outcomes of 2008 WPPC

158
 The 2008 WPPC policy implementation was the most remarkable of all attempts

to control water pollution since 1998. In 2010, Guangzhou held the Asian Games. The

Asian Games opening ceremony was held in Haixinsha, an island in the Pearl River.

In order to fulfill the commitment to “Green Asian Games”, Guangzhou carried out

the largest water pollution treatment project in its history (Wang, 2010).

The 2008 Work Plan made use of RMB 48.615 billion to renovate 121 rivers in

the city as an attempt to fundamentally improve the city’s water environment before

June 30, 2010 (Guangzhou government, 2008a).

4.3.1 The 2008 WPPC Objectives

The preceding section has discussed the use of organization-based instrument (i.e.

reorganization) in strengthening the structure and capacity of government departments

as “inputs”. The Guangzhou government’s impressive efforts at the formal

transposition of central directives to accomplish WPPC goals before 2012 could be

seen in the 2008 Work Plan issued on December 23, 2008. The 2008 WPPC Plan

consisted of objectives and key indices. The execution of this Plan will be discussed

in the following according to actors and their roles as well as their interactions and

coordination that resulted in the practical application of policy. The outputs of such an

application revealed another aspect of organization tools essential for accomplishing

WPPC goals in terms of its objectives, i.e. the provision of public goods and services

by the state or public enterprises through infrastructural building. The three specific

objectives of the 2008 WPPC Plan were concerned with the provision of public goods

and services vis-à-vis building basic infrastructures for sewage treatment, water

159
diversion and replenishment, and comprehensive river management (see Table 23

below for details).

Table 23

Water Pollution Control Objectives of Guangzhou from 2008 to 2010

General objective: The water environment of Guangzhou will be fundamentally
improved before the end of June 2010
Sub-objectives Key indices
Sewage control 38 sewage treatment plants, 75 sewage
pumping stations and 1140 km
municipal sewage pipe network to be
built, with an additional sewage
treatment capacity of 2.25 million tons
per day; set up a rural domestic sewage
treatment system.
Water diversion and replenishment Mainly includes one artificial lake, two
automatic control systems for sluice
pumps, 24 pumping stations, 37 sluices
and 17 connected rivers
Comprehensive rivers and creeks 121 rivers will be renovated, with a total
regulation length of 388.52 km
Note. Guangzhou Government (2008a).

4.3.2 The 2008 Work Plan, Actors and Responsibilities

The 2008 Work Plan listed 24 participants and their responsibilities in carrying

out WPPC works (see Table B1 in Appendix B for the members participated in the

2008 WPPC).

Although many actors were involved, GZWA, GZWIG and GZEPB were the

major actors or organizations responsible in this round of implementation. GZWA was

responsible for the overall planning of the entire city’s water pollution treatment and

river regulations. Its core responsibilities included:

·Formulating the work plan for sewage treatment and river regulations;

·Compiling the key points of engineering design;

160
·Planning the municipal sewage pipe network;

·Supervising the diversion and connection of rainwater and sewage in new residential

areas.

In addition, the GZWA cooperated with other departments in carrying out the

following tasks:

·Cooperating with the Guangzhou Construction Commission (GZCC) on finishing

rainwater and sewage diversion;

·Cooperating with the Guangzhou Planning Bureau on the site selection of various

facilities for sewage treatment system;

·Cooperating with the GZWIG and other departments on the funding plan for project

construction;

·Leading and guiding relevant districts (county-level cities) in the investigation of

polluting sources and rural sewage treatment;

· Cooperating with the Guangzhou Price Bureau and the GZEPB in providing

incentives for sewage treatment by enterprises or getting these enterprises to connect

their sewages to the municipal sewage pipe network;

· Cooperating with the GZDRC, Guangzhou Economic and Trade Commission

(GZETC), Guangzhou Finance Bureau and Local Taxation Bureau in formulating

policies to encourage enterprises (mainly industrial enterprises) to save water.

GZWIG was mainly responsible for the financing and engineering construction of

2008 WPPC works：

·Financing municipal sewage treatment and comprehensive river treatment;

·Constructing sewage pipe networks in the central urban area and leak detection;

·Constructing and operation management of sewage treatment facilities;

161
·Comprehensive treatment works in Shahe river and Liede river;

·Technical guidance on the investigation of pollution sources and the diversion of rain

and sewage in each district.

GZEPB was mainly responsible for the following supervision work in the process

of water pollution control：

· Issuing relevant administrative laws and regulations and cooperating with the

Guangzhou Legal Affairs Office in accordance with the Circular on Prohibiting the

Discharge of Sewage into Rivers;

·Organizing and strengthening the inspection and supervision of industrial pollution

sources in the entire city;

·Severely cracking down on illegal environmental behavior such as illegal pollutant

discharge;

·Supervising and urging enterprises with illegal pollutant discharge to rectify within

a time limit;

·Information disclosure.

GZWA, GZWIG and GZEPB played a major role in managing the 2008 WPPC

implementation. GZDRC, GZETC, GZAB, GZCC and other departments worked

closely with the three leading departments (i.e. GZWA, GZWIG, GZEPB) in

controlling water pollution so that water control policies and projects could be

smoothly introduced and completed. Peripheral departments, such as Highway Bureau,

Public Security Bureau, Land and Housing Bureau, had had relatively simpler

responsibilities of approving a certain procedure, which did not have any functional

conflicts with the three leading departments. All these departments accepted the

162
guidance and coordination of the General Office of the Guangzhou government, and

were subject to the assessment and supervision of the Organization Department of the

Guangzhou Party Committee. From the perspective of participants in the 2008 Work

Plan, this round of water pollution control was a division of labor and cooperation

between and among various departments of local governments at all levels. But non-

governmental organizations concerned with environmental protection and the public

were excluded. Thus, it was a closed system in policy implementation.

4.3.3 From Political Implementation to Experimental Implementation

The 2008 Work Plan stipulated a leadership responsibility system (zhuyao

lingdao fuzezhi), whereby leaders of all district (county-level city) governments,

municipal departments and construction owners were given responsibility for

implementing sewage treatment and comprehensive river treatment works before the

2010 Asian Games. WPPC works were to be evaluated in stages and in a unified way.

Leaders in district governments or municipal departments during their terms of office

were included in the government target assessment system. Guangzhou government

set up a special leading group for managing WPPC works (hereafter the GZWPPC

leading group), with the then Mayor as the leader. The office of the leading group was

located in GZWA, and the director of the office was the then director of GZWA. Each

district (county-level city) set up its own special leading group for managing WPPC

works with the district head as the leader.

The municipal leaders held a special meeting every month to coordinate and solve

problems, specifically led by the General Office of the Guangzhou government and

163
coordinated by GZWA. Each district (county-level city) government was headed by

main leaders in the government at each corresponding level with a special working

group, serving as a regular coordination mechanism (see Figure 11 below).

Figure 11

Operation Mechanism of 2008 Water Pollution Control in Guangzhou

GZWPPC Leading Group

Lead

General Office of Guangzhou Government &

Guangzhou Water Authority

Organize & Coordinate Organize & Coordinate

District Leading Group for Relevant Municipal

Water Pollution Control Departments of Guangzhou

Lead and Coordinate

District Relevant Business Guidance

Departments

Note. Adapted from Guangzhou Government (2008a).

In the 11th FYP from 2006 to 2010, the central government had included COD

quota as a binding indicator for the first time and introduced WPPC plans for major

rivers and lakes. Such a target filtered down and became an explicit target for local

governments. Being used to having economic development as a top priority, local

governments had had real difficulty in accepting the change made to the relationship

between economic development and environmental protection. This was even more

evident for district-level and township-level governments.

When the target of a single binding indicator appeared to be unambiguous as a

policy objective at face value and the means and institutional arrangements put forward
164
by the Guangzhou government were relatively clear-cut and straightforward, the

characteristics of WPPC policy presumably exhibited a low level of ambiguity. Yet,

the level of conflict was potentially high when the Guangzhou government attached

such great importance to completing WPPC tasks by lower-level governments within

a relatively short time period. As a one-off attempt at WPPC for the sake of the 2010

Asian Games, controlling water pollution could be justified on economic ground in

view of the economic and intangible benefits of holding the event in Guangzhou.

Implementing WPPC policy itself became politically imperative. The tension between

economic development and environmental protection was, therefore, not direct.

But the 2008 WPPC policy implementation was not purely political

implementation. It exhibited certain features of experimental implementation, i.e. high

in policy ambiguity and low in policy conflict. The ambitious objectives put forward

in the 2008 Work Plan were by no means compatible with the policy target of COD

quota as a single indicator for the standard of water quality. Thus, the presumably low

policy ambiguity was in actual fact highly ambiguous as implementation proceeded.

As SEPA did not have a specific pollution control plan for the Pearl River Basin,

this also reflected a shortcoming in the central government’s formulation of WPPC

policy. In elevating WPPC to an unprecedented level of importance, potential conflicts

of interest were alleviated when all levels of government departments displayed a high

degree of coordination and consistency. The level of conflict, instead of being high,

turned out to be low. This also owed much to the leadership and monetary investment

of the Guangzhou government, impressive efforts at reorganization and the efficacy of

165
command-and-control instruments. Therefore, local governments had had more rooms

and leeway for trials and errors. Besides, the central government lacked necessary

resources and power to force its will on local governments. In addition, without an

effective means to secure valid and reliable environmental information on water

quality, the effects of incentives and accountability mechanism in regulating the

behavior of local governments were at most limited.

4.3.4 Policy Tools and Rationale

The Guangzhou government’s 2008 WPPC was an attempt to achieve a

fundamental improvement in the water environment within a year and a half by

completing the objectives outlined in Table 23 above. In this context, what tools did

the Guangzhou government choose? Did these tools help to achieve its objectives? The

Guangzhou government had made use of three types of policy tools: organization,

authority and treasure. As discussed above, it made use of and heavily relied on

authority-based instruments and organization-based instruments. There were some

treasured-based instruments, but nodality-based instruments were absent.

1. Reorganization and Environmental Regulations

The Guangzhou government was well aware of the inadequacy of relevant basic

infrastructures, such as sewage pipes to collect industrial and domestic sewage, as one

of the shortcomings in past attempts at water pollution control (Li, 2022). Therefore,

through government reorganization, the Guangzhou government planned to build basic

infrastructures—sewage treatment plants, sewage pipes and sewage pumping

stations—essential to water pollution control. This process involved using

166
organization-based instruments to strengthen the structure and capacity of different

government departments involved in WPPC works through government reorganization

and the direct provision of goods and services by the state or public enterprise (see

chapter two).

Before the start of the 2008 WPPC, the Guangzhou government carried out

government reorganization of GZWRB by establishing GZWA as a correction to water

affairs functions previously being scattered among different organizations, such as

GZWRB, Guangzhou Landscape Bureau and GZCC. This facilitated unified planning

and coordination as well as avoided the previous situation of multiple departments

leading WPPC works. At the end of 2008, the Guangzhou Government set up GZWIG

as a wholly state-owned enterprise responsible for the provision of water-related goods

and services, such as water supply, drainage, water purification in downtown

Guangzhou, water-related investment and financing, construction and operation

(GZEEB, 2008).

The reorganization of GZWA and the establishment of GZWIG were significant

reforms taken by the Guangzhou government based on the lessons learned from years

of water pollution control (Li, 2022). Although several departments were involved in

water pollution control, GZWA and GZWIG are undoubtedly the two most important

agencies. The former was responsible for the overall planning and coordination of the

2008 WPPC, while the latter was in charge of implementing and managing specific

water-related projects and the provision of public goods and services (Guangzhou

Government, 2008a).

167
 The Guangzhou government issued the Notice on Prohibiting Direct Discharge

of Sewage to Rivers and Lakes (hereafter Notice), which targeted individual

households, industrial and commercial enterprises in discharging water pollutants

(Guangzhou Government, 2008b). Seven measures were put forward to restrict the

discharge of sewage directly into rivers; six of which involved the use of authority

tools. As command-and-control instruments, environmental regulations cover self-

regulation, bans, permits and standards. Six requirements for regulatees prohibited the

direct discharge of sewage and listed the penalties for failure to comply. Only one

option in the Notice involved treasure tools: discharge units would be exempted from

sewage charges if sewage were discharged into the urban sewage treatment system in

accordance with the standards put forward (see Table 24 below).

Table 24

Environmental Policy Tools Adopted in the Notice

Category of Requirements
Instrument
Prohibition of any outlet
in drinking water source
protection zones
Authority-
Prohibit the construction
based
of projects unrelated to
Instruments
water source protection in
the drinking water source
protection zone
Discharge units should
discharge domestic and
industrial wastewater into
urban sewage treatment
Environmental Policy Tools
Self-demolition or closure by deadline
If it is not dismantled or closed after
the deadline, it shall be
·forcibly dismantled or close;
·fined not less than RMB 500,000;
·may be ordered to suspend
production for rectification.
·Order to stop construction
·A fine of not less than RMB 100,000
and not more than RMB 500,000
·Order to dismantle or close
Deadline for completion and filing
If it is overdue, stop water and power
supply

168
 systems
Real estate development Deadline for rectification
projects should be
supported by the
construction of domestic
sewage treatment facilities
In non-drinking water ·Suspend production for rectification
protection zones, ·Penalty
discharge units are not ·Order to close and cancel business
allowed to exceed the license
standards and amount to
discharge
Reduce pollution from Discharge of sewage from ships
ships should comply with relevant standards
Treasure- All types of sewage Exemption from sewage charges for
based discharged into the urban discharge units that meet the standard
instruments sewage treatment systems
should meet the relevant
standards
Note. Adapted from Guangzhou Government (2008b).

2. Rationale for the Choice of Policy Tools

The Guangzhou government had attached great importance to the promise of

“Green Asian Games”. Consequently, efficiency and predictability were the primary

considerations for the Guangzhou government when choosing policy instruments. The

formation of GZWA had overcome problems due to multi-departmental water

management and improved efficiency in WPPC works. The establishment of GZWIG

had enabled the Guangzhou government to provide the infrastructures required for

WPPC directly through a public enterprise approach. This had avoided conflict, long

process of negotiation or ineffective implementation due to indirect provision.

In general, the use of organizational tools by the Guangzhou government was

more than adequate and appropriate. The central advantage of authority lies their high

predictability on policy effects, assuming that legal rules are effectively implemented

169
(Knill & Tosun, 2012). Hence, command-and-control instruments were widely used.

However, there were some problems with the application of authority tools compared

to the use of organization tools in this round of WPPC implementation. Discharge units

that violated the requirements of the Notice were imposed strict penalties, such as fines,

suspension of production and even closure. These measures, however, did not offer the

regulatees any rooms for adjustment and response. Such a harsh approach is not

sustainable in the long term. Nevertheless, the Guangzhou government’s choice of

policy tools in the 2008 WPPC was very much in line with its goal of improving water

quality within a relatively short time frame. The predictable instruments chosen were

not “the best”, but those deemed to work in view of the time constraint and the need

to complete WPPC implementation before the 2010 Asian Games. Due consideration

to the role of information for monitoring performance and the importance of public

participation in environmental protection were, therefore, not given much attention.

4.3.5 Assessment of 2008 WPPC Implementation Outcomes

As pointed out in the last section of chapter three on the characteristics of WPPC

policy before 2012, the State Council and its subordinates had successively issued

WPPC plans for Tai Lake, Liao River, Hai River, Huai River, Dianchi Lake, Wei River

and Songhua River. But there was no such plan for the Pear River Basin. The content

of these plans was similar and the target was to control the COD discharge in industrial

wastewater and urban domestic sewage. Hence, formal transposition had produced the

2008 Work Plan, which was in line with the intent of the central government on WPPC.

In terms of practical application, the use of organization had led to the establishment

170
GZWA and the construction of basic infrastructures with substantial investment, i.e.

money as a resource of treasure tools, by the Guangzhou government.

According to The Guangzhou Environmental Quality Report 2010, the city had

completed the comprehensive treatment of 121 rivers in the urban areas and water

quality in the rivers had been significantly improved. Among the 121 rivers, 92.6

percent of these rivers met the requirements of no black and odorous, 54.2 percent of

these rivers’ water quality had significantly improved, 31.4 percent somewhat

improved, and 9.3 percent improved by a little (GZEEB, 2011). In 2011, the

centralized drinking water quality had steadily improved and the water quality

standard rate was 100 per cent (see Figure 12).

Figure 12

Guangzhou Centralized Drinking Water Sources Quality

Standard Rate of Centralized Drinking Water Sources in Guangzhou

2006-2015

67.86% 75.99% 80.96% 82.23% 89.63% 100% 100% 100% 100% 100%

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

Note. GZEEB (2007-2016).

By the time of the 2010 Asian Games, water quality had improved in accordance

with the 2008 Work Plan. The Guangzhou Environmental Quality Report 2010 also

used vague terms such as “significantly improved” and “somewhat improved” to

171
describe the outcomes of water pollution control. But the so-called good quality of

rivers and creeks did not last long enough despite spending RMB 48.615 billion with

an average daily expenditure of RMB100 million. In reality, the improvements made

were short-lived.

According to the Guangzhou Environmental Quality Report 2013, the water

quality of main rivers and creeks in the urban areas became worse three years after the

2008 large-scale water pollution control (GZEEB, 2014). For four consecutive years,

those rivers and creeks with water bodies worse than Class Ⅴ were very high (see

Figure 13 below). By 2015, 48 of the 53 sections of rivers had had water bodies worse

than Class Ⅴ (GZEEB, 2016). The media reported that “the river was still black and

smelly” (Liu & Li, 2013).

Some achievements of 2008 WPPC could be seen in the “increase in the number

of sewage treatment plants from 17 in 2008 to 48 in 2013, the increase in domestic

sewage treatment capacity from 2.286 million cubic meters per day in 2008 to 4.71

million cubic meters per day in 2013” (General Office of Guangzhou Government,

2014). By 2013, the centralized treatment rate of urban domestic sewage reached 90.89

per cent; the sewage system construction of 448 administrative villages was completed,

and the rural domestic sewage treatment rate reached 43 per cent (General Office of

Guangzhou Government, 2014).

172
Figure 13

Water Quality of Main Rivers in Build-up Areas of Guangzhou 2013-2016

Note. GZEEB (2014-2017).

In 2013, Guangzhou was designated a pilot city for water ecological civilization

construction by the MWR. In the Guangzhou Ecological Water City Construction Plan

for 2014 to 2020 (hereafter the Construction Plan), past efforts at water pollution

control were evaluated. The Construction Plan, however, clearly pointed out that the

173
water quality of rivers was not optimistic as “the water quality standard rate of the

main water function areas was only 55 per cent, which was still far behind the

provincial standard rate of more than 70 per cent” (General Office of Guangzhou

Government, 2014). Among the 231 rivers in the central urban area, only 13 rivers out

of 198 rivers were intercepted comprehensively after the 2008 WPPC. The water

quality of rivers across Guangzhou and Foshan was still black and odorous. The city

needed to implement domestic sewage treatment in 1,205 villages (communities),

except 448 villages. While many facilities were built in the past for WPPC, they had

had little effect on the long-term improvement of water quality. This was not

acceptable to the public in view of the high cost incurred and the short span of time

with good water quality (He & Ye, 2013).

The failure of the 2008 WPPC attempt was largely due to insufficient time on the

side of the government and the limited effective use of technology for building

infrastructures to tackle water pollution problems efficiently. Moreover, an effective

monitoring system was non-existent. The public only started to learn about the details

of water quality data when the Guangzhou government began to publish such data on

water quality in main rivers and creeks in 2013. The public were never engaged in any

WPPC implementation processes. There were serious shortcomings in the collection,

disclosure and usage of environmental information.

According to experts’ estimates, the daily sewage production of four million tons

in 2010 would require the laying of tens of thousands of kilometers of pipe networks,

but the current pipe networks were just 2000 to 3000 kilometers (Liu & Chen, 2013).

174
After discovering the sources of pollution, pipe networks would need to be laid for

separating rainwater and sewage pollutants. To do so, land acquisition and demolition

along the river banks would be necessary. It would take a long time to complete the

above-mentioned pollution source investigation, the diversion of rainwater and sewage

pollutants, laying of pipe networks, land acquisition and demolition. Thus, a

fundamental change in water quality did not happen when water pollution control

actions started just two years before the Asian Games. The Director of the Guangzhou

Environmental Monitoring Center said that “if Guangzhou wanted to fully reach the

Class V of water quality, it still needed a long-term treatment process, and in the later

stage, river treatment would be more difficult” (G2, personal communication, March

22, 2019).

In retrospect, 22 days before the announcement of the 2008 water treatment plan,

12 top experts gathered in Guangzhou to participate in the Symposium on Guangzhou

Sewage Treatment Ideas and Countermeasures. Most experts questioned the feasibility

of the objectives and plan of fundamentally improving water environment by 2010

(Liu & Chen, 2013). But the leading cadres of the Guangzhou government did not

seriously consider those experts’ opinions. They believed that if the government could

invest more and put pressure on the subordinate departments, they would be able to

accomplish the tasks (Liu & Chen, 2013). The pursuit of short-term solution and cadres’

concerns with their political achievements also undermined the possibility of water

pollution control in the long run (Niu, 2013). To sum up, the implementation of 2008

WPPC in Guangzhou aimed to respond quickly to public calls for water pollution

175
control, minimize the tension between economic development and environmental

protection as well as meeting the COD target set by the central government. In spite

of substantial investment in this round of implementation, the root causes and sources

of pollution were not tackled systematically. In sliding to an experimental

implementation mode, it offered some precious lessons to be learnt. Most importantly,

the Guangzhou government was aware that pollution sources at the shores and banks

had not been properly addressed (G2, personal communication, March 22, 2019).

176
 Chapter 5 Implementing and Managing WPPC in Guangzhou (2016-2020)

Chapter four has explained Guangzhou’s unsatisfactory 2008 WPPC policy

implementation outcomes due to factors such as time constraint and the inadequacy of

depending on a single indicator for water quality. Yet, the policy outputs in terms of

building infrastructures, as practical application, had laid the foundation for

subsequent efforts in WPPC. The 2008 WPPC had made use of authority tools and

organization tools, supported by treasure tools, i.e. money, to avoid the fragmentation

of the implementation system and realize multi-sectors cooperation. As nodality tools

were not applied, public participation did not have a role in the skillful handling of

information essential for constructing an effective monitoring system.

When Guangzhou was designated a pilot city for building water ecological

civilization by MWR in 2013, the Guangzhou government, subsequently, promulgated

the Guangzhou Ecological Water City Construction Plan 2014-2020 and evaluated the

2008 WPPC. In 2016, 88.7 per cent of the 53 major rivers under treatment were still

worse than Class V water quality (GZEEB, 2017). A new round of WPPC took off in

2016, drawing on the lessons learnt hitherto. By 2020, the 2016 WPPC had achieved

unprecedented results, showing the potential of administrative implementation in

terms of low policy ambiguity and low conflict, application of resources, technology

and personnel in resolving water environmental problems in a top-down manner. This

chapter, therefore, attempts to explain such a potential.

Section one begins with the formal transposition of the 2015 APWPPC that took

the form of the Guangzhou Action Plan for Water Pollution Prevention and Control

177
(GZAPWPPC) promulgated in May 2016, in which better indicators for measuring

water quality were being put forward. Section two discusses the roles of government,

civil society and market in this round of WPPC policy implementation. The Central

Inspection (Group) on Ecological and Environmental Protection (CIEEP) or CIGEEP

functions as both an instrument of authority tools and nodality tools. The CIEEP

imposes pressure on provincial governments to achieve WPPC goals by engaging the

public in reporting environmental problems that failed to be addressed by local

governments. These reports provided valid and reliable information essential to

building an effective monitoring system.

Section two explains how conflicts cross-department, cross-level and cross-

jurisdiction due to the tension between economic development and environmental

protection on the one hand, and on the other, overlapping departmental functions in

implementing WPPC policy. When ENGOs and the public lodged complaints with

CIEEP or higher-level governments about the performance of local governments in

WPPC, they put more pressures on local governments to perform.

Section three reviews the River Chief System (RCS), which complemented the

work of CIEEP. Similar to the CIEEP, the RCS is an outcome of applying organization

tools and also functions as an instrument of authority tools and nodality tools. But RCS

reaches out to lower-level governments and the public below the provincial level. Both

systems hold local leaders accountable for implementing WPPC policy and webbed

into a working mechanism that emphasizes social inclusion and provides alternative

channels for interaction, communication and coordination. Such a mechanism

178
alleviates conflicts as well. In the process, a more complete implementation and

monitoring system for achieving WPPC objectives incrementally emerged. Advanced

communication technology has been used to enhance the functions of nodality tools,

i.e. public participation and information disclosure.

Section four looks into a more complete and thorough application of policy tools

in the 2016 WPPC and the construction of basic infrastructures with advance

technology for systematic sewage treatment. The final section discusses and assesses

the outputs and outcomes of the 2016 WPPC, pointing to the potential of

administrative implementation, albeit the shortcomings of local governments in not

addressing problems about economic transformation at the local level (see Baishan

village in section two below on the discussion of conflicts between Guangzhou

government and lower-level governments).

5.1 Objectives of the 2016 GZAPWPPC

On May 11, 2016, the Guangzhou government published the GZAPWPPC

according to the APWPPC issued by the State Council and the Guangdong Action Plan

for Water Pollution Prevention and Control (GDAPWPPC) issued by the Guangdong

government (Guangzhou Government, 2016). The GZAPWPPC put forward ten

Articles and 78 specific measures (see Table B2 in Appendix B) to achieve the main

objectives of WPPC (see Table 25 below).

Table 25

Main Objectives and Indices of GZAPWPPC

Deadline Objectives Key Indices
2020 Water environment quality The proportion of the quality of surface water

179
 in Guangzhou will be quality (reaching or above Class III) in the
periodically improved whole city should reach the target
requirements issued by the province.
Heavily polluted water By the end of 2017, quantity of black and
bodies dramatically reduced odorous water bodies in built-up areas in
Guangzhou city should be basically
eliminated.
Guaranteed drinking water Centralized drinking water source quality in
safety continuously cities should all reach or exceed Class Ⅲ and
improved drinking water safety in rural areas should be
basically guaranteed.
Maintaining the quality of The proportion of extremely poor
groundwater groundwater quality will be controlled within
10%.
Improving environmental The water quality in offshore areas should
quality in offshore areas remain stable, reaching the target
requirements of our city issued by the
province.
Improving water ecological Those water sections designated for surface
environment in Guangzhou water function zones should eliminate water
worse than Class V.
Note. Guangzhou Government (2016).

The 2016 WPPC objectives spelt out in the 2016 GZAPWPPC are clearer than

those stated in 2008 Work Plan. It takes into account a wider range of water bodies,

such as surface water, black and odorous water in urban built-up area, drinking water

source, groundwater and offshore water. The short-term goals aimed at improving the

quality of water environment by 2020; while long-term goals, restoring the functions

of water ecosystem by 2050. The 2016 WPPC implementation placed considerable

emphasis on main treatment, completion time, implementation standards, and leading

departments and participating departments responsible for WPPC works (see Table B2

in Appendix B which lists the ten articles and 78 specific ways for WPPC). The level

of policy ambiguity in the GZAPWPPC is comparatively lower, even though specific

goals for 2030 and 2050 have yet to be spelt out.

180
5.2 Roles and Conflicts: Government, Civil Society and the Market

The GZAPWPPC required different levels of government to “strengthen

information disclosure and public participation…listen to the opinions of social

organizations, release implementation plans and work progress to the public, accept

the supervision of the public and society, and guide the public to participate in WPPC”

(Guangzhou government, 2016, see Basic Principles). In addition, market mechanism

has had a role in improving price and water charges, widening investment and

financing channels, implementing green credit (Guangzhou government, 2016).

Although local governments are responsible for WPPC policy implementation, the

public, social organizations and the market are also included in the implementation

process. Government, civil society and market are the three main actors in carrying

out WPPC works. Civil society and the market play a complementary role. The former

provides human resources, services and supervision, while the latter provides financial

support to the government.

5.2.1 Leading Officials and Departments in the 2016 WPPC

The Chinese government is capable of promoting organizational coordination,

resource mobilization and information sharing to complete a large-scale program

(Wang & Chen, 2020). It formulates and supervises WPPC plan, while local

governments are the policy addressees.

Party Secretary and Mayor. As discussed in chapter four, Party Secretaries play

an authoritative role, while Mayors in local governments are responsible for the day-

to-day operation. In 2016, implementing and managing WPPC became a priority for

181
Party Secretaries and Mayors as the central government promoted the implementation

of River Chief System (RCS) nationwide. In May 2017, the Guangzhou River Chiefs

System Office (GZRCSO) released the list of municipal and district-level river chiefs.

Thirteen municipal leaders, including the Secretary of the Guangzhou Party

Committee, the Mayor, the Chairman of the Standing Committee of the Guangzhou

People’s Congress and the Chairman of the CPPCC Guangzhou Committee, became

the river chiefs of 42 major rivers. Among them, Ren Xuefeng, the then Party Secretary,

served as the first general river chief and Mayor Wen Guohui served as the general

river chief (Guangzhou government, 2017). When Mr. Ren was transferred to

Chongqing as a Deputy Party Secretary in July 2018, Zhang Shuofu, the former

Secretary of the Beijing Discipline Inspection Commission, became the Party

Secretary of Guangzhou Party Committee (CCTV, 2018). Zhang Shuofu has a doctoral

degree in environmental science and engineering and had previously worked in Hunan

province water resources system for 20 years (Local leaders database, n.d.). As a

municipal Party Secretary in a sub-provincial city, he is among the few with a

background in environmental protection.

Ten Major Leading Departments. According to the task division in the

GZAPWPPC, there are 28 participating departments in WPPC (see Table B3 in

Appendix B). GZEEB and GZWA are the core departments that had completed 56 of

78 tasks in the 2016 WPPC (Guangzhou Government, 2016). GZWA completed 22

leading tasks, involving the treatment of urban domestic sewage and black and odorous

water, the regulation of water resources, and coordination between major departments.

182
And, GZEEB completed 34 leading tasks with three main responsibilities:

(1) Water pollution control of industrial and groundwater pollution as well as rural

and coastal water environment protection;

(2) Pre-control of potential water pollution with strict marine environmental

access and issuance of pollutant discharge permits, in-process control through on-site

inspection and post-control by cracking down on environmental violation,

responsibility assessment and investigation;

(3) Disclosure of environmental information to the public according to the

relevant laws and regulations.

Other than GZWA and GZEEB, other participating departments include GZDRC，

Guangzhou Industry and Information Technology Commission (GZIITC), Guangzhou

Agricultural Bureau (GZAB), Guangzhou Housing and Urban Rural Development

Commission (GZHURDC), GZWIG, Guangzhou Urban Management Commission

(GZUMC), Guangzhou Public Security Bureau (GZPSB) and Guangzhou Finance

Bureau (GZFB). These departments are listed in Article 71 of the GZAPWPPC

concerned with the “strengthening of coordination and linkage among departments”

(Guangzhou Government, 2016). They are the most relevant sectors in WPPC. The

following briefly discusses the ten most important departments in this round of WPPC,

but not the remaining 18 participating departments (i.e., GZPA, GZMSA, GZFB,

GZSTC, GZHC) with fewer responsibilities for WPPC.

GZDRC and GZIITC are mainly responsible for energy conservation, circular

economy, comprehensive utilization of resources, special planning and policy

183
measures to promote cleaner production in the industrial field. Therefore, the two

departments have led projects in optimizing the spatial layout of enterprises,

eliminating backward production capacity, and developing green industry and circular

economy. They have closely cooperated with GZEEB in preventing and controlling

industrial pollution by strictly enforcing environmental laws. They have also worked

closely with the GZWA in treating urban domestic pollution, controlling total water

consumption and water usage efficiency.

GZAB is mainly responsible for promoting the prevention and control of

agricultural and rural pollution. It has cooperated with GZEEB and GZWA in

controlling agricultural non-point pollution, preventing livestock and poultry breeding

pollution, and promoting the construction of rural sewage treatment facilities.

GZHURDC is responsible for strengthening guidance, supervision and inspection

pertaining to the construction and management of sewage pipelines, and improving the

living environment in small towns and villages.

GZWIG is mainly responsible for the completion of construction tasks in those

projects led by GZWA, such as the construction of sewage plants and pipelines, and

the treatment of urban black and odorous water bodies. GZTB controls pollution in

docks and ships. GZUMC and GZPSB assist environmental protection departments in

law enforcement, improving environmental supervision and law enforcement

mechanism, and cracking down on environmental violation.

Central Inspection Group on Ecology and Environment Protection

(CIGEEP). After the 18th PC in 2012, CIEEP was set up to oversee and review the

184
implementation of local environmental protection policies by provincial party

committees and provincial governments. In July 2015, the Environmental Protection

Inspection Plan (Trial) (Huanjing baohu ducha fang’an (shixing) (EPIP (Trial)) was

officially passed. By the end of 2017, CIGEEP had conducted large-scale

environmental inspections in 31 provinces, municipalities and autonomous regions

across China (Zhang et al., 2017). From 2015 to 2017, the central inspection group

accepted more than 135,000 complaints from the public and nearly 20,000

officials were held accountable (Zhuang et al., 2019). CIEEP has become an

important player in binding local governments to the implementation of

environmental policies.

Table 26

Accountability in the Central Environmental Protection Inspection 2015 -2017

Inspection Start Provinces and Number Number of Number of
Batch Time Municipalities of Regulatory Accountab
Involved detainees Talks -ility
The first Jul. Inner Mongolia, 300+ 2000+ 3000+
Batch 2016 Heilongjiang,
Jiangsu, Jiangxi,
Henan, Guangxi,
Yunnan, Ningxia
The Dec. Beijing, 287 4066 2682
second 2016 Shanghai, Hubei,
Batch Guangdong,
Chongqing,
Shaanxi, Gansu
The third Apr. Tianjin, Shanxi, 355 6079 4018
batch 2017 Liaoning, Anhui,
Fujian, Hunan,
Guizhou
The Aug. Jilin, Zhejiang, 364 4210 5763
fourth 2017 Shandong,
batch Hainan, Sichuan,

185
 Tibet, Qinghai,
Xinjiang
Note. Zhuang et al. (2019)

5.2.2 Civil Society

Traditionally, WPPC was lacking in public participation. Unlike the 2008 WPPC,

the channels for public participation were being set up for building social consensus

by establishing Social River Chiefs (minjian hezhang), adopting services and

suggestions of environmental non-governmental organizations (ENGOs) and

encouraging public engagement and reporting (Li & Hu, 2017).

1. Local Residents and Volunteers as Social River Chiefs (SRCs)

The RCS is an institutional innovation of the central government in 2016.

According to OFIRCS, a river chief shall be in charge of the management and

protection of every river. River chiefs are held accountable by the main leaders of party

committees and governments at province, municipality, county and town levels

(General Office of the CC of the CCP & General Office of the State Council, 2016).

Although these leaders are primarily responsible for the designated rivers, they do not

patrol the river every day because implementing WPPC policy is just one of their

important tasks. Hence, creating the SRCs, made up of local residents and volunteers

familiar with the water environment, filled the need for daily patrolling of rivers. SRCs

assist Official River Chiefs (ORCs) in collecting information on rivers and lakes

during their daily patrols, implementing water environmental management, reporting

water pollution sources, publicizing and guiding ordinary people in protecting rivers

and lakes (Sun, 2020). Since July 2020, there has been 8,811 SRCs in Guangzhou,

186
including 3,867 party members, 232 enterprise staffs, 188 students, 3,599 volunteers

and 925 citizens (GZWA, 2020b).

2. Environmental Non-Governmental Organizations (ENGOs)

There are several types of ENGOs in Guangzhou’s WPPC. The first category of

ENGOs provides pollution source data for the public, governments and enterprises,

such as Guangzhou Green Net Environmental Protection Service Center (Guangzhou

lvwang huanjing baohu fuwu zhongxin), South China River and Lake Chiefs (Huanan

HeHu Zhang). The second category consisting of social organizations, such as New

Life Environmental Protection and Promotion Association (XinShengHuo HuanBao

CuJinHui, hereafter the New Life) and Liuxi River Ecological Protection Center

(Liuxihe shengtai baohu zhongxin), are directly involved in water pollution control,

river patrolling, supervision, publicity and policy advocacy. The third category belongs

to foundation-type ENGOs, such as Society of Entrepreneurs and Ecology (A’LeShan

JiJinHui), which provides financial support for other ENGOs. The first two categories

are in direct contact with the Guangzhou government in implementing WPPC policy.

3.The Public

In September 2017, Guangzhou took the lead in issuing the Guangzhou Measures

of Reward for Reporting of Illegal Drainage Acts (GZMRRIDA) to encourage public

supervision and management of illegal drainage actions (GZWA, 2017, 2020d). By the

end of 2019, several thousand reports were received. The public could report water

pollution activities through GZWA’s social media platform, i.e. the official WeChat

account of Guangzhou Water Service (See Figure 14 below for details).

187
Figure 14

Public Reporting Channels for WPPC in Guangzhou

Note. see WeChat account Guangzhou Water Services.

5.2.3 Market

In contrast to civil society, the market mainly provides financial and material

support to the government (Wang & Chen, 2020). Since the issuance of OFIRCS, the

Public-Private Partnership (PPP) model was piloted in some programs (see Table 27).

Market participation may bring social capital and advanced technologies needed by

local governments. However, the market is in a relatively weak position due to the

domineering role played by local governments. At present, large-scale resource

investment for WPPC still depends on local governments. Table 27 below shows that

very few water pollution control projects were built under the PPP model and the

amounts involved were not significant.

188
Table 27

List of PPP Projects for Water Pollution Control in Guangzhou

Total
Operation investment Project
No. Project Name
Mode (10,000 start time
Yuan)）
Sludge drying and reduction
treatment project of water
1 BOT 16470.00 2014
purification plant in Guangzhou
Development Zone
Sewage treatment system project in
2 central urban area of Zengcheng Other 298137.84 2016
District

Phase IV Project of Yonghe sewage

3 Other 28580.00 2020
treatment plant in Zengcheng District

Note. Guangzhou Finance Bureau (2020).

5.2.4 Conflicts in the 2016 WPPC

Compared with the 2008 WPPC, the 2016 WPPC is no longer a unilateral action

of the Guangzhou government, but a large-scale nationwide WPPC attempt of the

central government with a lasting impact. The 2016 WPPC is not a short-term and one-

off water governance. Local governments have to deal with escalating conflicts

coming from within and outside the public sector itself.

1. Conflicts Within Local Governments and Outside Organizations

Some scholars believe that Party Secretaries played an instrumental role in

conflict mediation (Ran, 2015). Conflicts may cross-department, cross-level and cross-

jurisdiction (Wang & Chen, 2020).

Governmental Departments and WPPC. Conflicts do exist among the ten

departments led by GZWA and GZEEB. Such conflicts are due to two reasons. Firstly,

189
conflicts arise out of the tension between environmental protection and economic

development. Ran (2015) believes that there are differences between environmental

protection departments and non-environmental protection departments in terms of

administrative functions and departmental priorities. For example, the main functions

and priority of GZWA and GZEEB are concerned with the protection of water

environment according to the GZAPWPPC, which involves treating water pollution,

building facilities for WPPC, controlling polluting sources and so forth. However, the

non-environmental functions of development and reform departments such as the

GZDRC and the GZIITC in macroeconomic planning and control, market price

adjustments, often overshadow their environmental functions, i.e. eliminating

backward production capacity, developing circular economy and promoting cleaner

production.

Secondly, conflicts due to overlapping departmental functions. The case of

GZWA and GZEEB is a typical example. Wang and Chen (2020) have pointed out that

China’s water management system is shaped by the dual leadership of MWR and MEP

(now MEE). In 1984, the WPPCL authorized environmental protection departments to

lead WPPC activities (NPC, 1984). However, the State Council’s institutional reform

plan in 1988 put the MWR in charge of water resources management with nine major

assisting departments (Wang, 2007). The first Water Law in 1988 also put MWR as

the leading department for water resources management. Thus, these two parallel paths

formed the basis of water management under different laws. Overlapping departmental

duties in water management led to conflicts between MWR and MEP. The two

190
agencies carried out separate programs to protect their own interests. The division of

labor dictated by GZAPWPPC required GZEEB to be responsible for the prevention

and control of industrial and agricultural pollution, while GZWA is in charge of urban

domestic pollution. The large number of urban villages and small workshops in

Guangzhou complicated the problems when industrial effluence mixed with domestic

sewage were discharged into rivers. 33 Overlapping functions and duties tend to

intensify conflicts and undermine efforts for WPPC.

Guangzhou Government and Lower-level Governments. Lower-level

governments, in particular, district governments are under pressure to implement

WPPC policy. 71 of the 78 tasks in GZAPWPPC required district governments’

cooperation (Guangzhou government, 2016). District government assign tasks to

town-level governments, which further delegate tasks to villages. However,

GZAPWPPC’s measures, such as cleaning up and banning “ten small” enterprises,

controlling livestock and poultry pollution and agricultural non-point source pollution

decimated sources of income in urban villages.

During the field research in Liuxi River Ecological Protection Center, an assistant

of the Head of Baishan village told us that the salaries of villagers’ committee members

did not come from government financial expenditure. Actually, the Taihe Town

Government only gave a little subsidy annually to committee members in Baishan

village. Villagers derived their main source of income from investments by enterprises.

33
Note: Among the first-tier cities in China, Guangzhou is the only one that still retains a large number of urban
villages in the central urban area. By the Feb.2020, there were still 139 urban villages in Guangzhou, mainly
distributed in five old urban areas, namely Tianhe District (28), Haizhu District (20), Baiyun District (58), Liwan
District (17) and Huangpu District (16). They accommodate more than 5 million people.
191
Raising fish in the only reservoir Helong in the village was prohibited. Fishing nets

had been removed and pig farming had also been restricted. Investments by two

enterprises, Yibao pure water production and a cement plant, were the main source of

income for the village (V3, personal communication, August 26, 2018). In 2018, the

cement plant’s illegal sewage discharge was reported after the environmental

protection inspection of Guangdong province. Instead of rectification, the plant was

forcibly demolished on the ground of imperfect land approval procedures. The village

coffers were badly affected (E1, personal communication, August 10, 2018). The

villagers’ committee had no choice but planned to replace polluting enterprises with

rural eco-tourism projects, which was no easy task when the ownership of lands

belonged to villagers. Each villager owned a small piece of land and the villagers’

committee had to negotiate the conditions of land use right for large-scale development

of tourism facilities. After two years, this work was still in progress at the time of the

author’s field work.

In August 2019, when the author visited Baishan village again, the person in

charge of Liuxi River Ecological Protection Center said that Baishan village was ready

to develop tourism facilities (E2, personal communication, July 15, 2019). The village

is, however, reluctant to change the existing economic structure simply because of the

implementation of WPPC policy and RCS. The Secretary of the villagers’ committee

of Baishan village said that “the former mayor, like Li Ziliu (tenure 1990-1996), was

very concerned about the situation at the grassroots level. He often came to investigate

our situation. This is no longer so these days. Nowadays cadres have a lot of

192
requirements, but they don’t know what the real situation is” (V4, personal

communication, August 20, 2018).

Baishan Village is typical of many urban villages in Guangzhou. By 2019, there

were still 272 urban villages in the urban built-up areas of Guangzhou, mainly

distributed in Panyu, Baiyun, Tianhe and Huangpu districts. 34 If the Guangzhou

government cannot mitigate conflicts with lower-level governments, this would affect

the implementation outcomes of WPPC policy. Besides, conflicts between subordinate

governments are rampant. Rivers usually cut cross different administrative regions.

The upstream pollution is likely to lead to serious downstream pollution such that

disputes about the point sources of pollution often lead to conflicts. As these conflicts

may be resolved by using technology, they will not be discussed in detail here.

2. Local Governments and External Organizations

Since the start of the 2016 WPPC, the Guangzhou government has to deal with

external pressures coming from ENGOs, the public and CIEEP. If local governments

at all levels failed to solve water pollution problems in time, ENGOs or the public may

lodge complaints with higher-level governments or CIEEP. Local leaders would be

held accountable. In December 2016, CIEEP received 31 reports on Xintang Eco-

Industrial Park of Zengcheng District during its inspection in Guangzhou. The public

complained about water pollution and surrounding air pollution caused by denim

enterprises in the industrial park. CIEEP informed the Guangdong provincial

government, which demanded rectification by Xintang Eco-Industrial Park. The

34 Letter of Guangzhou Planning and Natural Resources Bureau on the reply to the proposal of the fourth session
of the 15th Municipal People’s Congress No. 20192415(Guangzhoushi guihua he ziran ziyuan ju guanyu shi
shiwujie renda sici huiyi di 20192415 hao daibiao jianyi dafu de han). Available at http://ghzyj.gz.gov.cn/.
193
rectification work of Xintang Eco-industrial Park became the top priority of

Zengcheng District government. 76 enterprises in and around the eco-industrial park

were rectified. On February 10, 2018, all the 76 polluting enterprises stopped

production. In the process, Zengcheng district government carried out 2,130 joint law

enforcement exercises and dispatched 9,176 law enforcement personnel (Qie, 2018).

5.3 Mechanism for Ensuring Compliance

The general requirements of APWPPC proposed a new WPPC mechanism to be

“led by governments, implemented by enterprises, driven by market and participated

by the public” (State Council, 2015). To ensure effectiveness, the central government

promulgated the EPIP (Trial) in July 2015, and the OFIRCS in 2016, which constituted

two key systems in the 2016 WPPC: RCS and CIEEP are pressure systems with

indicators and targets distilled down to provincial and lower-level governments. Yet.

they are also effective means for alleviating conflicts inherent in local implementation

when local governments pay more attention to WPPC. In the process, they changed

the behavior of local officials by influencing their decision-making preferences (Lian,

2015).

5.3.1 Two Important Systems for Ensuring Compliance

1. River Chief System (RCS)

In 2007, the River Chief System (RCS) was first initiated by Wuxi City in Jiangsu

Province to deal with serious water pollution caused by the outbreak of blue-green

algae in Taihu Lake. Wuxi’s party and government leaders at various levels were

appointed as river chiefs of 64 rivers responsible for water pollution treatment. The

194
water qualification rate in functional areas improved from 7.1 percent in 2007 to 44.4

percent in 2015 (Liu, et al., 2019). The successful experience of Wuxi city gradually

diffused to other provinces, municipalities and autonomous regions. In 2016, RCS was

eventually promoted nationwide to reinforce the protection of rivers and lakes.

OFIRCS clearly stated that the whole country should fully establish RCS by the end

of 2018.

According to OFIRCS, RCS means every river in the country should have a river

chief responsible for its management and protection. Heads within the local party

committees and governments are assigned to waterways in their jurisdictions and

coordinated cross-jurisdictional water affairs. Specifically, the RCS consists of a four-

tier river chief system covering provinces, cities, counties and townships. Each

province, autonomous region, municipality directly under the central government

should be headed by a main river chief. River chiefs for major rivers and lakes in each

jurisdiction are made up of leaders corresponding to different levels and sections in

the provinces, cities, counties and townships. They are responsible for all management

and protection undertakings of their corresponding rivers, including water resource

protection, WPPC, water ecological restoration, law enforcement and monitoring.

Among these responsibilities, WPPC is a top priority tied to the accountability system

of environmental protection and performance evaluation of top officials (Jia, 2017).

River chiefs at the county level and above should set up corresponding RCS

offices (GOCCCCP & GOSC, 2016). An RCS office can be located in a department in

charge of environmental protection or water affairs. Given that WPPC needs a series

195
of measures taken by various departments in charge of water affairs, land use,

agriculture, etc., an RCS office often consists of key officials from various agencies

and the leader of such an office is the head of a government with specific duties and

tasks in a region. Besides, local governments also created a conference system, in

which river chiefs and departmental leaders at different levels and from different

regions convene for consultation on cross-jurisdictional and comprehensive issues

(Wang & Chen, 2020).

As a new command-and-control instrument and an organization-based instrument

being rolled out nationally, some scholars thought that the RCS might overcome

problems of fragmentation in water management (Wang & Chen, 2020; Liu, et al.,

2019; Li, et al., 2020). The RCS’s coordinating role has adapted well to China’s

institutional context than previous approaches (Chien & Hong, 2018; Ren, 2015; Wang

& Chen, 2020). Institutional context shapes the RCS with opportunities and constraints.

Constraints come from a centralized political authority (Zhu, 2014), the party-state

hierarchy (Cartier, 2015; Edin, 2003) and the cadre responsibility system (Burns, 1985;

Kostka, 2013). Under a centralized political authority, the central government assumed

overall responsibility while allocating regional responsibilities to local governments

and departments (Wang & Chen, 2020). The party-state hierarchy enhanced the orderly

and effective operation of the RCS’s four-tier management system (Chien & Hong,

2018). Higher-level governments are empowered to appoint and remove leaders in

lower-level governments based on top-down performance assessments, which include

local water management (Li, 2009). Thus, local leaders must prioritize environmental

196
protection alongside economic development. Quick response to severe water pollution

issues is possible when river chiefs are party and government officials responsible for

using their administrative autonomy within their local jurisdictions to address water

problems, some of which cannot be solved by individual departments or lower-level

governments alone.

The RCS, as an innovation and a product of China’s “pressure political system”,

is in essence a manifestation of the cadre responsibility system in sync with

environmental governance (Zhou, 2017). River chiefs are responsible for complex

water-related issues in their jurisdictions. In the past, this responsibility often belonged

to the water resources department and the environmental protection department. If

these departments wanted to make a difference in improving water quality, they had to

seek the support of main leaders in local party committees and governments, given

their limited power. However, RCS has reversed such a situation when leaders in local

party committees and governments, with decision making power over budgeting and

personnel issues, take charge of WPPC. With RCS, responsibility for WPPC falls on

the shoulders of a few key party and government officials under the constraints of the

cadre responsibility system. To complete WPPC tasks set by the central government

and receive a high rating in their performance assessments, these leaders have to seek

the professional support and collaboration of various water-related departments (Liu,

2019).

2. Central Inspection on Ecological and Environmental Protection (CIEEP)

Shortly after the announcement of APWPPC in 2015, the central government

197
officially passed the EPIP (Trial) and began the first round of environmental protection

inspection in 31 provinces, municipalities and autonomous regions. In June 2019, the

general office of the Central Committee of the CCP and the general office of the State

Council issued the Work Regulations for the Central Inspection on Ecology and

Environment Protection. It specified the organization, objectives, procedure, authority,

and discipline of CIEEP. In August 2019, the central government launched the second

round of inspection under CIEEP (Gao, 2018). As a regular exercise, the work of

CIEEP has been institutionalized.

The environmental indicators designed by the central government for cadre

performance assessments introduced strict reward and punishment measures, such as

“one vote veto” and “target assessment” to ensure the completion of WPPC tasks.

Though these environmental indicators are being set by the central government or

higher-level governments, Yuan and Yan (2020) have pointed out that there is still

room for political games and bargaining. To lessen pressure, lower-level governments

often play games with higher-level governments in order to weaken the constraints

imposed by these environmental indicators (Zhou & Lian, 2011). Some tactics of local

governments for coping with environmental inspection and assessment include covert

investigation, passive implementation, or even “collusive behavior” (Zhou, 2008).

Without public participation, local governments are more concerned with meeting the

demands of higher authorities rather than public interests. Furthermore, the lack of

channels for the public to communicate effectively with local governments on

environmental issues may lead to mass protest (Xue Quan, 2015). The work of

198
CIGEEP alleviated some of these problems (Yuan & Yan, 2020).

Instead of just putting pressure on local governments, CIGEEP, on behalf

of the central government, may motivate local officials to perform. In practice,

CIGEEP is sent to inspect and collect first-hand information from provincial-

level party committees and governments, 35 relevant departments of the State

Council and public enterprises. The inspection process of CIGEEP consists of

mobilization and on-site inspection. On-site inspection uses a variety of methods

to obtain information on local implementation. Feedback is provided to the

subject of inspection for rectification. The latter is required to formulate a

rectification plan in response to the problems being identified. Rectification may

be carried out during the inspection process, i.e. “correcting while inspecting

(bian du bian gai)”. Also, CIGEEP may also look back (hui tou kan), i.e. double-

check, if rectification were completed (GOCCCCP & GOSC, 2019).

The results of inspection will be sent to the central government and used as an

important basis for evaluating the performance of main leaders in local governments,

relevant departments and enterprises. These measures seek to prevent implementation

deficits, while also reduce information asymmetry between the central government and

local governments. In addition, CIGEEP’s inspection reports will be made public.

Beside obtaining information from material inspection and interviews with cadres,

CIGEEP also receives reports from the public; the latter is provided with CIGEEP’s

contact information. Access to information on problems not adequately addressed by

35
It may also inspect municipal party committees and governments and their relevant departments as required.

199
local governments enables CIGEEP’s ability to identify local environmental problems

at a relatively small cost.

5.3.2 Intergovernmental Relationships and Interactions: RCS, CIEEP and Civil

Society
In general, the Guangzhou government has to deal with three types of

relationships (see Figure 15 below) when implementing the 2016 WPPC. It has to, first

of all, deal with the requirements of both the central government and the Guangdong

government. The latter, as a provincial government, is also one of the higher-level

governments that plays an important role in implementation; it distributes and

supervises tasks assigned by the central government to lower-level governments.

1. Interaction between Guangzhou Government and Higher-level Governments

The Guangzhou government is mainly in the position of receiving tasks and

responding to higher-level governments’ supervision and assessment. Figure 15 below

shows the Guangzhou government being confronted with pressures from both the RCS

and the CIEEP. Driven by the RCS, the tasks of WPPC are distilled from the central to

local governments at all levels. After the central released the APWPPC, the then MEP

signed target responsibility letters (mubiao zeren shu) for WPPC with 31 provinces,

municipalities and autonomous regions in 2016 (CCTV, 2016). The then Guangdong

Environment Protection Department (GDEPD) 36 decomposed the indicators and

assigned tasks to the cities at or above prefecture level. The Work Plan for Water

Pollution Prevention and Control (WPWPPC) published by GDEPD (GDEED) since

2017 covered water quality control objectives and key tasks of cities at or above

prefecture level (GDEPD, 2017). Table 28 below shows the WPPC targets and key

36
GDEPD became Guangdong Ecology and Environment Department (GDEED) following the 2018 government
agency reform.
200
tasks set by GDEPD for Guangzhou in 2018.

Table 28

Guangzhou’s Key Tasks for WPPC Arranged by Guangdong Government in 2018

No. Key Tasks The Number of Key Tasks
1 Water quality target of surface Including 14 national examination and
water section provincial examination sections
2 Remediation of black and Including 35 black and odorous water
odorous water in urban built-up bodies listed and supervised by the state,
area and 102 newly discovered black and
odorous water bodies
3 Construction tasks of domestic 5 projects
sewage treatment facilities
4 Upgrading and reconstruction of 30 projects
sewage treatment facilities
5 Construction tasks of domestic 8 projects
waste treatment facilities
6 Construction tasks of sludge 2 projects
treatment and disposal facilities
7 Construction of landfill leachate 8 projects
treatment facilities
8 Clean transformation tasks of 3 projects
key industries
9 Tasks of rural domestic sewage Including 6 districts
treatment
10 Construction task of automatic 9 river sections
water quality monitoring station
11 Construction task of river 4 river sections
pollution flux monitoring
system
12 Construction task of biotoxicity 2 water sources
and ecological risk monitoring
system for urban centralized
water source
Note. Adapted from GDEPD (2018).

201
 Report and Feedback
Central Government
Authorize
First Press by RCS Assign Tasks
Figure 15
Inspect (Second Press)
Provincial Party Committee
Operation of 2016 WPPC in Guangzhou and Government Central Inspection
Report & Rectify
Group on Ecological and
Press by RCS Assign Tasks
Environmental
Local ENGOs Protection
Supervise GZ Party Committee and
Supervision Government
Policy Advocacy Coordinate Mobilization
Lead and Coordinate by GZRCSO
Providing Services ↓
Feedback Inspection
Propaganda
GZEE GZDR …… GZAR
GZWA ↓
B C B Inspect and Correct
Propaganda Complain ↓
Coordinate Press by RCS Assign Tasks Problem Feedback

202 202
Complain ↓
District Party Committee and
The Public Information Closure
Government in GZ
↓
Reinspection
Complete the targets

Performance Assessment

Complain
Note. Compiled by the author.
 In addition to assigning tasks, the Guangdong government also supervises and

assesses party committees and governments in cities at or above prefecture level

through the RCS in terms of indicator assessments, work evaluation and public

comments (Guangdong River Chief System Office [GDRCSO], 2019). Other than

indicators to protect main rivers and lakes, the RCS takes into account public

satisfaction with the water quality of main rivers and lakes. Officials in GZWA

believed that “the assessment indicators put pressure on the Guangzhou government”

(G3, personal communication, August 21, 2018; G4, personal communication,

November 26, 2020). Since 2018, the Guangdong government has been assessing the

implementation of the WPPC policy in 21 cities at or above prefecture level. After the

assessment, GDRCSO releases the assessment results to the public.37 This is the first

layer of pressure on the Guangzhou Government. The second layer of pressure on

municipalities comes from the environmental protection inspection work of the central

government and the Guangdong government (Yuan & Yan, 2020). From 2016 to 2021,

CIEEP, through CIGEEP, had inspected Guangdong province for three times (see Table

29 below). Thus, some scholars have considered the relationship between RCS and

CIEEP as complementary (Yuan & Yan, 2020).

In 2016, the Fourth CIGEEP’s first round of inspection in Guangdong province

received 1,667 reports from the public. The Guangdong Government referred these

reports to the relevant municipalities and departments for action. 1,011 enterprises

were rectified and 852 enterprises were penalized (Xie, 2016). Guangzhou received

169 cases referred by CIEEP (Du, 2016) and held 11 people accountable (Tang, 2016).

From June 5 to July 5, 2018, the Fifth CIGEEP carried out a “look-back” inspection to

37
Note：In the assessment from 2018 to 2020, only Guangzhou, Shenzhen, Zhuhai and Jiangmen cities have
won the excellent grade for three years. For details see Guangdong River and Lake Chiefs System Work
Assessment Results 2020. Available at
https://baijiahao.baidu.com/s?id=1701329223476047834&wfr=spider&for=pc.
203
 find out whether the problems found in Guangdong province during the first round of

inspection were rectified. The Fifth CIGEEP handed over 6,077 cases to the

Guangdong Government for processing (Wang et al., 2018). A total of 109 party and

government cadres were held accountable, including 19 department-level cadres

(tingji ganbu), 56 division-level cadres (chuji ganbu) and 34 cadres at section level

(keji ganbu) and below (Guangdong Provincial Party Committee & Guangdong

Government, 2020).

Table 29

CIGEEP’s Inspections in Guangdong Province 2016-2021

Reports
Duration of Inspection Enterprises Accountability Inquiry
from the
Inspection Group Involved (person) (person)
Public
Nov.28, 2016 The Fourth
1667 1863 116 332
-Dec.28,2016 CIGEEP
Jun.5, 2018 -
The Fifth
Jul.5, 2018 6077 7015 109 -
CIGEEP
(reinspection)
The Fourth
Aug.27, 2021
CIGEEP
-Sept. 6764 6646 307 917
Second
27,2021
inspection
Note. Compiled by the author from the information released by the GDEED.
http://gdee.gd.gov.cn/ztzl_13387/ .

On 27 August 2021, the Fourth CIGEEP conducted its second inspection for a

period of one month. This time the inspectors received a total of 6,764 reports from

the public, which were again referred to the Guangdong government for processing.

Of the 917 Party and government officials interviewed, 307 were held accountable

(Ministry of Ecology and Environment, 2021). The Guangdong government usually

sends its environmental protection inspection groups to check on rectification pointed

out by CIGEEP in various cities after the completion of central environmental

204
inspection. To local government officials, “CIGEEP has sent a signal to them that

environmental protection is one of the main responsibilities of local party committees

and governments, and it is a political responsibility. When it comes to environmental

protection, local governments just can’t cross the line, or they will be punished” (J1,

personal communication, July 20, 2019). This shows that CIEEP put some pressure on

local governments from the provincial level.

2. Interaction between Guangzhou Government and Lower-level Governments

To deal with the pressures from the central government and Guangdong

government, the Guangzhou government delegates WPPC tasks to subordinate

departments and lower-level governments. It also created a leading group responsible

for the overall design of WPPC and the implementation of RCS. The Guangzhou RCS

office is affiliated with this leading group, which is in charge of coordination, guidance,

supervision and assessment in WPPC. The Director of the Guangzhou RCS office is a

deputy Mayor in charge of water affairs, and its members include the heads of 30

principal units such as the Organization Department and the Propaganda Department

of Guangzhou Party Committee, GZWA, GZEEB. Each district in Guangzhou has also

set up a leading group and an RCS office accordingly. Hence, establishing such a

working mechanism under the RCS is pertinent to achieving WPPC targets.

The attitude of the Party Secretary of Guangzhou on WPPC is very important. It

determines to a large extent the preferences and interests of subordinate departments

and lower-level governments (Wu, 2008). Guangzhou’s then party secretary Zhang

Shuofu had issued 10 General River Chief Decrees in succession since taking office

in July 2018 (see Table 30). These decrees covered both the overall tasking of black

and odorous water bodies and WPPC innovations, such as the establishment of

watershed river chiefs and grid chiefs and measures in key areas like Nansha and

205
Zengcheng districts. The guidance spelt out in the General River Chiefs Decrees put

in place a working mechanism to achieve WPPC objectives.

Table 30

Ten General River Chief Decrees of Guangzhou

No. Release Main Tasks
Time
1st Decree Sept. 2018 Guangzhou Mission Statement of Comprehensively
Eliminating Black and Odorous Water 2018-2020
(Guangzhoushi quanmian jiaomie heichou shuiti
renwushu 2018-2020)
2nd Decree Nov. 2018 Responsibility System of River and Lake
Management in Nine River Basins (Districts) of
Guangzhou City (Guangzhoushi jiuda liuyu (pianqu)
hehu zhili zeren tixi))
3rd Decree Mar. 2019 Responsibilities of Grid Staff and Grid Chiefs under
River Chief System (Guangzhousohi hehuzhangzhi
wanggeyuan, wanggezhang zhize)
4th Decree Sept. 2019 The Responsibility System of “Drainage Unit
Achieving Standard” in Nine Major Watersheds in
Guangzhou (Guangzhoushi jiuda liuyu “paishui
danyuan dabiao”gongjian zeren tixi)
Task list of Guangzhou Drainage Unit up to Standard
Action (2019-2024) (Guangzhoushi “paishui
danyuan dabiao” gongjian xingdong renwu qingdan
(2019-2024nian))
5th Decree Dec. 2019 Problems and regulation requirements of Jiaomen
national examination section in Nansha District
6th Decree Dec. 2019 Problems and regulation requirements of Dadun
national examination section in Zengcheng Distrct
7th Decree Mar. 2020 Carrying out the action of reaching the standard for the
Shijinghekou provincial examination section in
Baiyun District
8th Decree Apr.2020 List of tasks to remedy suspected illegal water-
related construction and small water bodies in
Guangzhou (Guangzhoushi sheshui yisi weifa jianshe
ji xiaowei shuiti zhengzhi renwu qingdan)
9th Decree Nov.2020 Target and Responsibility System of Clean Water and
Sewage Diversion Reconstruction of Combined
Channel Box in Guangzhou (Guangzhoushi heliu
quxiang qingwu fenliu gaizao mubiao ji zeren tixi)

206
 10th Apr.2021 Requirements for Treatment Work and List of Primary
Decree Tributaries of worse than class V in 2021 (Zhili
gongzuo yaoqiu ji 2021nian liewulei yiji zhiliu
gongjian qingdan)
Note. GZWA Government Information Disclosure Platform.
http://swj.gz.gov.cn/gkmlpt/search?keywords=%E6%80%BB%E6%B2%B3%E9%
95%BF%E4%BB%A4.
The RCS has been optimized based on reality. Guangzhou has a total of 1,368

rivers with a water area of 754.6 square kilometers, divided into nine major watersheds

(Li, 2022). Many of the key rivers for treatment flow through built-up, densely

populated urban villages. There are 231 rivers located in the central urban area (Li,

2022). The organization structure of RCS has been adapted to different jurisdictions.

In general, river chiefs in cities include four levels: municipal level, district level,

township level and village level. There are nine watershed river chiefs on top of the

river chiefs at the city level, in which 197 black and odorous water bodies in

Guangzhou are divided into nine zones according to watersheds (see Guangzhou

General River Chief Decree No. 2 listed in Table 30). Under the leadership of

Guangzhou general river chiefs, a watershed river chief is responsible for coordinating

and managing WPPC affairs as well as supervising and guiding the party committees

and governments at the district level in the river basin.

Under the village river chiefs, grid chiefs and grid staffs are added (see

Guangzhou General River Chief Decree No. 3 listed in Table 30); this is in line with

the idea of grid-based WPPC proposed by Guangzhou. As the area under the

management of village river chiefs is huge, the Guangzhou government has divided

the city into 19,660 smaller areas, or grids, for water pollution control.

The grid staffs manage smaller areas and could better identify problems. For

instance, 46 villages within Xintang Town in Zengcheng District of Guangzhou are

made up of 216 grids, each with a grid staff. Mr. Huang, a grid staff of Yaotian Village

207
in Xintang Town is in charge of the Baidou Industrial Zone, which consists of four

buildings with dozens of enterprises related to hardware, warehouses, maintenance,

furniture and so on. He said, “I usually come to inspect the area from Monday to Friday.

During our inspection, if we find any litters scattered on the road or by the river, we

will take care of it first. As soon as the sources of pollution or other serious situations

are identified, we will immediately report it to the village river chief. Once, there was

an auto repair center here discharging waste directly into the sewers and the enterprise

did not have the drainage permit. I immediately reported the situation through the

River Chief App. The enterprise had been closed for rectification” (G5, personal

communication, August 26, 2019). So far, Guangzhou has established a seven-level

RCS (see Figure 16).

Guangzhou was confronted with some problems when it started implementing the

RCS (G3, personal communication, August 21, 2018). Initially, there was no proper

working mechanism and rules for river chiefs on how to solve the problems they found.

Communications between river chiefs and higher authorities, such as reporting

problems and solving them through the traditional flow of official documents were

very inefficient. Also, river chiefs at the township and village levels did not have

expertise related to WPPC. Without a unified information system to manage rivers,

lakes and river chiefs, information asymmetry existed between upper- and lower-level

governments due to problems with information inquiry and the compilation of

statistics.

208
Figure 16

Seven-level RCS of Guangzhou

Guangzhou General River Chiefs

Nine Watersheds River Chiefs

City-level River Chiefs

District-level River Chiefs

Township-level River Chiefs

Village-level River Chiefs

Grid Chiefs and Grid Staffs

Note. Compiled by the author.

In 2017, the Guangzhou River Chief System Office (GZRCSO) began to work on

a systematic workflow for river chiefs at the district, town and village levels by first

issuing the Guidance on River Patrol in Guangzhou (Guangzhoushi hezhang xunhe

zhidao yijian) and provided regular training (GZRCSO, 2017). It clearly specified the

details concerning patrolling by (social) river chiefs, inspection frequency, inspection

records and the handling of problems. The “Guangzhou River Chiefs Training” app

(see Figure 17 below) was developed to popularize the expertise of WPPC to river

chiefs, including both official river chiefs and social river chiefs (GZWA, 2020c).

209
Figure 17

Guangzhou River Chief Training App

Note. see Guangzhou River Chiefs Training App.

River chiefs are being supervised through the “Guangzhou River Chief” app. The

app recorded the river chiefs’ patrol time, patrol routes and problems reported.

GZRCSO discloses the performance of river chiefs in the form of a red and black list.

In addition, GZRCSO also organizes various forms of special inspection. 11 inspection

working groups are stationed in Guangzhou’s 11 districts to supervise the water

pollution control work (Li, 2022). Guangzhou People’s Congress (GZPC) and Chinese

People’s Political Consultative Conference Guangzhou Committee (CPPCCGZC) are

also reigned in to help with such supervision. In 2018 alone, GZPC and CPPCCGZC

conducted 60 inspections. Besides, a 60-member unannounced team with officials

from water-related departments and journalists are involved in tracking the progress

of WPPC projects. From 2019 to 2020, GZRCSO had organized more than 90

unannounced media visits and found more than 160 water pollution problems (Li,

2022).

As for accountability, the Guangzhou government had issued a series of

210
documents to reward or punish river chiefs. These include Guangzhou River Chief

System and Lake Chief System Assessment Method (Guangzhoushi hezhangzhi

huzhangzhi kaohe banfa) (General Office of Guangzhou Municipal Party Committee

& General Office of Guangzhou Government, 2019), Opinions on Accountability for

Water Environment Management in Guangzhou (Guangzhoushi shuihuanjing zhili

zeren zhuijiu gongzuo yijian) (OAWEMGZ) (General Office of Guangzhou Municipal

Party Committee & General Office of Guangzhou Government, 2017) and River

Chiefs Performance Evaluation System (hehang lvzhi pingjia tixi). As formal

transposition, these documents incorporated WPPC works into the Guangzhou

government’s assessment system for departments and lower-level governments. Hence,

officials lacking in significant contribution to WPPC works or any failure to complete

key projects would be held accountable. In GZRCSO’s terms, it consists of five-steps:

supervision, handing over, inspection, inquiry, and accountability. By July 2020, 199

river chiefs who did not perform or incorrectly performed their duties had been held

accountable in accordance with OAWEMGZ (Li, 2022). The RCS and CIEEP,

therefore, served as the basis for a set of policy implementation, monitoring and

accountability mechanism.

3.Interaction between the Guangzhou Government and Civil society

APWPPC clearly proposed public participation as an important link in the

implementation of WPPC policy. Therefore, interaction between the Guangzhou

government and civil society in WPPC is a product of the pressure imposed by the

central government. Both GDAPWPPC and GZAPWPPC have offered a role for

public participation. Thus, local governments have no choice but to take public

participation seriously. The on-site inspection of CIGEEP permits public complaints

211
through telephone or letters, thereby securing valid and reliable environmental

information. The Guangzhou government is able to rouse public interest and co-opt

the participation of the public and ENGOs. ENGOs’ inputs, such as policy proposals

and provision of goods and services, have contributed to WPPC work, enhanced the

collection of reliable and valid data as well as improved communication with the

public. All this is helpful in closing the gaps in WPPC implementation. Three forms of

public participation serve as effective means for dealing with the pressures from the

top.

Establishing SRC Teams. The original intention of the Guangzhou government

in establishing the SRC teams is to mobilize enthusiastic citizens to participate in water

environmental management (Li, 2022). Citizens with some expertise in water

management are ideal candidates. The Guangzhou government has used Guangdong

Province’s “i volunteer” platform to recruit SRCs. 38 SRCs serve as an important

support for official river chiefs.

There are two types of SRC. One type of SRC is officially recruited and appointed

by the Guangzhou government when they passed a professional test. These SRCs

record the track of river patrols and report problems through the “Guangzhou River

Chief” app. In June 2017,13 college students recommended by their colleges were

among the first to be appointed as SCRs by the Guangzhou government. They are

responsible for the river patrols of 13 rivers in the Guangzhou University City (Lu &

Du, 2017). Volunteers or social workers involved in WPPC activities are the second

38 The official website of the “i volunteer” platform is https://wxcs.gdzyz.cn/.

212
type of SCR.

As SRCs, they provide government departments with timely and accurate

information on water quality, pollution problems and public opinions of rivers and

creeks. Any violations found during river patrolling would be reported timely. These

SCRs respond to questions about water management policy from the community and

residents. They also advise government departments on water management and

supervise the activities of water-related government departments (S1, personal

communication, August 5, 2018). To help SRCs play their role well, GZRCSO have

been holding seminars or trainings concerned with patrolling rivers and tackling

problems for SRCs to improve their expertise in WPPC. In addition, official river

chiefs have also established communication with SCRs via WeChat groups so that the

former could be informed of any problems in a timely manner (E3, personal

communication, August 20, 2018).

Promoting ENGO’s Participation in WPPC. ENGOs serve as a bridge between

the government and citizens and make suggestions according to local conditions. For

example, the ENGO New Life was registered in Guangzhou Civil Affairs Department

in 2013 and is committed to protecting rivers through advocacy and raising public

awareness.39 It has been training SCRs in water source investigation and protection.

In 2017, GZRCSO invited New Life to participate in its recruitment exercise for

SCRs. By 2020, New Life had formed more than 20 SRC teams from the community,

more than 10 SRC teams from colleges, and 9 SRC teams with younger students (Li,

39
More information about New Life can be found on their Weibo page. https://weibo.com/u/1760535212.

213
2022). They keep residents and students informed of Guangzhou’s WPPC policy and

train them in professional skills so that SRC teams could better assist the government

in monitoring water quality and sources of pollution. Guangzhou’s famous SRC teams,

such as “Lexing Sima Creek (lexing sima chong)” and “Huilong Brave Running Team

(huikong yongpao dui)”, were established with the help of New Life (E3, personal

communication, March 10, 2018).

New Life has also assisted the government in communicating with the public.

Chebei river was one of the 35 black and odorous rivers in Guangzhou that needed

treatment. In 2017, nearby villagers opposed the laying of the last 300 meters sewage

pipeline and attempted to hinder the project because they were concerned about noise

pollution, the safety of housing and surrounding businesses. New Life staff visited the

villagers several times to persuade them and organized village representatives to

communicate with the relevant authorities. This had promoted mutual understanding

and trust between the two sides. New Life has played an important role in speeding up

the progress of WPPC projects in Chebei river (E3, personal communication, August

21, 2018).

Realizing that ENGOs have an important role to play in WPPC, relevant

departments in Guangzhou have gradually increased their interactions with ENGOs.

Table 31 below lists the interactions between the New Life and WPPC related

departments from 2013 to 2018.

214
Table 31

Communications between New Life and WPPC Related Departments 2013-2018

No. of Interactive
Year Activities Involved in
Interaction Department
·Symposium: introduction of the New
2013 1 GZWA
Life
·Symposium: the two sides exchanged
2014 1 GZWA views on communication ways and river
patrol mechanism
·Jan. 29: GZWA held a forum on the
adjustment of Liuxi River water intake
·Jul.27: Visit Water Affairs Bureau in
Baiyun District and confirm its volunteers
GZWA, to participate in the activities of river
2015 3 Guangzhou patrol
Procuratorate · Secretary General of the New Life
participated in the special meeting on the
Environmental Public Interest Litigation
organized by Guangzhou People’s
Procuratorate
· Interacted with the GZWA and its
subordinate departments for 9 times, and
the topics involved discussion on the
establishment of a Public Consultation
and Supervision Committee for major
water projects, environmental
improvement of Chebei creeks, public
participation and information disclosure,
GZWA， SRC, remediation of black and odorous
GZEEB， water bodies in Tianhe District, inspection
2016 11 Guangzhou of Liuxi River, sewage treatment plant,
Youth League illegal drainage, etc.
Committee ·The Environmental Protection Bureau of
Panyu District invited the New Life and
other social organizations to attend the
forum on Cooperation with ENGOs for
Environmental Publicity Work.
·Participated in the evaluation forum for
the Guangdong Environmental Protection
Regulations organized by the Guangzhou
Youth League Committee
2017 22 GZWA， ·Discuss with the GZWA and GZEEB on

215
 GZEEB， the topics of treatment of Metro A, SiMa
District and ShaJi creeks,
government the interaction between official river
chiefs and SRC, the publicity, and the
Trial Measures for the Reward Reporting
of Illegal Drainage.
· Hold the Seminar on Environmental
Protection Social Organizations with
Environmental Protection Bureau in
Chancheng district, Foshan city.
· Interacted with the GZWA and its
subordinate departments on issues of SRC
training, river management measures,
black and odorous water body treatment
·Participated in the review meeting on the
GZWA，MEE，
Preliminary Design Report of the Water
Guangzhou
Environment Management Projects
Civilization
2018 18 organized by the Water Affairs Bureau
Office,
and the Agriculture Bureau of Liwan
Neighborhood
District
Committee
·Communicate with staffs of MEE on
black and odorous water treatment and
drinking water source protection
· Interact with Guangzhou Civilization
Office once
Note. Compiled by the author according to the information obtained from fieldwork in
the New Life.

From 2014 to 2019, New Life had taken advantage of these exchanges and

submitted proposals 54 times for river protection to 64 relevant government

departments in Guangzhou (Li, 2022). Many of the suggestions had been adopted by

the government. On January 13, 2022, GZWA invited comments on the “14th Five-

Year Plan for Guangzhou Water Development”, and all six comments submitted by

New Life were accepted (GZWA, 2022).

Encouraging the Public to Report Illegal Drainage with Reward. The

Guangzhou government encourages the public to report illegal drainage with reward.

216
This not only raises the levels of public awareness but promotes social inclusion in

WPPC works as well. Given that huge number of enterprises secretly discharged

pollutants into rivers, especially in urban villages, engaging the public in monitoring

activities by opening up reporting channels makes up for the shortcomings of relying

mainly on the efforts of the government, SRCs and ENGOs (See Figure 14 above).

Reports that are confirmed to be useful will receive a minimum of RMB 300 as reward,

while whistleblowers receive a reward up to RMB 1 million upon the indictment of

any violators.

The river chief billboard nearby each river section (see Figure 18 below) showed

the names, responsibilities and mobile phone numbers of river chiefs from district level

to village level as well as the government service hotline 12345 or the Guangzhou

water complaint phone, and the Guangzhou Water Service official WeChat account for

public reporting and lodging of complaints. According to GZWA, reporting via

WeChat is the most popular channel (G3, personal communication, August 21, 2018).

By September 2020, Guangzhou Water Service official WeChat account had received

13,956 complaints from the public and 13,455 cases had been handled (GZWA, 2021).

From September 2017 to the end of 2020, GZRCSO received 9,830 reports

involving 4,066 drainage offences. Of these, 2,616 reports were valid and a total of

RMB 1.43 million were paid out as rewards (Li, 2022).

217
Figure 18

Guangzhou River Chiefs Billboard

Note. A photograph taken by the author during field research.

5.4 A More Complete Application of Policy Tools

The application of policy tools in the 2016 WPPC is distinctly different from the

2008 WPPC in two aspects. The first aspect is the management of enterprises, cadres

and the public through a hierarchical, networking and monitoring mechanism via

advanced communication technology as pollution problems are being discovered. The

second aspect is concerned with tackling and managing the root causes of water

pollution. Such a difference is primarily related to a change in the principle of

Guangzhou’s water governance from treating the sources of pollution at the surface to

treating the root causes of pollution, given a longer time frame for carrying out WPPC.

5.4.1 Managing Enterprises, Cadres and the Public

Chapter four has highlighted the use of authority tools, organization tools and

treasure tools with the exception of nodality tools (i.e., information and public

218
participation) in the 2008 WPPC. In spite of government re-organization and building

basic infrastructures in a top-down manner, experts, then, were doubtful of the water

treatment plans put forward by the government. Without public participation, valid and

reliable information on water pollution could not be collected; hence, the lack of an

effective monitoring system.

The contributions of nodality tools to such a monitoring system in the 2016

WPPC via public participation and information disclosure depended on its integration

with other policy tools, which permeated through a hierarchical and networking

mechanism. Such a mechanism helped in holding enterprises accountable for industrial

pollution and cadres accountable for WPPC works with the cooperation of the public.

Advanced communication technology is used throughout different levels of the party

committees and governments, which successfully linked up with citizens in the society.

In reporting industrial pollution, the public may bring into light environmental issues

that have not been addressed by local governments.

As discussed in the introduction, section three and section four in this chapter,

public participation and information disclosure through the CIEEP and the RCS,

including the participation of ENGOs, experts, and involvement of residents and

volunteers as SRCs have greatly contributed to a more complete implementation and

monitoring mechanism. Such a mechanism is supported by a hierarchical and

networking control system that in the process manages enterprises, cadres and the

public. In differentiating domestic pollutants from industrial pollutants, the

Guangzhou government has dealt with enterprises as the source of pollution by raising

219
charges for industrial pollutant discharge, thereby standardizing and regulating the

behavior of enterprises (Li, 2022). This is typical example of environmental

regulations as an instrument of authority tools.

5.4.2 Uncovering and Managing the Root Causes of Pollution

Similar to the 2008 WPPC, the government has continued to invest heavily in

building infrastructures (i.e. treasure tools), strengthened the structure and capacity of

governmental departments and public enterprises (i.e. organization tools) in the

provision of public goods and services as well as tightened environmental regulations

(authority tools) in the 2016 WPPC. The difference between the two WPPCs lies in a

relatively more complete and thorough application of policy tools as well as a

systematic approach to uncover and manage the root causes of pollution. Three

measures— uncovering the root causes of water pollution, getting rid of potential

causes of pollution and a systematic approach for managing sewage discharge— are

explained below.

1. Before the 2016 WPPC, the “four cleansing” movement—cleansing buildings,

wells, pipes and rivers—was undertaken by town and street river chiefs,

Guangzhou City Water and Sewage Discharge Company, Guangzhou City

Management Committees and district-level governments to uncover the root

causes of water pollution. GZWIG, a municipal water company and other traffic

departments were involved in pipe network management. These tasks of cleansing

movement are now led and coordinated by the Guangzhou city water and sewage

discharge company, which was set up in 2018 (Li, 2022). The company has also

220
 taken charge of pipe network management after signing a business agreement with

the Guangzhou government. This is an example of a complete and thorough

application of organization tools by means of government reorganization and the

direct provision of public goods and services by the state or public enterprises (see

Table 32).

Table 32

Main Policy Tools Adopted in the “Four Cleansing” Movement

Activities Content Policy Policy tools
addressees
Cleanse Including Town and streets direct provision by the
buildings registration of river chiefs state
buildings around
major creeks
Cleanse wells Check the Guangzhou city Direct provision by the
and pipes operational water discharge public enterprise；
conditions of wells company Government
and pipe networks reorganization
Cleanse rivers Clear sludge on Guangzhou town direct provision by the
river banks, above management state
and below the committees and
rivers district level
governments
Note. Adapted from Li (2022).

2. To get rid of potential causes of pollution, the Guangzhou government has been

dismantling illegal constructions along both sides of rivers and creeks, and clearing

scattered polluted sites. The former is an onerous task in view of the history of such

buildings and the economic interests at stake. Thus, the Guangzhou government

issued the Eighth River Chief Decree, Three-Year (2018-2020) Action Plan

Dealing with Illegal Constructions in Guangzhou and Work Plan for Investigating

Responsibility for Illegal Constructions. It also set up a leading group with the

221
 Guangzhou Party Secretary as the group leader and the Mayor as the assistant

group leader in charge of these tasks. Government reorganization and strict

command-and-control instruments are also instrumental in clearing scattered

polluted sites when the Guangzhou government issued the Work Plan to Double

Up the Clearance of Scattered Polluted Sites in 2018.

3. Managing Sewage Pollutant Discharge

This round of WPPC has included procurement of facilities with advanced

technology as part of building basic infrastructures for better management of

sewage treatment. Table 33 below shows a systematic application of organization

tools and authority tools in managing sewage pollutant discharge in the three stages

and facilities with advanced technology for collection, transmission and treatment.

Table 33

Policy Tools Used in Managing Sewage Pollutant Discharge

Stages Measures Policy Tools
Collection of Pollutant Diversion Direct provision by public
Front-end Within the City enterprise
pollutants Drainage Per Unit Command-and-control
Indicator
Mid-end Sewage Pipe Direct provision by public
Pollutant Construction, Alteration enterprise
Transmission of Sewage Diversion
Back-end Expansion of Sewage Direct provision by public
Pollutant Treatment Factory enterprise
Treatment
Note. Adapted from Li (2022).

5.5 The Outputs and Outcomes of 2016 WPPC

5.5.1 Formal Transposition and Practical Application as Policy Outputs

Pressman and Wildavsky (1984) defined policy implementation as the interactive

222
process between the setting of policy objectives and the actions taken to achieve these

objectives in their pioneering work on policy implementation. As discussed in chapter

three, after the central government set the goals for WPPC, Guangzhou took actions in

two aspects. In formal transposition, specific provisions of a given public policy are

being incorporated into the existing legal and administrative systems. Practical

application puts a policy into practice (Knill & Lenschow, 1998). The following

introduces the documents released in Guangzhou pertaining to formal transposition

and analyzes how Guangzhou actually put these provisions in the official documents

into practice.

1. Formal Transposition

To achieve policy objectives, it has to be implementable. In the 2016 WPPC in

Guangzhou, there were three stages in formal transposition. In the first stage, the rules

and regulations produced in the documents before May 2016 were still relevant for the

completion of the latest WPPC plan. The second stage was concerned with documents

issued between 2016 and 2017. For example, the 13 annexes mentioned in

GZAPWPPC (see Table B4 in Appendix B) on water quality objectives for important

watersheds, groundwater, drinking water sources etc., construction plans for main

domestic sewage treatment facilities, main domestic waste leachate treatment facilities

and comprehensive treatment work of main rivers (streams), the transformation of key

industries, enterprises and industrial clusters, were basically completed before 2017.

The third stage consisted of documents released after 2018, which summarized the

achievements of water pollution control in the past (see Table B5 in Appendix B on

223
the formal transposition of GZAPWPPC in three different stages).

The three evaluation criteria for the completion of formal transposition include

time frame, completeness and correct integration into the regulatory context (see p.73

Table 9). In terms of time frame, Guangzhou government followed the directives of

the central government in releasing WPPC documents. As for completeness, it did not

exactly follow the objectives set by the central government for tackling the five

categories of water bodies due to the onerous task of eradicating black and odorous

water bodies.

Documents on the treatment plans for key river basins, drinking water source

protection and black and odorous water bodies were successively released in 2016 and

2017. While the plan for offshore waters was released after 2018, the action plan for

the prevention and control of groundwater pollution was not released until 2020. In

terms of the number of times the same subject file is being published, documents on

the management of black and odorous water bodies were published four times in 2017

and 2018. Later, different treatment targets were set for the five categories of water

bodies with higher goals set for the water quality of main river basins, domestic sewage

treatment facilities and comprehensive projects for rivers. However, no specific goals

were set to improve the groundwater quality and offshore water; the water quality was

proposed to be kept stable.40

After the central government set the targets or objectives for dealing with the five

categories of water bodies by 2020 (see p.124 Table 19), the Guangzhou government,

40
Note: Guangzhou had evaluated the water quality of 9 groundwater monitoring points in 2013, of which 6
points were poor, and 3 were good.
224
then, began focusing on the improvement of the water quality in key river basins as

well as black and odorous water bodies in urban built-up areas. The prevention and

control of groundwater and offshore water pollution was put forward after 2020. The

completeness of policy could only be incremental due to the actual conditions of

Guangzhou and the need for arrangements. In the GZAPWPPC, Guangzhou

government has clarified the responsibilities for different levels of governments,

delegated responsibilities to leading and participating departments, and innovated the

RCS system. Thus, the formal transposition of central directives gradually integrated

various provisions into the WPPC policy for implementation.

2. Practical Application

Three aspects of GZAPWPPC’s practical application put policy into practice: the

provision of policy-related services, provision of non-coercive incentives for

compliance, and monitoring and enforcement (Knill & Tosun, 2012).

Provision of Policy-related Services. The leading departments of WPPC are

GZWA and GZEEB. According to their work reports from 2016 to 2020, major tasks

included tackling black and odorous water bodies and the protection of groundwater.

GZWA and GZEEB provided policy-related services in the following four main areas.

Identifying the point sources of water pollution in Guangzhou, an industrial and

densely populated city, is an onerous task. From 2016 to 2020, GZWA and GZEEB

invested significant amount of manpower and resources to investigate the sources of

water pollution, whereby 962,500 personnel were mobilized into action in the “four

cleansing” movement for buildings, wells, pipes and rivers (GZEEB, 2020). By 2020,

225
1,726,700 buildings had been dealt with, 10,447 kilometers pipes and 360,000 wells

had been cleansed, rivers were cleansed 4,209 times with 217,400 sources of pollution

being identified (Li, 2022). In accordance with the Eighth River Chief Decree, the

leading small group demolished buildings built illegally covering a land area of

13,805,800 square meters despite issues concerned with history and economic interests.

These buildings were either being closed down or upgraded and refurbished.

16 sewage treatment plants previously requested by the First River Chief Decree

were built and in operation. In 2020, Guangzhou’s sewage treatment capacity achieved

7.74 million tons per day, exceeding the level of average daily water supply (Li, 2022).

In this aspect, Guangzhou is ranked second in the country. As far as the laying of pipes

is concerned, Guangzhou water and sewage discharge company provided unified

control and management of rainwater and sewage shunting and reconstruction works.

During the period of the 13th FYP from 2016 to 2020, Guangzhou’s new added sewage

network was 18,900 kilometer long. In 2020, rainwater and sewage shunting area

reached 68.89 per cent (Li, 2022). A municipal centralized collection network of

sewage water centrally collected sewage from the kitchens and toilets of individual

households which encompassed all villages within the city. By 2020, 141

reconstruction works related to pollution prevention and sewage redirecting to

pipelines were completed. According to the Fourth River Chief Decree, by 2024

Guangzhou city’s rainwater and sewage shunting rate is expected to reach 90 percent

and above. From the above three aspects, Guangzhou’s WPPC has moved from surface

treatment of pollution sources to treating the root causes of pollution sources.

226
 Provision of Incentives for Compliance. Local governments are the main actors

in implementing WPPC. The incentives used by the Guangzhou government to ensure

compliance from local governments include both mandatory and non-mandatory

measures taken by GZWA and GZEEB (see Table 34 below). The River Chief System

(RCS), cadre performance assessments for WPPC, and other measures imposed on

cadres such as inquiry (yuetan), warning letter, listing for supervision (guapai duban),

are mandatory measures. Whereas, online and offline trainings for leaders and staff

related to WPPC, and business guidance for subordinate governments and departments

are non-mandatory measures.

Table 34

Provision of Incentives for WPPC of Guangzhou

Incentive Leading
Year Provision of incentives for compliance
Type Department
·Urge all governmental units in each district to
make effort to meet the water quality standards of
the test sections through on-site inspection, Mandatory
appointment, sending warning letter, listing for
2017 supervision, notification, etc.. GZEPB
·Strengthen the training of cadres, and form a
multi-level and multi-platform training mechanism Non-
including special training, cadre rotation training, Mandatory
and training in universities.
·Take the lead in implementing River Chief
System and Lake Chief System in the whole
province, build a four level RCS of city, district, Mandatory GZWA
township and village which included 3,030 River
2018 Chiefs and 828 Lake Chiefs.
· Hold special training courses for cadres of
environmental protection system, and organize Non-
leading cadres of all departments and environmental Mandatory GZEEB
protection system to participate in the training

227
 ·Guide the environmental protection bureaus of all
districts to carry out training for environmental
protection supervision inspectors in town (street)
and industrial parks, send 8 batches of teachers to Non-
train the staffs, and two training courses for Mandatory
professional backbone of full-time environmental
protection personnel in the city were held, with 266
people trained.
·Continue to strengthen the training of cadres,
complete 16 systematic training programs of the
Bureau, train 1668 staffs, hold special training Non-
courses for ecological civilization construction of Mandatory
the city and training courses for cadres’
2019
comprehensive quality GZEEB
·Revise the Guangzhou Assessment Method of
Environmental Protection Target Responsibility, and
Mandatory
evaluate the Party committees, governments in each
district and 11 departments.
·Enhance the ability of environmental protection
Non-
publicity and education, and improve the citizens’
Mandatory
2020 awareness of ecological civilization. GZEEB
·Continued to strengthen cadre training. Organize Non-
14 internal training projects Mandatory
Note. Adapted from the annual work reports of GZWA and GZEEB.
http://www.gz.gov.cn/zwgk/zjgb/bmgzzj/2020n/.

Monitoring and Enforcement. In terms of monitoring and enforcement, GZEEB

and GZWA have established an information management system for rivers,

strengthened environmental protection inspection, disclosed water quality information

to the public as a monitoring mechanism (see Table 35 below on the monitoring and

enforcement measures for WPPC from 2016 to 2020).

Table 35

Monitoring and Enforcement for WPPC of Guangzhou

Monitoring and Actions (Leading Governmental Agencies) Time
Enforcement
Measures
Establishing Completed the development of information 2016

228
information management system for key rivers. (GZEPB)
monitoring and Built four automatic water quality monitoring 2016
management system stations in Liuxi River. (GZEPB)
Promoted initiatives of enterprises in 2016
environmental information work (GZEPB)
Taking the lead in the R&D of the river chief 2018
app, drainage inspection and management app
and agricultural sewage management app, and
gradually establish a fully covered and
traceable management system (GZWA)
Building a whole process real-time monitoring 2019
and management system. (GZWA)
Public Monitoring Released the water quality monitoring 2016
information of 50 key rivers monthly.
(GZEPB)
Formulate and implement the joint law 2016
enforcement work plan for cross-border rivers.
(GZEPB)
Built Teams of SRC. 1,138 SRCs participated 2019
in the WPPC. (GZWA)
Disclosed water quality ranking of 156 primary 2019
tributaries in key river basins.
Disclosed water quality ranking of 156 primary 2020
tributaries in key river basins.
Establishing working Promulgated Guangzhou Measures on 2016
mechanism for Rewarding and Reporting Environmental
monitoring Violation (Trial). (GZEPB)
Formulated the Plan for Joint Law 2016
Enforcement in cross-border rivers. (GZEPB)
Issued Guangzhou Measures of Reward for 2017
Reporting of Illegal Drainage Act. (GZWA)
More than 30 local regulations, government 2018
documents related to water affairs issued.
(GZWA)
WPPC Inspection Environmental protection departments jointly 2017
carried out 22 environmental protection special
law enforcement inspections involving water
environment. (GZEPB)
Seven outstanding environmental problems 2017
such as Baini River and five key enterprises
were listed for supervision. (GZEPB)
Cooperated with the provincial inspection of 2017
WPPC. (GZEPB)
Established teams of environmental protection 2017
229
 inspectors for town (street) and industrial
parks, with a total scale of 2,747 people.
(GZEPB)
Carried out special law enforcement actions on 2018
water environment of Guangzhou-Foshan cross
boundary rivers, key water pollution discharge
units. (GZEEB)
Carried out supervision and spot checks on the 2019,
clean-up and rectification of “scattered and 2020
polluted sites”. (GZEEB)
Carried out special law enforcement actions on 2019,
large-scale livestock and poultry breeding and 2020
rural domestic sewage treatment facilities.
(GZEEB)
Establishing Teams Planned to establish teams of environmental 2017
for environmental protection inspectors for town (street) and
inspection industrial parks, involving 2,747 people.
(GZEPB)
Recruited 2,240 full-time environmental 2018
protection inspectors. (GZEEB)
Note. Annual work reports of Guangzhou Water Authority and Guangzhou Ecology
and Environment Bureau. Available at
http://www.gz.gov.cn/zwgk/zjgb/bmgzzj/2020n/.

5.5.2 The Outcomes of the 2016 WPPC

By the end of 2020 and after five years of water pollution control, the water

quality of Guangzhou’s rivers had significantly improved (see Table 36, 37 and 38).

Table 36

Outcomes of WPPC in Guangzhou 2017-2020

Year Projects completed Honor Gained
2017 ·Eliminate the first batch of 35 black and
odorous rivers listed for supervision by
MHURD.
·Five new sewage treatment plants built.
·1,392km of sewage pipelines have been
laid.

2018 ·The first batch of 35 black and odorous ·National model city for the
rivers achieved the standard of long- treatment of black and odorous
term clean status. water bodies.
230
 ·Completed the main projects of the ·Guangzhou’s RCS Work received
second batch of 112 black and odorous National Inspection Incentive
rivers. (guojia ducha jili)41
·Laid 3,901 km of sewage pipelines.
·The water quality of 8 state and
provincial sections met the annual
assessment requirements.

2019 ·Eliminated 147 black and odorous ·Baiyun District of Guangzhou

rivers and met the national assessment
requirements.
·The water quality of 12 sections of the
state and Guangdong province was
improved from worse than class V to IV
selected as one of the 10 advanced
counties (districts) in the River and
Lake Chief System Work 2019
issued by MWR.
·Guangzhou’s RCS Work received
National Inspection Incentive.
·Guangzhou appeared as an
advanced provincial capital city at
the national TV and telephone
conference about promoting urban
sewage treatment.

2020 ·National Water Saving City

·Laid 8,383 km of sewage pipelines.
·Guangzhou Haizhu National
·The sewage treatment capacity per day Wetland Park represented China in
ranked second in China. the competition for the 12th Dubai
·Eliminated 147 black and odorous International Sustainable
rivers listed for supervision by the Development Best Practice Award.
MWR.
·The water quality of 13 state and
provincial sections met the requisite
standard.

Note. Adapted from Typical Cases of Water Pollution Control in Guangzhou compiled
by the GZWA and work report of Guangzhou government 2017-2020. Available at
http://www.gz.gov.cn/zwgk/zjgb/zfgzbg/index.html.

41
Note：The National Inspection Incentive is an award set by the State Council and covers 30 areas of local
governments’ work. It provides incentives to localities that have achieved significant results in implementing
major national policies and measures. The awards will be paid out from the relevant funds of the central
government. Water environment in key river basins and the work of the RCS fall within the scope of these
incentives. For details, please refer to the circular issued by the State Council. Available at
http://www.gov.cn/zhengce/content/2018-12/10/content_5347465.htm.
231
 Table 37

Proportion of Water Quality Categories at National Examination and Monitoring

Stations in Guangzhou unit: %

Worse than
Year Class Ⅰ-Ⅱ Class Ⅲ Class Ⅳ Class Ⅴ
Class Ⅴ

2015 42.9 14.3 21.4 14.3 7.1

2016 40 30 20 10 0
2017 33.3 33.3 22.2 11.1 0
2018 11.1 55.6 22.2 11.1 0
2019 55.6 11.1 33.3 0 0
2020 46.2 30.7 23.1 0 0
Note. Adapted from Guangzhou Environment Report 2015-2020.
http://sthjj.gz.gov.cn/zwgk/hjgb/.

Table 38

Remediation of Black and Odorous Water Bodies (BOWB) in Guangzhou 2018-2020

The The Number

The
Number of of BOWB is
Time Number of Assessment
BOWB is being
BOWB
Completed rectified
1st quarter,
Not assessed
2018
197 68 129
2nd quarter,
Not assessed
2018
3rd quarter,
197 77 120 Not assessed
2018
35 black and odorous water
bodies have passed the
4th quarter,
197 197 0 municipal assessment and
2018
reached long-term clean-up
(chang zhi jiu qing)
104 black and odorous water
bodies passed the initial
1st quarter, municipal review and
197 197 0
2019 assessment; 58 black and
odorous water bodies are
under assessment

232
 107 black and odorous water
bodies passed the initial
2nd quarter, municipal review and
197 197 0
2019 assessment; 55 black and
odorous water bodies are
under assessment
109 black and odorous water
bodies passed the initial
3rd quarter, municipal review and
197 197 0
2019 assessment; 53 black and
odorous water bodies are
under assessment
162 black and odorous water
th
4 quarter, bodies passed the initial
197 197 0
2019 municipal review and
assessment
35 black and odorous water
bodies have reached long-term
clean-up;
34 black and odorous water
1st quarter,
197 197 0 bodies are under the long-term
2020
clean-up assessment;
128 water bodies have not yet
carried out long-term clean-up
assessment
2nd quarter, 35 black and odorous water
197 197 0 bodies have reached long-term
2020
clean-up;
3rd quarter, 162 black and odorous water
197 197 0 bodies are under long-term
2020
clean-up assessment
th
4 quarter, 197 rivers have reached long-
197 197 0
2020 term clean-up
Note. Adapted from Lists of Black and Odorous Water Bodies Treatment progress in
Guangzhou issued by the GZWA. Available at
http://swj.gz.gov.cn/mssw/sjfb/index.html.

In 2020, Guangzhou achieved the objectives put forward in the GZAPWPPC after

five years of water governance. First, the proportion of surface water quality reaching

or above Class III in the whole city reached 70 percent – a target set by the Guangdong

provincial government. Second, 197 black and odorous water bodies in built-up areas

233
in Guangzhou were eliminated (see Table 38 above). Third, centralized drinking water

source quality in Guangzhou reaching or exceeding Class Ⅲ guaranteed drinking

water safety in rural areas. Fourth, those river sections designated for surface water

function zones with Class V water quality were eliminated. Last but not least, the

quality of groundwater and water quality in offshore areas remained stable.

The results achieved in the 2016 WPPC were far greater than those achieved in

the past two decades. Guangzhou’s achievements in both the construction of hardware

facilities for WPPC, such as sewage pipes, domestic sewage treatment plants, and

institutional development of water management are unprecedented. Whether these

results could be sustained remains to be seen. Yet it is interesting to see what

motivation, other than the pressures exerted by the central government, could have

inspired the Guangzhou government to do so much to combat water pollution. This

will be the task of the next chapter.

234
 Chapter 6 Principal-Agent Relationships in WPPC:

An Interests-Incentives-Information (3I) Framework

In political implementation, implementation outcomes are decided by power

because compliance is not automatically forthcoming. Matland’s ambiguity-conflict

model (1995) implicitly pointed to the importance of principal-agent relationship at

work due to different factors—interests, incentives and information—for bringing

about compliance. Hence, this chapter attempts to explain the variations in the

behavior of local governments as agents of higher-level governments, i.e. the central

government and provincial government. Specifically, it is an attempt to account for the

variations in the behavior of local governments in the implementation of the 2008

WPPC and the 2016 WPPC in Guangzhou despite relatively similar features in the

central policies before and after 2012.

Chapter three and chapter four have explained that a political implementation

mode gradually emerged in 2002 in regard to the implementation of WPPC policies at

the local level in China. In chapter four, the 2008 WPPC policy implementation in

Guangzhou slid from a political implementation mode to an experimental

implementation mode; implementation outcomes were unsatisfactory due to reasons

such as time constraint and the dependence on a single indicator as the measurement

of water quality. Whereas, chapter five has discussed the 2016 WPPC policy

implementation in Guangzhou and highlighted the unprecedented achievements of

Guangzhou in WPPC and the potential of an administrative implementation mode,

signaling better implementation outcomes in the future. Administrative

235
implementation denotes low policy ambiguity and conflict; efficient top-down

implementation achieves policy objectives through the effective and efficient

utilization of personnel, resources, technology and information. In terms of interests,

this implies the overcoming of Guangzhou’s divergent interests and conflicts with

higher level governments in the 2016 WPPC.

In this chapter, section one explains how the efforts made by Guangzhou to

develop its economy in a sustainable manner before the release of the 2015 APWPPC

by the central government gradually led to the convergence of interests with the central

government’s APWPPC objectives. After all, Guangzhou’s economic capacity has to

be reckoned with as it is one of the first-tier cities in China. However, this criterion

alone is insufficient for explaining satisfactory WPPC implementation outcomes as

Guangzhou had failed in the 2008 WPPC implementation. Therefore, why and how

Guangzhou responded positively to the incentives— political, economic, moral –

offered or imposed by the central government is also crucial to resolving the tension

between economic development and environmental protection.

Section two, therefore, discusses how the central government increasingly utilizes

different incentives— political, economic, and moral– in dealing with the divergent

interests of local governments in order to secure the compliance of local governments

in implementing WPPC, given the drive to develop ecological civilization after 2012.

The effective or ineffective deployment of these incentives also depends to a

significant degree on the capacity of the central government, which is very much

enabled or constrained by its ability to acquire valid and reliable environmental

236
information at the local level; without which, the problems of information asymmetry

will be an obstruction to an accurate picture of the performance of local governments

in carrying out WPPC works. Section three recapitulates the implementation outcomes

of the 2008 WPPC and the 2016 WPPC in Guangzhou from an interests-incentives-

information (3I) framework that reflected their differences in terms of the divergence

or convergence of interests between principals and agents in the implementation

processes.

6.1 Divergence or Convergence of Interests?

6.1.1 The Divergence of Interests in Environmental Protection

Interests are the starting point for discussion concerning principal-agent problems.

Attempts at the alignment of interests determine to a greater extent the principal’s

design of incentives and monitoring mechanism for the agents. Environmental

governance involves many stakeholders, the most important of which are the central

government and local governments in China (Yu, 2011), engendering different

interests. As public choice theory holds, “Instead of being regarded as motivated only

by the public interest, individual bureaucrats and politicians should be looked on as

trying to maximize their own utility and enhance their own welfare, rather than

focusing on furthering the public interest” (Owen E. Hughes, 2012, p.12). The central

government may emphasize the harmonious development of economy, society and

environment, but local governments seek to maximize economic benefits within their

jurisdictions (Yu & Liu, 2011). The divergence of interests between them has much to

do with the externalities of the environment (Kostka, 2013). Environmental protection

237
is often highly invested and slow in yielding results, with a time lag between inputs

and outcomes; whereas the tenure of local government officials is fixed and short.

Local governments may be more concerned with their immediate interests than the

long-term benefits of environmental protection. Whereas, the central government,

however, is concerned with the political challenges that may arise from environment

degradation and its legitimacy and image in the international community (Yu & Liu,

2011).

Table 39

The Interests of Central Government and Local Government in Environmental

Protection at Different Times

Period Interests of Central Government Interests of Local Governments

local governments gained more
Gradually realized the seriousness discretion with decentralization and
1973- of environmental problems and market-oriented reforms. In its own
1995 became concerned about interests, local governments
environmental protection developed the economy rather than
environmental protection.
Under the GDP-driven promotion
The central government paid more mechanism, local governments
attention to environmental issues maintained a high motivation for
1996-
and formally implemented the economic development. They even
2005
strategy of sustainable development avoided implementing environmental
since 1996. policies that hindered economic
development.
Local governments still had the
The central government raised the
impulse to develop economically.
status of environmental protection.
Through the central government’s
At the 17th PC, the SOD was
2006- increased incentives for
included in the Party Statute
2010 environmental protection, they began
emphasizing comprehensiveness,
trying to balance economic
coordination and sustainable
development and environmental
development.
protection to a certain extent.

238
 The central government has
regarded environmental protection
as its main task. After the 18th PC,
2011-
building an ecological civilization is
present
of equal importance to political,
economic, cultural and social
development.
Note. Adapted from Tang and Chen (2017).
The need for local economic
transformation, increase in public
concern for environmental protection,
and changes in central promotion
rules have motivated local
governments to participate in
environmental governance.

Environmental governance is long-term oriented. The interests between the

central government and local governments are not set in stone. Tang and Chen (2017)

have pointed out that the change in interests between the two has gone through

approximately four stages (see Table 39 above).

In the first two of these four stages, there was no divergence of interests between

the central government and local governments on environmental protection. Although

the central government gradually recognized the importance of environmental

protection, there were no substantial constraints on local governments to do so.

Economic development remained at the top of the policy agenda. Therefore,

environmental policies were largely unenforced or token at the local level until 2006.

After 2006, the divergent interests between the two gradually increased. Recognizing

the potential challenge posed by environmental degradation to regime stability, the

central government has been increasing its incentives and oversight over the

implementation of environmental policies by local governments. The documents

issued in 2006 and 2009 on the assessment of leading cadres specified that

environmental protection was a component of the performance assessments for cadres

(Tang & Chen, 2017).

Local governments found it difficult to change their ways of developing the

239
economy and yet protect the environment at the same time. As a result, they had mainly

responded to the pressure from the top by means of short-term campaign-style

treatment. Once the centrally set targets were met and the pressure lifted, economic

interests would prevail until the next central pressure arrived (Yu, 2011). Thus,

conflicts of interest between the central government and local governments were

greater during the period from 2006 to 2010; this led to frequent collusions among

local governments, falsification of data and campaign-style governance (Zhou, 2010).

Conflicting interests between the central and the local on environmental protection

have persisted even after 2011. However, with more incentives from the central

government and a gradual change in the perceptions of environmental protection, some

local governments have gradually ranked well in implementing environmental

protection policies. Uneven implementation of environmental policies among local

governments is common.

6.1.2 Guangzhou’s Convergence with the Central Government’s Interest

Table 39 above shows that the interests of the Guangzhou government over the

years largely coincided with the motivations of local governments at each stage. Prior

to 1996, the Guangzhou government had been focusing on economic development and

there were no large-scale actions to treat water pollution. The inclination to combat

water pollution at this stage was extremely low. After nearly two decades of rapid

economic development, Guangzhou’s water sources dwindled and the water

environment deteriorated. The central government responded by proposing a

sustainable development strategy in the 15th PC (1997) and 16th PC (2002). Hence,

240
Guangzhou began to improve water quality through WPPC in the Pearl River Basin in

1998. Then in 2003, Guangzhou launched the “Blue Sky and Green Water” project and

prepared a comprehensive plan for the improvement of rivers and creeks (see Table 20

in Chapter 4). But it continued to prioritize economic development as it lacked the

necessary institutional supports for the long-term implementation of WPPC. The

performance of cadres in advancing economic development was still the main

consideration for promotion. When WPPC measures contradicted economic

development, Guangzhou government clearly favored the latter.

The period from 1996 to 2011 was a stage of rising conflicts between the central

government and local governments over concerns for environmental protection. Even

with the rise in the status of environmental protection for socialist construction after

2006, Guangzhou government’s attempt at implementing WPPC policy yielded

unsatisfactory outcomes partly due to conflicting economic and political interests.

When fiscal pressure on local governments increased following the 1994 tax sharing

reform, the Guangzhou government formed an alliance with enterprises to attract

investments and increase GDP growth rate (Yu, 2011). Officials were keenly aware

that large heavy industrial enterprises were vital to the achievement of economic

targets by local governments. Consequently, industrial pollution was tolerated.

The alliance between government and business was not entirely for the sake of

“political performance”, but for black profit as well (Yu, 2011). Through

administrative interventions, local government officials imposed heavy charges on

polluting enterprises, thereby gaining a share in their profits. Such rent-seeking

241
behavior being described by Buchanan and Krueger (1974) was particularly prevalent

in many county and township governments. With local governments acting as the

umbrellas for these enterprises, government agencies and environmental protection

departments were forbidden from carrying out inspection of illegal pollutant discharge

without the permission of a local government (Chen, 2007). The law enforcement

capacity of environmental protection departments was undermined. Pan Yue, former

deputy director of SEPA, once mentioned that “many local environmental protection

bureau chiefs actually had to write anonymous letters to SEPA to inform them of local

pollution” (Chen, 2007).

The report of the 18th PC in 2012 first time elevated ecological construction to

the same level of importance as economic, political, cultural and social constructions.

This heightened Guangzhou government’s interests in WPPC when the appraisal and

promotion of local officials became an essential aspect of environmental governance.

Public concern with the quality of water environment in Guangzhou was another

reason for such a heightened interest in WPPC. In addition, the need to transform the

local economic development patterns led the Guangzhou government into paying

serious attention to environmental management. Hence, Guangzhou started its WPPC

initiatives even before the central government issued the APWPPC in 2015 and

promoted the RCS in 2016. In 2014, the Guangzhou government issued the Guangzhou

Eco-Water City Construction Plan 2014-2020. In the same year, Guangzhou set up the

RCS at city, district, town and township levels. In 2015, the Guangzhou government

issued another Notice on the Comprehensive Improvement of Water Environment in

242
Liuxi River Basin and Work Plan for the Comprehensive Improvement of the Water

Environment in the Liuxi River Basin (GZEEB, 2015). Thus, by the time the central

government issued its WPPC policy nationwide, the Guangzhou government had

already accomplished part of the tasks.

6.2 Incentives for Dealing with Divergent Interests

While local governments enjoy considerable discretions in policy implementation,

the central government has an absolute advantage in the control of personnel and

financial resources (Zhou & Lian, 2011). To deal with the divergent interests of local

governments, the central government translate those advantages into proper incentives

to guide local governments’ behavior through institutional arrangements (Blanchard &

Shleifer, 2000). For Barnard (1938), there are monetary and non-monetary incentives:

An organization can secure the efforts necessary to its existence, then, either by

the objective inducements it provides or by changing states of mind...The specific

inducements that may be offered are of several classes, for example: a) material

inducements; b) personal non material opportunities; c) desirable physical

conditions; d) ideal benefactions. (p.142)

Political incentives, economic incentives and moral incentives are often

mentioned in studies of central government’s incentives to local governments (Ran,

2015). These incentives include monetary and non-monetary incentives as mentioned

above.

6.2.1 Political Incentives in Environmental Policy Implementation

Political incentives for policy implementation are those that provide the relevant

243
actors and their institutions some form of political rewards in exchange for full

implementation (McDermott, 2006). Government officials tend to seek the

maximization of their own political or administrative power (Ran, 2013). In a

democratic political system, elections are the main way to gain political power. The

ballot box is the greatest political incentive for those who seek election to office. In

China’s authoritarian political system, competitive selection and appointment by

higher-level Party Committees is the main way to produce local officials (Zhu, 2008).

Therefore, promotion or advancement is the most important political incentive for

local cadres (Heberer & Senz, 2011; Kostka, 2013). For Zhou (2007), this model of

promotion is a “political tournament”. The State Council and its subordinate

departments sign target responsibility letters with provinces, municipalities and

autonomous regions. 42 Organizational departments at all levels then decide on the

Cadre Performance Evaluation System (CPES). Target Responsibility System (TRS)

and top-down CPES are institutional guarantees for providing political incentives,

such as the appointments and promotions of local cadres.43

Under China’s pressure-based system, soft indicators as expected indicators and

hard indicators as binding indicators are set by the central government for assessing

the performance of local officials. The setting of environmental protection indicators

and their evaluations by the central government have been changing over the past two

42
For example, the MEP signed WPPC target responsibility letters with 31 provinces, autonomous regions and
municipalities in 2016. Available at http://news.cctv.com/2016/11/30/ARTI3s7yJeYMkkwhQLYKwAI016113
0.shtml.
43 Article 18 of the Guangdong Provincial Civil Service Appraisal Measures (for trial) issued in 2009 clearly

states, “The results of the annual civil service appraisal are used as the basis for adjusting civil servants' positions,
ranks and salaries, as well as civil servants' rewards, training and dismissal.” Available at http://www.gdqy. gov.
cn/xxgk/zzjg/zfjg/srlzyhshbz/zcfg/zcwj/content/post_297264.html.
244
decades. Many environmental protection indicators had been gradually transformed

into binding “hard indicators” and given more weight in the evaluation system. The

most weighted and binding hard indicators is often that of a veto. The likelihood of

local government officials being held accountable for poor achievements of such

binding indicators is very high (Ni, 2008; Chen, 2018). The central government

ensures the implementation and enforcement of central policies at the local level by

linking agents’ achievements of policy objectives to their career prospects (Edin, 2003).

Environmental protection objectives have been included in national FYPs since

the late 1990s. However, these objectives were accorded low priority and took the form

of soft indicators when the emphasis was more on national economic growth (Wang,

2013). In the 11th FYP from 2006 to 2010, central planners in Beijing raised some

environmental targets from “expected” to “binding” status. They were thereafter

written into the annual responsibility contracts of local leading cadres and became

criteria for promotion. Binding environmental targets had been expanded from the

initial four in the 11th FYP to a total of 12 in the 13th FYP from 2011 to 2015. The

number of binding indicators related to WPPC had increased from one to four (see

Table 40). In adding new binding indicators to the two most recent national FYPs,

Beijing has added teeth to its green growth ambitions (Kostka, 2014).

Table 40

Key Targets of 11th -13th FYPs on Water Environment Protection

FYP Key Indicators on Water Environment Protection Type

-Water use per unit of value-added industrial output to
11th FYP binding
be reduced by 30%;
12th FYP -Water use per unit of industrial value-added output to binding

245
 be reduced by 30%;
-Aggregate major pollutant emissions reduction (%) binding
·Chemical oxygen demand (COD): 8%
·Ammonia nitrogen:10%
-Water use per 10,000 Yuan GDP to be reduced by 23%; binding
-Surface water quality of Grade III or better to be over binding
70% and worse than Grade V to be less than 5%;
13th FYP
-Aggregate major pollutant emissions reduction binding
·COD: 10%
·Ammonia nitrogen:10%
Note. Central Compilation & Translation Bureau (2016).

Secondly, the number of indicators for environmental protection has gradually

increased and expanded from individual environmental areas to multiple areas. In

addition to the FYP on national economic and social development, the national

Environmental Protection FYP (EPFYP) has also increased the number of

environmental protection targets with binding indicators (see Table 41 and Table 42

below). The 11th EPFYP (2006-2010) specified only five environmental indicators

(State Council, 2007); the 12th EPFYP (2011-2015) increased this to seven (State

Council, 2011). But these plans did not mention if those indicators were binding. From

the 13th EPFYP (2016-2020) onwards, the main indicators for environmental

protection included ten areas with a total of 26 indicators, 12 of which are binding

indicators (State Council, 2016). This is the first time when binding indicators

appeared in the EPFYP. Such indicators were not limited to air and water quality, but

soil quality, wildlife and natural shorelines as well.

Table 41

Main Environmental Protection Indicators (EPI) in 11th and 12th EPFYP

No. EPI of 11th EPFYP EPI of 12th EPFYP
1 Total COD emission Total COD emission
2 Total sulfur dioxide emissions Total sulfur dioxide emissions
246
 3 Proportion of surface water quality Total ammonia nitrogen emission
inferior to class V in national
control section
4 The proportion of national control Total nitrogen oxide emissions
section of seven major water
systems is better than that of class
III
5 The proportion of more than 292 Proportion of surface water quality
days that the air quality of key inferior to class V in national control
cities is better than class II sections
standard
6 The proportion of national control
section of seven major water systems is
better than that of class III
7 Proportion of air quality above grade II
in cities above prefecture level
Note. Adapted from State Council (2007) and State Council (2011).
Table 42

Main Indicators of 13th EPFYP

Indicators Type
Percentage of days with good air quality in cities at
binding
prefecture level and above（%）
Cumulative decline proportion of fine particulate
1.Air Quality matter (PM2.5) concentration in cities above binding
prefecture level
The proportion of severe pollution days in cities at
expected
prefecture level and above decreased（%）
The proportion of surface water quality reaching or
binding
better than Class III water body（%）
Proportion of surface water inferior to class V（%） binding
2.Water Water quality up to standard rate of water function
expected
Environment areas in important rivers and lakes（%）
Quality Proportion of extremely poor groundwater quality
expected
（%）
Proportion of coastal waters with good water quality
expected
(class I and II)（%）
3.Soil Safe utilization rate of polluted farmland（%） binding
Environmental
Quality Safe utilization rate of contaminated land（%） binding
4.Ecological Forest coverage rate（%） binding
Condition Forest volume (100 million cubic meters) binding

247
 Wetland Reserve (100 million mu) expected
Comprehensive vegetation coverage rate of
expected
grassland（%）
Index of ecological environment status in counties of
expected
key ecological function areas
Chemical oxygen demand binding
5.Total Emission
Ammonia nitrogen binding
Reduction of Major
Sulfur dioxide binding
Pollutants
Nitrogen oxide binding
6.Reduction of Volatile organic compounds in key areas and
expected
Regional Total industries
Pollutant Total nitrogen in key areas expected
Emissions（%） Total phosphorus in key areas expected
7.Protection rate of national key protected wild animals and plants
expected
（%）
8.National Natural shoreline protection rate（%） expected
9.Newly increased area for desertification control（10,000 square
expected
kilometers）
10.New soil erosion control area（10,000 square kilometers） expected
Note. State Council (2016).
Chinese leaders have increasingly relied on binding indicators. Kostka (2014)

pointed to the pragmatism of Chinese leaders. Indeed, the target-based approach had

delivered intended policy outcomes in the past. For example, the family planning

targets of China’s one-child policy (Huang, 1996). Environmental targets are, however,

unlike family planning in several important ways. Allocating environmental targets

can be contentious in view of the high costs for local businesses and local employment

(Kostka, 2014). There is a time lag between inputs and outcomes and it is also

problematic when the cycle of realizing such policies is not synchronized with the

rhythm of cadre rotation (Kostka, 2014). In addition, non-compliance with

environmental policy targets such as energy intensity targets is not as easy to detect as

deviation from the one-child policy by local authorities (Rietbergen & Blok, 2010).

Some environmental targets such as air quality, water quality and energy efficiency are
248
complex and difficult to measure as their effects are not easily observable. While

binding environmental targets produced some positive outcomes, there are problems

as well (Kostka, 2014):

Heavy reliance on binding environmental targets can also be problematic as

allocated targets can be (a) inappropriate to local circumstances and units of

protection, (b) unscientific, (c) rigid, (d) arbitrarily inflated as they get passed

down the administrative hierarchy, and (e) difficult to verify. (p.10)

Coercive orders and rigid incentives do not always result in compliance and

effective responses (Chen, 2020). As the number of hard targets for veto increases,

lower-level governments could be overwhelmed by responsibilities with limited power.

As a result, local officials have resorted to various evasive tactics such as falsification,

obfuscation and collusion to avoid punishment, which in turn weakened the binding

effect of the “one-vote veto”. Thus, the central government has introduced some

mechanism to regulate the behavior of local officials. The introduction of the RCS

across the country has made key leaders responsible for WPPC. In August 2015, the

General Office of the CPC Central Committee and the General Office of the State

Council issued the “Measures for Accountability for Ecological and Environmental

Damage by Leading Party and Government Cadres (for Trial)” (Dangzheng lingdao

ganbu shengtai huanjing sunhai zeren zhuijiu banfa (shixing)). Article four states that

leading party and government cadres will be held accountable for life in regard to

ecological and environmental damage. The introduction of such a mechanism is a

relatively sophisticated and scientific approach in applying political incentives. As

249
political incentives alone are not sufficient, the following discusses economic

incentives, moral incentives and the importance of securing information to bring about

the compliance of local governments.

6.2.2 Economic Incentives in Environmental Policy Implementation

Successful implementation of a policy requires not only political but also

financial incentives. Kung et al. (2009) have pointed out that the ability of village

leaders to do things for their villages is constrained by the material resources at their

disposal and this is also closely related to material incentives from their superiors.

Generally, the central government gives economic incentives to local governments in

two main ways. One is the central government expenditure on environmental

protection; the other is guiding the allocation of funds through a project-based system.

1. Central Government Expenditure on Environmental Protection

Research in environmental economics shows that it is only when a country invests

more than 2 per cent of its GDP in environmental protection that it is possible to control

the deteriorating trend of environmental pollution (Su, 2007). However, there has been

a lack of internationally accepted statistics on how to calculate a country’s spending

on environmental protection. The EU divides this into three areas: inputs from the

private and public sectors specializing in the provision of environmental protection

services, public finance and industry.44 Given the dominant position of the Chinese

government in environmental protection, some scholars emphasized the importance of

44 Environmental protection expenditure accounts. Available at https://ec.europa.eu/eurostat/statistics-

explained/index.php?title=Environmental_protection_expenditure_accounts#National_expenditure_on_environm
ental_protection.

250
investment via public finance (Su et al., 2008). It was not until 2006 that China

formally incorporated environmental protection expenditure account into the national

budget. Prior to this, investment in environmental protection by the central government

and local governments was ambiguous and uncertain. Table 43 below shows the central

government’s expenditure in environmental protection from 2007.

Central government’s total expenditure on environmental protection includes

both the central government’s spending at its own level and transfer payments to local

governments. Overall, central government spending on environmental protection has

shown an upward trend. From 2010 to 2015, there was a relatively large increase in

central spending with growth rates mostly exceeding 10 per cent. In 2010 and 2012, it

even exceeded 20 per cent. After 2015, central spending on environmental protection

entered a relatively stable phase, at roughly RMB 200 billion per year.

Table 43

Central Government Expenditure on Environmental Protection (EP) 2007-2020

Central-
Total Central
level Proportion of Proportion of
central transfer
expenditure CLEEP to CTPEP to
expenditure payments on
on EP central central
Year on EP EP(CTPEP）
(CLEEP) environmental environmental
(100 million (100 million
(100 million expenditure expenditure
yuan) yuan)
yuan)
2007 1027.51 79.93 947.58 7.78% 92.22%
2008 1040.30 66.21 974.09 6.36% 93.64%
2009 1151.81 37.91 1113.90 3.29% 96.71%
2010 1443.10 69.48 1373.62 4.81% 95.19%
2011 1623.03 74.19 1548.84 4.57% 95.43%
2012 1998.42 63.65 1934.77 3.19% 96.81%
2013 1803.93 100.26 1703.67 5.56% 94.44%
2014 2033.03 344.74 1688.29 16.96% 83.04%
2015 2254.81 400.41 1854.4 17.76% 82.24%

251
 2016 2076.53 295.49 1781.04 14.23% 85.77%
2017 2086.44 350.56 1735.88 16.80% 83.20%
2018 2153.56 427.56 1726.00 19.85% 80.15%
2019 2263.46 421.19 1842.27 18.61% 81.39%
2020 2077.76 344.26 1733.50 16.57% 83.43%
Note. National government final accounts 2007-2020.
http://yss.mof.gov.cn/caizhengshuju/ .
The central government’s transfer payments to localities are divided into general

transfer, earmarked transfer and special transfer. Transfers related to environmental

protection, especially WPPC, are specific fund earmarked for transfer; as earmarked

transfer, lower-level governments are required to use such fund for purpose specified

by higher-level governments. Earmarked transfer covers ten areas such as renewable

energy development, air pollution prevention and control. There are two types of

funding for water management. One is fund for WPPC and the other is concerned with

subsidies for urban pipe networks and sewage treatment (see Table 44 below).45 There

has been a significant increase in the central transfer payments for WPPC since 2015,

which is strongly linked to the implementation of APWPPC. In addition, the central

government’s transfer payments for WPPC occupy a very high proportion of the

transfer payments for environmental protection. WPPC has accounted for 16 to 25

percent of such payments since 2015. This is also a positive sign for local governments

in terms of economic or financial incentives for carrying out WPPC works.

Table 44

Central Government Earmarked Transfers on Water Environment Management (WEM)

Year WPPC funds Subsidies for urban Total transfers The proportion of
(100 million pipe networks and for WEM central transfers on
yuan) sewage treatment (100 million WEM to central

45
The Ministry of Finance has only been publishing specific accounts for central environmental transfers since
2014.
252
 (100 million yuan) yuan) transfers on EP
2014 70.00 105.87 175.87 10.42%
2015 121.50 180.00 301.50 16.26%
2016 140.00 185.00 325.00 18.25%
2017 115.00 166.50 281.50 16.22%
2018 150.00 186.50 336.50 19.50%
2019 190.00 186.22 376.22 20.42%
2020 197.00 126.21 323.21 18.64%
Note. National government final accounts 2014-2020.
http://yss.mof.gov.cn/caizhengshuju/.

2. Project-based System for Environmental Protection

The central government is not the actual implementer of environmental policy,

but it holds significant financial resources for environmental protection (Ran, 2015).

How does the central government guide local fiscal spending according to its will?

Earmarked fund is a form of financial transfer in which a higher-level government

specifically earmarks certain functions for transfer. It operates mainly through top-

down project bidding and bottom-up project application bidding; it is mostly not

mandatory (She & Chen, 2011). Some scholars have summarized this as “project-

based governance” (Zhou, 2012). The “project-based system” has become the most

dominant mode of operation and management of fiscal transfer from the central

government to local governments after the tax-sharing reform (Zhou, 2012). Prior to

2014, more than 90 percent of central government spending on environmental

protection was in the form of central to local transfer. After 2014, the proportion

declined, but still remained above 80 per cent (Ministry of Finance, 2007-2020). When

funds are earmarked for various large national environmental protection construction

projects, they are allocated to localities. It included some WPPC projects, such as

“Three Gorges Reservoir and Upper Stream Water Pollution Management Project”,

253
“Three Rivers and Three Lakes Pollution Control Project”. These large-scale

environmental management projects are generally managed by ministries and

commissions of the central government, which include not only MEP (MEE) and

MWR, but also all the ministries related to water environment functions such as MA

and NDRC. Local governments can only receive earmarked funding if project

applications are approved by their higher-level government counterparts (Zhou, 2012).

The central government also transfers earmarked fund to local governments in

the form of “prizes in lieu of subsidies” (yi jiang dai bu, hereafter PLS). The fifth point

of the APWPPC clearly stated PLS as a mean to increase government funding. As a

form of financial assistance, it turns the original fixed subsidy into a flexible award.

The central government pays these awards to local governments based on the actual

completion of a project and relevant criteria. By establishing such criteria, the central

government guides local governments in implementing policies according to its will.

The PLS has changed earmarked fund from ex ante to ex post transfer. This approach

is an incentive to encourage excellence and motivate the participation of local

governments.

Since 2018, the central government has encouraged local governments to apply

for “Model Cities for the Treatment of Black and Odorous Water Bodies”

(MCTBOWB), which is an example of PLS. Before the selection of model cities, three

central departments issued two documents: Guidelines for the Application of Model

Cities for the Remediation of Urban Black and Odorous Water Bodies and Outline for

the Preparation of Implementation Plans for Model Cities for the Remediation of Black

254
and Odorous Water Bodies (MF, MHURD & MEE, 2018). Cities participating in such

a selection should meet the criteria listed in the documents and are recommended by

their provinces. These criteria reflected the central government’s plan to guide the

behavior of local governments in three areas. First, the root causes of black and

odorous water bodies should be treated. 46

Second, the cooperation between

government and society is being promoted. Third, a long-term mechanism for

monitoring WPPC performance should be established. Cities at prefecture level and

above that have already achieved a certain level of success in these three areas are

likely to be shortlisted cities. The three central ministries gather experts to review

applications and decide on the shortlisted cities through competitive evaluation. The

results are made known to the community. In 2018, the central government allocated

RMB 600 million to each shortlisted city. In addition to the selection of MCTBOWB,

there are also the State Council Inspection Incentives (General Office of State Council,

2018), the selection of National Advanced Counties (districts), Collectives and

Individuals of the River and Lake Chief System organized by MWR. These are

examples of PLS related to WPPC.

There are some limitations in the economic incentives offered by the central

government. First and foremost, although the central government’s spending on

environmental protection has been increasing, local governments still assume the

lion’s share of environmental protection expenditure (see Figure 19). From 2007 to

46
The documents clearly stated that “in-situ restoration and spreading of chemicals in the river as the main
treatment measures, in particular the transfer of water to flush out pollution, will be considered as a substandard
scheme” (MF, MHURD & MEE, 2018).
255
2020, local governments shouldered around 95 percent of the national public

expenditure on environmental protection. It included EPB human resources and other

standard office costs, environmental management projects, environmental

infrastructure development, urban greening projects and so on. 47 This imposed a

heavy burden on local finance. Local governments face many difficulties in gaining

access to financial resources when implementing environmental policies. In strictly

enforcing environmental policies, local governments have difficulties attracting more

business investments to their jurisdictions. This in turn aggravates the burden on local

public finance.

Figure 19

The Share of Expenditure Between the Central Government and Local Governments

2007-2020 in Environmental Protection

The Share of Expenditure Between the Central

Government and Local Governments in Environmental
Protection (Union: 100million)
8000.00

6000.00

4000.00

2000.00

0.00
2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Central government's own expenditure on environmental protection

Local governments expenditure on environmental protection

Note. National Government Final Accounts 2007-2020.

http://yss.mof.gov.cn/caizhengshuju/ .

The central government has transferred a large proportion of earmarked fund for

47
For details, see the departmental final account of the GZEEB from 2015-2021. Available at
http://sthjj.gz.gov.cn/gkmlpt/index#645.
256
environmental protection to local governments through the project-based system and

PLS. PLS applies to local governments with a certain achievement in environmental

protection. Local governments need to have both sufficient fund and sound governance

in WPPC. Project applications usually require matching fund from local governments.

The complex and lengthy application process in the project-based system may

ultimately result in a waste of funds and resources. According to Zhou (2012), a

complete project system came with a very strict audit system, which standardized the

management and control of specific fund. All this means greater difficulty for such

funds to reach the grassroots level. As a result, the attitude of local authorities towards

projects varied greatly.

6.2.3 Moral Incentives in Environmental Policy Implementation

Moral incentive is about teaching people to believe that a particular policy is

appropriate and that loyal implementation is the right thing to do, thereby achieving a

desirable policy outcome (Honig, 2008). Unlike the impact of political and economic

incentives on policy implementers, the value of moral incentives is mainly at the

individual psychological and cognitive level. It is often closely linked to values, ways

of perceiving, attitudes and beliefs that are formed on the basis of education. As a result,

its impact on individuals varies greatly.

Before 2012, it is difficult to find anything that can be identified as a moral

incentive for environmental policy implementation in China. Local officials had had

two main interpretations of environmental policies formulated by the central

government (Ran, 2013). There was, firstly, a general perception among local

257
implementers that China’s environmental policies were “soft” laws, highly conflicting,

ambiguous and symbolic. Such policies were unlikely to be implemented in the first

place. Secondly, when guidelines and environmental policies were perceived as

serving the needs of economic development, the second perception of local

implementers was that leaders at all levels did not really care much about

environmental protection. Both perceptions led to the belief that environmental policy

implementation did not boost one’s self-esteem or attract the admiration and approval

of others in the political system. Consequently, local officials did not feel guilty for

not implementing environmental policies. However, with the change in the attitude

and awareness about environmental protection at the top, the situation has been

changing. This section focuses on the central government’s moral incentives for local

governments in terms of the changes made to environmental education for cadres as

well as speeches by key central leaders.

1. Environmental Education in Party Schools and Administrative Colleges

Many studies have pointed to the position of party schools and administrative

colleges in the top-down education and training of cadres in China (Shambaugh, 2008;

Liu, 2009; Zhao, 2013). The organization department laid down the rules for leading

cadres at all levels to go for training in party schools or administrative colleges on a

regular basis.48 Party schools place more emphasis on the ideological, political and

theoretical education of cadres; while administrative colleges, on the ability to solve

48
For example, the National Plan for the Education and Training of Cadres 2018-2022 issued by the CC of the
CCP in 2018 set out the number of cadres to be trained at all levels, the duration of training, the content of
training, etc. Details are available at http://www.gov.cn/zhengce/2018-11/01/content_5336680.htm.
258
practical problems. The fundamental aim is to train a group of political elites who are

loyal and capable of implementing the policies of the central government. In

Shambaugh’s studies, central policy adjustments and changes were evident in the

changes made to the curricula of party schools (Shambaugh, 2008).

Few months after the establishment of the sustainable development strategy in

the report of the 15th PC in 1997, the National Party Schools and Administrative

Colleges held a seminar on “Sustainable Development and Environmental Protection”.

Education on the ideas of sustainable development and environmental awareness is an

important aspect of improving the quality of cadres in view of the new situation in

China”. It was recommended that “Party schools at all levels should include the theory

of sustainable development and environmental protection in the teaching of Party

schools” (Zhao, 1998, p.67). As an initial attempt, it was the first time to find courses

on sustainable development included in some cadet courses in the party schools and

administrative colleges.

In 2007, Hu Jintao put forward the SOD in the report of the 17th PC, which

included some broad content and ideas on environmental protection and sustainable

development. Hence, a course related to environmental protection was part of the

training on SOD. At this stage, environmental education for cadres did not have a

stable curriculum plan, syllabus, specialized teaching materials and a specialized

teaching and research team. Environmental education and training only began in 2012

(Li et al., 2013). In 2013, several central ministries and the National School of

Administration (NSA) jointly organized a seminar on promoting ecological

259
civilization for leading cadres at provincial and ministerial levels. The Continuing

Education Department of the NSA produced a teaching material, Construction of

Ecological Civilization Readings, being the first publicly reported environmental

education course for officials at the highest level. In 2017, the NSA once again held a

seminar on promoting ecological civilization and low-carbon development for

provincial and ministerial-level cadres (XinHuanet, 2017). Later, the Central Party

School’s Further Training Department held a number of classes on ecological

civilization at the local and departmental levels.

During fieldwork in the Guangzhou Administrative Colleges and the Guangzhou

Institute of Socialism (mainly training for non-party cadres), the author learned that no

courses on environmental education were offered in 2007. Apart from some

government officials in GZEPB and GZWRB who attended studies organized by

higher authorities, few implementers of local environmental policies received

systematic environmental education in these party schools or administrative colleges

(C1, personal communication, May 16, 2020; C2, personal communication, June 2,

2020). After the 18th PC in 2012, provincial and municipal party schools began offering

courses on ecological civilization. In the case of Guangzhou, the Guangzhou

Municipal Party School has included “Leading the Construction of Ecological

Civilization with the Concept of Green Development” as a special tutorial in its

teaching program for young and middle-aged cadres (C1, personal communication,

May 16, 2020).

2. Speeches on Environmental Protection by National Leaders

260
 Jiang Zemin’s speech on environmental protection. In September 1995, the

Fifth Plenary Session of the Fourteenth Central Committee of the CCP formally wrote

the sustainable development strategy into the proposal of the CPC Central Committee

as Formulating the Ninth Five Year Plan for National Economic and Social

Development and the Long-term Goals for 2010 and put forward that “comprehensive

social development must be placed in an important strategic position to realize the

coordinated and sustainable development of the economy and society” (The CC of the

CCP, 1995). This is the first time that the concept of “sustainable development” was

used in party documents. General Secretary Jiang Zemin delivered a speech entitled

Correctly Handling Several Major Relations in the Socialist Modernization

Construction at the meeting, stressing that “in the modernization process, we must take

the realization of sustainable development as a major strategy” (Jiang, 1995).

In 1999, Jiang Zemin made an important speech on environmental protection and

China’s environmental policy at the opening of the fifth meeting of the Conference of

the Parties to the Vienna Convention and the eleventh Ministerial Meeting of the

Parties to the Montreal Protocol in Beijing. He said,

Environmental issues have a bearing on the future and destiny of every nation's

people on earth. It is the common aspiration of all peoples and the common

responsibility of all governments to solve environmental problems and to maintain

and create a better home for human beings to live in together. (Jiang, 1999)

He also pointed out that China has a responsibility to contribute to global

environmental protection through relentless efforts to address China’s environmental

261
problems, especially the reduction of harmful emissions (Jiang, 1999).

It was after the World Conference on Environment and Development in 1992 that

the CCP proposed a sustainable development strategy. This conference formulated and

adopted an important document, Agenda for Action in the 21st Century and the Rio

Declaration, which formally introduced the strategy for sustainable development.

Jiang Zemin’s speech in 1999 was also an opportunity to proclaim China’s role in

environmental protection to the world at some important international environmental

conferences. The importance attached to environmental protection in the speeches of

central leaders at this stage was symbolic and intended to project a good image to the

international community. As a result, these speeches had had little impact on the

implementation of environmental protection policies by local governments.

Hu Jintao’s speech on environmental protection. At the 17th PC in 2007,

General Secretary Hu Jintao put forward in his report the essence of SOD being

people-oriented and for sustainable development.

In 2006, when Hu Jintao participated in the voluntary tree planting activities in

Beijing, he stressed that

Party committees and governments at all levels should persevere in the protection

and construction of the ecological environment, strive to solve outstanding

problems concerning the protection and construction of the ecological

environment, and earnestly create a good production and living environment for

the people. Through the unremitting efforts of the whole society, we should make

the sky bluer, the earth greener, the water cleaner and the relationship between

262
 man and nature more harmonious. (Xinhua News Agency, 2006)

In his report to the 18th PC in 2012, Hu Jintao vigorously promoted the

construction of ecological civilization. From the introduction of SOD in 2004 to the

vigorous promotion of ecological civilization in 2012, Hu Jintao stressed the need to

protect the environment actively in important domestic conferences (such as Party

Congresses and Two Sessions) and occasions. However, the central leaders’ ideas on

environmental protection were not systematic. The relevant discourse was enmeshed

in ideas about SOD, which had had not much impact on the thinking or actions of local

governments.

Xi Jinping’s speech on ecology and environment. Since the 18th PC, General

Secretary Xi Jinping has delivered a series of important speeches on the construction

of socialist ecological civilization. The Literature Research Office of the Central

Committee of the Communist Party of China has edited Xi Jinping’s speeches on the

Construction of Socialist Ecological Civilization. The contents of the book included

more than 80 important documents on speeches, reports, talks, instructions and

congratulatory letters by Xi Jinping from November 15, 2012 to September 11, 2017.

Seven topics were discussed in two hundred and fifty-nine speeches. Table 45 below

lists some of Xi Jinping’s speeches on ecological civilization, including speeches on

WPPC during his two visits to Guangdong Province that showed great concern for

environmental issues. Compared to the speeches of national leaders on environmental

protection before the 18th PC, Xi’s speeches seemed to be more specific, systematic

and pragmatic. All these are supposed to serve as positive moral incentives for local

263
governments in regard to their roles and responsibilities in environmental protection

in time to come.

6.3 Information: A Working Mechanism and a Monitoring System

The information in this study refers to the authenticity and validity of information

secured by the central government and local governments. On the one hand, it refers

to the authenticity of the information that the central government received from local

governments. On the other hand, it concerns whether information from the central

government can be effectively conveyed to local governments (Lieberthal &

Oksenberg, 1988). In principal-agent theory, information asymmetry is a problem. As

far as the principal-agent relationships between the central government and local

governments are concerned, information not only helps higher-level governments

make decisions, but also serves as a guide to the behavior of the lower-level

governments. Therefore, information entails incentives offered by the central

government and the behavioral strategies of local governments. The central

government’s access to environmental information goes through the following four

stages (Tang & Chen, 2017).

From 1973 to 1995, ineffective environmental monitoring system hindered the

central government’s capacity to supervise local governments in the implementation

of environmental policies. Outdated environmental monitoring equipment and

technology, improper methods, low quality of personnel, lack of financial support and

interference by local governments resulted in the failure to provide valid and reliable

data for environmental management (WAN, 1996).

264
 Table 45

Excerpts from Xi Jinping’ s Speech on Ecological Civilization

No. Content Source
1 The 18th PC incorporated the construction of ecological civilization into the overall layout Study and implement the spirit of the
of the socialism with Chinese characteristics, which integrated the strategic position of the 18th PC by focusing closely on adhering
construction of ecological civilization with economic construction, political construction, to and developing socialism with
cultural construction and social construction. Chinese characteristics (November 17,
2012).
2 If we continue to develop in a sloppy manner...what will be the situation of pollution? I am Speech on the economic situation in the
afraid that the resources and environment will not be able to carry the load at all... What is first quarter at the 18th meeting of the
the situation... the people’s sense of well-being is greatly reduced, or will this lead to strong Standing Committee of the Political

265 265
public discontent. Therefore, we cannot treat ecological civilization, environmental Bureau of the CPC Central Committee
protection ... as merely economic issues. There is a great deal of politics in it. (April 25, 2013).
3 Ecological environment, especially air, water and soil pollution, has become a prominent Notes on the proposal of the CPC
short board of building a well-off society in an all-round way. To reverse the deterioration Central Committee on formulating the
of the environment and improve the quality of the environment is an ardent expectation of 13th FYP for national economic and
the people. It is an important work that must be attached with great importance and to be social development (October 26, 2015)
promoted in the 13th FYP.
4 Since the reform and opening up, China's economic development has made historic Speech at the seminar on learning and
achievements... At the same time, we have accumulated a large number of ecological and implementing the spirit of the Fifth
environmental problems, which have become obvious shortcomings and prominent Plenary Session of the 18th CPC Central
problems strongly reflected by the people. For example, all kinds of environmental Committee for leading cadres at the
pollution are prevalent... Such a situation must be reversed with great efforts. provincial and ministerial level (January
18, 2016)
 5 I take ecological and environmental protection issues very seriously. Since the 18th PC, I have Speech at the 41st collective study of the
repeatedly given instructions on matters that have seriously damaged the ecological environment Political Bureau of the 18th CPC Central
and requested that they should be seriously investigated and dealt with...The reason why I have Committee (May 26, 2017)
to keep an eye on the ecological and environmental issues is because if we do not grasp and
tighten our grip and allow the problems of damaging the ecological environment to continue, it
will be difficult for us to fundamentally reverse the trend of the deterioration of our ecological
environment, which is irresponsible to the Chinese nation and future generations.
6 Guangdong's water pollution problem is relatively prominent, in which we must be determined Speech during a working tour in
to cure; to fully eliminate urban black smelly water bodies... We need to deepen the construction Guangdong (October 22-25, 2018)
of ecological civilization, co-ordinate the system of mountain, water, forest, lake and grass
management. Deepen ecological and environmental protection cooperation with Hong Kong and
Macao, and strengthen collaboration with neighboring provinces to carry out joint prevention and
treatment of pollution, and make up for the ecological deficit.
7 We must maintain the strategic determination to strengthen the ecological civilization... we Speech at the deliberations of the Inner
cannot consider... the idea of sacrificing the environment in exchange for economic growth, and Mongolia delegation at the second

266 266
even find ways to break through the ecological protection red line just because economic session of the 13th NPC (March 5, 2019)
development encounters a little difficulty. In the process of shifting from a stage of high economic
growth to a stage of high-quality development, pollution prevention and environmental
management is an important hurdle that needs to be crossed, and we must bite the bullet and
climb over this slope and step over this hurdle.
8 Adhere to the new development concept, adhere to high-quality development. You should show Speech during a working tour in
new and greater efforts in the ecological civilization construction, protection and improvement Guangdong (October 12-13, 2020)
of people's livelihood and other aspects...We must promote the comprehensive management of
the Han River basin to make the water clean and clear.
Note. Database of Xi Jinping’s series of important speeches. http://jhsjk.people.cn/article/30959333.
 During the second stage from 1996 to 2005 and in accordance with the Tenth

Five-Year Plan from 2001 to 2005, SEPA developed and implemented the

environmental statistics reporting system in 2001. However, the lack of an effective

verification mechanism means the data collected often failed to reflect the actual state

of the environment when there were significant discrepancies between national and

local data (Tang & Chen, 2017).

From 2006 to 2010, the environmental monitoring system underwent major

reform that equipped it with effective monitoring capabilities (Tang & Chen, 2017). A

data accounting mechanism specifically for total emission reduction began to take

shape with the publication in 2007 of the “three methods” on statistics, monitoring and

evaluation of major pollutants (Zhang & Qi, 2010). The confirmation of pollution

emission data was transferred to the central government, which broke the long-

standing information asymmetry between the central government and local

governments. This led to an initial oversight of implementation outcomes over local

governments.

By the end of the 11th Five-Year Plan in 2010, China had established an efficient

national environmental monitoring network covering the whole country. At this stage,

information was not only shared between the central government and local

governments, but was made available to the public. The public has accessed to the

daily air quality and water quality of nearby rivers and lakes. The establishment of the

environmental pollution complaint platform allows major environmental issues that

cannot be resolved by local governments to be re-directed to the relevant central

267
ministries. The central government is then able to have a realistic picture of the local

environmental situation as problems accrued to information asymmetry were resolved.

In general, each stage was characterized by different interests, incentives and

information on the part of the central government (see Table 46 below). In the first two

stages before 2006, there was either non-implementation or symbolic implementation

of environmental policies by local governments due to a lack of motivation in

environmental protection at both the central and local levels, an absence or inadequacy

of relevant incentives and an ineffective environmental monitoring system. By the

third and fourth stages, political implementation of environmental policies by local

governments gradually became the norm. Differences between the central government

and local governments over the implementation of environmental policies and the

conflicts of interest intensified. At the same time, the central government began to

changed and improved its incentives and information tools. The final section below

proceeds to discuss and explain the combined impact of Interests-Incentives-

Information (3I) on the 2008 and 2016 WPPC policy implementations in Guangzhou,

which took off in the third and fourth stages respectively.

268
 Table 46

Background to the Implementation of Environmental Policies by Central Government

Period Interests
1973- The interests of the central
1995 government and local
governments were aligned
and policies focused on
economic development.
1996- Increased divergence of
2005 interests between the central
Incentive
Lacking in the provision of incentives to promote the
implementation of environmental protection policies
by the central government for local governments.
Lacking in the provision of incentives to promote the
implementation of environmental protection policies
Information
The development of environmental
monitoring systems was lagged behind
and could not provide complete,
accurate and realistic data for the
central government
Ineffective environmental monitoring
system with problems in technology,

269
government and local by the central government for local governments. methods and personnel in the

269
governments in collection of accurate environmental
environmental protection. statistics and data and the lack of a
verification mechanism.

2006- The divergence of interests
2010 between the central
government and local
governments in
environmental protection
intensified.
The central government began to set up political The environmental monitoring system
incentives and economic incentives for local underwent major reforms and was
governments: gradually equipped with effective
·Environmentally binding targets appeared in the FYP; monitoring capabilities.
·Increase in financial spending allocated for
environmental protection by the central government;
·Fewer speeches on environmental protection by key
central leaders;
·Little education and training in environmental

2011- The divergence of interests
present between the central
government and local
governments in
environmental protection
remains substantial.
270
270
Note. Compiled by the author.
protection for key local leaders.
Central government set up political, economic and Environmental monitoring
moral incentives: construction is in full swing. A national
· more and more environmental binding indicators； environmental monitoring network
·The number of national environmental governance with nationwide coverage is currently
documents issued by the central government in place
increased;
·Environmental achievements increase its influence on
the promotion of local officials;
·Increasingly sophisticated evaluation indicators for
officials' environmental performance assessment;
·Central fiscal expenditure on environmental
protection continued to increase; specific funds have
been transferred to local governments through
environmental protection projects or in the form of
PLS;
·Increased education and training of key local leaders
in environmental matters;
·More speeches by central leaders on ecological
civilization.
6.4 The Combined Impact of Interests-Incentives-Information (3I) on WPPC

6.4.1 The Impact of 3I on the 2008 WPPC in Guangzhou

As discussed in chapter four, the Guangzhou government launched the WPPC in

2008 as a response to the central government’s incentives for environmental protection

during the 11th FYP from 2006 to 2010 pending the 2010 Asian Games. Yet it was a

failed attempt because of the divergence of interests between the central government

and local governments, lack of a rational and well-designed incentive mechanism and

an effective monitoring system for securing valid and reliable environmental

information.

In the third stage of the history of China’s environmental protection from 2006 to

2010, the central government had gradually changed its attitude and awareness about

environmental protection. Conflicts with local governments were also escalating as a

political implementation mode was advanced by the central government. The crucial

question hinged on whether the central government possessed the capacity to force its

will on local governments, thereby securing compliance. But the central government

was unable to do so as the problems of information asymmetry were serious without a

working mechanism to sustain a monitoring system for acquiring valid and reliable

environmental information that revealed the truth about the performance of local

governments in environmental protection at the local level.

Local environmental monitoring system was not well developed at this stage. For

example, the number of state-controlled surface water stations during the 11th FYP

period was 759 (State Council, 2011). There are 31 provinces, municipalities and

271
autonomous regions in the country, so that on average there are only 25 monitoring

stations in a province. In Guangdong’s case, it has 21 prefectural cities; each prefecture

on average had only one to two monitoring stations. As a result, it was difficult for the

central government to judge the performance of local governments in WPPC. Then,

the central government did not adopt measures, such as central environmental

inspection, channels for public reporting of environmental problems to deal with the

ineffective monitoring of water quality at the local level.

The capacity of the central government to force local governments to act

according to its will was also undermined by the dependence on a single indicator for

measuring water quality in WPPC. According to Kostka (2014), binding

environmental targets were often inappropriate to local circumstances. In her analysis,

non-ferrous metal pollution in Chenzhou city in Hunan province was not mentioned

until the 12th FYP. Thus, making some binding environmental targets in the FYP often

means neglecting other important environmental targets and issues for some regions.

Hence, the reduction of a particular pollutant, COD by 10 per cent, stipulated in the

11th FYP as a binding target did not change the overall water quality. Although twelve

factors were then used to evaluate surface water quality, the evaluation method

generally relied on a single factor. Therefore, when one of the indicators exceeded the

standard value of a corresponding function, the water body no longer fully met the

requirements of that function.49 In other words, surface water quality was assessed

based on a single indicator that performed the worst. For local governments, WPPC

49
The specific water quality assessment can be found in the Environmental Quality Standard for Surface Water
GB3838-2002 issued by SEPA in 2002.
272
was merely about controlling COD discharge. However, there were multiple pollutants

in the rivers. For example, the Second National Pollution Source Census in Guangdong

Province found that the discharge of main water pollutants in the Pearl River Delta

region included COD, total nitrogen and ammonia nitrogen (Du, 2020). As a result,

focusing on COD alone did not improve water quality in the rivers. This partially

explained the failed implementation by local authorities.

Secondly, lack of clarity concerning the authority and responsibility of leading

cadres in governments added difficulty to the assessment and accountability of local

officials. As long as local government officials completed their tasks concerned with

just one indicator, they would not be subjected to “one veto” in the cadre appraisal

process. Moreover, the 2008 WPPC objectives specified only the number of projects

to be completed but not the targets to be achieved for water quality. Whether these

projects could ultimately achieve better water quality were, at best, unclear. Hence, the

public was not satisfied with the 2008 WPPC when local leaders were not held

accountable for unsatisfactory implementation outcomes (Jianchi, 2014).

During the 11th FYP period (2006-2010), the central government’s incentives for

WPPC were set in a simple and sloppy manner. Local governments could easily meet

the requirements through a short-term campaign-style treatment of water pollution.

Since these requirements did not have a substantial impact on the promotion of local

officials, they also failed to steer local governments away from their short-term

interests. The cost of ecological governance was inflated and unsustainable (Yu, 2011).

A staff from the New Life pointed out that the Guangzhou government often put the

273
cart before the horse when money was invested to treat the symptoms but not the root

causes (E3, personal communication, March 10, 2018).

6.4.2 The Impact of 3I on 2016 WPPC in Guangzhou

As discussed in chapter five, the 2016 WPPC initiated by the Guangzhou

government was a response to the APWPPC issued by the State Council in 2015. This

round of WPPC belonged to the fourth stage of China’s environmental policy

implementation (i.e. the 18th PC in 2012 and after), where a political implementation

mode prevailed.

Before this round of WPPC, the divergence of interests between the central

government and local governments were still prominent. The level of conflict was still

high. The promulgation of APWPPC led the MHRUD and the then MEP into

conducting the first round of nationwide screening for black and odorous water bodies

in built-up areas in cities at prefecture level and above in 2016. Of the 295 cities at

prefecture level and above, there was a total of 216 cities with 1,811 black and odorous

water bodies. As discussed in the first section, Guangzhou was well ahead in WPPC

and converged with the interest of the central government’s 2015 APWPPC objectives

and the promotion of RCS in 2016. This was due to the inclusion of cadre assessments

as part of environmental governance, public concern with the quality of water

environment and the need to transform the local economic development pattern. As

early as 2013, Guangzhou came up with the Guangzhou Cleaner Water Construction

Program in 2013 to comprehensively treat 51 rivers and get rid of water bodies worse

than Class V by the end of 2015 (GZWA, 2016). It is worth noting that the release of

274
APWPPC also produced major changes from the past in terms of incentives and access

to environmental information. This has had a positive impact on WPPC and water

governance in Guangzhou.

1. Changes in Incentives

In terms of political incentives, the central government has been using the TRS

and the CPES to incentivize local authorities to combat water pollution. The difference

is that by 2015, the targets and measures to be taken are clearer as well as long term in

perspective. The APWPPC put forward water quality objectives to be achieved in the

near term (2020), medium term (2030) and long term (2050) for the five water

categories. This is a significant departure from the short-term nature of previous water

pollution control targets. The ten measures proposed in the APWPPC for achieving the

objectives are not the usual methods of dredging, regulating and replenishing water,

but more on tackling the root causes of pollution. To promote the structural

transformation of the economy, industrial emission pollutants have to be controlled

across the board. In addition, the ten measures also dealt with institutional

development in WPPC, such as strict environmental enforcement and supervision,

strengthening water environment management, clarifying and implementing the

responsibilities of all parties, and strengthening public participation and oversight by

the public. These measures guide local governments into adopting a scientific and

rational approach, taking into account long-term institutional development to control

water pollution.

Besides, the central government had introduced a nationwide RCS in 2016 and

275
designed strict assessment indicators for river patrolling. RCS places the main

responsibility of WPPC on the main leaders in local governments. The introduction of

the CEEPI had also provided another political incentive for local governments to

implement environmental policies. In terms of accountability, the central government

issued the Measures for Pursuing Responsibility for Ecological and Environmental

Damage by Leading Party and Government Cadres (for Trial Implementation) to

pursue responsibility for ecological and environmental damage due to negligence and

failure on the part of leading party and government cadres for life. The appointment of

Zhang Shuofu as the Party Secretary of Guangzhou Party Committee with

qualification in environmental science and engineering and 20 years of past experience

in water resources management in 2018 was an additional political incentive from the

central government.

In terms of economic incentives, the transfer of specific fund from the central

government to local governments in the form of PLS has transformed financial

resources from ex ante subsidies to ex post subsidies. Cities that are recommended to

participate in the PLS should be competitive enough to participate in the selection

process. This is attractive to Guangzhou not only that it offers the possibility of

obtaining financial support from the central government, but also allows Guangzhou

to demonstrate its capacity and competitiveness, financially and materially, in

outperforming other cities in WPPC, in particular, water resources management (Li,

2022).

Since the 18th PC, the status of ecological civilization has been raised to an

276
unprecedented height. General Secretary Xi Jinping had made important statements

about ecological civilization on a number of occasions both at home and abroad. As

moral incentives, they made local governments realize that environmental protection

is a top priority for the central government and that past campaign-style governance

can no longer cope with the central government’s assessment and evaluation methods.

In the past, scholars, local people’s congress representatives, ENGOs and the public

had raised serious doubts about the Guangzhou government’s ability to tackle water

pollution in view of many failed WPPC attempts (Southern Talks, 2013; Jianchi, 2014;

Xu, 2014; Zheng, 2016). Thus, the Guangzhou government had realized its mistakes

and abandoned traditional short-term campaign style treatment for WPPC. To sum up,

the incentives put forward by the central government have matched the needs and

context of Guangzhou, resulting in the improvement of the 2016 WPPC policy

implementation.

2. Capacity of the Central Government and Access to WPPC Information

Another reason for the central government’s capacity to provide incentives that

boosted the performance of local governments in implementing WPPC lies in the

success of securing valid and reliable information through a working mechanism that

includes building and sustaining an effective monitoring system through hierarchy and

networks that also embraced public participation as discussed in chapter five.

Firstly, the central government has significantly increased the number of state-

controlled surface water monitoring stations. The number of state-controlled surface

water stations was 759 in the 11th FYP period and 972 in the 12th FYP period (Ministry

277
of Environmental Protection, 2016). In 2016, the then MEP published the 13th FYP for

setting up the national surface water environmental quality monitoring network. The

program changed the original 972 state-controlled stations to 2,767 stations by

transforming the stations that were previously under local monitoring into national

monitoring. The original number of state-controlled stations in the Pearl River Basin

was only 54, but now it has 293 sections (Ministry of Environmental Protection, 2016).

In this way, the central government ensured the accuracy of data on water quality in

the country’s major watersheds and important regions, and prevented interference from

local and grassroots leaders and their grassroots monitoring stations. The MEE’s

National Automatic Surface Water Quality Monitoring Real-time Data Dissemination

System (NASWQMRTDDS) allows information on state-controlled monitoring cross-

sections to be viewed at any time (see Figure 20 below).

Figure 20

Real-Time Data from State-Controlled Monitoring Sections in Guangzhou

Note. National Automatic Surface Water Quality Monitoring Real-time Data Dissemination
System. http://106.37.208.243:8068/GJZ/Business/Publish/Main.html.

278
 Other than the application of advanced technology in monitoring activities, the

establishment of a long-term information gathering (working) mechanism has been

crucial to the central government’s access to valid and reliable environmental

information. This has boosted the capacity of the central government when problems

due to information asymmetry and the obstruction of a more accurate picture on the

performance of local governments in WPPC were overcome. River patrolling and data

collection by (social) river chiefs and the regular inspections undertaken by the CIEEP

not only imposed pressures on provincial governments and local governments but also

constituted part of a working mechanism for sustaining an effective monitoring system.

Such a system permeated hierarchy and networks as first-hand information on the

environment could be collected. The process also engages the public in oversight when

information is disclosed to the public through NASWQMRTDDS, a website set up by

the MHURD and the MEE that publicizes information on black and odorous water

bodies and also offers a platform for the public to lodge complaint. 50

As discussed in chapter five, the CIGEEP receives complaints through direct

phone contacts made known to the public. Inspection teams also receive letters and the

visits by the public during on-site inspection. As for RCS, contact information of river

chiefs is displayed in the billboards along rivers for complaints to be lodged through

WeChat account (see Figure 21 below). The WeChat account compiles and publishes

a weekly report of public complaints (see Figure 22 below). All these have contributed

to strengthening the capacity of the central government and enhancing the potential of

50
See National Information Release on Urban Black and Odorous Water Bodies. http://www.hcstzz.com/.

279
policy implementation in a top-down manner, i.e. administrative implementation.

Figure 21

WeChat Account for Public Participation in Urban Water Environment

Note. see WeChat Account for Public Participation in Urban Water Environment.

Figure 22

Weekly Report on Public Participation in the Urban Water Environment

Note. see WeChat Account for Public Participation in Urban

Water Environment.

In general, China’s WPPC policies are largely characterized by political

implementation. Thus, the power and resources available to the central government

determine whether it has the capacity to force local governments to act in accordance

with its political will.

280
 Specifically, when the central government and local governments have divergent

interests in policy implementation, non-implementation or poor implementation will

be the norm. This tends to be case when the central government failed to acquire

accurate local environmental information or to offer incentives attractive enough to

motivate local governments’ compliance or to impose strong administrative sanctions

as deterrents against collision or selective implementation by local governments. Prior

to 2012, the implementation of WPPC policies was at an overall low level due to the

lack of access to local environmental information and unattractive political incentives

offered by the central government. However, the problem of information asymmetry

between the central government and local governments on the implementation of

WPPC policies has, to a large extent, been resolved after 2012. On this basis, the

central government has proposed a series of political incentives. This includes the

introduction of clear and systematic policy objectives and measures, clear attribution

of responsibility for policy implementers (RCS), regular inspections (CIEEP), and

strict assessments and accountability of cadres. Such political incentives have been

incorporated into the formal system and will influence the behavior of local

governments. For example, the RCS was incorporated into the newly revised WPPCL

in 2017; inspections conducted by CIEEP have been normalized. In making WPPC

policy a priority on the policy agenda of local governments, the central government

has successfully exerted pressure on them to tackle the root causes of water pollution.

When the central and localities have divergent interests in policy implementation,

the effectiveness of central economic and moral incentives is determined by the

281
resources and conditions at the local level. In the 2016 WPPC, the central

government’s PLS policy required local governments to invest a large amount of

money in WPPC and achieve certain outcomes before they can receive the central

earmarked funding. WPPC also requires professional knowledge and scientific as well

as technological support. Usually, economically well-developed regions are able to

attract highly qualified professionals and secure investments for the development and

maintenance of technological products. Thus, Guangzhou’s economic standing,

relatively open discourse environment, experiences in implementing WPPC have put

it in good stead when responding to the central government’s moral incentives for

environmental protection as well.

282
 Chapter 7 Conclusion

7.1 Research Questions, Design and Significance

This study has explored and investigated the differences in the performance of

local governments in implementing WPPC policies, using Guangzhou as a case study.

Various studies have analyzed the local implementation of environmental policies in

China mainly through a structural or process perspective. Scholars supporting the

structural perspective have argued that the outcomes of environmental policy

implementation by local governments are due to the central government’s goal setting

and political will (Edin, 2003; He & Kong, 2011; Xue & Yang, 2011; Qia & Wu, 2013).

Theories such as fragmented authoritarianism, Chinese style federalism, and pressure-

based institutions have been applied in these studies. Through a process perspective,

scholars have analyzed the interactions between the central government and local

governments based on a principal-agent theory. Thus, the interests of the central

government and local governments, incentive compatibility and information

asymmetry during implementation became the focal points and concerns (Ding, 2004;

Ran, 2013; Gong & Qi, 2014; Cai, 2000; Zhou, 2010). Studies based on a process

perspective have shown that enforcing and implementing environmental policies at the

local level did not always fail as there were successful cases as well.

These two perspectives have given us much insight into the implementation of

environmental policies by local governments, notwithstanding their limitations.

Studies adopting a structural perspective have situated local policy implementation

within China’s formal system, but failed to explain different implementation outcomes

283
in different regions and contexts. These studies have ignored the disparity in economic

and social development across regions. In treating environmental policy holistically,

they have also ignored the characteristics of different environmental sub-policies.

Process perspective analysis might address some of these issues. Research adopting a

process perspective has used case studies to demonstrate a region’s interest in a

particular environmental policy and its response to the central government’s incentives.

But there is a problem with focusing on a single element out of the three factors–

interests, incentives and information – in these studies. It is a problem because the

behavior of local governments, as agents of the central government, is more likely to

be influenced and affected by a combination of these three factors. As a result,

contradictory findings often appeared in these studies. Besides, the central

government’s re-calibration of environmental policies and the rapid development of

technology make it necessary to adopt a dynamic view when studying environmental

policy implementation.

In view of the above, this present study has embraced both structural and process

perspectives as explained in chapter one and chapter three on policy formulation and

legitimation at the center in particular. Such an attempt has, therefore, taken into

account recent advances in governance studies on the need to take implementation

arrangements seriously when policy implementation is a formative stage in the policy

process, and to account for the mutual influence of structures and power as explained

in chapter one. The remaining empirical chapters (chapters four, five and six) have

continued to relate the significance of central policies and directives in terms of formal

284
transposition and practical application in WPPC implementation. The application of

case study has also taken into account all three important elements—interests,

incentives and information—that influence and affect the principal-agent relationships

(chapter six). Thus, this study has raised the following research questions when

exploring and investigating the two large-scale WPPC implementations undertaken by

the Guangzhou government in the past two decades. Firstly, what were the changes in

the position of the Chinese government towards environmental protection as a whole

and WPPC specifically in the past 40 and more years? How did these changes impact

on the characteristics of WPPC policies in different periods? Secondly, in the two

WPPC implementations undertaken by the Guangzhou government in 2008 and 2016,

what factors or conditions could possibly account for the failure or success of these

two large scale WPPC implementations? Thirdly, the central government launched a

national action plan, i.e. APWPPC in 2015. What has prompted the Guangzhou

government to take or not to take action in accordance with this action plan? How does

one explain Guangzhou government’s unsatisfactory performance or satisfactory

performance in WPPC policy implementation when it is being compared with other

local governments’ performance?

This thesis has made use of concepts and theories on policy implementation and

principal-agent theory as a framework for explaining the above issues (chapter two).

Matland’s model (1995) has been used to explain the characteristics of WPPC policies

when analyzing the level of policy ambiguity and policy conflict. The birth and

changes in the characteristics of WPPC policies have influenced the direction of policy

285
implementation to a certain extent as well as affected the behavior of local

governments and their choice of policy tools. Delving into the actors involved in policy

implementation, choice of policy instruments and criteria for successful or satisfactory

implementation further helped in providing a thick description and critical

appreciation of the implementation processes in the two WPPCs in Guangzhou. On

this basis, such a framework has aided in offering a critical analysis of the Guangzhou

government’s performance in the two WPPC implementations (chapter four and

chapter five).

The selection of a case is critical in this study. Considering the shortcomings of

past studies and the subject matter of this study, this case should meet at least two

criteria. One is that in a region itself, there could be multiple experiences when

implementing a particular environmental policy and that the effects of implementation

may vary over time as well. The other one is the central government’s perception of

an environmental policy and those measures preferred or adopted may evolve and

change with time. The Guangzhou government’s implementation of WPPC policies

came into the author’s view after initial data collection and fieldwork. As the central

government’s formulation and legitimation of WPPC policies had evolved and

changed over the years, the implementation outcomes of WPPC policies in 2008 and

2016 and its effectiveness or effectiveness were similarly affected by those changes

due to policymaking from atop. Thus, the case is expected to offer a dynamic rather

than a static perspective of how various factors had influenced and affected the

implementation of WPPC policies in a particular region; in this case, the southern

286
China region in which Guangzhou is located.

This research has collected both primary and secondary data. The primary data

was obtained through field studies, including personal interviews with environmental

organizations, governmental officials, (social) river chiefs and the author’s

participation in environmental organizations’ activities. The secondary data consisted

of government statistical reports and documents, articles in professional journals and

some internal materials provided by local governments and ENGOs.

7.2 Research Findings and Contribution

Analysis of WPPC documents issued before and after 2012 indicated that the

central government’s WPPC policy orientation throughout supported a political

implementation mode. This contradicts the conventional perception of China’s

environmental policy implementation as, in general, symbolic, i.e. mainly

characterized by a high level of policy ambiguity and conflict. Although political

implementation has loomed large in both pre- and post-2012 WPPC policy

implementation, it differs in three aspects.

First of all, the central government’s stance and attitude toward environmental

protection after 2012 is not as vague as it was before 2012. Instead of just putting

forward the ideas of environmental protection in the Party Congress reports or a few

environmental targets in the FYPs, the central government had issued a series of

documents (DSMICCDR, OABEC, OPRECS), revised environmental protection laws

and issued environmental protection action plans to build ecological civilization in

2013. Secondly, the central government had also issued a national APWPPC for the

287
first time in 2015. The objectives listed in the APWPPC are relatively complete,

systematic and operational. It is unlike the WPPC targets set before 2012 when local

governments were cajoled into self-financing WPPC and achieving unrealistic policy

objectives within a short period of time. Third，the central government had taken

several measures to mitigate the high level of conflict in the implementation of WPPC

policy after 2012. Introduction of the RCS, the release of MAPGLCEED (for Trial)

and elevation of the role of Environmental Protection Departments are some of these

measures.

Since the late 1990s, the problems of water pollution have become increasingly

serious and the citizens of Guangzhou have been quite vocal. In the 2008 WPPC,

Guangzhou government formally transposed the WPPC policy formulated by the

central government. As political implementation, the level of policy ambiguity at the

start appeared to be low at face below because the central directives of controlling the

quota of COD discharge as a binding indicator since the 11th FYP appeared to be “clear”

to local governments in Guangzhou. Hence, they acted in accordance with the WPPC

plan for other major rivers and lakes rolled out by SEPA and other departments. Similar

to the implementation in Liaohe River Basin and perhaps elsewhere as discussed in

chapter three, the level of conflict between the central and local in implementing

WPPC policies during this period was high. Everywhere, local governments had had

real difficulty in coming to terms with the change in the relationship between economic

development and environment protection. They had been accustomed to taking

economic development as their top policy priority for years. In addition, overlapping

288
functions among departments had also raised the level of conflict. Conflicts were

conspicuous in the economic development sector and the environmental protection

sector. This had been the case with implementing WPPC policies in Guangzhou as

well.

The specification for water quality based on a single indicator was one of the

shortcomings of the WPPC policy before 2012. The lack of a WPPC plan specifically

for the Pearl River Basin was also problematic. To host the 2010 Asian Games,

improvement to water quality in Guangzhou was expected to be achieved in a very

short period of time. Economic incentives for motivating local governments were

insufficient despite the investment of RMB48.615 billion by the Guangzhou

government and the prestige accorded to Guangzhou for hosting the Games. As

implementation proceeded, the level of policy ambiguity became high. After all, the

completion of projects had no clear connection with achieving policy objectives. The

lack of an effective monitoring mechanism means that the central government had no

ways to regulate the behavior of local governments. Nevertheless, the Guangzhou

government’s attempt to hold the “Green Asian Games” provided the justifications for

reining in different departments and lower-level governments to work together and

coordinate in a consistent manner, making the WPPC “experiment” their top priority.

As discussed in chapter four, the level of conflict in this round of implementation

turned out to be low. When policy ambiguity was high and policy conflict was low, the

implementation itself had, inadvertently, slidden into an experimental implementation

mode. Hence, the unintended consequence was learning from mistakes rather than

289
achieving expected results.

In terms of principal-agent relationships, the 2008 WPPC in Guangzhou showed

that the divergence of interests existed between the central government and local

governments. The central government was unable to force its will on local

governments to achieve WPPC objectives as the incentives offered by the former were

unattractive. Although there were some political and economic incentives, there were

no moral incentives. Adding binding targets for WPPC was not sufficient to change

the overall water pollution situation and improve water quality. A mechanism for

holding local leaders and governments accountable on WPPC was lacking when there

were not enough water environment monitoring stations located in Guangzhou for

securing valid and reliable environmental information. Without such information and

public participation, the Guangzhou government undertook a short-term campaign-

style treatment of water pollution problems. Whether or not the central government

has access to valid and reliable environmental information will determine if it has an

accurate picture of the performance of local governments in WPPC; this also affects

how incentives will be set and whether an effective accountability mechanism is in

place or not.

The “impressive” results of Guangzhou’s 2008 WPPC were short-lived despite

spending a huge sum of money. Thereafter, the Guangzhou government was skeptical

about WPPC. However, Guangzhou’s relatively open public opinion environment had

inadvertently led to a high level of involvement by the media and public in WPPC later.

A search on Baidu for "Guangzhou spends 48.6 billion on water treatment" showed

290
significant number of criticisms and questions from academics and environmental

protection groups then. Even before the ideas of building ecological civilization were

mooted by the central government, Guangzhou was bidding the time for another round

of WPPC as pointed out in chapters five and six. When the 2015 APWPPC clearly put

forward the level of water quality to be achieved for the five categories of water bodies

at different times, ten categories of measures and 78 action programs, they served as

an important reference for the formal transposition of central policy that appeared later

in the form of GZAPWPPC. The Guangzhou government is committed to making a

difference in WPPC, one that fights water pollution in the long term and brings about

a fundamental change in economic development as well.

The Guangzhou 2016 WPPC had also reflected policy characteristics, to a large

extent, typical of political implementation. This implies a high degree of conflict

existed between the central government and local governments when departments and

leaders from the environmental protection sector and the economic development sector

were involved. Unlike the 2008 WPPC, the central government had improved its

incentives and gained access to environmental information in this round of WPPC

implementation. Incentives include political incentives, economic incentives and

moral ones. In addition to the establishment of more binding targets, political

incentives also involved the introduction of RCS, the implementation of central

inspection, i.e. CIGEEP and the strengthening of a working mechanism that included

key party and government cadres and the public permeating hierarchy and networks,

thereby sustaining an effective monitoring system. Such a system not only allows the

291
central government to secure valid and reliable information, but keeps local

governments’ performance in check and holds them accountable. As pointed out in

chapter six, Zhang Shuofu’s appointment as the Party Secretary of the Guangzhou

Party Committee was an additional political incentive, given his qualifications and

many years of experience in water resources management.

Interestingly, Zhang Shuosu, was later transferred to the post of vice chairman of

the Standing Committee of the Guangdong Provincial People’s Congress because of

the “banyan tree incident” in 2021. 51 The central government’s message for local

government officials is that they may be promoted for their competence in

environmental protection as well as being held accountable for their mistakes. In terms

of economic incentives, the central government has been increasing its investment in

environmental protection. Large sum of money has been transferred to local

governments for environmental protection through the project system. Moral

incentives were reflected in the increasing number of speeches by Chinese leaders on

environmental protection, which were included in the training courses for leading

cadres at party schools and colleges. As far as access to environmental information is

concerned, the central government turned a large number of local surface water

monitoring stations into state control status. The MEE’s National Automatic Surface

Water Quality Monitoring Real-time Data Dissemination System is in operation. The

51
Banyan tree incident: Guangzhou relocated and cut down more than 3,000 banyan trees in a year due to the
implementation of "road greening quality improvement" and "city park renovation and upgrading" projects. On
12 December 2021, the Central Commission for Discipline Inspection (CCDI) issued a notice on the website of
the State Supervision Commission (SSAC), holding 10 relevant leaders and cadres in Guangzhou seriously
accountable. The then Municipal Party Secretary Zhang Shuofu and Mayor Wen Guohui, as key leaders of
Guangzhou, were not directly held accountable but were transferred to the Guangdong Provincial People's
Congress and the Guangdong Provincial Political Consultative Conference respectively.
292
central government has also established a platform for public complaints about black

and odorous water bodies through CIGEEP and RCS.

Local governments still borne 95 percent of financial burden for implementing

environmental policies in spite substantial financial inputs by the central government

on environmental protection in the form of specific transfer for WPPC, made through

a project-based system by means of earmarked fund or in the form of “prized in lieu

of subsidies” (PLS). Local governments are required to provide corresponding

matching fund or invest a certain amount of money as a show of achievement before

receiving the central government’s funding support. It is, however, particularly

difficult for local governments in poorly developed regions or in poor financial

situation to access the central government’s earmarked funding this way. Thus, the

strict enforcement of environmental policies might add to the financial burdens of local

governments over time.

The economic standing of Guangzhou as one of the “high-powered economic

houses” in China implies that it has an edge over cities in less developed regions when

it comes to implementing WPPC policy. As one of the first-tier cities in China with

high GDP growth rates and land prices, the GZAPWPPC clearly stated that a certain

percentage of the annual revenue from land sales should be allocated to WPPC. Yet,

the 2008 WPPC and the unsatisfactory implementation outcomes also point to the

importance of other factors and conditions in a particular context that needed to be

accounted for if satisfactory or successful implementation were to happen. Therefore,

huge investment proved to be essential and necessary but not sufficient for ensuring

293
satisfactory or successful implementation of WPPC policy.

Although a number of Chinese cities are also becoming exemplary in the

implementation of WPPC policies, considerable variations across regions and cities

still exist. The findings in this study suggest that the unevenness of policy

implementation is not only related to the unevenness of economic development across

different regions in the country. It is also related to the divergence of interests and

conflicts of interest between the central and local governments, the attractiveness or

unattractiveness of incentives being offered by the central government and whether

the central government has the capacity to hold local leaders and governments

accountable by means of an effective monitoring system that cuts across hierarchy and

networks. Such a system could only be made possible through a working mechanism

that involved different parties from the government, market and the society. The

participation of enterprises, ENGOs and the public are equally important. Compared

to WPPC before 2012, the central government has a greater capacity and more

resources at its disposal to impose its will on local governments. As a result, the

implementation of WPPC policy has become better in many aspects as seen in the case

of Guangzhou, which has shown the potential for administrative implementation of

WPPC policy in the future. In administrative implementation, not only is the level of

policy ambiguity low, but the level of conflict is low as well.

7.3 Future Research Outlook

In the study of WPPC in Guangzhou, there are several interesting issues that are

covered but not well-developed due to the subject matter and length of the thesis.

294
However, they are still worthy of further consideration.

First of all, chapter five has made clear the general requirements of APWPPC and

a new proposed WPPC mechanism to be “led by governments, implemented by

enterprises, driven by market and participated by the public” (State Council, 2015).

The present research has focused substantially on governments rather than enterprises

or the market in implementing WPPC. Future research into WPPC may be able to shed

some light on the roles and functions of enterprises or the market in environmental

protection as well as their rationales or motives for cooperation or resistance in relation

to the efforts of local governments in advancing environmental protection.

Secondly, WPPC and economic development are very closely related. Water

pollution in Guangzhou is apparently the result of years of rapid and sloppy economic

development. In order to tackle the root causes of water pollution, Guangzhou’s WPPC

in 2016 had carried out a large-scale clean-up of “scattered and disorganized” sites and

demolished illegal buildings. Many of the industries in which villagers in urban

villages depended for their livelihood had been shut down and banned because of those

clean-up actions. This has, no doubt, impacted the local economy in a negative manner.

Will the Guangzhou government provide relevant policies to bring about economic

transformation in these urban villages? This is crucial because the divergent interests

of lower-level governments not only impact WPPC implementation process and

outcomes negatively; they could lead to greater challenge for Guangzhou in coming

up with a sustainable economic development model that embraces environmental

protection.

295
 Thirdly, there is also a very close relationship between environmental protection

and technological progress. For example, the present study has touched on real-time

monitoring system for surface water established by the state. The Guangzhou River

Chiefs’ Office uses an app to keep track of the river chiefs’ patrols, and uses big data

to identify “scattered and disorganized” sites. GZWA uses WeChat account to obtain

complaints from the public about illegal drainage. Officials are able to establish good

communication with the public by joining the WeChat groups of SCR or

environmental organizations. Results that once require changes in institutions or

organizational structures are currently achievable with technological advances. It is

worth considering the extent in which technology influences the implementation of

environmental protection policies or even replaces some features of the existing

system in the future.

Last but not least, the status of ENGOs has been changing. As discussed in the

introductory chapter, their role in environmental protection has been greatly enhanced

During central environmental protection inspection, i.e. CIGEEP, the Guangzhou

government actively solicited local ENGOs’ support in the hope that they could help

in identifying gaps and problems in implementation for timely rectification. The

central inspection teams also expect that ENGOs actively report local environmental

problems. Future studies can investigate if such a positive relationship between local

government and ENGOs in regard to WPPC implementation is replicated in other

cities or regions as well.

The prevention and control of water pollution is a long and complex process. It

296
involves a large number of actors and requires a high level of technical expertise. This

study has studied and analyzed it mainly from the perspective of policy

implementation, which has probably unlocked a tip of the iceberg about WPPC

implementation process. In view of the current economic crisis worldwide, the

progress in advancing WPPC work is very likely to be affected in a negative manner

when huge investment is a necessary condition for implementing WPPC. The extent

and impact of economic crisis on the progress of WPPC work and the final outcome

of China’s ongoing fight against water pollution deserves further attention.

297
 Reference

Aberbach, J. (1990). Keeping a Watchful Eye: The Politics of Congressional Oversight.

Washington, DC: The Brookings Institution.

Alchian, A. A., & Demsetz, H. (1972). Production, Information Costs, and Economic

Organization. American Economic Review, 62 (12),777-795.

Anderson, J. (2010). Public Policymaking: An Introduction. Belmont, CA: Wadsworth

Publishing.

Andrews, S.Q. (2008). Inconsistencies in air quality metrics: ‘Blue Sky’ days and

PM10 concentrations in Beijing. Environmental Research Letters, 3(3), 1-14.

Anselin, L. (2001). Spatial Effects in Econometric Practice in Enviromental and

Resource Economics. American Journal of Agricultural Economics, 83(3), 705-

710.

Ansell, C., & Gash, A. (2008). Collaborative Governance in Theory and Practice.

Journal of Public Administration Research & Theory, 18(4), 543–571.

Bai, C., Tao, Z., & Tong, Y. S. (2008). Bureaucratic Integration and Regional

Specialization in China. China Economic Review, 19(2), 308–319.

Baier, V., March, J.G., & Saetren, H. (1986). Implementation and Ambiguity.

Scandinavian Journal of Management Studies, 2,197-212.

Bardach, E. (1977). The Implementation Game: What Happens After a Bill Becomes a

Law. Cambridge, MA: MIT Press.

Barkow, R.E. (2010). Insulating Agencies: Avoiding Capture Through Institutional

Design. Texas Law Review, 89, 15–79.

298
Bawn, K. (1997). Choosing Strategies to Control the Bureaucracy: Statutory

Constraints, Oversight, and the Committee System. Journal of Law, Economics,

and Organization, 13(1), 101–26.

Beeson, M. (2012). The Coming of Environmental Authoritarianism. Environmental

Politics, 19 (2),276–29 4.

Berman, P. (1978). The Study of Macro- and Micro- Implementation. Public Policy,

26(2), 157–184.

Berman, P. (1980). Thinking about Programd and Adaptive Implementation: Matching

Strategies to Situations. In Ingram, H. and Mann, D. (Eds.), Why Policies Succeed

or Fail. Beverly Hills, Calif.: Sage.

Bressers, H. & Klok, P.-J. (1988). Fundamentals for a Theory of Policy Instruments.

International Journal of Social Economics, 15(3–4), 22–41.

Brettell, A. (2000). Environmental NGOs in the People’s Republic of China: Innocents

in a co–opted environmental movement? Journal of Pacific Asia, 6, 27–56.

Brettell, A. (2001). Environmental disputes and public service law: Past and present.

China Environment Series, 4, 66–68.

Bunker, S. G. (1985). Underdeveloping the Amazon: Extraction, unequal exchange,

and the failure of the modern state. Urbana: University of Illinois Press.

Burns, J. P. (1985). Local Cadre Accommodation to the "Responsibility System" in

Rural China. Pacific Affairs, 58, 607–625.

Buttel, F. H. (1998). Some observations on states, world orders, and the politics of

sustainability. Organization & Environment, 11(3), 261-286.

299
Cai, Y. S. (2000). Between State and Peasant: Local Cadres and Statistical Reporting

in Rural China. China Quarterly,163,783–805.

Cai, Y.S. (2008). Power Structure and Regime Resilience: Contentious Politics in

China. British Journal of Political Science, 38(03),411-432.

Cao, Z.H. (2011). Zhongguo shangxia fenzhi de zhili tizhi jiqi wending jizhi [China's

divided governance system and its stabilization mechanism]. Sociological

Research, 26(1),1-40.

Cao, Z.H., & Zhou, J. (2013). Shehui fengxian yu difang fenquan--zhongguo shipin

anquan jianguan shixing difang fenji guanli de yuanyin [Social risk and local

decentralisation - Reasons for local hierarchical management of food safety

supervision in China]. Sociological Research, 28(1),182-205.

Cartier, C. (2015). Territorial Urbanization and the Party-state in China. Territory,

Politics, Governance, 3(3), 294–320.

Chinese Academy of Social Sciences. (2008). 2007 nian zhongguo gongzhong

huanjing yishi diaocha baogao [2007 China General Public Environmental

Survey]. http://www.chinaceap.org/download/8.pdf.

CCTV. (2016, November 30). Huanbaobu: yiyu 31ge shengqushi qianding shuiwuran

fangzhi mubiao zerenshu [MEP: 31 provinces, autonomous regions and

municipalities have signed water pollution prevention and control target

responsibility letters]. http://news.cctv.com/2016/11/30/ARTI3s7yJeYMkkwhQ

LYKwAI0161130.sht.

CCTV. (2018, July 20). Zhang Shuofu, Ren Xuefeng tongzhi zhiwu renmian

300
 [Appointment and removal of comrades Zhang Shuosu and Ren Xuefeng].

http://news.cctv.com/2018/07/20/VIDEyArE6dOI0YyiTIM7QVgH180720.shtml

CCTV. (2019, January 9). Qinling weijian bieshu zhengzhi shimo [The beginning and

end of the regulation of illegal villas in Qinling] [vedio]. http://

news.cctv.com/2019/01/09/ARTIl00SY58z4iOBNnOWJGHj190109.shtml.

Central Committee of the CCP, & State Council. (2015a, April 25). Guanyu jiakuai

shengtai wenming jianshe de yijian [Opinions on Accelerating the Building of

Ecological Civilization].

http://www.gov.cn/xinwen/2015-05/05/content_2857363.htm.

Central Committee of the CCP, & State Council. (2015b, September 21). Shengtai

wenming tizhi gaige zongti fang'an [Overall Plan for the Reform of Ecological

Civilization System]. http://www.gov.cn/guowuyuan/2015-09/21/content_29363

27.htm.

Central Committee of the CCP, & State Council. (2015c, August 17). Dangzheng

lingdao ganbu shengtai huanjing sunhai zeren zhuijiu banfa (shixing) [Measures

on Accountability of the Party and Government Leading Cadres for Ecological

Environment Damage (for Trial)]. http://www.gov.cn/zhengce/2015-08/17/con

tent_2914585.htm.

Central Committee of the CCP. (1995, September 28). Formulating the Ninth Five Year

Plan for National Economic and Social Development and the Long-term Goals for

2010. http://www.gov.cn/test/2008-04/21/content_950407.htm.

Central Committee of the CCP. (2013, November 12). Guanyu quanmian shenhua

301
 gaige ruogan zhongda wenti de jueding [Decision on Several Major Issues

Concerning Comprehensively Deepening Reform]. http://www.gov.cn/

zhengce/2013-11/15/content_5407874.htm.

Central Committee of the CCP. (2018, March 21). Shenhua dang he guojia jigou gaige

fang'an [Programme for deepening the reform of party and state institutions].

http://www.gov.cn/zhengce/2018-03/21/content_5276191.htm#1.

Central Committee of the CCP. (2019, March 17). Dangzheng lingdao ganbu xuanba

renyong gongzuo tiaoli [Regulations on the Selection and Appointment of the

Party and Government Leading Cadres]. China Government Net.

http://www.gov.cn/zhengce/2019-03/17/content_5374532.htm.

Central Compilation and Translation Bureau. (2016). The 13th Five-Year Plan for

Economic and Social Development of the People’s Republic of China (2016-2020).

Central Compilation & Translation Press.

Chan, H. S., Won, K., Cheung K. C., & Lo, J.M. (1995). The Implementation Gap in

Environmental Management in China: The Case of Guangzhou, Zhengzhou, and

Nanjing. Public Administration Review, 55(4),333-340.

Chen, G. (2009). Politics of China's Environmental Protection: Problems and

Progress. Singapore: World Scientific.

Chen, M. (2007, September 26). Dui huanjing zhifa chuizhi guanli de qidai [ What to

expect from vertical management of environmental enforcement]. China

Economic Times.

Chen, X. (2010). State-generated Data and the Study of Contentious Politics in China,

302
 in Carlson, A., Gallagher, M., Lieberthal, K. and Manion, M. (Eds.), Chinese

Politics: New Methods, Sources and Field Strategies. Cambridge: Cambridge

University Press.

Chen, S. (2010). Fenshuizhi gaige, difang caizheng zizhuquan yu gonggongpin gongji

[Tax-share reform, local fiscal autonomy, and public goods provision]. Economics

(Quarterly)，9(4),1427-1446.

Chien, S., & Hong, D. (2018). River Leaders in China: Party-state Hierarchy and

Transboundary Governance. Political Geography, 62, 58–67.

Chinese Academy of Sciences. (2007). 2007nian zhongguo kechixu fazhan zhanlue

baogao--shui:zhili yu chuangxin [China sustainable development strategy report

2007–water: governance and innovation].Beijing: Science Press.

Chhotray, V., & Stoker, G. (2009). Governance: From theory to practice. In

Governance theory and practice (pp. 214-247). Palgrave Macmillan, London.

Clark, P. & Wilson, J. (1961). Incentive systems: A theory of organizations.

Administrative Science Quarterly, 6(3), 129–166.

Davidson, D. J., & Frickel, S. (2004). Understanding environmental governance: a

critical review. Organization & Environment, 17(4), 471-492.

Ding, M. (2016, December 23). Shuiwuran fangzhifa xiugai beihou de minsheng

guanqie [The livelihood concerns behind the amendments to the Water Pollution

Prevention and Control Law]. NPCnet. http://www.npc.gov.cn/zgrdw/npc/xin

we n/lfgz/2016-12/23/content_2004626.htm.

Ding, H. (2004). Liyi fenxi: yanjiu zhengce zhixing wenti de jiben fangfalun yuanze

303
 [Interest analysis: a fundamental methodological principle in the study of policy

implementation]. Journal of Guangdong Institute of Public Administration，16(3),

27-34.

Du, J. (2016, December 7). Guangzhou quanli tuijin zhongyang huanbao ducha

jiaoban anjian [Guangzhou goes all out to promote cases handed over by the

CIGEP]. Guangzhou Daily.

Du, J. (2020, September 30). Guangdong gongbu wuranyuan pucha jieguo

[Guangdong Announced Pollution Source Census Results]. Guangzhou Daily.

https://gzdaily.dayoo.com/pc/html/2020-09/30/content_872_724262.htm.

Eaton, S., & Kostka, G. (2014). Authoritarian Environmentalism Undermined? Local

Leaders' Time Horizons and Environmental Policy Implementation in China.

China Quarterly, 218(218), 359-380.

Economy, E. C. (2004). The River Runs Black: The Environmental Challenge to

China's Future. Ithaca & London: Cornell University Press.

Edin, M. (2003). Remaking the Communist Party-state: The Cadre Responsibility

System at the Local Level in China. China: An International Journal, 1(1), 1–15.

Elmore, R. F. (1985). Forward and Backward Mapping, in Hanf, K. and Toonen, T.

(Eds.), Policy Implementation in Federal and Unitary Systems. Dordrecht:

Martinus Nijhoff.

Etzioni, A. (1961). Complex Organizations: A Sociological Reader. New York: Holt,

Rinehart, and Winston.

Frijns, J., Phuong, P. T., & Mol, A. P. J. (2000). Ecological modernization theory and

304
 industrializing economies: The case of Vietnam. In A. P. J. Mol & D. Sonnenfeld

(Eds.), Ecological modernization around the world: Perspectives and critical

debates (pp.257-275). London/Portland, OR: Frank Cass.

Fudenberg, D., & Tirole, J. (1991). Game Theory. Cambridge, MA: MIT Press.

Gao, J. (2017, June 22). Shuiwuran fangzhifa xiuzheng’an cao’an ershen, gengda lidu

baohu shuihuanjing [The second deliberation of the revision of the WPPCL (draft),

make greater efforts to protect the water environment]. Xinhuanet.

http://www.xinhuanet.com/politics/2017-06/22/c_1121194353.htm.

Gao, J. (2018, December 28). Di’erlun Zhongyang shengtai huanbao ducha

2019nianqidong [Second round of Central Inspection on Ecological and

Environmental Protection to start in 2019]. China Government Net.

http://www.gov.cn/hudong/2018-12/28/content_5353011.htm.

General Office of Guangzhou Government. (2014, August 29). Guangzhoushi

shengtai shuicheng jianshe guihua (2014-2020) he Guangzhoushi shengtai

shuicheng jianshe shishi fang'an (2014-2016) [Guangzhou ecological water city

construction plan 2014-2020 and Guangzhou ecological water city construction

implementation plan 2014-2016]. http://www.gz.gov.cn/zfjgzy/gzsrmzfbgt/zfx

xgkml/bmwj/qtwj/content/post_4436363.html.

General Office of Guangzhou Municipal Party Committee, & General Office of

Guangzhou Government. (2017, April 5). Guangzhoushi shuihuanjing zhili Zeren

zhuijiu gongzuo yijian [Opinions on Accountability for Water Environment

Management in Guangzhou]. http://www.gzjjjc.gov.cn/ljgzw/xxgk/xxgkml/gzzd/

305
 content/post_144931.html.

General Office of the Central Committee of the CCP, & General Office of the State

Council. (2016, December 11). Guanyu quanmian tuixing hezhangzhi de yijian

[Opinions on the Full Implementation of the River Chief System].

http://www.gov.cn/ xinwen/2016-12/11/content_5146628.htm.

General Office of the Central Committee of the CCP, & General Office of the State

Council. (2018, January 4). Guanyu zai hupo shishi huzhangzhi de zhidao yijian

[Guidance on the Implementation of the Lake Chief System].

http://www.gov.cn/zhengce/ 2018-01/04/content_5253253.htm.

General Office of the Central Committee of the CCP, & General Office of the State

Council. (2019, June 17). Zhongyang shengtai huanjing baohu ducha gongzuo

guiding [Work Regulations for the Central Ecology and Environment Protection

Inspection]. China Government Net. http://www.gov.cn/zhengce/2019-06/17/

content_5401085.htm.

Gong, M.J., & Qi, Y. (2014). Cong xinxi jiegou shijiao jiexi difang zhengfu huanjing

jianguan xingwei -- yi"shiyiwu"wuranwu zongliang jianpai weili [Analysis of

local governments' environmental regulatory behavior from the perspective of

information structure: an example of total pollutant emission reduction in the

eleventh Five-Year Plan]. Journal of Nanjing University of Technology (Social

Science Edition), 13(1), 39-46.

Gortner, H., Nichols, K.& Ball, C. (2007). Organization theory: A public and nonprofit

perspective. Belmont,CA: Wadsworth/Thomson Learning.

306
Greenpeace. (2011). Greenpeace Insights & Commentary: China’s 12th Five-Year

Plan. http://www.greenpeace.org/eastasia/Global/eastasia/publications/reports/

others/2011/greenpeace-commentary-twelfth-five-year-plan.pdf.

Gu, R.Z., & Luo, S. (2014, April 24). Quanguo renda changweihui biaojue tongguo

xiuding de huanbaofa [Standing Committee of the National People's Congress

votes to adopt revised environmental protection law]. China Government Net.

http://www.gov.cn/xinwen/ 2014-04/24/content_2666232.htm

Guangdong Environmental Protection Department. (2017, August 9). 2017nian

Guangdongsheng shuiwuran zhengzhi gongzuo fang’an [Work Plan for Water

Pollution Prevention and Control 2017]. http://gdee.gd.gov.cn/gkmlpt/content/2/2

305/post_2305328.html#2232.

Guangdong Environmental Protection Department. (2018, August 7).

Guangdongsheng shuiwuran fangzhi gongjianzhan 2018nian gongzuo fang’an

[Work plan for water pollution prevention and control in Guangdong Province

2018]. http://gdee. gd.gov.cn/shbtwj/content/post_2305552.html.

Guangdong Provincial Party Committee, & Guangdong Government. (2020, January).

Guangdongsheng tongbao zhongyang huanjing baohu ducha “huitoukan” qijian

shengtai huanjing sunhai wenti ji wenze qingkuang [Guangdong Province

informed of ecological damage during the "look-back" period of the CIGEP and

the accountability situation]. http://gdee.gd.gov.cn/htkxwbd/content/post_2878

471.html.

Guangdong River Chief System Office. (2019, January 10). Guangdongsheng

307
 quanmian tuixing hezhangzhi huzhangzhi gongzuo 2018niandu kaohe shishi

fang’an [Implementation plan for the 2018 annual assessment of the

comprehensive implementation of the river and lake system in Guangdong

Province]. http://slt.gd.gov.cn/csdt/content/post_2119737.html .

Guangzhou Agriculture and Rural Affairs Bureau. (2021, November 10). Zhuyao zhize

[Main responsibilities of Guangzhou Agriculture and Rural Affairs Bureau].

http://nyncj.gz.gov.cn/gkmlpt/content/7/7899/post_7899632.html#15348.

Guangzhou Daily. (2020, May 9). Zhishui jianchengxiao Guangzhoushi baiyunqu huo

guowuyuan jiangli 1000wan yuan [Baiyun District of Guangzhou was awarded

10 million yuan by the State Council for water pollution control]. https://news.

dayoo.com/gzrbyc/202005/09/158752_53335601.htm.

Guangzhou Development and Reform Commission. (2022, April 18). Guangzhoushi

fazhan he gaige weiyuanhui zhuyao zhize [Main responsibilities of Guangzhou

Development and Reform Commission]. http://fgw.gz.gov.cn/gkmlpt/content/

8/8193/post_8193318.html#475.

Guangzhou Ecology and Environment Bureau. (2003a, December 9). Guangzhou

environmental quality report 1999. http://sthjj.gz.gov.cn/zwgk/hjgb/content/

post_2808258.html.

Guangzhou Ecology and Environment Bureau. (2003b, December 9). Guangzhou

environmental quality report 2000. http://sthjj.gz.gov.cn/zwgk/hjgb/content/post

_2808256.html.

Guangzhou Ecology and Environment Bureau. (2003c, December 9). Guangzhou

308
 environmental quality report 2001. http://sthjj.gz.gov.cn/zwgk/hjgb/content/

post_2808289.html.

Guangzhou Ecology and Environment Bureau. (2003d, December 9). Guangzhou

environmental quality report 2002. http://sthjj.gz.gov.cn/zwgk/hjgb/content/

post_2808287.html.

Guangzhou Ecology and Environment Bureau. (2007, June 5). Guangzhou

environment quality report 2006. http://sthjj.gz.gov.cn/zwgk/hjgb/content/post

_2808284.html

Guangzhou Ecology and Environment Bureau. (2008, July 4). Guangzhou

environment quality report 2007. http://sthjj.gz.gov.cn/zwgk/hjgb/content/post_

2808248.html.

Guangzhou Ecology and Environment Bureau. (2009, May 23). Guangzhou

environment quality report 2008. http://sthjj.gz.gov.cn/zwgk/hjgb/content/post_

2808261.html.

Guangzhou Ecology and Environment Bureau. (2010, May 31). Guangzhou

environment quality report 2009. http://sthjj.gz.gov.cn/zwgk/hjgb/content/post

_2808254.html.

Guangzhou Ecology and Environment Bureau. (2011, June 7). Guangzhou

environment quality report 2010. http://sthjj.gz.gov.cn/zwgk/hjgb/content/post_

2808292.html.

Guangzhou Ecology and Environment Bureau. (2012, July 18). Guangzhou

environment quality report 2011. http://sthjj.gz.gov.cn/zwgk/hjgb/content/post_

309
 2808291.html.

Guangzhou Ecology and Environment Bureau. (2013, June 21). Guangzhou

environment quality report 2012. http://sthjj.gz.gov.cn/zwgk/hjgb/content/post_

2808290.html.

Guangzhou Ecology and Environment Bureau. (2014, March 7). Guangzhou

environment quality report 2013. http://sthjj.gz.gov.cn/attachment/0/60/60279/

5634259.pdf.

Guangzhou Ecology and Environment Bureau. (2015). 2015nian Guangzhoushi

huanjing baohu gongzuo zongjie [Summary of Environmental Protection Work in

Guangzhou in 2015]. http://sthjj.gz.gov.cn/zwgk/gs/ndjhzj/content/post_280245

7.html.

Guangzhou Ecology and Environment Bureau. (2015, January 23). Guangzhou

environment quality report 2014. http://sthjj.gz.gov.cn/attachment/0/60/60279/

5634259.pdf.

Guangzhou Ecology and Environment Bureau. (2016, February 3). Guangzhou

environment quality report 2015. http://sthjj.gz.gov.cn/attachment/0/60/60279/

5634259.pdf.

Guangzhou Ecology and Environment Bureau. (2017, March 13). Guangzhou

environment quality report 2016. http://sthjj.gz.gov.cn/attachment/0/59/59140/56

28432.pdf.

Guangzhou Ecology and Environment Bureau. (n.d.-a). Guangzhoushi shengtai

huanjingju jigou jianshe gaikuang [Overview of institutional development of

310
 Guangzhou Ecology and Environment Bureau]. http://sthjj.gz.gov.cn/zwgk/

jgszyzn/ssthjjznygk/content/post_2808301.html.

Guangzhou Ecology and Environment Bureau. (n.d.-b). Guangzhoushi shengtai

huanjingju zhuyao zhize [GZEBB Organization and Functions]. http://sthjj.gz.

gov.cn/zwgk/jgszyzn/.

Guangzhou Finance Bureau. (2020, August 14). Guangzhoushi PPP xiangmu

qingkuangbiao (jiezhi 2020nian 6yuedi) [List of PPP projects in Guangzhou (By

the end of June 2020)]. http://czj.gz.gov.cn/gkmlpt/content/6/6497/post_

6497283.html#615.

Guangzhou Government. (2008, December 29). Guangzhoushi wushui zhili he

hechong zonghe zhengzhi gongzuo fang’an [Work Plan on Sewage Treatment and

River Comprehensive Management in Guangzhou]. https://www.docin.com/p-

176 9833336.html.

Guangzhou Government. (2016, May 11). Guangzhoushi shuiwuran fangzhi xingdong

jihua shishi fang'an [Guangzhou Action Plan on Water Pollution Prevention and

Control]. http://www.gz.gov.cn/zfjgzy/gzsrmzfbgt/zfxxgkml/bmwj/qtwj/content/

post_4435826.html.

Guangzhou Government. (2017, May 9). 2865 ming hezhang! Xinban quanshi

hezhang mingdan chulu [2,865 river chiefs! The new version of the city's river

chiefs list is available]. http://www.gz.gov.cn/zwgk/zcjd/zcjd/content/post_3088

840.html.

Guangzhou Government. (2008b, December 31). Guanyu jinzhi xiang jianghe hupo

311
 zhijie paifang wushui de tonggao [Notice on Prohibiting Direct Discharge of

Sewage to Rivers and Lakes]. http://www.gz.gov.cn/gfxwj/szfgfxwj/gzsrmzf/

content/post_5444718.html.

Guangzhou Industry and Information Technology Bureau. (2022, March 15).

Guangzhoushi gongye he xinxihua ju zhuyao zhize [Main responsibilities of

Guangzhou Industry and Information Technology Bureau]. http://gxj.gz.gov.cn/

gkmlpt/content/8/8135/post_8135756.html#89.

Guangzhou River Chief System Office. (2017, August 7). Guangzhoushi hezhang

xunhe zhidao yijian [Guidance for River Patrol by Guangzhou River Chiefs].

Guangzhou Water Authority. http://swj.gz.gov.cn/gkmlpt/content/1/1321/post_

1321352.html#1040.

Guangzhou Water Authority. (2016, January 5). Guangzhou shuigengqing 51 tiao

hechong zhili [51 rivers treated for clearer water in Guangzhou].

http://swj.gz.gov.cn/gkmlpt/content/1/1318/post_1318905.html#1045.

Guangzhou Water Authority. (2017, September 27). Guangzhoushi weifa paishui

xingwei youjiang jubao banfa [Guangzhou Measures of Reward for Reporting of

Illegal Drainage Acts]. http://swj.gz.gov.cn/gkmlpt/content/5/5494/post_549426

6.html#1039.

Guangzhou Water Authority. (2019, March 25). Guangzhoushi shuiwuju zhuyao zhize

[The Main Responsibilities of GZWA]. http://swj.gz.gov.cn/gkmlpt/content/3/

3465/post_3465742.html#1034.

Guangzhou Water Authority. (2020a, April 40). Guangzhou's accomplishments in

312
 urban villages' habitats and water governance [vedio]. http://swj.gz.gov.cn/

swyw/swgg/content/post_6894615.html.

Guangzhou Water Authority. (2020b, July 8). Hezhang tongling quanmin canyu

gongjian gongxiang--Guangzhou tansuo tedaxing chengshi zhishui xinlujing

[River chiefs lead, the public participate in exploring a new path for water

management in Guangzhou]. Guangzhou Government. http://www.gz.gov.cn/ xw/

zwlb/bmdt/sswj/content/post_6445227.html.

Guangzhou Water Authority. (2020c, March 30). Shenhua luoshi

“hulianwang+hezhangzhi” “Guangzhou hezhang peixun” xiaochengxu zhengshi

shangxian [Deepening the implementation of the "Internet + RCS", the

Guangzhou River Chiefs Training app is officially online].

http://swj. gz. gov. cn //content/5/5749/post_5749522.html#1045.

Guangzhou Water Authority. (2020d, March 12). Guangzhoushi weifa paishui xingwei

youjiang jubao banfa [Guangzhou Measures of Reward for Reporting of Illegal

Drainage Acts]. http://swj.gz.gov.cn/gkmlpt/content/5/5729/post_5729137. html

#1039.

Guangzhou Water Authority. (2022, February 25). Guangzhoushi shuiwuju guanyu

piqian gongshi guangzhoushi shuiwu fazhan shisiwu guihua chengguo de tongzhi

[Notice of GZWA on the pre-approval of the results of the “14th Five-Year Plan

for Guangzhou Water Development”]. http://swj.gz.gov.cn/hdjlpt/yjzj/answer/

15970#feedback.

Guo, Y. Y. (2008, January 15). Guangzhou shuiwuju guapai chengli [Guangzhou Water

313
 Authority was established]. SOHU. http://news.sohu.com/20080115/n2546707

73.shtml.

Guo, J. C (2015, August 28). Quanguo renda changweihui zhifa jianchazu: zhongguo

shuihuanjing zhiliang burong leguan [Law enforcement inspection team of NPC

Standing Committee: China's water environment quality is not optimistic].

RenMin Daily. http://npc.people.com.cn/n/2015/0828/c398703-2752797 4.html.

Hall, T.E., & O'Toole, L.J.J. (2000). Structures for Policy Implementation: An Analysis

of National Legislation, 1965–1966 and 1993–1994. Administration &

Society, 31(6), 667–686.

Hammond, T. H., & Knott, J. (1996). Who Controls the Bureaucracy? Presidential

Power, Congressional Dominance, Legal Constraints, and Bureaucratic

Autonomy in a Model of Multi-institutional Policy-Making. Journal of Law,

Economics, and Organization, 12(1), 119–66.

Hanf, K., & O'Toole, L.J.J. (1992). Revisiting Old Friends: Networks, Implementation

Structures and the Management of Inter-organizational Relations. European

Journal of Political Research, 21(1–2),163–80.

Hannigan, J. A. (1995). Environmental sociology: A constructionist perspective.

London/New York: Routledge.

Hart, O., & Holmstrrom, B. (1987). Theory of Contracts.in Bewley, T.F.(Ed.),

Advances in Economic Theory: Fifth World Congress. Cambridge: Cambridge

University Press.

He, D.X., & Ye, X. Z. (2013, June 29). 486.15Yi！Guangzhou zhishui ritou 1yiduoyuan

314
 weineng huo shimin manyi [48.615 billion! Guangzhou’s daily investment of more

than 100 million yuan in water pollution control failed to meet the public's

satisfaction]. RenMinNet. http://politics.people.com.cn/n/2013/0629/c1001-2201

7006.html.

He, D.H., & Kong, F.B. (2011). Gonggong zhengce zhixing de zhongguo jingyan [The

Chinese experience in public policy implementation]. Chinese Social Sciences,

(5), 61-79.

Heberer, T. & Senz, A. (2011). Streamlining Local Behavior through Communication,

Incentives and Control: A Case Study of Local Environmental Policies in China.

Journal of Current Chinese Affairs,40(3), 77–112.

Heimer, M. (2006). The Cadre Responsibility System and the Changing Needs of the

Party, in Brodsgaard K. E. and Zheng Y. N. (Ed.), The Chinese Communist Party

in Reform. London:Routledge.

Hill, M.J. (2009). The Public Policy Process. Harlow: Pearson.

Hjern, B. & Hull, C. (1982). Implementation Research as Empirical Constitutionalism.

European Journal of Political Research, 10(2), 105–116.

Hjern, B. (1982). Implementation Research: The Link Gone Missing. Journal of

Public Policy, 2(3),301–308.

Hjern, B., & Porter, D.O. (1981). Implementation Structures: A New Unit of Adm-

inistrative Analysis. Organization Studies, 2(3), 211–227.

Ho, P. (2001). Greening without conflict? Environmentalism, NGOs, and civil society

in China. Development & Change, 32(5), 893–921.

315
Ho, P., & R.L. Edmonds. (2007). Perspectives of time and change: Rethinking

embedded environmental activism in China. China Information, 21(2): 331–344.

Holzinger, K., Knill, C., & Schäfer, A. (2006). Rhetoric or Reality? “New Governance”

in EU Environmental Policy. European Law, 12(3): 403-420.

Honig, M. I. (2008). District Central Offices as Learning Organizations: How

Sociocultural and Organizational Learning Theories Elaborate District Central

Office Administrators’ Participation in Teaching and Learning Improvement

Efforts. American Journal of Education, 114,627–664.

Hood, C. (1986). The Tools of Government. Chatham: Chatham House.

Hood. C., & Margetts, H.Z. (2007). The Tools of Government in the Digital Age.

Basingstoke: Palgrave Macmillan.

Howlett, M. (1991). Policy Instruments, Policy Styles and Policy Implementation:

National Approaches to Theories of Instrument Choice. Policy Studies

Journal,19(2), 1–21.

Howlett, M., Ramesh, M. & Perl, A. (2009). Studying Public Policy: Policy Cycles

and Policy Subsystems. Oxford: Oxford University Press.

Howlett, M., Ramesh, M. (2003). Studying Public Policy: Policy Cycles and Policy

Subsystems (2nd edition). Oxford: Oxford University Press.

Hu, J.T. (2007, October 15). HuJintao's report at the 17th PC. People. http://

cpc.people.com.cn/GB/104019/104101/6429414.html.

Hu, J.T. (2012, November 8). HuJintao's report at the 18th PC. People. http://

politics.people.com.cn/n/2012/1118/c1001-19612670-1.html.

316
Hu, Y.B. (1982, September 8). HuYaobang's report at the 12th PC. Zhongguo jigou

bianzhi Web. http://www.scopsr.gov.cn/zlzx/ddh/ddh17_3983/ddh170/201811/t2

0181121_328513.html.

Huber, J.D., & Shipan, C.R. (2002). Deliberate Discretion: The Institutional

Foundations of Bureaucratic Autonomy. Cambridge: Cambridge University Press.

IFENG. (2010, August 23). Guangzhou tou juzi zhengzhi shuihuanjing [Guangzhou

invested heavily to improve the water environment]. http://phtv.ifeng.com/

program/nyjs/detail_2010_08/23/2100902_0.shtml.

Ingram, H. (1977). Policy Implementation through Bargaining: Federal Grants in Aid.

Public Policy, 25(4),499-526.

Jahiel, A. (1998). The organization of environmental protection in China. China

Quarterly, 156, 757–787.

Jensen, M., & Meckling, W. (1976). Theory of the Firm: Managerial Behavior, Agency

Costs and Ownership Structure. Journal of Financial Economics, 3(3),302–325.

Jia, S. F. (2017, Sept. 8). A system to better protect water bodies. China Daily.

http://www.chinadaily.com.cn/opinion/2017-09/08/content_31712865.htm.

Jianchi. (2014, May 21). Juzi zhishui wuxiao, shimin wufa jieshou [Huge sums of

money for ineffective water treatment are unacceptable to the public]. Southern

Metropolitan News. http://epaper.oeeee.com/G/html/2014-05/21/content_207561

4.htm

Jiang, Z.M. (1992, October 12). JiangZemin’s report at the 14th PC. CNTheory.

http://www.cntheory.com/tbzt/sjjlzqh/ljddhgb/202110/t20211029_37376.html.

317
Jiang, Z.M. (1995, September 28). Zhengque chuli shehui zhuyi xiandaihua jianshe

zhong de ruogan zhongda guanxi [Correctly addressing some major relationships

in socialist modernisation]. China Government Net. http://www.gov.cn/test/2008-

07/10/content_1041256.htm.

Jiang, Z.M. (1997, September 12). JiangZemin’s report at the 15th PC. CNTheory.

http://www.cntheory.com/tbzt/sjjlzqh/ljddhgb/202110/t20211029_37375.html.

Jiang, Z.M. (1999, December 2). JiangZemin zhuxi zai weiyena gongyue diyuefang

dahui diwuci huiyi shang de zhici [Speech by President Jiang Zemin at the fifth

meeting of the Conference of the Parties to the Vienna Convention]. CNTV.

http://news.cntv.cn/china/20111222/114230.shtml.

Jiang, Z.M. (2002, November 8). JiangZemin’s report at the 16th PC. CNTheory.

http://www.cntheory.com/tbzt/sjjlzqh/ljddhgb/202110/t20211029_37374.html.

Jiang, B. (2016). Dui hezhangzhi guanli zhidu wenti de sikao [Considerations for

Leader Responsible System in governance of rivers and lakes]. China Water

Resources, 21(11),6-7.

Josephson, P.R. (2004). Resources under Regimes: Technology, Environment, and the

State. Cambridge, MA: Harvard University Press.

Kelman, S. (1984). Using Implementation Research to Solve Implementation

Problems: The Case of Energy Emergency Assistance. Journal of Policy Analysis

and Management, 4(1), 75-91.

Kiewiet, R., & McCubbins, M. (1991). The Logic of Delegation: Congressional

Parties and the Appropriations Process. Chicago: University of Chicago Press.

318
Knill, C. & Lenschow, A. (Eds.). (2000). Implementing EU Environmental Policy:

New Directions and Old Problems. Manchester: Manchester University Press.

Knill, C. & Lenschow, A. (1998). Compliance with Europe: The Implementation of

EU Environmental Policy and Administrative Traditions in Britain and Germany.

Journal of European Public Policy, 5(4), 597–616.

Knill, C. (2006). Implementation, in Richardson J. (Ed.), European Union, Power and

Policy-Making. New York: Routledge.

Knill, C., & Lenschow, A. (2000). Implementing EU environmental policy: New

directions and old problems. Manchester University Press.

Knill, C., &. Lehmkuhl, D. (2002). Private Actors and the State: Inter nationalization

and Changing Patterns of Governance. Governance, 15(1): 41-63.

Knill,C., & Tosun, J. (2012). Public policy: A new introduction. New York: Palgrave

Macmillan.

Kostka, G. (2013). Environmental Protection Bureau Leadership at the Provincial

Level in China: Examining Diverging Career Backgrounds and Appointment

Patterns. Journal of Environmental Policy & Planning, 15(1), 41-63.

Kostka, G. (2014). Barriers to the Implementation of Environmental Policies at the

Local Level in China. World Bank Policy Research Working Paper No. 7016.

Washington D.C.: World Bank.

Kostka, G. (2022). Barriers to the Implementation of Digital Policies at the Local Level

in China. https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4047764.

Kostka, G., & Hobbs, W. (2012). Local energy efficiency policy implementation in

319
 china: Bridging the gap between national priorities and local interests. The China

Quarterly, 211, 765-785.

Kostka, G., & Hobbs, W. (2013). Embedded interests and the managerial local state:

The political economy of methanol fuel-switching in China. Journal of

Contemporary China, 22(80), 204-218.

Kostka, G., & Mol, A. P. J. (2013). Implementation and Participation in China's Local

Environmental Politics: Challenges and Innovations. Journal of Environmental

Policy & Planning, 15(1), 3-16.

Kung, J., Cai, Y. S. & Sun, X. L. (2009). Rural Cadres and Governance in China:

Incentive, Institution and Accountability. The China Journal, (62), 61–77.

Kwong, Charles C. L., & Lee, P.K. (2000). Business-Govemment Relations in

Industrializing Rural China: A Principal-Agent Perspective. Journal of

Contemporary China, 9(25), 513-34.

Laffont, J.-J., & Martimort, D. (2001). The Theory of Incentives: The Principal-Agent

Model. Princeton, NJ: Princeton University Press.

Laffont, J.J., & Tirole, J. (1991). The Politics of Government Decision Making: A

Theory of Regulatory Capture. Quarterly Journal of Economics, 106(4): 1089–

127.

Landry, P. F. (2008). Decentralized Authoritarianism in China: The Communist Party’s

Control of Local Elites in the Post-Mao Era. New York: Cambridge University

Press.

Lane, J.E. (2005). Public Administration and Public Management: The Principal-

320
 Agent Perspective. New York: Routledge.

Lemos, M. C., & Agrawal, A. (2006). Environmental governance. Annual Review of

Environment and Resources, 31(1), 297-325.

Li, J. (2022). Public participation in China: the case for environmental

enforcement. Journal of Chinese Governance, 7(2), 159-179.

Li, J., Shi, X., Wu, H.Q., & Liu, L.W. (2020). Trade-off between Economic

Development and Environmental Governance in China: An Analysis Based on the

Effect of River Chief System. China Economic Review, 60,1-15.

Li, J., Zhang,H., Zhang, C. Y. & Yan, Z.H. (2013, November, 11). Dangxiao ruhe

chengwei ganbu huanjing jiaoyu zhuqudao [How party schools can become the

main channel of environmental education for cadres]. China Environment News.

http://epaper.cenews.com.cn/html/2013-11/11/node_5.htm.

Li, W.X. (2011). Self-motivated vs. Forced Disclosure of Environmental Information

in China—A Comparative Case Study of the Pilot Disclosure Programs. The

China Quarterly, 206, 331–351.

Li, W.X., & Zusman, E. (2006). Cong yiyuan dao xingdong: zhongguo difang

huanbaoju de jigou nengli yanjiu [From will to action: A Study on the institutional

capacity of local environmental protection bureaus in China]. Environmental

Science Research, 19(B11), 7.

Li, W.X., & Higgins, P. (2013). Controlling Local Environmental Performance: An

Analysis of Three National Environmental Management Programs in the Context

of Regional Disparities in China. Journal of Contemporary China, 22(81), 409-

321
 427.

Li, Y. (2004). Lun gongzhong canyu huanjing yingxiang pingjiazhongde xinxi gongkai

zhidu [On the information disclosure system of the public participation in

environmental impact assessment]. Jianghai Academic Journal, 1, 126–132.

Li, Y. H., & Hu, Y.F. (2019). Shuihuanjing zhili de zhidu chuangxin yu

shijian:quanmian tuixing hezhangzhi de Anhui jingyan [System innovation and

practice of water environment treatment: Anhui experience of implementing river

chief system in an all-round way].Government Management Review, (5),78-89

Li, Y.S. (2009). Cong liuyu shuiwuran fangzhi kan "hezhangzhi" [Study of the River

Chief System from the perspective of basin-scale water pollution prevention and

control]. Environmental Protection, (9), 24–25.

Lian, H. (2012). Jili sheji, shangxiji hudong he zhengqi guanxi [Incentive design,

hierarchical interaction and corporate relations]. [Doctoral dissertation, Peking

University].Wanfang Dissertation.

Lian, H. (2016). Zhuyili jingzheng--jiyu canyu guancha yu duoanli de zuzhixue

fenxi[Competition for attention - an organizational analysis based on participant

observation and multiple cases]. Sociological Research, (4),1-27.

Lieberthal, K.G., & Lampton, D.M. (Ed.). (1992). Bureaucracy, Politics, and Decision

Making in Post-Mao China. Oxford: University of California Press.

Lieberthal, K.G., & Oksenberg, M. (1988). Policy Making in China: Leaders,

Structures, and Processes. Oxford:Princeton University Press.

322
Lieberthal, K.G. (1992). Introduction: The "Fragmented Authoritarianism" Model and

Its Limitations, in Lieberthal, K.G., & Lampton, D.M. (Eds.), Bureaucracy,

Politics, and Decision Making in Post-Mao China. Oxford: University of

California Press.

Linder, S.H., & Peters, B.G. (1989). Instruments of Government: Perceptions and

Contexts. Journal of Public Policy, 9(1), 35–58.

Lipsky, M. (1980). Street-Level Bureaucracy: The Dilemmas of Individuals in the

Public Service. New York: Russell Sage Foundation.

Liu, A.J. (2004). Shengtai wenming yu zhongguo huanjing lifa [Ecological civilization

and China’s environmental legislation]. China Population, Resources and

Environment, 14 (1), 36-38.

Liu, J., & Chen, S. (2013, July 4). Guangzhou 486 yi zhishui fang'an beizhi jigongjinli,

ceng zao zhuanjia zhiyi [Guangzhou's $48.6 billion water treatment plan accused

of being a quick fix, once questioned by experts]. https://finance.sina.com.cn/

china/20130704/081816011267.shtml.

Liu, J., & Li, W. (2013, July 4). Guangzhou zhishui tou 486 yi jin 1he dabiao ,fang'an

ceng zao zhuanjia zhiyi [Guangzhou's RMB 48.6 billion water control plan has

been questioned by most experts]. https://news.sina.com.cn/c/2013-07-04/03

1927570475.shtml?t=t.

Liu, J. (2018, October. 31). Quanguo heichou shuiti zhili, Guangzhou ruwei shifan

chengshi [National black and odorous water treatment, Guangzhou was shortlisted

for demonstration city]. Southern Metropolitan News. http://epaper.oeeee.

323
 com/epaper/A/html/2018-10/31/content_55993.htm?from=groupmessage.

Liu, Q. J. (2008). Zhongguo gongchandang huanjing baohu gongzuo de Shijian yu

jingyan [The practice and experience of the Chinese Communist Party in

environmental protection]. Contemporary World and Socialism, (2), 69-74.

Liu, X.X., & Chen, L. (2009). "Hezhangzhi": pojie zhongguo shuiwuran zhili kunju

[The River Chief System: crack the dilemma of water pollution control in China].

Environmental Protection, (9), 13-16.

Liu, Alan P. L. (2009). Rebirth and Secularization of the Central Party School in China.

The China Journal, (62), 105–125.

Liu, H., Chen, D., Liu, T., & Lin, L. (2019). The River Chief System and River

Pollution Control in China: A Case Study of Foshan. Water, (11),1-14.

Liu, K.J. (2017). Yundongshi zhili de lishi,xianzhuang yu zhuanxing:yige yanjiu

zongshu [The history, status and transformation of campaign-style governance: a

review]. Journal of Shanxi Agricultural University (Social Science Edition), 16(3),

57-64.

Liu, X.X. (2015). Xin huanjing baohufa: geihuanjing zhili moshi dailai naxie

zhuanbian? [The new Environmental Protection Law: what changes to the

environmental governance paradigm?]. World Environment, (3),4.

Liu, Y. (2018). Shizhang shouxian yao zhaozhun zhize dingwei [The mayor must first

find the right position for his duties]. China Party and Government Cadres Forum,

(9),2.

Local leaders database: resume of Zhang shuofu. (n.d.). People net. http://ldzl.

324
 people.com.cn/dfzlk/front/personPage6347.htm.

Lu, H. Y. (Ed.). (2002). Fenji Fenshui Caizheng Tizhi [Multi-level Tax Sharing Fiscal

System]. Beijing: Chinese Finance and Economy Publishing House.

Lu, M. Q., & Du, J. (2017, June 7). Guangzhou shoupin minjian hezhang, 13ming

daxuesheng chizheng shanggang [Guangzhou's first appointment of the SRC，13

college students got the positions]. Guangzhou Daily. https://static.

nfapp .southcn.com/content/201706/06/c466406.html.

Lu, Y. (2007). Environmental civil society and governance in China. International

Journal of Environmental Studies, 64(1), 59–69.

Ma, Q. (2005). Non-governmental organizations in contemporary China paving the

way to civil society?. NY: Routledge.

Mason, M. (2012). Environmental Democracy: A Contextual Approach. Routledge.

Matland, R.E. (1995). Synthesizing the Implementation Literature: The Ambiguity-

Conflict Model of Policy Implementation. Journal of Public Administration

Research and Theory, 5(2),145-174.

May, P.J. (2003). Policy Design and Implementation. in Peters, B.G. and Pierre, J.

(Eds.), Handbook of Public Administration. Thousand Oaks: Sage.

Mayntz, R. (1979). Public Bureaucracies and Policy Implementation. International

Social Science Journal, 31(4): 633–45.

Mayntz, R. (1979). Public Bureaucracies and Policy Implementation. International

Social Science Journal, 31(4), 633–645.

McCubbins, M., Noll, R. & Weingast, B. (1987). Administrative Procedures as

325
 Instruments of Political Control. Journal of Law, Economics & Organization, 3(2),

243–277.

McDermott, K. A. (2006). Incentives, Capacity, and Implementation: Evidence from

Massachusetts Education Reform. Journal of Public Administration Research and

Theory, 16(1), 45–65.

Mei, C. Q. (2009). Brings the Politics back in: Political Incentive and Policy

Distortion in China. [Doctoral Dissertation, Maryland University, USA].

ProQuest Dissertation Globalization.

Mei,C.Q., & Liu, Z.L. (2013). Xingzheng wenze yu zhengce xingwei

congzhong:"shiyiwu"jieneng mubiao shishi jindu diqujian chayi kaocha

[Administrative accountability and policy behavioral conformity: an examination

of regional disparities in the progress of implementation of the 11th Five-Year Plan

energy efficiency targets]. China's Population, Resources and Environment,

22(12), 127- 134.

Meier, K.J. (2000). Politics and the Bureaucracy: Policymaking in the Fourth Branch

of Government. New York: Harcourt College.

Mertha, A.C. (2008). China’s Water Warriors: Citizen Action and Policy Change.

Ithaca: Cornell University Press.

Milgrom, P., & Roberts, J. (1992). Economics, Organization and Management.

Englewood Cliffs, NJ: Prentice Hall.

Ministry of Agriculture. (2017, December 17). Zhineng peizhi [Functions].

http://www.moa.gov.cn/jg/bjs/201712/t20171217_5986506.htm.

326
Ministry of Ecology and Environment. (2021, December 13). Zhongyang disi shengtai

huanjing baohu duchazu xiang Guangdongsheng fankui ducha qingkuang [The

Fourth CIGEP gave feedback to Guangdong Province]. http://gdee.gd.gov.cn/

ztzl_13387/zysthjbhdczgd/htkxwbd/content/post_3718576.html.

Ministry of Environmental Protection. (2016, March 16). "Shisanwu" guojia

dibiaoshui huanjing zhiliang jiancewang shezhi fang'an [The 13th Five-Year Plan

for Setting up the National Surface Water Environmental Quality Monitoring

Network].

http://www.mee.gov.cn/gkml/hbb/bwj/201603/t20160322_334062.htm.

Ministry of Finance, Mistrty of Housing and Rural-Urban Development, & Ministry

of Ecology and Environment. (2018, September 19). Sanbumen fabu guanyu zuzhi

shenbao 2018nian chengshi heichou shuiti zhili shifan de tongzhi [Three

Departments Issue Notice on Organizing the Application of Model Cities for the

Treatment of Urban Black and Odorous Water Bodies in 2018].

http://www.gov.cn/xinwen/2018-09/21/content_5324255.htm.

Ministry of Housing and Rural-Urban Development. (2016). Notice on announcing the

investigation of black and smelly water bodies in cities nationwide.

http://www.mohurd.gov.cn/wjfb/201602/t20160219_226677.html.

Ministry of Water Resources. (n.d.). Zuzhi jigou [Organization structure]. http://www.

mwr.gov.cn/jg/zzjg/gyslb/.

Mitnik, B. (1980). The Political Economy of Regulation. New York: Columbia

University Press.

327
Moe, T. M. (1984). The New Economics of Organization. American Journal of

Political Science, 28(4),739-777.

Mohr, L.B. (1988). Impact Analysis for Program Evaluation. Chicago: Dorsey.

Mol, A. P. (1996). Ecological modernization and institutional reflexivity:

Environmental reform in the late modern age. Environmental Politics, 5(2), 302-

323.

Mol, A. P. (2009). Urban environmental governance innovations in China. Current

Opinion in Environmental Sustainability, 1(1), 96-100.

Mol, A.P., & Carter, N.T. (2006). China's Environmental Governance in Transition.

Environmental Politics, 15 (2),149–170.

Mol, A.P. (2009). Urban Environmental Governance Innovations in China. Current

Opinion in Environmental Sustainability, 1(1), 96-100.

Moore, S. M. (2014). Modernisation, Authoritarianism, and the Environment: The

Politics of China’s South–North Water Transfer Project. Environmental Politics,

23(6), 947-964.

Mueller, D.C. (1989). Public Choice Ⅱ: A Revised Edition. Cambridge: Cambridge

University Press.

Myerson, R. B. (1997). Game Theory: Analysis of Conflict. Cambridge, MA: Harvard

University Press.

National Bureau of Statistics, & Ministry of Environment Protection. (2017). China

Statistical Yearbook on Environment. China Statistics Press.

National Development and Reform Commission. (n.d.). Zhineng peizhi yu neishe

328
 jigou [Functions and internal structure]. https://www.ndrc.gov.cn/fzggw/bnpz/?

code=&state=123.

National People's Congress. (2020a, September 22). Weiyuanhui lishi [History of the

Environment and Resources Protection Commission of the NPC].

http://www.npc.gov.cn/npc/c34468/202009/57da3782b0614b44933ba0fcf390c4

52.shtml.

National People's Congress. (2020b, September 22). Environment and Resources

Protection Commission of the NPC. http://www.npc.gov.cn/npc/c34468/2020

09/57da3782b0614b44933ba0fcf390c452.shtml.

Newton, K., & van Deth J. W. (2010). Foundations of Comparative Politics.

Cambridge: Cambridge University Press.

Niskanen, W. A. (1971). Bureaucracy and Representative Government. Chicago:

Aldine-Atherton.

Niu, R.C. (2013, July 5). Fansi “yundongshi zhishui”ying tancheng huiying

gongzhong guanqie [Reflection on “campaign-style water pollution control”

should honestly respond to public concerns]. YangCheng Evening News.

http://cpc.people.com. cn/pinglun/n/2013/0705/c78779-22090196.html.

O'Neill, K., Weinthal, E., Marion Suiseeya, K. R., Bernstein, S., Cohn, A., Stone, M.

W., & Cashore, B. (2013). Methods and global environmental governance. Annual

Review of Environment and Resources, 38, 441-471.

O’Toole, L.J. Jr. (2003). Interorganizational Relations in Implementation, in Peters

B.G. and Pierre J. (Eds.), Handbook of Public Administration. Thousand

329
 Oaks:Sage.

O'Brien, K.J., & Li, L.J. (1999). Selective Policy Implementation in Rural China.

Comparative Politics, 31(2): 167-186.

OECD. (2007). OECD Environmental Performance Reviews China. OECD Publishing.

Olsen, J. P. (1970). Local Budgeting-Decision Making or Ritual Act?. Scandinavian

Political Studies, (5),85-118.

Olson, M. (1993). Dictatorship, Democracy, and Development. American Political

Science Review, 87(9), 567-576.

Payne, Rodger A. (1995). Freedom and the Environment. Journal of Democracy,

6(3),41-55.

Pressman，J.L., & Wildavsky, A. (1984). Implementation: How Great Expectations in

Washington Are Dashed in Oakland. Berkeley: University of California Press.

Project Group of Guangzhou Statistics Bureau. (2011). Yayunhui dui 2010nian

Guangzhou jingji yingxiang de yuce fenxi [Forecast analysis of the impact of the

Asian Games on the Guangzhou economy in 2010]. Social Science Literature

Press.

Purdy, J. (2010). The Politics of Nature: Climate Change, Environmental Law, and

Democracy. Yale Law Journal, 119, 101–188.

Qi, J.C. (1992). Fiscal reform and the economic foundations of local state corporatism

in China. World Politics, (45),99-126.

Qi, Y., & Wu, T. (2013). The Politics of Climate Change in China. Wiley

Interdiscilinary Reviews: Climate Change,4(4),301–313.

330
Qi, Y., & Zhang, L. (2014). Local Environmental Enforcement Constrained by Central-

Local Relations in China. Environmental Policy and Governance, 24(3),204-215.

Qian, Y. Y., & Weingast, B. R. (1997). Federalism as a Commitment to Preserving

Market Incentives. The Journal of Economic Perspectives, 11(4), 83-92.

Qian, Y. Y., & Xu, C. G. (1993). Why China's Economic Reforms Differ: the M-Form

Hierarchy and Entry/Expansion of the Non-State Sector. Economics of Transition,

(1),135-170.

Qie, J. R. (2018, December 19). Zhongyang huanbao ducha tuoxia xintang

chanyeyuan huanbao majia, guanting wuran qiye [The CEPIG took off the

environmental protection disguise of Xintang Eco-Industrial Park, shut down

polluting enterprises]. People. http://env.people.com.cn/GB/n1/2018/1219/c1010-

3047720 7. html.

Qiu, B. (2014, January 22). XiJinping zhuchi zhaokai zhongyang quanmian Shenhua

gaige lingdao xiaozu diyici huiyi [XiJinping presided over the first meeting of the

Group on Comprehensively Deepening Reforms]. Zhongguo jigou bianzhi Web.

http://www.scopsr.gov.cn/zlzx/sgzhy/201811/t20181120_326537.html.

Qu, G.P. (2010). Huanjing juexing: renlei huanjing huiyi he zhongguo diyici huanjing

baohu huiyi [Environmental Awakening: The Human Environment Conference

and China's First Environmental Protection Conference]. China Environmental

Science Press.

Qu, J.D. (2012). Xiangmuzhi:yizhong xinde guojia zhili tizhi [The project system: a

new system of state governance].Chinese Social Sciences, (5), 113-130.

331
Ran, Ran. (2013). Perverse Incentive Structure and Policy Implementation Gap in

China's Local Environmental Politics. Journal of Environmental Policy &

Planning, 15(1), 17-39.

Ran, R. (2014). Zhongguo huanjing zhengzhizhong de zhengce kuangjia tezheng yu

zhixing piancha [Policy Framework Features and Implementation Biases in

Chinese Environmental Politics]. Teaching and Research, (5), 55-63.

Ran, R. (2015). Zhongguo difang huanjing zhengzhi: zhengce yu zhixing zhijian de juli

[Local environmental politics in China: the gap between policy and

implementation.]. Beijing: Central Compilation and Publishing House.

Rauscher, M. (2005). International Trade, Foreign Investment, and the Environment.

Handbook of Environmental Economics, 3, 1403-1456.

Ren, M. (2015). "Hezhangzhi": yige zhongguo zhengfu liuyu zhili kuabumen xietong

de yangben yanjiu [River Chief System: a sample study of inter-departmental

coordination on watershed management in China].Journal of Beijing Academy of

Administration，(3),25-31.

Rex, J. (2020). Anatomy of agency capture: An organizational typology for diagnosing

and remedying capture. Regulation & Governance, 14(2), 271-294.

Robichau, R.W., & Lynn jr L.E. (2009). The Implementation of Public Policy: Still the

Missing Link. Policy Studies Journal, 37(1), 21–36.

Rong, J. B. (1998). Cong yalixing tizhi xiang minzhu hezuo tizhi de zhuanbian:

xianxiang liangji zhengzhi tizhi gaige [Transformation from a pressure-based

system to a democratic cooperative system: political system reform at the county

332
 and township levels]. Beijing:Central Compilation and Publishing House.

Ross, S. A. (1973). The Economic Theory of Agent: The Principal's Problem.

American Economic Review, 63(2), 134-139.

Sabatier, P. A., & Mazmanian, D.A. (1980). The Implementation of Public Policy: A

Framework of Analysis. Policy Studies Journal, 8(4), 538–560.

Sabatier, P. A. (1986). Top-Down and Bottom-Up Approaches to Implementation

Research: a Critical Analysis and Suggested Synthesis. Journal of Public Policy,

6(1): 21–48.

Sager, F. & A. Gofen. (2022). The polity of implementation: Organizational and

institutional arrangements in policy implementation. Governance, (35), 347–364.

Saich, T. (2000). Negotiating the state: The development of social organizations in

China. China Quarterly, 161, 125–141.

Saich, T. (2015). Governance and Politics of China. England: Palgrave.

Scheberle, D. (2004). Federalism and Environmental Policy: Trust and the Politics of

Implementation, Revised and Updated. Georgetown University Press.

Schnaiberg, A., & Gould, K. (1994). Environment and society: The enduring conflict.

New York: St. Martin’s.

Schnapp, K.-U. (2000). Ministerial Bureaucracies as Stand-In Agenda Setters? A

Comparative Description. WZB Discussion Paper, FS III 00–204.

Schneider, A., & Ingram, H. (1997). Policy Design for Democracy. Lawrence:

University of Kansas Press.

Schwartz, J. (2004). Environmental NGOs in China: Roles and limits. Pacific Affairs,

333
 77(1), 28–49.

Shambaugh, D. (2008). Training China's Political Elite: The Party School System.

China Quarterly, (196), 824-844.

Shang, Y. H. (2005). Zhili huanjing wuran wenti de jingji boyi fenxi [Economic game

analysis for combating environmental pollution problems.]. Theoretical

Exploration, 6(4), 93-95.

SHAW C. H. (2005). Central Leading Small Groups: China’s Highest Policy

Formulation Bodies. EAI Background Briefs, (225), 1-10.

She, X.Y., & Chen, Y.Y. (2011). Xiangmuzhi de fenji yunzuo jizhi he zhili luoji--dui

"xiangmu jincun"anli de shehuixue fenxi[The mechanism and governance logic

of the hierarchical operation of the project system-a sociological case study of

“projects entering the village"].Chinese Social Sciences, (4), 126-148.

Shue, V. (1988). The Reach of the State: Sketches of the Chinese Body Politic. Stanford:

Stanford University Press.

Southern Talks. (2013, No.43). Guangzhou 486 yi zhishui beipan shibai, jiti juece

zhaoshei wenze [Guangzhou's RMB 48.6 billion water treatment failed Who held

accountable for collective decisions]. Tengxun net. https://gd.qq.com/zt2013/

gzzhishui/.

Spaargaren, G., & Mol, A. P. J. (1992). Sociology, environment, and modernity:

Ecological modernization as a theory of social change. Society and Natural

Resources, 5, 323-344.

Spillane, J. P., Reiser, B. J. & Reimer, T. (2002). Policy Implementation and Cognition:

334
 Reframing and Refocusing Implementation Research. Review of Educational

Research, 72(3), 387–431.

Stanbury, W.T., & Fulton, J. (1984). Suasion as a governing instrument, in Maslove,

A. (Ed.), How Ottawa spends 1984: the new agenda. Toronto: James Lorimer.

Standing Committee of the National People's Congress. (1989, December 26).

Environmental Protection Law of the People's Republic of China. BeiDaFaBao.

Standing Committee of the National People's Congress. (2008, February 28). Water

Pollution Prevention and Control Law of the People's Republic of China (2008

Revision). BeiDaFaBao.

Standing Committee of the National People's Congress. (2014, April 24).

Environmental Protection Law of the People's Republic of China (2014 Revision).

BeiDaFaBao.

Standing Committee of the National People's Congress. (2017, June 27). Water

Pollution Prevention and Control Law of the People's Republic of China (2017

Revision). BeiDaFaBao.

State Council. (1998, January 6). Taihu shuiwuran fangzhi “jiuwu” jihua ji 2010nian

huihua [The Ninth Five-Year Plan and the 2010 Plan for the Prevention and

Control of Water Pollution in Taihu Lake]. http://www.gov.cn/zhengce/

content/2010-11/19/content_5185.htm.

State Council. (2016, December 5). Notice of the State Council on the issuance of the

13th Five-Year Plan for Ecological and Environmental Protection.

http://www.gov.cn/zhengce/content/2016-12/05/content_5143290.htm.

335
State Council. (2007, November 22). Guojia huanjing baohu "shiyiwu" guihua

[Eleventh Five Year Plan for National Environmental Protection].

http://www.gov.cn/zhengce/content/2008-03/28/content_4877.htm.

State Council. (2011, December 15). Notice on the Issuance of the Twelfth Five-Year

Plan for National Environmental Protection. http://www.gov.cn/zwgk/2011-

12/20/content_2024895.htm.

State Council. (2015, April 2). Shuiwuran fangzhi xingdong jihua [Action Plan for

Water Pollution Prevention and Control]. http://www.gov.cn/zhengce/content/

2015-04/16/content_9613.htm.

State Council. (2005, December 3). Guanyu luoshi kexue fazhanguan jiaqiang

huanjing baohu de jueding [Decision on implementing the Scientific Outlook on

Development and strengthening environmental protection]. China Government

Net. http://www.gov.cn/zwgk/2005-12/13/content_125736.htm.

State Environmental Protection Administration. (2003, February 24). Liaohe liuyu

shuiwuran fangzhi "shiwu" jihua [Tenth Five-Year Plan for Water Pollution

Prevention and Control in Liaohe River Basin]. https://www.mee.gov.cn/gkml/

zj/wj/200910/t20091022_172170.htm.

Stigler, G. J. (1971). The theory of economic regulation. Bell Journal of Economics

and Management Science, 2: 3-21.

Su, M., Liu, J.M., & Zhang, J. (2008). Cujin huanjing baohu de gonggong caizheng

zhengce yanjiu[A study on public finance policies to promote environmental

protection]. Financial Research, (7), 20-33.

336
Sun, C. (2020, December 4). Minjian hezhang zhuli hehu guanli [Social river chiefs

help manage rivers and lakes]. People. http://society.people.com.cn/n1/2020/

1204/c1008-31954603.html.

Sun, W.Z., Luo, D.L., Zheng, S.Q., & Wan, G.H. (2014). Huanbao kaohe,difang

guanyuan jinsheng yu huanjing zhili--jiyu 2004-2009nian zhongguo 86ge

zhongdian chengshi de jingyan zhengju [Environmental assessment, local official

promotion and pnvironmental governance -empirical evidence from 86 key cities

in China 2004-2009]. Journal of Tsinghua University (Philosophy and Social

Science Edition), 29(4), 49-62.

Sun, Y., & D. Zhao. (2008). State-society relations and environmental campaigns. In

O’Brien, K. J. (Ed.), Popular protest in China. Cambridge: Harvard University

Press.

Tang, N. (2016, December 12). Guangzhou zai huanbao lingyu shishi wenze 11 ren

[Guangzhou held 11 people accountable in environmental protection]. Guangzhou

Daily.

Tang, X., & Chen, W. (2017). Dongji,jili yu xinxi -- zhongguo huanjing zhengce

zhixing de lilun kuangjia yu leixingxue fenxi [Motivation ， incentive and

information: the theoretical framework and typological analysis of China’s

environmental policy implementation]. Journal of National Academy of

Governance, (1),76-81.

Tang, X. (2016). Zhengshi yu feizhengshi jili: zhongguo huanjing zhengce zhixing jizhi

yanjiu [Formal and informal incentives: a study of environmental policy

337
 implementation mechanisms in China]. Beijing: China Social Science Press.

The 17th National Party Congress of the CCP. (2007, October 21). Zhongguo

gongchandang dangzhang [Constitution of the CCP]. People. http://cpc.people.

com.cn/ GB/64162/64168/106155/106156/6439183.html.

The 18th National Party Congress of the CCP. (2012, November 14). Zhongguo

gongchandang dangzhang [Constitution of the CCP]. People. http://dangshi.

people. com.cn/n/2012/1119/c234123-19618241.html.

Tilt, B. (2007). The political ecology of pollution enforcement in China: A Case from

Sichuan’s rural industrial sector. China Quarterly, 192, 915–932.

Tong, Y. Q. (2007). Bureaucracy Meets the Environment: Elite Perceptions in Six

Chinese Cities. China Quarterly, (189), 100–121.

Tong, J. (1999). A Principal-Agent Analysis of Fiscal Decentralization, In Edwin A.

Winckler. Boulder (Ed.), Transition from Communism in China: Institutional and

Comparative Analyses. London: Lynne Rienner Publishers.

United Nations. (1973). Report of the United Nations Conference on the Human

Environment. https://www.un.org/en/conferences/environment/stockholm1972.

Van Meter D.S., & Van Horn C. E. (1975). The Policy Implementation Process: A

Conceptual Framework. Administration and Society, 6(4),445-487.

Van Rooij, B. (2006a). Regulating Land and Pollution in China: Lawmaking,

Compliance, and Enforcement: Theory and Cases. Netherlands: Leiden

University Press.

Van Rooij, B. (2006b). Implementation of Chinese environmental law: Regular

338
 enforcement and political Van Rooij campaigns. Development & Change, 37(1),

57–74.

Walder, A.G. (1995). Local Governments as Industrial Firms: An Organizational

Analysis of China's Transitional Economy. American Journal of Sociology,101(2),

263-301.

Wan, P. (2018, March 29). From “leading group” to “committee”: comprehensively

deepening reforms enter a new stage (cong “lingdaoxiaozu” dao “weiyuanhui”:

quanmian shenhua gaige jinru xinjieduan). CPCNews. http://theory.people.

com.cn/n1/2018/0329/c40531-29895329.html.

Wan, B.T. (1996). Zhongguo huanjing jiance gongzuo de chengjiu,wenti yu duice

[Achievements, problems and countermeasures of environmental monitoring in

China].China Environmental Monitoring, 12(2), 27－31．

Wang, P. (2010, October 10). Guangzhou fushizhang tan yayun huanbao “tiewanzhiwu”

dazao “lantianbishui” [Guangzhou's deputy mayor talks about environmental

protection for the Asian Games: "Iron-fisted pollution control" to create "blue sky

and blue water"]. China Government Net. http://www.gov.cn/jrzg/2010-10/10/

content_1718584.htm.

Wang, Q. (2017, June 22). Shuiwuran fangzhifa xiuzheng’an ershen, nijiada dui weifa

xingwei chufa lidu [Water pollution prevention and control law draft amendments

to the second review, intended to increase the penalties for violations]. NPC Net.

http://www.npc.gov.cn/zgrdw/npc/lfzt/rlyw/2017-06/23/content_2023922.htm.

Wang, S., & J. He. (2004). Associational Revolution in China: Mapping the Landscape.

339
 Korea Observer, 35(3).

Wang, T. (2012, September 13). Huanbaofa xiuding: yijian yiluokuang [Environmental

Protection Law revision: a flood of opinions]. Southern Weekend. http:// www.

infzm.com/contents/80777.

Wang, W. X. (2012, May 10). Huanbao touzi: jiceng difang zhengfu bukan zhongfu,

zhongyang zhengfu zhichu dai zengjia [Investment in environmental protection:

the grass-roots local governments are overwhelmed, the central government

expenditure needs to be increased]. China Economic News (Zhongguo jingji

daobao).

Wang, Y. (2007). Diagnosis and Recommendations for Trans-jurisdictional Water

Pollution Management in China. Frontiers of Environmental Science &

Engineering in China, 1(4), 401–417.

Wang, Z. F., Xie, Q. Y., & Hu, Z. H. (2018). Zhongyang huanbao ducha “huitoukan”

xiang guangdong jiaoban qunzhong xinfangjian 6077 jian [CIGEP "look back" in

Guangdong and hand over 6,077 cases of mass letters and visits]. Guangdong

Ecology and Environment Department. http://gdee.gd.gov.cn/htkxwbd/content/

post_2352193.html.

Wang, Y.H., & Chen, X.N. (2020). River chief system as a collaborative water

governance approach in China. International Journal of Water Resources

Development, 36(4),610-630.

Warwick, M., & L. Ortolano. (2007). Benefits and costs of Shanghai’s environmental

citizen complaints system. China Information, 21, 237–264.

340
Weale, A., Pridham, G., Cini, M., Konstadakopulos, D., Porter, M., & Flynn, B. (2000).

Environmental Governance in Europe: An Ever Closer Ecological Union. Oxford:

Oxford University Press.

Wedeman, A. (1999). Agency and Fiscal Dependence in Central-Provincial Relations

in China. Journal of Contemporary China, 8(20), 103-22.

Whiting, S. H. (2000). Power and Wealth in Rural China: The Political Economy of

Institutional Change. Cambridge: Cambridge University Press.

Wilson, J. Q. (1989). Bureaucracy. New York: Basic Books.

Wilson, J.Q. (1974). Political Organizations. Beverly Hills: Sage.

Winter, S.C. (2003). Implementation Perspectives: Status and Reconsideration, in

Peters B.G. and Pierre J. (Eds.), Handbook of Public Administration. Thousand

Oaks, CA: Sage.

Wong, K. (2003). The environmental awareness of university students in Beijing,

China. Journal of Contemporary China, 12(36), 519–536.

Wong, K., & H.S. Chan. (1996). The environmental awareness of environmental

protection bureaucrats in the People’s Republic of China. Environmentalist, 16(3),

213–219.

World Bank. (1997). Five years after Rio: Innovations in Environmental Policy.

https://documents.worldbank.org/zh/publication/documents-reports/document

detail/209081468739294734/five-years-after-rio-innovations-in-environmental-

policy

Wu, J., Deng, Y., Huang, J., Morck, R., & Yeung, B. Y. (2013). Incentives and

341
 Outcomes: China's Environmental Policy. Cambridge: National Bureau of

Economic Research.

Wu, F.S. (2009). Environmental Politics in China: An Issue Area in Review. Journal

of Chinese Political Science, 14(4), 383-406.

Wu. Q.L. (2008). Lun dangwei shuji de quanli [Powers of the Party Secretary]. Journal

of the Party School of the Tianjin Municipal Committee of the CCP, 10(4), 15-21.

Xi, J. P. (2017, October 18). XiJinping's report at the 19th PC. People. http://cpc.

people.com.cn/n1/2017/1028/c64094-29613660.html.

Xie, J.L. (2019, April 18). Cong huanjing baohu bu dao shengtai huanjing bu--guapai

yinianjian [From the Ministry of Environmental Protection to the Ministry of

Ecology and Environment - One year after its launch]. China Environment News.

http://epaper.cenews.com.cn/html/2019-04/18/node_2.htm.

Xie, P. (2008). Taihu lanzao de lishi fazhan yu shuihua zaihai [Historical development

of cyanobacteria and water bloom hazards in Taihu Lake]. Beijing: Science

Publishing House."

Xie, Q. Y. (2016). Guangdong yi leiji shoudao zhongyang huanbao duchazu

zhuanbanjian 1667zong [Guangdong has received a total of 1,667 referrals from

the CIGEP]. Guangdong Ecology and Environment Department.

http://gdee.gd.gov.cn/dcdt/content/post_2351509.html.

Xinhua News Agency. (2006, April 22). Hu Jintao: Persistently grasp the work of

ecological protection and construction. China Government Net. http://www.gov.

cn/ node_11140/2006-04/22/content_261047.htm.

342
XinHuanet. (2017, September 8). Discussion between Zhang Gaoli and participants

of a seminar for provincial and ministerial-level cadres on promoting ecological

civilization and low-carbon development. http://www.xinhuanet.com//politics/

2017-09/08/c_1121633525.htm.

Xu, Y. (2014, November 20). Guangzhou za 140yi zaizhishui, renda daibiao: xiqu

yayun zhishui jiaoxun [Guangzhou spends 14 billion to treat water again, NPC

delegates: learn from Asian Games water treatment lessons]. Southern

Metropolitan News. http://epaper.nandu.com/epaper/A/html/2014-11/20/content_

3347210.htm?div=-1.

Xu, C.G. (2011). The Fundamental Institutions of China's Reforms and Development.

Journal of Economic Literature, 49(4), 1076-1151.

Xue, L.Q, & Yang, S.W. (2011). Lun zhongguo zhengce zhixing moshi de tezheng--yi

"shiyiwu"qijian chenggong guanting xiaohuodian weili [The characteristics of

China's policy implementation model: an example of successful shutdown of

small thermal power plants during the eleventh Five-Year Plan]. Journal of Public

Administration (Gonggong guanli xuebao), 8(4), 1-7.

Xue, Q. (2015). Yalixing tizhi moshixia de shehui zuzhi fazhan--jiyu wenzhou ge'an

de yanjiu [Development of NGOs by the Pressure System Model：A Case Study

of Wenzhou]. Journal of Public Administration (gonggong guanli xuebao), 12(4),

131-142.

Yackee, S.W. (2014). Reconsidering Agency Capture During Regulatory

Policymaking. In Carpenter, D., & Moss, D.A. (Eds.). Preventing Capture:

343
 Special Interest Influence in Regulation, and How to Prevent It. CUP, Cambridge,

MA.

Yang, G. (2005). Environmental NGOs and institutional dynamics in China. China

Quarterly, 182, 46–66

Yang,H.G. (2016).Woguo difang zhengfu huanjing zhili de zhengce gongju yanjiu[A

study of policy instruments for environmental governance in local governments

of China]. Shanghai: Shanghai Social Science Press.

Yang, H.S., Chen, S.L., & Zhou, Y.Z. (2008). Difang zhengfu jingzheng yu huanjing

zhengce --Laizi zhongguo shengfen shuju de zhengju [Local Government

Competition and Environmental Policy - Evidence from Provincial Data in China].

Southern Economy, (6), 15-30.

Yang, J. (2019). You chuishaoren fa'an yinfa dui guangzhoushi weifa paishui xingwei

youjiang jubao zhidu de sikao [Thinking about “Whistler Act” for illegal drainage

in Guangzhou city]. Guangdong Water and Hydroelectricity，(12), 82-85.

Yang, M. (2002). Huan jing wen ti yu huan jing yi shi [Environment issues: awareness

and perceptions]. Beijing: Huaxia Publishing House.

Young, O. R. (1981). Natural resources and the state: The political economy of

resource management. Berkeley: University of California Press.

Yu, H.X., & Liu, J.W. (2012). Gaige kaifang hou zhongguo gongchandang dui

huanjing wenti renshi de zhuanbian--jiyu lici dangdaihui baogao de shijiao [The

transformation of the Chinese Communist Party's understanding of environmental

issues after reform and opening up - a perspective based on the reports of

344
 successive party congresses]. Journal of Theoretical Studies，217(3),39-42.

Yu, M.J. (2011). Lun shengtai zhilizhong de zhongyang yu difang zhengfujian liyi

xietiao [Interests coordination between central and local governments on

ecological governance]. Social Sciences，(9),23－32．

Yu, M.J. (2011b). Shengtai zhili zhong de zhongyang yu difang fujijian xietiao:yige

fenxi kuangjia[Intergovernmental coordination between central and local

governments in ecological governance: an analytical framework].Comparison of

Economic and Social Systems,(2), 148-156.

Yuan, C.H., & Yan, Y. (2020). Zhongyang huanbao ducha:yalixing huanjing zhili

moshi de ziwo tiaoshi--yixiang jiyu neirong fenxifa de anli yanjiu [Central

Environmental Protection Inspectors: Self-adaptation of a pressure-based

environmental governance model - A case study based on a content analysis

approach].Governance Research,191(1),57-68.

Zhan, X., Lo, W. H., & Tang, S. Y. (2013). Contextual Changes and Environmental

Policy Implementation: A Longitudinal Study of Street-Level Bureaucrats in

Guangzhou, China. Journal of Public Administration Research & Theory, 24(4),

1005-1035.

Zhang, J. Y., & Barr, M. (2013). Green Politics in China: Environmental Governance

and State-Society Relations. Pluto Press.

Zhang, L., He, G., & Mol, A. P. J. (2015). China’s new environmental protection law:

A game changer? Environmental Development, 13, 1-3.

Zhang, L.J., Li, Y.H., & Liu, Z. P. (2017). Zhongyang kending, difang zhichi, baixing

345
 dianzan, chengxiao xianzhu zhongyang huanbao ducha weilida [Central

environmental protection inspectors are powerful，which is affirmed by the central

government, supported by the local, praised by the public]. China Economic

Weekly, 43, 19-31.

Zhang, K.M., Wen, Z.G. & Peng, L.Y. (2007). Dangdai zhongguo de huanjing zhengce:

xingcheng,tedian yu pingjia [Environmental policies in China: evolvement,

features and evaluation]. China's Population, Resources and

Environment,17(2),1-7.

Zhang, L.Y., & Qi, Y. (2010). Difang huanjing jianguan kunjing jieshi--zhengzhi jili

yu caizheng yueshu jiashuo [Explanations for the local environmental regulatory

dilemma - the political incentive and financial constraint hypothesis].

Administration in China，2010 (3), 93-97．

Zhang, T.Y. (2014). Huanjing guizhi de lvse chuangxin jili yanjiu [A study of green

innovation incentives for environmental regulation]. [Doctoral dissertation,

Chinese Academy of Social Sciences]. CNKI.

Zhang, Y. (2017). “Lingdao xiaozu”zai guojia zhili tixi zhong de gongneng yanjiu

[Study on the function of the "leadership group" in the national governance

system]. [Doctoral Dissertation, DongHua University, China]. CNKI.

Zhao, Z.Y. (1987, October 25). ZhaoZiyang's report at the 13th PC. CNTheory.

http://www.cntheory.com/tbzt/sjjlzqh/ljddhgb/202110/t20211029_37377.html.

Zhao, M.F. (1998). Quanguo dangxiao,xingzheng xueyuan xitong "kechixu fazhan yu

huanjing baohu"lilun yantaohui huiyi jiyao [Proceedings of the theoretical

346
 seminar on "Sustainable Development and Environmental Protection" in the

National System of Party Schools and Administrative Colleges]. Studies in

Natural Dialectics，(2),7-10.

Zhao, X.F., & Cai, T.J. (2020). Zhengce gongju youxiao gaishanle "jiulongzhishui"

kunjing ma?--Jiyu 1984-2018 nian zhongguo shui wuran zhili de zhengce wenben

yanjiu [Have policy instruments effectively improved the " nine dragons rule the

water" dilemma? --policy text study based on water pollution control in China

1984-2018].Public Administration Review (gonggong xingzheng pinglun), (4),

108-129.

Zhao, Y. (2013). Zhengce de "jiema" he "bianma"--zhengce guocheng zhong de

zhongguo gongchandang dangxiao [Decoding and encoding of policy - the Party

School of CCP in the policy process]. Journal of Shanghai Academy of

Administration, 14(1), 60-68.

Zheng, X. (2016, May 12). Guangzhou baoyu chongkua 4yi zhengzhi gongcheng,

wangyou:500yi zhishui dou buxing [Guangzhou rainstorm washed away 400

million remediation projects, netizens: 50 billion to treat water pollution failed].

Yang cheng Evening News. http://news.cnr.cn/native/gd/20160512/t201605

12_522123985.shtml.

Zheng, S.Y, & Meng, T.G. (2021). Huanjing zhili de xinxi zhengzhixue:zhongyang

huanbao ducha ruhe qudong gongzhong canyu? [The informational politics of

environmental governance: how do central environmental inspectors drive public

participation?]. Comparison of Economic and Social Systems，213(1), 80-92.

347
Zhou, L.A. (2010). Incentives and Governance: China's Local Governments.

Singapore: Cengage Learning.

Zhou, F.Z. (2012). Caizheng zijin de zhuanxianghua jiqi wenti:jianlun xiangmu zhiguo

[The Problems of Fiscal Earmarked Funds: also on project governance]. Society，

32(1),1-37.

Zhou, L.A. (2007). Zhongguo difang guanyuan de jinsheng jinbiaosai moshi yanjiu [A

Study of the Promotion Tournament Model for Local Officials in China].

Economic Research, (7),36-50.

Zhou, L.A. (2014). Xingzheng fabaozhi [Administrative contracting system]. Society,

34(6),1-38.

Zhou, W. (2015). “Lingdao xiaozu”ruhe lingdao? – dui “Zhongyang lingdao xiaozu”de

yixiang zhengtixing fenxi ["How is the Leading Small Group led? --A holistic

analysis of the "Central Leading Small Group"]. Theory and Reform, (1),95-99.

Zhou, W. (2018). Chaoyue yishi xietiao: lingdao xiaozu de yunxing luoji ji moshi

fenhua [Beyond deliberative coordination: the operational logic and model

differentiation of leadership groups]. China Administration, (3), 113-117.

Zhou, X.G. (2008). Jiceng zhengfujian de "gongmou xianxiang"--yige zhengfu

xingwei de zhidu luoji [The phenomenon of " collusion" among grassroots

governments - the institutional logic of a government's behavior]. Sociological

Research，(6),21.

Zhou, X.G. (2010). The Institutional Logic of Collusion among Local Governments in

China. Modern China,36(1),47-78.

348
Zhou, X.G. (2012). Yundongxing zhili jizhi: zhongguo guojia zhili de zhidu luoji zai

sikao [Campaign-style governance mechanisms: Rethinking the institutional logic

of Chinese state governance]. Open Times，(9):105-125.

Zhou, X.G. (2014). Zhongguo guojia zhili jiqi moshi: yige zhengtixing shijiao [State

Governance in the Context of Contemporary China]. Academic Monthly, 46(10),

5-11.

Zhou, X.G., & Lian, H. (2011). Zhengfu neibu shangxiaji bumen jian tanpan de yige

fenxi moxing--yi huanjing zhengce shishi weili [Bureaucratic bargaining in the

Chinese government: the case of environmental policy implementation]. Chinese

Social Sciences, (5),80-96.

Zhou, X.G., & Lian, H. (2012). Zhongguo zhengfu de zhili moshi [The Chinese

government's governance model: a theory of "control"]. Sociological Research,

(5), 69-93.

Zhu, D.，& Ru, J. (2008). Strategic Environmental Assessment in China: Motivations，

Politics, and Effectiveness. Journal of Environmental Management，88(4)，615

- 626.

Zhu, X. (2014). Mandate versus Championship: Vertical Government Intervention and

Diffusion of Innovation in Public Services in Authoritarian China. Public

Management Review, 16(1), 117–139.

Zhu, G.L., & Zhang, Z.H. (2005). “Zhize tonggou” pipan [Critique of the "duty

isomorphism"]. Journal of Peking University (Philosophy and Social Science

Edition), (01), 101-112.

349
Zhuang, Y.Y. (2016). Zhongguo de difang huanbao zhili: xuanzexing zhengce zhixing

yu zhongyang de zaijiquan [China's local environmental governance: selective

policy implementation and re-centralization reforms]. [Doctoral dissertation, The

Chinese University of Hong Kong]. ProQuest Dissertations & Theses Global.

Zhuang, Y.Y., Hu, R. &You, Y. (2019). Huanbao ducha yu difang huanbao bumen de

zuzhi tiaoshi he kuoquan--yi sheng xian weili [Environmental protection

inspectors and the organizational adaptation and expansion of local environmental

protection departments - the case of county S in province H]. Public

Administration Review (gonggong xingzheng pinglun), 12(02),12-29.

Zou, Liang. (1992). Threat-based incentive mechanisms under moral hazard and

adverse selection. Journal of Comparative Economics, 16(1),47-74.

350
 Appendices

Appendix A
Table A1 CCP’s Understanding of Environmental Protection in Reports of PC
Year,
Party
Cognition Specific Statement in the reports
Congress,
Reporter
In the future, we must firmly control population
1982, 12th PC Population control;
growth, resolutely protect various agricultural
Hu Yaobang Ecological balance
resources, and maintain ecological balance.
Population control, environmental protection
and ecological balance are important issues
related to the overall economic and social
development...We must emphasize the
Population brings importance of sound maternal and child care and
environmental improve the quality of the population... While
1987, 13th PC
problems; Economic promoting economic development, we should
Zhao Ziyang
development brings vigorously protect and rationally use various
pollution problems natural resources, strive to carry out
comprehensive treatment of environmental
pollution, strengthen the protection of ecological
environment, and combine economic, social and
environmental benefits well.
We will conscientiously implement the
fundamental national policies of controlling
population growth and environmental
Environmental
protection... We should enhance the
1992, 14th PC protection is a
environmental awareness of the whole nation,
Jiang Zemin fundamental national
protect and rationally utilize natural resources
policy
such as land, mineral resources, forests and
water, and strive to improve the ecological
environment.
We must implement the strategy of sustainable
development. Adhere to the fundamental state
Sustainable policies of family planning and environmental
development; protection, and correctly handle the relationship
th
1997, 15 PC Environmental between economic development and population,
Jiang Zemin protection serves for resources and environment. Resources
economic development and conservation should be carried
development out simultaneously, conservation should be put
in the first place, and resource utilization
efficiency should be improved. We should make

351
 overall plans for the development and
improvement of land and resources, and strictly
implement the laws concerning the management
and protection of land, water, forests, minerals,
and oceans. Implement the system of
compensated use of resources. We should
strengthen the control of environmental
pollution, plant trees and grass, preserve soil and
water, conserve and prevent desertification, and
improve the ecological environment.
To continuously enhance the sustainable
development ability, improve the ecological
environment, and significantly improve the
2002, 16th PC Sustainable
utilization efficiency of resources, so as to
Jiang Zemin development
advance the harmony between man and nature,
and promote the civilized development path of
production, affluence and good ecology.
There is still a big gap between our work and the
expectations of the people. We still face many
difficulties and problems in our progress. The
prominent one is that the cost of resources and
environment for economic growth is too high.
Scientific outlook on
To build ecological civilization and basically
development;
form an industrial structure, growth mode and
The relationship
consumption mode that can save energy and
2007, 17th PC between
resources and protect the ecological
Hu Jintao environmental
environment. The circular economy has formed
protection and
a large scale, and the proportion of renewable
maintaining political
energy has increased significantly. The
stability
discharge of main pollutants has been effectively
controlled, the quality of ecological environment
has been significantly improved, and the concept
of ecological civilization has been firmly
established in the whole society.
To make great progress in building a resource-
saving and environment-friendly society...the
Building ecological resource recycling system has been initially
civilization; established. Energy consumption and carbon
2012, 18th PC The challenge of dioxide emissions per unit of GDP decreased
Hu Jintao environmental significantly, and the total emissions of major
problems to the pollutants decreased significantly... speed up
governance capability the establishment of an ecological civilization
system, improve the system and mechanism for
the development of land and space, and the

352
 conservation of ecological and environmental
protection.
Building ecological civilization is a long-term
plan related to the well-being of the people and
the future of the nation···Give prominence to the
building ecological civilization and realize the
sustainable development of the Chinese nation.
Building ecological civilization is the
millennium plan for the sustainable development
of the Chinese nation. We must uphold and
practice the idea that lucid waters and lush
mountains are invaluable assets, adhere to the
fundamental national policy of saving resources
and protecting the environment, treat the
ecological environment like life, coordinate the
th Ecological
2017, 19 PC management of mountains, rivers, forests,
civilization;
Xi Jinping fields, lakes and grasses, implement the strictest
Green development
ecological environment protection system, form
a green development and lifestyle mode , and
firmly adhere to the civilized development of
production development, rich life and good
ecology road, build a beautiful China, create a
good production and living environment for the
people, and contribute to global ecological
security.
Note. Adapted from the reports of the previous PC.
http://cpc.people.com.cn/GB/64162/64168/index.html.

353
 Table A2 Main Documents for Water Environment Protection Issued by the
Central Government
Release
Documents Issuing Authorities
Time
Opinions on Comprehensively Strengthening
Ecology and Environment Protection and
Resolutely Fighting a Tough Battle for The Central Committee
Jun.24,2018 Pollution Prevention and Control (Guanyu (CC) of the CCP;
quanmian jiaqiang shengtai huanjing baohu State Council
jianjue dahao wuran fangzhi gongjianzhan de
yijian)
The general office of the
Guidance on the Implementation of Lake Chief
CC of the CCP;
Jan.4,2018 System in Lakes (Guanyu zai hupo shishi
The general office of the
huzhangzhi de zhidao yijian)
State Council
The general office of the
Opinions on the Full Implementation of the
CC of the CCP;
Dec.11,2016 River Chief System (Guanyu quanmian
The general office of the
tuixing hezhangzhi de yijian)
State Council
Implementation Plan on the Control of the
The general office of the
Nov.10,2016 Pollutant Discharge Permit System (Kongzhi
State Council
wuranwu paifang xukezhi shishi fang’an)
Action Plan on Water Pollution Prevention and
Apr.2,2015 State Council
Control
Regulations on Prevention and Control of
Pollution from Large-scale Livestock and
Nov.11,2013 State Council
Poultry Breeding (Chuqin guimo yangzhi
wuran fangzhi tiaoli)
Regulations on Urban Drainage and Sewage
Oct.2,2013 Treatment (Chengzhen paishui yu wushui State Council
chuli tiaoli)
Opinions on Implementing the Strictest Water
Resources Management System (Guanyu
Jan,12,2012 State Council
shixing zuiyange shuiziyuan guanli zhidu de
yijian)
Regulations on the Management of Taihu Lake
Sept.7,2011 State Council
Basin
Reply on the National Groundwater Pollution
State Council （ MEP for
Prevention and Control Plan (2011-2020)
Oct.10,2011
[Guanyu quanguo dixiashui wuran fangzhi
instruction）
guihua (2011-2020nian) de pifu]
Opinions on Strengthening Water SEPA, NDRC, MWR,
Jan,12,2008 Environment Protection of Important Lakes Ministry of Finance, and
(Guanyu jiaqiang zhongdian hupo Ministry of Construction

354
 shuihuanjing baohu gongzuo de yijian) (Forwarded by the general
office of the State Council)

Reply on Water Pollution Prevention and

Control Plan of Songhua River Basin (2006- State Council (SEPA,
Aug.23,2006
2010) [Guanyu songhuajiang liuyu shuiwuran NDRC for instruction)
fangzhi guihua (2006-2010nian) de pifu]
Reply on Governance Planning of Weihe River
State Council (MWR,etc.
Dec.16,2005 Basin (Guanyu weihe liuyu zhongdian zhili
for instruction)
guihua de pifu)
Notice on Strengthening the Safety Guarantee
of Drinking Water (Guanyu jiaqiang The general office of the
Aug.17,2005
yinyongshui anquan baozhang gongzuo de State Council
tongzhi)
Reply on Agreeing to Establish the Inter-
Ministerial Joint Conference System for Water
Pollution Prevention and Control in the Three
State Council (SEPA for
Jul.15,2005 Gorges Reservoir Area and Its Upstream
instruction)
(Guanyu tongyi jianli sanxia kuqu jiqi
shangyou shuiwuran fangzhi buji lianxi huiyi
zhidu de pizu)
Notice on Strengthening the Prevention and
Control of Water Pollution in the Huaihe River The general office of the
Dec.28,2004
Basin (Guanyu jiaqiang huaihe liuyu State Council
shuiwuran fangzhi gongzuo de tongzhi)
Notice on Promoting Water Price Reform,
Promoting Water Conservation and Protecting
The general office of the
Apr.19,2004 Water Resources (Guanyu tuijin shuijia gegai
State Council
cujin jieyue yongshui baohu shuiziyuan de
tongzhi)
Reply on the Tenth Five Year Plan for Water State Council [SEPA,
Pollution Prevention and Control in Dianchi State Development and
Mar.12,2003
Lake Basin (Guanyu Dianchi liuyu shuiwuran Planning Commission
fangzhi “shiwu” jihua de pifu) (SDPC) for instructions]
Reply on the Tenth Five Year Plan for Water
Pollution Prevention and Control in Haihe State Council (SEPA,
Mar,4,2003
River Basin (Guanyu Haihe liuyu shuiwuran SDPC for instructions)
fangzhi “shiwu” jihua de pifu)
Reply on the Tenth Five Year Plan for Water
Pollution Prevention and Control in Liaohe State Council (SEPA,
Jan.30,2003
River Basin (Guanyu Liaohe liuyu shuiwuran SDPC for instructions)
fangzhi “shiwu” jihua de pifu)
Reply on the Tenth Five Year Plan for Water State Council (SEPA,
Jan.11,2003
Pollution Prevention and Control in Huaihe SDPC for instructions)

355
 River Basin (Guanyu Huaihe liuyu shuiwuran
fangzhi “shiwu” jihua de pifu)
Regulations on the Management of the
Jan.2,2003 Collection and Use of Sewage Charges State Council
(Paiwufei zhengshou shiyong guanli tiaoli)
Notice on Approving the Plan for the The general office of the
Prevention and Control of Water Pollution in State Council (SEPA,
Mar.11,1999
the Haihe River Basin (Guanyu pizhun Haihe SDPC, MWR for
liuyu shuiwuran fangzhi guihua de tongzhi) instructions)
Notice on Approving the Ninth Five Year Plan
The general office of the
for Water Pollution Prevention and Control in
State Council (SEPA,
Mar.11,1999 Liaohe River Basin and the 2010 Plan (Guanyu
SDPC, MWR for
pizhun Liaohe liuyu shuiwuran fangzhi
instructions)
“jiuwu” jihua ji 2010nian guihua de tongzhi)
Reply on the Ninth Five Year Plan for the
Prevention and Control of Water Pollution in State Council (SEPB,
Jan.6,1998 Tai Lake and the 2010 Plan (Guanyu Taihu SDPC, MWR for
shuiwuran fangzhi jiuwu jihua ji 2010nian instructions)
guihua de pifu)
Note. Compiled according to the China’s government online document library.
http://sousuo.gov.cn/s.htm?t=zhengce&q=%E6%B0%B4%E6%B1%A1%E6%9F%9
3

356
 Table A3 Evolution of China’s Environmental Protection Authority
Build-
Name of the Organ Remark
up Time
The State Council held the first environmental
Environmental
protection conference, at which an
Protection Leading
1974 environmental protection organization, the
Group Office of the
Environmental Protection Leading Group Office
State Council
of the State Council was established.
After the first institutional reform of the State
Council, the Environmental Protection Bureau
Environmental
1982 was formally established and was under the lea
Protection Bureau
dership of the Ministry of Urban-Rural Constru
ction and Environmental Protection at that time.
The Environmental Protection Bureau was rena
med as the State Environmental Protection
State Environmental
1984 Bureau, which was still under the management
Protection Bureau
of Ministry of Urban-Rural Construction and
Environmental Protection.
Due to the institutional reform of the State
Council again, it was independent from the Mi
State Environmental nistry of Urban-Rural Construction and Environ
1988
Protection Bureau mental Protection, and became an institution (at
the deputy ministerial level) directly under the
State Council.
State Environmental
The State Environmental Protection Bureau was
Protection
1998 upgraded to the State Environmental Protection
Administration
Administration (at the ministerial level).
(SEPA)
Ministry of
According to the Institutional Reform Plan of
2008 Environmental
the State Council, it was upgraded to the MEP.
Protection
At the first session of the 13th NPC, the
Ministry of Ecology decision on the Institutional Reform Plan of the
2018
and Environment. State Council was adopted and the establishme
nt of the MEE was approved.
Source: LiuQiushi. (2013). Woguo huanjing baohu xingzheng jigou de yange ji
suomianlin de xianshi kunjing [The Evolution of China's Environmental Protection
Administrative Institutions and Their Practical Difficulties]. Citizen and Law (Law
Edition) (7), 32-35.

357
 Table A4 Targets, Main Measures, Actions and Leading Department in Central
APWPPC
Ten Action Main Measures Concrete Actions Leading
Plans Department
Overall Paying special To close down “ten MEP
Control of attention to categories of small”
Pollutant prevention and enterprises.
Discharge control of industrial Specially rectifying ten major MEP
pollution industries
Treating water pollution in MEP
industrial agglomeration
areas on a centralized basis.
Strengthening To accelerate construction MHURD
control of urban and alteration of urban
domestic pollution sewage treatment facilities
Fully reinforcing supporting MHURD
pipe network construction.
Promoting sludge treatment MHURD
and disposal
Boosting To prevent and control MA
prevention and livestock and poultry farming
control of pollution
agricultural and Controlling agricultural non- MA
rural pollution point source pollution
Adjusting planting structure MA, MWR
and layout.
Accelerating comprehensive MEP
improvement of rural
environment.
Strengthening To actively deal with ship MT
control over ship pollution
and port pollution Enhancing ability to prevent MT
and control port and terminal
pollution
Promotion Adjusting To eliminate outdated MIIT
of industrial structure industrial capacity according
transformati to the law
on and Making stricter MEP
updating of environmental permission
economic standard
structure Optimizing spatial To reasonably determine NDRC, MIIT
layout development layout, structure
and scale

358
 Promoting exit of polluting MIIT
enterprises
Actively protecting MLR, MHURD
ecological space
Advancing cyclic To strengthen recycling use NDRC, MIIT
development of industrial water.
Promoting utilization of MHURD
reclaimed water
Promoting seawater NDRC
utilization
Focus on Controlling total To perform strictest MWR
water water consumption management of water
resources resources
saving and Strictly controlling MWR, MLR
conservatio groundwater overexploitation
n Increasing water To establish water use MWR
use efficiency efficiency assessment
systems, and include
fulfillment of water saving
targets into performance
evaluation for local
governments
Paying attention to industrial MIIT, MWR
water saving
Strengthening water saving in MHURD
cities and towns
Developing agricultural water MWR, MA
saving
Scientifically To perfect water resources MWR
conserving water conservation assessment
resources system
Strengthening water dispatch MWR
and management in rivers,
lakes and reservoirs
Scientifically measuring MWR
ecological flow
Strengtheni Disseminating and MST
ng of Sci- demonstrating
Tech appropriate
Support technologies
Making great MST
efforts to develop
prospective
technologies
359
 Striving to develop To regulate environmental NDRC
environmental industry market.
protection industry Speeding up environmental NDRC, MF
protection service industry
Give full Straightening out To speed up water price NDRC
play to the price taxes reform
function of Improving charge policies NDRC, MF
market Improving taxation policies MF, SAT
mechanism Promoting To guide the investment of PBC, NDRC, MF
diversified social capital
financing Increasing governmental MF
capital inputs
Setting up To improve a leading system NDRC
incentive of water conservation and
mechanism environmental protection
Implementing green credit PBC
Implementing trans-boundary MF
water environment
compensation
Tightening Improving To perfect laws and OLA
of regulation regulations
environmen standards Improving standard system MEP
tal law Strengthening law MEP
enforcement enforcement
and Enhancing To improve basin MEP
supervision supervision level coordination mechanism
Perfecting water environment MEP
monitoring network
Increasing environmental MEP
regulation capability
(grid administration)
Effective Strengthening To define targets of water MEP
Strengtheni management on quality protection of all kinds
ng of water environmental of water
environmen quality objectives body, and investigate whether
tal such targets are met
managemen Deepening control To improve pollutant MEP
t over total pollutant statistical monitoring system
emissions
Tightening To prevent environmental MEP
environmental risk risks
control

360
 Proper dealing with water MEP
pollution incidents
Fully implementing To issue pollutant discharge MEP
pollution discharge license in accordance with
permit laws
Strengthening license MEP
management
Full Guaranteeing safe To regulate drinking water MEP
Guarantee sources of drinking safety throughout the process
of Water water ranging from source of water
Ecological to faucet
Environmen Strengthening protection of MEP
t Safety drinking water source
environment
Preventing and controlling MEP
groundwater pollution
Deepening To formulate and implement MEP
pollution water pollution prevention
prevention and and control
control in key planning for seven major
basins basins
Strengthening protection of MEP
good water bodies
Enhancing To implement pollution MEP, SOA
environmental prevention and control plans
protection in for offshore areas
offshore areas Advancing ecologically MA
healthy aquaculture
Exercising strict control over MEP
environmental hormone
chemicals pollution
Treating black and MHURD
odorous water
bodies in cities
Protecting water To strengthen protection of MEP, SFA
and wetlands water ecology in rivers and
ecosystems lakes, and scientifically
designate ecological red lines
Protecting marine ecology MEP, SOA
Defining Strengthening MEP
and water environment
Fulfilling protection
the responsibility of
Responsibili local governments
361
ties of Each
Party

Strengthening MEP
coordination and
linkage
Fulfilling entity MEP
responsibilities of
pollutant
discharging units
Exercising strict MEP, MF
assessment of
targets and tasks
Strengtheni Making publish lists of the best and MEP
ng of Public environmental worst 10 cities nationwide
Participatio information public and water
n and Social according to the environment conditions in
Supervision law. provinces
provinces (autonomous MEP
regions and municipalities)
should regularly publish
water environment quality
status in cities (autonomous
prefectures and leagues) at
prefecture level within
respective administrative
regions
Strengthening MEP
social supervision
Forming a public MEP
participation
pattern
Note. ①The full name of the Departments are as follows: MEP：Ministry of
Environmental Protection; MHURD ： Ministry of Housing and Urban-Rural
Development; MA: Ministry of Agriculture; MWR: Ministry of Water Resources;
MT: Ministry of Transport; MIIT: Ministry of Industry and Information Technology;
NDRC: National Development and Reform Commission; MLR: Ministry of Land
and Resources; MST: Ministry of Science and Technology MF: Ministry of Finance;
SAT: State Administration of Taxation; PBC: People’s Bank of China; OLA: Office
of Legislative Affairs; SOA: State Oceanic Administration; SFA: State Forestry
Administration. ②The blank space indicates that there is only one aspect for both
the main measures and concrete actions.

362
 Appendix B
Table B1 Participants and Task Allocation in 2008 WPPC
No. Participants Task Allocation
1 Publicity Department of Guide public opinion
Guangzhou Party
Committee
2 Organization Department Establish the mechanism of examination and
of Guangzhou Party supervision
Committee
3 General Office of Coordinate all districts (county-level cities) and
Guangzhou Municipal relevant functional departments
Government
4 GZDRC Approval of project construction
5 Guangzhou Economic Organize and coordinate the promotion of cleaner
and Trade Commission production; Cooperate with the GZEPB to carry out the
(GZETC) rectification of enterprises' up to standard emissions
and shut down the enterprises that fail to meet the
standards.
6 Guangzhou Supervision Carry out administrative efficiency supervision
Bureau
7 Guangzhou Finance Be responsible for budget estimate review; Set up a
Bureau special water treatment fund account, allocate funds
regularly, and strictly supervise the use of funds
8 Guangzhou Land and Responsible for the approval of land use procedures for
Housing Bureau water pollution treatment and river regulation

9 Guangzhou Construction Be responsible for the overall planning and

Commission (GZCC) coordination of the project construction and coordinate
the land acquisition and demolition of each district
(county-level city); Take the lead in organizing the
joint review of the project scheme; Take the lead in
organizing the rainwater and sewage diversion and
transformation in the whole city.
10 GZWA Overall planning of water pollution treatment and river
regulation in the city
11 Guangzhou Agriculture Supervise the use of pesticides in agricultural
Bureau (GZAB) production and the discharge of livestock pollution
sources, and guide the implementation of rural
domestic sewage treatment projects.
12 Guangzhou Health Formulate the collection and treatment plan of hospital
Bureau domestic sewage and medical waste, and cooperate
with the GZEPB to conduct law enforcement
inspection.
13 GZEPB Responsible for the investigation of industrial pollution
sources in the whole city; Cooperate with the municipal
Legal Affairs Office to issue the Circular on
Prohibiting the Discharge of Sewage into Rivers; take
363
 the lead in organizing and strengthening the inspection
and supervision of pollution sources, and crack down
on illegal environmental behaviors
14 Guangzhou Planning Take the lead in organizing and implementing the site
Bureau selection of various facilities of the sewage treatment
system, and be responsible for the examination and
approval of the red line of land acquisition and
demolition for river regulation.
15 Guangzhou Landscape Responsible for the examination and approval of
Bureau municipal road excavation involved in sewage and
drainage engineering construction; Responsible for
laying sewage pipeline and rainwater pipeline
16 Guangzhou Appearance Responsible for water surface cleaning of Pearl River
and Environmental and urban rivers and creeks
Sanitation Bureau
17 Guangzhou Price Bureau Formulate a new charging method for domestic sewage
treatment in Guangzhou and appropriately increase the
charges for domestic sewage treatment
18 Guangzhou Industry and Responsible for the management of business
Commerce Bureau registration of pollutant discharge enterprises, and to
cooperate with the law enforcement work of inspection,
rectification and closure of pollutant discharge
enterprises in violation of regulations。
19 Guangzhou Urban Cooperate with GZEPB and GZWA to investigate and
Management Bureau deal with illegal construction projects
20 Guangzhou Highway Responsible for the coordination and approval of
Bureau highway excavation
21 Guangzhou Legal Affairs Responsible for organizing the formulation of
Office documents related to sewage treatment and river
training projects, and revising the Regulations on
Prevention and Control of Drinking Water Source
Pollution in Guangzhou. Put forward opinions on the
decentralization of administrative examination and
approval authority.
22 Guangzhou Public Cooperate with relevant departments to do a good job
Security Bureau in municipal road excavation approval, and be
responsible for timely review of relevant traffic relief
schemes
23 Guangzhou Demolition Formulate the compensation standard for demolition
Office according to the specific situation of each district
24 Guangzhou Water Undertake the financing task of municipal sewage
Investment Group Co., treatment and river comprehensive treatment;
Ltd (GZWIG) Responsible for the construction of municipal sewage
pipe network, sewage pumping station and sewage
treatment plant of sewage treatment project in central
urban area
Note. Work Plan on Water Pollution Control and River Comprehensive Treatment in
Guangzhou.

364
 Table B2 Guangzhou Action Plan for Water Pollution Prevention and Control

Ten Action Main Concrete Actions Leading

Plans Measures Department
Overall Control Pay special 1.To close down “ten categories GZEPB
of Pollutant attention to of small” enterprises.
Discharge prevention 2.Specially rectifying water GZEPB
and control of pollution in major industries
industrial 3.Carrying out cleaning GZIITC,
pollution rectification on paper-making, GZEPB
nonferrous metals, printing and
dyeing etc.
4.Treating water pollution in GZEPB
industrial agglomeration areas on
a centralized basis.
Strengthen 5.To improving the supporting GZWRB
control of pipe network of sewage
urban treatment plant
domestic 6.To accelerate construction and GZWRB
pollution alteration of urban sewage
treatment facilities
7.Promoting sludge treatment GZWRB
and disposal in urban sewage
treatment plant
8.Promoting the construction of GZUMC
landfill leachate treatment
facilities
Boost 9.To prevent and control GZAB,
prevention livestock and poultry farming GZEPB
and control of pollution
agricultural 10.Controlling agricultural non- GZAB
and rural point source pollution
pollution 11.Adjusting planting structure GZAB
and layout.
12.Accelerating comprehensive GZEPB
improvement of rural
environment.
Strengthen 13.To actively deal with ship GZMSB
control over pollution
ship and port 14.Enhancing ability to prevent GZPA
pollution and control port and terminal
pollution

365
Promotion of Adjust 15.To eliminate outdated GZIITC
transformation industrial industrial capacity according to
and updating of structure the law
economic 16.Making stricter GZEPB
structure environmental permission
standard
Optimize 17.To reasonably determine GZDRC,
spatial layout development layout, structure GZIITC
and scale
18.Actively protecting ecological
GZLRC,
space GZWRB,
GZHURDC
Develop 19.Strengthening the obligatory GZDRC,
green industry constraints of water saving and GZIITC
and cyclic emission reduction
economy 20.Promoting utilization of GZWRB
reclaimed water
Focus on water Control total 21.To perform strictest GZWRB
resources water management of water resources
saving and consumption 22.Strictly controlling GZWRB,
conservation groundwater overexploitation GZLRC
Increase 23.To establish water use GZWRB
water use efficiency assessment systems
efficiency 24.Paying attention to industrial GZWRB,
water saving GZIITC
25.Strengthening water saving in GZWRB
cities and towns
26.Developing agricultural water GZWRB,
saving GZAB
Scientifically 27.To perfect water resources GZWRB
conserve conservation assessment system
water 28.Strengthening water dispatch GZWRB
resources and management in rivers, lakes
and reservoirs
29.Scientifically measuring GZWRB
ecological flow
Strengthen Sci- Disseminate 30.To speed up the GZSTIC,
Tech Support and popularization and application of GZEPB
demonstrate technological achievements
appropriate 31.Strengthening the research of GZSTIC
technologies water pollution prevention and
and make control technology
great efforts
to develop
366
 prospective
technologies
Strive to 32.To regulate environmental GZDRC
develop industry market.
environmental 33.Speeding up environmental GZDRC
protection protection service industry
Give full play to Straighten out 34.To speed up water price GZDRC
the function of price taxes reform
market and promote 35.Improving charge policies GZDRC, GZFB,
mechanism diversified GZSAT,
financing GZLTA
36.To broaden investment and GZFSMB,
financing channels GZDRC
Set up 37.To improve a leading system GZDRC
incentive of water conservation and
mechanism environmental protection
38.Implementing green credit GZFSMB
Tighten Improve 39.To improve the legal system GZOLA
environmental regulation and working mechanism
law standards 40.Strictly implementing GZEPB
enforcement standards
and supervision Strengthen 41.All pollutant discharging units GZEPB
law must achieve environmentally
enforcement acceptable discharges according
to the law
42.To improve environmental GZEPB
supervision and law enforcement
mechanism
43.Cracking down GZEPB
environmental illegal behaviors
Enhance 44.To improve basin GZEPB
supervision coordination mechanism
level 45.Perfecting water environment GZEPB
monitoring network
46.Increasing environmental GZEPB
regulation capability
Effectively Strengthen 47.To make clear the water GZEPB
Strengthen management quality protection objectives
water on 48.To improve pollutant GZEPB
environmental environmental statistical monitoring system
management quality
objectives
49.To prevent environmental GZEPB
risks
367
 Tighten 50.Proper dealing with water GZEPB
environmental pollution incidents
risk control
Fully 51.To issue pollutant discharge GZEPB
implement license in accordance with laws
pollution 52.Strengthening license GZEPB
discharge management
permit
Full Guarantee Deepen 53.Deepening pollution GZEPB
of Water pollution prevention and control in key
Ecological prevention river basins
Environment and control in 54.Strengthening protection of GZEPB
Safety key basins good water bodies
Guaranteen 55.Strengthening the supervision GZEPB
safe sources of drinking water safety
of drinking 56.Overall planning and GZEPB
water optimization of the city's water
supply and drainage grid to build
a safe water supply system
57.Strengthening the protection GZWRB,
of drinking water source with the GZEPB
focus on Liuxi River Basin
58.Strengthening the risk control GZEPB
of drinking water source
59.Preventing and controlling GZEPB
groundwater pollution
Enhance 60.To implement pollution GZEPB, GZAB
environmental prevention and control plans for
protection in offshore areas
offshore areas 61.Advancing ecologically GZAB
healthy aquaculture
62.Exercising strict control over GZEPB
environmental hormone
chemicals pollution
Treat black 63.To formulate black and GZWRB
and odorous odorous water treatment plan
water bodies 64.Strengthening the treatment GZWRB
in cities of black and odorous water
Protect water 65.Strengthening the ecological GZFLB
and wetlands protection of river source and
ecosystems water conservation area
66.Promoting the protection of GZAB
aquatic organisms
67.Further strengthening wetland GZFLB
368
 protection
68.Strengthening the protection GZAB
of marine coastal ecology
Define and Strengthen 69.Strengthening the GZEPB
Fulfill the water responsibility of water
Responsibility environment environment protection in each
of Each Party protection district
responsibility 70.Strengthening the GZFB,
of local responsibility of government All district
governments capital investment governments
Fulfill entity 71.Strengthen the coordination GZWRB
responsibilitie and linkage of departments
s of 72.Strengthen the responsibility GZEPB
departments of water environment protection
and pollutant of pollutant discharge units
discharging
units
Exercise strict 73.Strict target and task GZEPB
assessment of assessment
targets and 74.Strengthening administrative GZEPB
tasks accountability
Strengthen Make 75.Regularly publishing the GZEPB
Public environmental water environment quality status
Participation information 76.Promoting enterprises to GZEPB
and Social public actively disclose environmental
Supervision according to information
the law.
Strengthen 77.Unblocking the channel of GZEPB
social social supervision
supervision 78.Strengthening water GZEPB,
conservation publicity and GZWRB, GZEB
education

369
 Table B3 Labor Division of Guangzhou Governmental Departments in
2016WPPC

Department No. of No. of

Projects Projects Main Task Assignment
Led Involved
GZEEB 34 32 ·Take the lead in the prevention and control
of industrial pollution; Rural water
environment protection; Make strict
environmental access; Strengthen law
enforcement; Implement discharge permits;
Strengthen responsibility assessment and
investigation; Disclose environmental
information according to the law; Smooth
social supervision channels etc. Tasks.
GZWA 22 33 ·Take the lead in the treatment of urban
domestic pollution; Actively protect the
ecological space; Promote the utilization of
reclaimed water; Control the total amount of
water consumption; Improve water use
efficiency; Scientific protection and
regulation of water resources; Ensure the
safety of drinking water sources; Renovate
the urban black and odorous water bodies;
Strengthen the coordination and linkage of
departments etc.
GZDRC 8 32 ·Take the lead in optimizing the spatial
layout; Developing green industry and
circular economy; Vigorously develop
environmental protection industry;
Rationalizing the price, tax and fee and
promoting multiple financing etc.
GZARAB 8 24 · Take the lead in agricultural and rural
pollution control; Accelerate the
development of agricultural water saving;
Promoting the protection of aquatic
organisms etc.
GZIITC 5 29 · Take the lead in eliminating backward
production capacity; Optimize the spatial
layout; Developing green industry and
circular economy
GZLPC 2 14 ·Take the lead in protecting the ecological
space actively; Strictly control over
exploitation of groundwater
370
GZSTB 2 6 · Take the lead in promoting and
demonstrating technology, research and
development of forward-looking technology
for water pollution prevention and control
GZFB 2 16 ·Take the lead in improving the charging
policy; Strengthen the responsibility of
government capital investment
GZFSB 2 0 ·Take the lead in broadening investment and
financing channels; Promote green credit
GZFLB 2 1 ·Take the lead in the ecological protection
of river source and water conservation area;
Further strengthen wetland protection
GZHURDC 1 32 · Take the lead to actively protect the
ecological space. Participate in
strengthening water pollution control in
industrial agglomeration area; Improve the
supporting pipe network of sewage
treatment plant and so on.
GZUMB 1 6 ·Lead the construction of landfill leachate
treatment facilities
· Participate in pollution prevention and
control of key river basins; Strengthen the
treatment of black and odorous water;
Strengthen the coordination and linkage of
departments; Make strict target and task
assessment and so on.
GZMSA 1 3 · Take the lead in the control of ship
pollution;
· Participate in strengthening the
management of pollutant discharge permit
GZPA 1 1 ·Take lead in enhancing the capacity of
pollution prevention and control at ports and
terminals
NTBGZ 1 0 ·Improving the charging policy
GZLTB 1 0 ·Improving the charging policy
GZGOLA 1 0 · Improve the legal system and working
mechanism
GZEB 1 0 ·Participate in water conservation publicity
and education
GZCB 0 1 ·Participate in strengthening water pollution
control in industrial agglomeration areas
GZWIG 0 7 · Participate in the improvement of the
pipelines of the sewage treatment plant;
Speed up the construction and conversions
371
 of urban sewage treatment facilities;
Promote sludge treatment in urban sewage
treatment plants; Strengthen the treatment of
black and odorous water etc.
GZQSB 0 5 ·Participate in the control of agricultural
non-point source pollution; Actively control
ship pollution; Industrial water saving;
Strengthen urban water saving; Strict
implementation of standards
GZTB 0 5 ·Participate in the active control of ship
pollution; Enhance the ability of pollution
prevention and control of ports and
terminals; Improve the legal system and
working mechanism etc.
GZHC 0 7 ·Participate in strengthening the research of
water pollution prevention and control
technology; Actively prevent water
environment risk; Strengthen the
supervision of drinking water safety etc.
GZPSB 0 4 · Participate in and strengthening law
enforcement; Improve the environmental
supervision and law enforcement
mechanism; Crack down on environmental
violations etc.
GZOEC 0 3 · Participate in and strengthening law
enforcement; Improve the environmental
supervision and law enforcement
mechanism; Improve the ability of
environmental supervision
GZSB 0 2 ·Participate in improving the environmental
supervision and law enforcement
mechanism; Strength accountability
GZSSB 0 1 · Participate in the prevention of water
environment risk
GZSASAC 0 1 · Participate in strengthening the
responsibility of water environment
protection of pollutant discharge units
Note. Adapted from Guangzhou Government (2016).

372
 Table B4 13 Annexes of GZAPWPPC
No. Name of Appendixes Main Contents Deadline
1 List of water quality Region, water body name, section name, water 2017
target of river basin quality status and water quality objectives of
the river basin
2 List of urban Water source name, type, service population, 2017
centralized drinking water quality status and water quality
water sources objectives
3 List of groundwater Points name, region, water quality 2017
monitoring points and comprehensive evaluation in 2013 and water
water quality quality objectives
objectives
4 Water quality target Station number, longitude, latitude and 2017
list of monitoring contents of various chemicals
stations in offshore
waters
5 List of important Reservoir name, region, storage capacity and 2017
reservoirs rainwater collection area
6 List of main water Water supply channel/drainage channel, river Jun.2016
supply and drainage section, buffer zone
channels and buffer
zones
7 2015-2017 Region, name of sewage treatment plant, 2017
construction plan for newly added treatment scale, newly added
domestic sewage pipe network length, starting and ending years
treatment facilities of construction
8 2015-2017 Region, name of the project, scale of leachate 2017
construction plan for treatment facilities, starting and ending years
landfill leachate of construction
treatment facilities
9 List of enterprises Region, name and address of the unit, time for 2016-
unfinished “leaving the enterprise to apply for closure and 2018
the secondary industry relocation
and entering the
tertiary industry
(tui’er jinsan)”
10 2015-2017 Region, project name, river length, 2016-
construction plan for construction plan and implementation period 2017
comprehensive
treatment of main
rivers and creeks
11 Summary of cleaning Enterprise name, location, remediation 2016-
transformation requirements, remediation period 2017
projects in some key
373
 industries
12 Checklist of major Name, location, main industry, approval unit, End of
industrial clusters regulation requirements and time limit of the 2016
gathering area
Special treatment (clean transformation) End of
scheme for key industries 2016
Urban sewage treatment facilities construction End of
and transformation plan 2016
Comprehensive prevention and control of Jun.2016
agricultural non-point source pollution and
clean-up of livestock and poultry breeding in
forbidden and restricted areas
Pollution prevention and control plan for port Dec. 2016
terminals and loading and unloading stations
Annual plan for elimination of backward Jan. of
Key plans for special production capacity every
13
programs year
Water scheduling scheme based on ecological 2017
flow guarantee
Water environment quality standard program Jun.2016
Emergency plan for water pollution accident 2016
disposal
Good water ecological environment 2017
protection plan
Treatment scheme of black and odorous water Jun. 2016
body in urban built-up area
Special scheme for river cleaning in Jun. 2016
Guangzhou
Note. Guangzhou Government (2016).

374
 Table B5 Formal Transposition in Water Pollution Prevention and Control of
Guangzhou
Main Documents Documents Issued from Documents Issued
Measures Issued before May 2016 to Dec. 2017 after 2018
May 2016

Pay special -Appe.13-5Annual -Action plan for

attention to elimination plan of strengthening the
prevention and backward production cleaning and
control of capacity rectification of
industrial -Notice on cleaning up and “scattered and
pollution rectifying “scattered and polluted” places in
polluted” places in key Guangzhou
river basins
-Appe.11Summary of
cleaning transformation
projects in some key
industries
-Appe.13-1Special
treatment (clean
transformation) scheme for
key industries
-Implementation plan of
green and clean production
in Guangzhou during the
13th FYP
-Appe.12 Checklist of
major industrial clusters

Strengthen -Notice on -Appe.6 List of main water -Three years action

control of speeding up the supply and drainage plan for improving
urban domestic upgrading and channels and buffer zones quality and efficiency
pollution reconstruction of -Appe.10 Construction of urban sewage
urban sewage plan for comprehensive treatment in
treatment plants treatment of main rivers Guangzhou 2019-
-Notice of the and creeks 2015-2017 2021
sludge drying and -Appe.7 Construction plan
reduction work of main domestic sewage
plan in treatment facilities 2015-
Guangzhou 2017
municipal sewage -Appe.8 Construction plan
treatment plant of main landfill leachate
treatment facilities 2015-
2017

375
Boost -Work plan of -Appe.13-3
prevention and implementing Comprehensive prevention
control of rural and control of agricultural
agricultural and environmental non-point source pollution
rural pollution protection action and clean-up of livestock
plan in and poultry breeding in
Guangzhou2015- forbidden and restricted
2017 areas
Strengthen -Emergency plan for the
control over accident of ships polluting
ship and port water area in Guangzhou
pollution -Appe.13-4 Pollution
prevention and control
plan for port terminals and
loading and unloading
stations
Adjust -Guidance on the -Appe.13-5 Annual
industrial implementation of elimination plan of
structure differentiated backward production
environmental capacity
protection access
in Guangdong
Province to
promote regional
coordinated
development
Optimize -Guangzhou -Appe.9 List of enterprises
spatial layout manufacturing unfinished “leaving the
2025 strategic secondary industry and
plan entering the tertiary
industry”
Developing -Water saving plan of
green industry Guangzhou（2018-
and cyclic 2035）
economy

376
Control total -Water -The strictest water -Guangzhou
water consumption resources management implements the most
consumption quota of system in Guangzhou strict assessment
Guangdong 2016-2020 method of water
Province resources management
(DB44/T1461） system
-Water saving plan of
Guangzhou (2018-
2035)
-Incentive measures
for water saving in
Guangzhou (Trial)
-Work plan for
groundwater pollution
prevention and control
in Guangzhou
Increase water -Water saving plan of
use efficiency Guangzhou (2018-
2035)
Scientifically -Water saving plan of
conserve water Guangzhou (2018-
resources 2035)

Disseminate -Notice on Guangzhou

appropriate water pollution
technologies prevention and control
and make great technology
efforts to achievements
develop catalogue (the first
prospective batch)
technologies
Strive to -Implementation plan of -Guangzhou
develop pilot project of promoting implementation plan
environmental cooperation between for promoting the
protection government and social development of key
capital in Guangzhou areas of
environmental
protection industry
(2020-2022)
Straighten out -Notice on the adjustment
price taxes of sewage treatment fee
and promote standard and supporting
diversified policies in central urban
financing area

377
Set up
incentive
mechanism
Improve -Discharge limits -Regulations on
regulation of water pollutants prevention and control
standards in Guangdong of drinking water
Province source pollution in
Guangzhou (revised in
2018)
Strengthen law
enforcement
Enhance -Monitoring work
supervision plan of
level Guangzhou
Nanyue water
purification and
refinement
Strengthening -Appe.1 River Basin water
management on quality target list
environmental -Appe.2 List of urban
quality centralized drinking water
objectives sources
-Appe.3 List of
groundwater monitoring
points and water quality
objectives
-Appe.4 Water quality
target list of monitoring
stations in coastal waters
-Appe.5 List of important
reservoirs
Tightening -Emergency plan for
environmental the treatment of water
risk control pollution accidents in
Guangzhou
Fully -Guangzhou emission
implementing permit approval
pollution technical audit work
discharge guideline (2020
permit Edition)
Deepening -Regulations of -Guangzhou's work plan
pollution Guangzhou on the for the implementation of
prevention and protection of Liuxi “action plan for clearer
River Basin water in southern

378
control in key -Scheme for Guangdong” (2017-2020)
basins comprehensive -Water environment
improvement of quality standard plan of
water environment Guangzhou City
in Liuxi River -The protection plan of
Basin good water ecological
environment in Guangzhou
Guaranteeing -Regulations of -Optimal design of water -Regulations of
safe sources of Guangzhou on supply and drainage Guangzhou on water
drinking water prevention and system in Guangzhou supply and
control of drinking consumption
water source -Work plan of
pollution groundwater pollution
-Construction prevention and control
scheme of Liuxi in Guangzhou
River and other -Regulations on
Guangzhou- prevention and control
Foshan cross of drinking water
source pollution in
boundary river
Guangzhou (revised in
regulation projects 2018)

Enhancing Action plan of coastal

environmental pollution control in
protection in Guangdong Province
offshore areas 2018 - 2020
Treating black -Work plan of joint law -Implementation plan
and odorous enforcement special action of urban black and
water bodies in to eliminate pollution odorous water
cities sources of black and treatment in
odorous water in Guangzhou
Guangzhou -Action plan for
strengthening the
cleaning and
remediation of
"scattered and
polluted" places in
Guangzhou
Protecting -Guangzhou wetland
water and protection regulation
wetlands
ecosystems

379
Strengthen -Work plan of water
water pollution prevention and
environment control in various districts
protection of Guangzhou.
responsibility Implementation plan of
of local river chief system in
governments Guangzhou
Fulfill entity
responsibilities
of departments
and pollutant
discharging
units
Exercise strict -Opinions on -Guangzhou
assessment of accountability of water assessment method of
targets and environment treatment drainage unit reaching
tasks the standard (Trial)
-Assessment methods
for the
implementation of the
system of river chief
and lake chief in
Guangzhou
Make
environmental
information
public
according to
the law.
Strengthen -Measures of Guangzhou -Measures of
social Municipality on rewarding Guangzhou
supervision and reporting illegal Municipality on
drainage activities (2017) rewarding and
reporting illegal
drainage activities
(2020)
Strengthen -Emergency plan for the
control over accident of ships polluting
ship and port water area in Guangzhou
pollution -Appe.13-4 Pollution
prevention and control
plan for port terminals and
loading and unloading
stations

380
Adjust -Guidance on the -Appe.13-5 Annual
industrial implementation of elimination plan of
structure differentiated backward production
environmental capacity
protection access
in Guangdong
Province to
promote regional
coordinated
development
Optimize -Guangzhou -Appe.9 List of enterprises
spatial layout manufacturing unfinished “leaving the
2025 strategic secondary industry and
plan entering the tertiary
industry”
Developing -Water saving plan of
green industry Guangzhou（2018-
and cyclic 2035）
economy
Control total -Water -The strictest water -Guangzhou
water consumption resources management implements the most
consumption quota of system in Guangzhou strict assessment
Guangdong 2016-2020 method of water
Province resources management
(DB44/T1461) system
-Water saving plan of
Guangzhou (2018-
2035)
-Incentive measures
for water saving in
Guangzhou (Trial)
-Work plan for
groundwater pollution
prevention and control
in Guangzhou
Increase water -Water saving plan of
use efficiency Guangzhou (2018-
2035)
Scientifically -Water saving plan of
conserve water Guangzhou (2018-
resources 2035)

381
Disseminate -Notice on Guangzhou
appropriate water pollution
technologies prevention and control
and make great technology
efforts to achievements
develop catalogue (the first
prospective batch)
technologies
Strive to -Implementation plan of -Guangzhou
develop pilot project of promoting implementation plan
environmental cooperation between for promoting the
protection government and social development of key
capital in Guangzhou areas of
environmental
protection industry
(2020-2022)
Straighten out -Notice on the adjustment
price taxes of sewage treatment fee
and promote standard and supporting
diversified policies in central urban
financing area
Set up
incentive
mechanism
Improve -Discharge limits -Regulations on
regulation of water pollutants prevention and control
standards in Guangdong of drinking water
Province source pollution in
Guangzhou (revised in
2018)
Strengthen law
enforcement

Enhance -Monitoring work

supervision plan of
level Guangzhou
Nanyue water
purification and
refinement
Strengthening -Appe.1 River Basin water
management on quality target list
environmental -Appe.2 List of urban
quality centralized drinking water
objectives sources
382
 -Appe.3 List of
groundwater monitoring
points and water quality
objectives
-Appe.4 Water quality
target list of monitoring
stations in coastal waters
-Appe.5 List of important
reservoirs
Tightening -Emergency plan for
environmental the treatment of water
risk control pollution accidents in
Guangzhou
Fully -Guangzhou emission
implementing permit approval
pollution technical audit work
discharge guideline (2020
permit Edition)
Deepening -Regulations of -Guangzhou's work plan
pollution Guangzhou on the for the implementation of
prevention and protection of Liuxi “action plan for clearer
control in key River Basin water in southern
basins -Scheme for Guangdong” (2017-2020)
comprehensive -Water environment
improvement of quality standard plan of
water environment Guangzhou City
in Liuxi River -The protection plan of
Basin good water ecological
environment in
Guangzhou
Guaranteeing -Regulations of -Optimal design of water -Regulations of
safe sources of Guangzhou on supply and drainage Guangzhou on water
drinking water prevention and system in Guangzhou supply and
control of drinking consumption
water source -Work plan of
pollution groundwater pollution
-Construction prevention and control
scheme of Liuxihe in Guangzhou
River and other -Regulations on
Guangzhou- prevention and control
Foshan cross of drinking water
source pollution in
boundary river
Guangzhou (revised in
regulation projects 2018)

383
Enhancing Action plan of coastal
environmental pollution control in
protection in Guangdong Province
offshore areas 2018 - 2020
Treating black -Work plan of joint law -Implementation plan
and odorous enforcement special action of urban black and
water bodies in to eliminate pollution odorous water
cities sources of black and treatment in
odorous water in Guangzhou
Guangzhou -Action plan for
strengthening the
cleaning and
remediation of
"scattered and
polluted" places in
Guangzhou
Protecting -Guangzhou wetland
water and protection regulation
wetlands
ecosystems
Strengthen -Work plan of water
water pollution prevention and
environment control in various districts
protection of Guangzhou.
responsibility -Implementation plan of
of local river chief system in
governments Guangzhou
Fulfill entity
responsibilities
of departments
and pollutant
discharging
units
Exercise strict -Opinions on
assessment of accountability of water
targets and environment treatment
tasks
Make
environmental
information
public
according to
the law.

384
Strengthen -Measures of Guangzhou -Measures of
social Municipality on rewarding Guangzhou
supervision and reporting illegal Municipality on
drainage activities (2017)rewarding and
reporting illegal
drainage activities
(2020)
Note. Compiled based on documents issued by the Guangzhou Government and its
subordinate departments from 2014 to 2020.

385
 ProQuest Number: 30686741

INFORMATION TO ALL USERS

The quality and completeness of this reproduction is dependent on the quality
and completeness of the copy made available to ProQuest.

Distributed by ProQuest LLC ( 2023 ).

Copyright of the Dissertation is held by the Author unless otherwise noted.

This work may be used in accordance with the terms of the Creative Commons license
or other rights statement, as indicated in the copyright statement or in the metadata
associated with this work. Unless otherwise specified in the copyright statement
or the metadata, all rights are reserved by the copyright holder.

This work is protected against unauthorized copying under Title 17,

United States Code and other applicable copyright laws.

Microform Edition where available © ProQuest LLC. No reproduction or digitization

of the Microform Edition is authorized without permission of ProQuest LLC.

ProQuest LLC
789 East Eisenhower Parkway
P.O. Box 1346
Ann Arbor, MI 48106 - 1346 USA