Progress and Retreat for Environmental Transparency in China: Announcing the 2009-10 Pollution Information Transparency Index (PITI) Results

Environmental transparency in China showed both progress and retreat over the past year, and many implementation challenges still remain.

This was one of the overall findings of the second annual Pollution Information Transparency Index (PITI), which the Institute of Public & Environmental Affairs (IPE) and NRDC launched in Beijing earlier this week. PITI is an assessment and ranking of environmental transparency in 113 cities commenced by IPE and NRDC in 2009.
This year’s PITI launch included for the first time participation from local Chinese environmental officials. Representatives from Ningbo (the top ranked city in the PITI ranking), Chongqing (the top ranked city from western China), and Huangshi, Hubei Province spoke at the launch about the practical challenges of complying with China’s information disclosure rules. This level of open engagement between Chinese government officials and environmental non-governmental organizations (NGOs) is a positive sign for the development of greater transparency in China in the years to come.

Mr. Tang Yuanpeng of the Huangshi environmental protection bureau raised the benefits of such exchange explicitly in discussing an IPE- and NRDC-sponsored meeting in May 2010 where more than 50 Chinese government officials met with NGOs and academics to discuss the first PITI results: “I was very inspired, especially by the idea that environmental open information is a way to increase public right to know, and reconcile differences between the public, enterprises, and the government. This gave us much impetus to improve, so after we returned to Huangshi we renovated our existing environmental protection website to strengthen its ability to disclose information and its user friendliness.”

2009-10 PITI Results:

The Chinese version of the second PITI report is available now, and we plan to release an English version of the report in January. Stay tuned. In the meantime, here are a number of the key findings from this year’s report:

• Although average information disclosure performance remained low, the overall level of  environmental transparency in China improved.

This year’s PITI evaluation found that overall environmental information disclosure performance remained low, with an average score of 36 out of 100 possible points for all 113 cities evaluated.[1] Nonetheless, the average score increased by five points. Eighty-two cities (73 percent) received a higher score than last year.

• Improved performance of the “All-Star” team shows that good information disclosure is possible in China right now.

By combining the top-scoring city in each of the eight evaluated information disclosure categories, we created a hypothetical team of “All-Star” cities for information disclosure. The All-Star team scored 89.5 out of 100 points last year, showing that in each category of information disclosure China already had cities performing relatively well. This year, the All-Star team’s overall score increased by 5.8 points to 95.3, which is close to the maximum points possible under PITI. Once again, this highlights the fact that Chinese cities are already capable of good government information disclosure. The data proves wrong those cities that claim China’s current level of development does not provide the resources or capacity to implement good environmental transparency.

A few other findings of note:

• Response to public information requests improved modestly, with 49 of 113 cities responding to information requests this year, compared to 44 in the 2008 PITI evaluation.
• Progress on transparency was uneven and regional disparities have widened. The most progress was seen in eastern and southern coastal regions, which widened the gap with the central and western cities.
• In the run-up to the hosting of major events, a number of cities improved their environmental transparency. This included Beijing (2008 Summer Olympics), Jinan in Shandong Province (2009 National Games), Shanghai (2010 World Expo), and Guangzhou (2010 Asian Games). In Beijing, these practices were not sustained after the Olympics. Whether these practices will be maintained in these other cities remains to be seen.
• Many provincial capitals performed poorly in absolute terms and relative to other cities within their provinces. This is a surprising result given the superior financial, policy, and human resources typically found in Chinese capital cities. Five capital cities scored in the 20 point range. Eleven capital cities were not the top performers in their province, and a few capitals (such as Hangzhou and Shijiazhuang) performed quite poorly in their provinces.

The complete PITI report contains a great deal more analysis of trends and comparisons among regions, cities, and provinces. The Chinese version of the report can be found here.

An Annual Review of China’s Environmental Transparency:

This year’s PITI report also includes a new feature – a review of general developments in Chinese environmental transparency over the last year. Overall environmental transparency in China, like with the 113 cities in our PITI evaluation, showed both progress and retreat. A few specific points:

China’s Ministry of Environmental Protection (MEP) began to disclose substantial documents for environmental inspections related to company refinancing. In October 2010, MEP disclosed a more than 300-page document with information about more than 100 Sinopec subsidiaries. The document contained emissions data for certain pollutants from 2007 to 2009 and a range of other environmental information. Since October 2010, MEP has released similar documents in connection with 14 other company refinancings. We hope to see this sort of disclosure for a much broader range of companies in the future. Various ministries also began to disclose information related to enterprise energy efficiency performance. In May 2010, the National Development and Reform Commission (NDRC) provided disclosure related to the performance of China’s “Top-1,000” energy-consuming enterprises against allocated energy intensity reduction targets. In June 2010, the Ministry of Industry and Information Technology (MIIT) disclosed a list of 2,087 industrial facilities from 18 industries with technology required to be taken out of operation. For the MIIT disclosure, media reports quickly pointed out that a number of the pieces of equipment listed did not exist or had been taken out of operation long ago. We view this as a reason for continued disclosure, since public scrutiny of this sort of government information will tend to make it more accurate and reliable in the future.

The disclosure of environmental information in China still faces inordinate challenges. The July 2010 Zijin Mining Group chemical spill was a prime example. The accident killed nearly 2000 tons of fish, and Zijin’s nine-day delay in reporting the accident was a stark reminder of the inadequacy of public company information disclosure and public awareness of environmental risks. A variety of stakeholders, including NGOs, stock exchanges and environmental officials, proposed technical measures to address this problem, but the larger question is whether the Zijin incident will be China’s “Minamata moment” and lead to transformative changes in disclosure of the hidden environmental risks lurking behind companies like Zijin. To date, we have not yet seen serious proposals for this sort of game-changing action.

We have seen a number of cases of citizens having difficulty in obtaining environmental information through government information requests. Southern Weekend (a leading Chinese newspaper), a Friends of Nature-affiliated group, Greenpeace and others all publicized difficulties in obtaining environmental information through public information requests. This is consistent with the findings of our PITI evaluation. Moreover, anecdotal evidence suggests that appeals to the courts regarding information request denials have faced some difficulty as well. Lack of standing to request information has been the grounds in several cases. Details of several cases are discussed in this year’s PITI report. How government agencies and courts handle these open information disclosure matters in the coming few years will have a major impact on level of public trust in China’s open government information system.

Most importantly, disclosure of information regarding factory-level pollutant releases is still fairly limited in China. Chinese environmental regulations only require disclosure of such emissions/discharge data for a limited number of black-listed companies, and in practice it has been difficult to get even these companies to disclose the amount of pollution they release into the environment. It is well-known in China and abroad that open disclosure of enterprise pollutant release data is critical to effective environmental management. Such disclosure has been shown time and again in countries around the world to reduce pollution by motivating companies, enhancing public monitoring and supervision, and strengthening the government’s ability to prioritize and target enforcement efforts.
General public disclosure of enterprise-level pollutant release data, such as through the creation of a pollutant release and transfer register (i.e., a pollutant release database), is a natural next step for China.
The environmental official from Chongqing who spoke at the PITI launch this week noted that a great deal of useful environmental information is gathered under China’s clean production audit rules and other Chinese legal requirements, so it would not be technically difficult to take the next step to disclose this information to the public. Such an effort would go a long way in helping to strengthen environmental management and reduce pollution in China.

Media Coverage of the PITI Launch:

CCTV China News Program 《中国新闻栏目》 (PITI coverage from 9:51 to 11:02)

Ningbo tops pollution transparency list (Global Times环球时报英文版)

Cities stay tightlipped over pollution data – South China Morning Post香港南华早报 [behind pay wall]

A ranking of environmental open information in 113 Chinese cities: Beijing fails to pass（中国113城市环境信息公开排名:北京不及格）- China Daily中国日报 (Chinese)

Only ten percent of cities receive a passing grade for pollution information disclosure（污染源信息公开水平及格城市仅1成）- Caijing财经 (Chinese)

Environmental open information – between progress and retreat（环境信息公开 进退之间）-  China.com.cn 中国网 (Chinese)

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[1] Under the PITI framework, slightly more than 60 points represent information disclosure obligations under the law and nearly 40 points represent actions that are encouraged by Chinese policy or otherwise improve public user convenience.  A score in excess of 60 points is deemed a “passing” grade under PITI.