VZCZCXRO7622
RR RUEHCN RUEHGH RUEHVC
DE RUEHGZ #0701/01 1682358
ZNR UUUUU ZZH
R 172358Z JUN 07
FM AMCONSUL GUANGZHOU
TO RUEHC/SECSTATE WASHDC 6180
INFO RUEHOO/CHINA POSTS COLLECTIVE
RUEAEPA/HQ EPA WASHDC
RUEAIIA/CIA WASHDC
RUEKJCS/DIA WASHDC
RHHMUNA/HQ USPACOM HONOLULU HI

UNCLAS SECTION 01 OF 02 GUANGZHOU 000701 
 
SIPDIS 
 
SIPDIS 
 
EPA FOR INTERNATIONAL 
STATE FOR EAP/CM AND OES 
USPACOM FOR FPA 
 
E.O. 12958: N/A 
TAGS: SENV PGOV CH
SUBJECT: South China EPB Structural Deficiencies Hurt Enforcement 
 
¶1. (U) Environmental accidents and major polluting discharges occur 
with all too frequent regularity in south China, the result of a 
failure to enforce existing regulations and to punish those who 
profit by ignoring public health and welfare.  Even with increased 
media attention and campaigns by authorities to demonstrate that 
their commitment to enforcement is genuine, the real underlying 
problem is the lack of an environmental framework and 
infrastructure.  There are four clear cut challenges that EPA 
Science fellow and Congen S and T officer believe China needs to 
address in order to deal with its overarching problems 
 
Challenges to Creating Advanced Environmental 
Framework and Infrastructure in China 
--------------------------------------------- 
 
¶2.  (U) First, detailed environmental permits are needed to build a 
fair and transparent compliance and enforcement program. 
Environmental permits must be clear and enforceable.  Permits should 
be specific for each discharger.  Such permits should contain daily 
and longer term (weekly or monthly) limits for all pollutants of 
concern as well as specify monitoring requirements, including 
specific sampling and analytical procedures.  They should also 
include reporting requirements.  Permits can be an effective tool to 
ensure that facilities develop accident prevention programs and 
spill response plans.  Permits issued today vary greatly within a 
single Environmental Protection Bureau (EPB).  Companies need to 
know exactly what they have to do, and compliance and enforcement 
has to be fair and transparent. 
 
¶3.  (U) Second, inspections need to be effective; and environmental 
monitoring needs to be properly conducted and reported.  Inspectors 
should first review existing permits and submitted reports.  They 
should be trained to observe good practices in the plants and should 
be taught to identify areas of concern.  Inspectors should be able 
to advise facilities -- after looking at both the production process 
and the treatment plant -- about good housekeeping techniques and 
sound management practices.  Follow-up measures also have to be 
factored into all planning. 
 
¶4. (U) Moreover, specific locations should be identified along with 
sampling protocols.  All data should be reported to the 
environmental authority, not just the samples that show compliance. 
Facility inspections should also include visits to the sampling 
locations and laboratory.  Instruments and lab notebooks should be 
checked, and concerns should be addressed by the discharger. 
 
¶5.  (U) Third, new factories as well as existing factories that are 
expanding their operations need to be encouraged to use cleaner 
production equipment.  Cleaner production - using production methods 
and equipment that efficiently convert resources to products, 
prevent pollution, minimize waste, and reduce energy usage - should 
be encouraged, especially when new factories are designed, 
constructed, and during expansions at existing plants.  Pollution 
prevented or reduced at the source offers important economic 
benefits. 
 
¶6.  (U) More attention needs to be given to controlling thousands of 
small and medium size businesses that discharge heavy metals, 
organic solvents, oils, and other pollutants to municipal sewage 
treatment facilities. 
 
¶7.  (U) Finally, Municipal sewage agencies in south China are 
responsible for operating treatment plants, but they have no control 
over industries that discharge into sewer systems.  The EPBs are 
responsible for controlling indirect dischargers.  But they have 
many other duties and such indirect discharging is a lower overall 
priority compared to factories discharging directly into rivers. 
EPBs need special resources dedicated to inspecting and controlling 
the thousands of indirect dischargers.  Another possibility would be 
to delegate these responsibilities to the municipal sewage agencies 
where user charges and fees could finance inspections, monitoring, 
and proper control of indirect discharging industries. 
 
The Way Forward 
--------------- 
 
¶8. (U) Strengthening environmental permits, increasing inspections, 
monitoring the building blocks that go into each program, promoting 
cleaner production, and controlling indirect industrial dischargers 
into municipal sewage systems will help the Chinese State 
Environmental Protection Administration (SEPA) and EPBs develop and 
implement a strong compliance and enforcement program.  When 
everyone knows what the requirements are, and a real environmental 
and compliance framework is in place to enforce the requirements, 
China will be better able to stop wastewater discharges and the 
 
GUANGZHOU 00000701  002 OF 002 
 
 
pollution of the streams and rivers of the Pearl River Delta. 
 
GOLDBERG