Closing Longstanding Gaps - · Closing Longstanding Gaps 2016-2017 Pollution Information Transparency Index (PITI) 4 The comprehensive national investigation and targeted inspections

12016-2017 Pollution Information Transparency Index (PITI)

Institute of Public & Environmental Affairs (IPE) Natural Resources Defense Council (NRDC)

Closing Longstanding Gaps2016-2017 Pollution Information Transparency Index (PITI)

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Authors:Institute of Public & Environmental Affairs (IPE): Ma Jun, Guo Ye, Ying Shan, Ren Yili, Wei Feng, Ruan Qingyuan, Chen Yiting, Zhang Yi, Si Wenjun, Chen Qifeng, Lv Xinghua, Tan Bowen, Wang Mingxuan Natural Resources Defense Council (NRDC): Wang Yan, Wu Qi, Zhang Xiya, Gao Yuhe, Erin Wong, Brian Bartholomew

Nanjing Green Stone: Fang Yingjun, Li Jia, Chao Bo

Colleagues from Green Anhui, Shandong Green Qilu, Green Home of Fujian, Nanjing Green Stone, Green Jiangxi, Green Taihang, and Hubei Xingchejingchu contributed to the to the assessment of their provinces. Nanjing University conducted analyses on 25 cities

English Translation: Erin Wong, Brian Bartholomew, Gao Yuhe, and Wu Qi

IPE and NRDC would like to thank the following experts for their advice, assessment and guidance in the production of this report: Wang Hua, Wang Canfa, Wang Xixin, Yang Pingjian, Zhang Lixin, Yang Sujuan, Shan Guangnai, Zhu Xiao, Zhao Zheng, Guo Hong Yan, Jia Feng, Yuan Qingdan, Geng Ziwei and Zeng Hongying IPE and NRDC would also like to thank the following partners and volunteers for their support and assistance in the production of this report: Li Jintao, Cao Qin, Cong Yadi, Wu Wei, Li Zhongsheng, Li Qingwei, Xie Mengxi and Yu Yinghan

Institute of Public and Environmental Affairs (IPE)

The Institute of Public & Environmental Affairs (IPE) is a registered non-profit environmental research organization based in Beijing. Since its establishment in May 2006, IPE has developed the Blue Map Database (www.ipe.org.cn), as well as the Blue Map app, the first Chinese environmental mobile app to track real-time pollution data, which went live in June 2014. IPE works to promote environmental information disclosure, public participation, and sound environmental governance strategies.

Natural Resources Defense Council (NRDC)

The Natural Resources Defense Council (NRDC) is an international nonprofit environmental organization with more than 2 million members and supporters. Since 1970, our lawyers, scientists, and other environmental specialists have worked to protect the world's natural resources, public health, and the environment. NRDC works in countries and regions including the United States, China, India, Canada, Mexico, Chile, Costa Rica, and the European Union.


It is a momentous time for environmental enforcement and transparency in China.

The central government’s environmental protection inspections, which began in Hebei in January

2016, have now extended to 31 provincial-level administrative zones. These inspections are holding local

government and party officials accountable for misconduct and inefficiency. The high-profile release of

inspection results for each province—and the severity of the tools and language used to deliver admonitions

—have undercut the status quo of caution, inaction and red tape.

These inspections are revealing the reasons why some places have long failed to make progress in

controlling pollution and disclosing environmental information.

In Tianjin, which consistently ranks low in PITI evaluations, these inspections found forged documents

pertaining to water pollution control. They also found that officials curtailed traffic around air monitoring

stations and inflated the actual number of water clean-up operations. Shanxi, home to cities such as Linfen

that have failed to adequately disclose environmental information, received the harshest appraisal. The

inspections cited Shanxi for loosening pollution control requirements, ignoring the public’s environmental

demands, being slow to act, and ultimately contributing to severe environmental degradation. With such

local governance, how can environmental enforcement overcome issues of protectionism, and how can

transparency improve?

By reviewing numerous documents, conducting on-site inspections, and analyzing tens of thousands of

public comments and complaints, the inspections have uncovered hidden problems that have persisted under

previous, less rigorous regulations. In light of these findings, the inspections have pushed local officials to

monitor and correct problems within their jurisdictions. Inquiries spanning the past three years uncovered and

publicized 620,000 historical violations, exposing longstanding issues to the public at last.

In addition to the nationwide inspections, the Ministry of Environmental Protection (MEP) also initiated

targeted special investigations. The MEP called upon 5,600 environmental inspectors to launch a one-year

special investigation into air pollution in the Beijing-Tianjin-Hebei region. Through daily disclosure on MEP’s

official Weibo account, the MEP keeps the public informed on the necessity of combating industrial pollution

and the challenges at hand.

Foreword: From concentrated clean-up to long-term governance

Closing Longstanding Gaps2016-2017 Pollution Information Transparency Index (PITI)

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The comprehensive national investigation and targeted inspections have exposed 620,000 illegal

construction projects. This concentrated clean-up has significantly increased the extent of supervision

information available to the public. As a result, for the first time in the PITI’s eight-year history, an extra point

has been added to the evaluation to reflect this disclosure, which is added to each city’s score in addition to

points earned based on the normal benchmarks.

These additional points were added outside of the PITI’s usual framework because of the singular nature

of this campaign. The scope of resources mobilized to carry out such an investigation prohibits annual or

continuous inspections, and once the investigation is finished, recent improvements may fade quickly.

Recent reforms to the Environmental Protection Law and the Air Pollution Prevention and Control Law

(often referred to as the “Air Law”) provide new tools with which to promote environmental information

transparency. The Measures for the Disclosure of Environmental Information by Enterprises and Public

Institutions, released by the MEP to work in tandem with the new Environmental Protection Law, require that

cities disclose directories of key pollution-discharging entities. The Air Law mandates that air polluters in these

directories must install automatic monitoring systems and publicly disclose their readings in real-time.

While elaborating on smog control in this year’s government work report, Chinese Premier Li Keqiang

emphasized the importance of improving regulation of pollution sources. He stated that China should

“implement round-the-clock online monitoring for key industrial polluters. It should establish clear deadlines

for companies to comply with regulations, and force closures at companies that fail to meet regulatory

requirements on time.” This strategy emphasizes the use of technological advancements to protect

the environment. Although key enterprises for pollution monitoring may receive protection from local

governments, requiring these companies to accept round-the-clock monitoring—and requiring the results to

be publicly disclosed in real-time—will ensure that environmental protection is enforced and that polluters are

held accountable.

The MEP’s inspections have galvanized administrative resources and the authority of the central

government, and have proven invaluable in pollution control. Faced with numerous pollution sources, the

inspections and the centralized clean-up actions should seek to systematize enforcement rather than dealing

with problems on a case-by-case basis. China should strictly enforce mandated environmental information

transparency regulations, and punish companies that fail to comply. These efforts—ensuring that every

smokestack is open to the public eye, along with the help of public supervision—will lay the necessary

foundation for effective, long-term, and sustainable environmental governance.


On May 1, 2008, the Measures for Environmental Information Disclosure (Trial) went into effect. That

year, the Institute of Public & Environmental Affairs (IPE) and the Natural Resources Defense Council (NRDC)

jointly developed the Pollution Information Transparency Index (PITI) to establish a baseline for the first

year of China’s environmental information disclosure and to record every step of the country’s information

transparency.

The Measures for Environmental Information Disclosure (Trial) have now been implemented for nine

years, and eight rounds of the PITI evaluation have been conducted. Regular evaluations are made possible

by IPE’s continuous collection, organization, and analysis of pollution source supervision information from all

levels of environmental protection departments. From less than 2000 supervision records collected by the

Water Pollution Map Database in 2006 to nearly 70,000 records obtained in 2016, the quantity of data added

to IPE's Database reflects the historical progress of China’s environmental information disclosure.

Figure 1. Annual Number of Pollution Source Supervision RecordsAdded to the Blue Map Database Since 2006

China’s Environmental Information Disclosure:From Difficulties to Historical Progress

Ten-YearReview

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While reviewing PITI reports over the years, one can observe the subtle trajectory of change and analyze

the motivations behind progress by finding clues in the report names: from the first report “Breaking the Ice”;

to the second, “Between Advance and Retreat”; followed by “Taking Stock.” The fourth evaluation, “Bottlenecks

and Breakthroughs” notes the clear deceleration of progress. The fifth round, “Breakthroughs and Beginnings,”

reflects the first time the world achieved such major progress in automatic monitoring data disclosure. Next,

the sixth evaluation, “New Mindsets, Innovative Solutions,” details how Shandong, Zhejiang, and other regions

demonstrated an entirely new basis for understanding leadership in information disclosure. The seventh eval-

uation, “Gaining Momentum, Towards Breakthroughs,” witnesses how the new Environmental Protection Law

and Air Pollution Control Law work together to create even greater potential for information disclosure, which

we anticipate in excitement.

Figure 2. Eight Years of PITI Evaluations

Over eight PITI reports, we observed the quantity, quality, frequency, and user-friendliness of pollution

supervision information disclosure. Most gratifying of all, we observed the solid foundation of environmental

legislation and policy development behind these trends. From the 2003 Cleaner Production Promotion Law

and Environmental Impact Assessment Law; to the 2008 Measures for Environmental Information Disclosure

(Trial), which raised 17 major disclosure requirements; to the 2014 Measures on Self-Monitoring and Informa-

tion Disclosure for Key State-Monitored Enterprises, which established mandatory requirements for real-time

monitoring data disclosure; to the 2015 new Environmental Protection Law, a dedicated chapter of which

clearly highlights information disclosure and public participation; we can see how legislation for environmental

information disclosure has taken meaningful steps towards legalization and systematization. It is only a matter

of time before change accelerates, for it is clear by now that this trend will not lose favor, encounter resistance,

or easily regress.

2017

2009


Figure 3. Legislative Milestones of China’s Environmental Information Disclosure

When compared over time, China’s pollution information disclosure has made historic progress.

Looking at regulations, the Southeast coast, Beijing, Shandong, and other leading regions have already reached the basic regulatory re-quirements.

Comparing sectors, corporate information disclosure clearly lags behind that of the government and struggles to meet societal expectations.

Comparing across domestic regions, the East is performing much better than the West, and the gap remains significant. Shanxi, Gansu, and Heilongjiang are among several cities with the lowest degree of disclosure.

From a global persepctive, the Yangtze River Delta, the Pearl River Delta, Beijing, Shandong, and other areas applications already demonstrate an ad-vanced level of disclosure relative to international standards.

Considering practical applications, information disclosure has initially proven effective towards pollution reduction, but there is still a great deal of potential to be realized.

Through the past eight PITI evaluations, our overall observations:

Beginning Landmark Breakthrough Convergence withInternational standards

a. Cleaner Production Promotion Law of the People’s Republic of China

b. Environmental Impact Assessment Law of the People’s Republic of China

c. Interim Measures for Public Participation in Environmental Impact Assessments

a. Regulations on Government Information Disclosure

b. Measures on Environmental Information Disclosure (Trial)

a.NotificationConcerningtheReinforcement of Pollution Source Environmental Supervisory Information Disclosure

b. Measures for Self-monitoring and Information Disclosure for Key State-Monitored Enterprises (Trial)

a. Environmental Protection Law of the People’s Republic of China

b. Measures for the Disclosure of Environmental Information by Enterprises and Public Institutions

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Key Improvement 1: Information regarding the review of illegal construction projects has been fully disclosed, thus significantly expanding corporate environ-mental information

In order to address various historical issues from before the new Environmental Protection Law, in May 2016, the Ministry of Environmental Protection (MEP) issued the Notice on Moving Toward Completion of the Review Work of Construction Project Enviromental Violations to review construction projects from before the 2003 Environmental Impact Assessment Law. This notice includes requirements to specify clean-up measures, responsible parties, specific time limits, and ongoing progress, as well as requirements for public information disclosure of screening such projects before June 10, 2016, and those for the disclosure of clean-up results, before November 30, 2016.1

According to data collected by IPE’s Blue Map Database, 31 provinces (including province-level municipalities and autonomous regions, excluding Tibet) released information encompassing the review of more than 620,000 illegal construction projects.

Figure 4. Provincial Distribution of Illegal Construction Projects

Key Improvements

1. Notice on Moving Toward Completion of Review Work of Construction Project Environmental Violations, Central Supervision Office (2016) No. 46, May 2016


The disclosure of the above data demonstrates a huge step for environmental transparency, exposing en-

vironmental violations of more than 600,000 illegal construction projects. Taking into account this widespread,

comprehensive information disclosure, the PITI added an additional 1 point to the scores of all 120 cities. This

is the first time in eight years of the PITI assessment that additional points have been awarded to scores, in

order to recognize the one-time clean-up and disclosure of long-term problems in addition to regular super-

vision.

Key Improvement 2: 14 cities scored greater than 70 points, doubling last year’s number of high achievers

The PITI rankings are based on a percentage system: the higher the score, the greater the level of information transparency. The disclosure requirements of Chinese law account for 70 points out of 100; additional efforts beyond the law account for 30 points. That is to say, to exceed the PITI score of 70 points is to have already surpassed the specific requirements of the law.

During this evaluation period, fourteen cities exceeded 70 points, doubling the number of cities that had already passed the 70-point mark. New additions include Shenyang, Zhongshan, Xiamen, Jinan, Suzhou, Shanghai, Shaoxing, Dongguan, which all entered the ranks of city leaders for environmental transparency. Among them, Shenyang scored 74.8 points during this period, coming in as a dark horse that achieved fifth place and became the first northeastern city to squeeze into the top ten.

Figure 5. 14 Cities Scoring Greater than 70 Points

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During the evaluation of all 120 cities, 80 cities achieved higher scores than last year. The information transparency of enough cities improved such that the average PITI score increased to 52.34 points, the first time since the 2013 update in PITI standards that the average score has surpassed 50 points.

Figure 6. Average PITI Score for 120 Cities for Four Most Recent Evaluations

Key Improvement 3: Using supervision information on pollution sources for mul-tiple purposes can compel perpetrators to reduce their emissions.

To fully employ pollution source supervision information, in December 2013, the Ministry of Environmental Protection, the National Development and Reform Commission, People’s Bank of China, and China Banking Regulatory Commission jointly developed and released the Measures for Corporate Environmental Credit Ratings (Trial), a guide to corporate environmental credit/performance evaluation.

Administrative licensing, government purchase, government awards, financial support, credit and qualification ratings will all factor in corporate environmental credit results, which will effectively pressure polluting businesses to improve their behavior and consequently achieve greater pollution reduction. Jiangsu Province even implemented differentiated utility rates and wastewater treatment fees based on environmental credit ratings to promote compliance by enterprises.

Aside from credit ratings, pollution source information disclosure can also be used for green supply chain, green finance, public environmental risk alerts and public supervision.

• China Real Estate Green Supply Chain Initiative

On June 5, 2016, SEE, China Urban Realty Association (CURA), China Real Estate Chamber of Commerce (CRECC), Vanke, and Landsea jointly initiated the “China Real Estate Industry Green Supply Chain Action.” As of December 2016, 71 real estate companies have joined the initiative. The Green Supply Chain Action works with real estate businesses and their suppliers to develop a “white list” of suppliers deemed to have essentially achieved environmental compliance, based on the time, number and severeity of suppliers' environmental violations, as well as the PITI scores of cities where they are located. Companies on the “white list” have priority in transactions with the 71 real estate companies.


Figure 7. Website of the “China Real Estate Industry Green Supply Chain Action” (Source: http://www.cura.cn/index.htm, 2017/8/24)

• Pollution supervision information disclosure fosters the implementation of green finance strategies and policies

The China Banking Regulatory Commission issued “Green Credit Guidelines,” which state that financial institutions should effectively identify, measure, monitor and control environmental and social risks during credit and loan services; set up environmental and social risk management systems; and further improve credit policy systems.

To effectively identify environmental risks in a timely manner, financial institutions must fully understand the environmental performance of pollution sources in order to avoid risk. The supervision information of pollution sources, and the establishment of corporate environmental risk ratings based on pollution practices allow financial institutions to use green credit as a way to promote the transformation of economic development patterns and restructuring. The environmental supervision information of Blue Map Database is already linked to the Green Finance Committee under China Finance Academy, as well as the China Finance Information Website, as a tool for risk evaluation.

Figure 8. Environmental Supervision Information Linked to China Green Finance Committee Platform (Source:http://www.greenfinance.org.cn/,2017/8/24)

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Shortcoming 1: Key polluting entities have failed to fully meet information dis-closure requirements mandated by the new Environmental Protection Law and Air Pollution Control Law

The 2016 Air Pollution Prevention and Control Law stipulates that key polluting entities shall install and operate automated air pollution monitoring equipment, integrate it with the systems of departments in charge of enviromental protection ensure that it operates smoothly and disclose emissions information according to law.

Of 120 cities that were evaluated as part of this report, 91 cities developed and released directories of key polluting entities. 88 of those directories disclosed key air pollution emitters2, encompassing some 2,4103 enterprises. However, public emissions data is available only for 284 of those companies. Most companies have thus far failed to comply with the Air Pollution Control Law’s information transparency requirements, either failing to disclose their data outright or displaying data only on screens on their own premises where the data cannot be readily accessed by the public.

Figure 9. Disclosure of Automatic Monitoring Data by Key Air Pollution-Discharging Entities

KeyShortcomings

2. Excluding state-controlled exhaust emissions3. Some directories do not clearly distinguish between different types of emissions, in which case the project team selected statistics for key

polluting enterprises in the steel, glass, power generation, cement, coking, waste incineration and ceramics industries, among others.


Another key problem is the quality of directories that cities have produced. Some directories included only Key State-Monitored Enterprises—which have already been marked for additional supervision—or only added several laboratories or hospitals in addition to these enterprises. At the same time, they fail to include significant emitters such as waste incineration and disposal companies. Elevated pollution sources, such as chimneys and smokestacks, are likewise missing.

To evaluate the quality of the directories, we compared lists of registered polluters in Shenyang, Lanzhou, Jinan, Zibo, Shenzhen, Xiamen, and other cities to the number of registered polluters expected based on corresponding CO2 and NO emissions data from 2015. According to these calculations, of the 91 cities that released directories, 54 failed to include more than a third of polluting entities that were not already classified as Key State-Monitored Enterprises. These include cities with heavy air pollution such as Shijiazhuang, Jining, Tangshan, Handan, Pingdingshan, Anyang, Rizhao, Weihai, Weifang, and Baoding.

The inadequate quality of these directories limits the ability of the new Environmental Protection Law and the Air Pollution Control Law to improve environmental information transparency.

Figure 10. Information Disclosure Among Key Polluting Entities

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To further advance the environmental information disclosure of enter-prises and public institutions, and to improve both flexibility and prac-ticality, the MEP revised the Measures on Environmental Information Disclosure for Enterprises and Public Institutions (MEP Order No. 31) and released the draft revision for public comment. The draft revision stipulates that the MEP establish an integrated environ-mental information disclosure platform for enterprises and public institutions. It also requires that key pollution-discharging entities install automatic monitoring equipment and connect the moni-toring data with the integrated MEP platform to be disclosed in real-time. In addition, MEP will develop unified criteria for the formulation of directories of key pollution-discharging entities.

Figure 11. Disclosure of Pollution Source Supervision Information in 2016


Shortcoming 2: Disclosure of pollution source supervision information remains incomplete

Although some cities such as Beijing, Wenzhou, Guangzhou, Qingdao, and Xiamen have made great strides in releasing pollution source supervision data, this information remains inaccessible in many places. According to data from the MEP, some 137,800 environmental law violations were investigated and addressed in 2016. Our Blue Map Database, drawing from online public information disclosure, identified only 62,000 violations, 45% of those recorded by MEP. MEP data also indicates daily penalties were imposed in 1017 cases nationwide in 2016, while Blue Map identified only 273, 26.8% of all cases. Three MEP inspection campaigns made initial filings against 15,586 emitters, imposed fines totaling 775 million yuan, investigated 1,154 pollution cases, and detained 1,075 individuals, yet detailed corresponding records could not be found.

Of the 120 cities that were evaluated, seven exceeded our projected information disclosure. 105 cities, some 87.5%, disclosed less than half of their expected level of environmental data. 42 cities disclosed less than one-tenth of the information that they were expected to disclose.

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Shortcoming 3: A Pollution Release and Transfer Register regime is necessary to address the inadequate regulation of hazardous and toxic pollutants

In April of this year, the presence of industrial wastewater ponds in Hebei, Tianjin, and other places drew widespread public attention. The difficulty of determining which companies or even how many companies dumped industrial waste at those locations made clear the current lack of effective regulation of toxic and hazardous substances.

When the PITI program began in 2009, it emphasized that China should draw from the European and American experiences to establish a Pollutant Release and Transfer Register (PRTR) system. In such a system, the government would require companies to record and disclose their use, discharge, and transfer of pollutants, with particular attention to heavy metals, volatile organic compounds, and dangerous chemicals. Such a system would be a powerful tool to track and reduce the release of pollutants.

To date, companies’ handling of toxic and hazardous substances remains opaque. Of 120 cities evaluated, only Shenyang was home to industries that disclosed information on dangerous chemicals and emergency contingency plans.

Figure 12. Wastewater Ponds in Northern China (Image Source: Chongqing Liangjiang Voluntary Service Center)


Push environmental protection bureaus lagging in supervision information disclosure to improve within a set timeline, and advance the establishment of a unified platform.

Topromotetransparencyandfulfill thepublic’senvironmentalright-to-knowandtosupervise,regulatorsshouldbeginbyimproving dedication to information disclosure at the local EPB level. These departments have both the responsibility to enforce environmental regulations and the data collected in the course of their regulatory duties. Most of these departments also have functional websites. We recommend that the central government and the MEP, in their inspection campaigns, scrutinize regions that have consistently lagged in supervision information disclosure. Moreover, we recommend that the central government and MEP provide these EPBs with targets and timelines to come into compliance with information disclosure requirements.

Overthelongterm,Chinashouldcoordinateaverticalmanagementandpermitprogramandestablishaunifiedplatformforenvironmentaldata. InJuneof2017,theLegislativeAffairsOfficeoftheStateCouncilreleasedtheRegulationsofthePeople's Republic of China on the Disclosure of Government Information (Revised Draft for Comment), which established the principle: “disclosure as the norm, and non-disclosure as the exception”. The State Council also released Several Opinions of theGeneralOfficeoftheStateCouncilonStrengtheningtheServiceforandSupervisionofMarketSubjectsbyApplyingBigData,whichproposestheestablishmentofaunifiedinformationdisclosureplatformforindustry.Thisprospectispromising,butrealizingthisgoalwillrequiresignificantadditionaleffort.

Firmly implement the new Air Pollution Law and ensure that polluting entities comply with the law’s automatic monitoring data disclosure requirements.

Although China’s new Air Pollution Prevention and Control Law has already been in effect for more than a year and half , Key Polluting Entities have yet to fully meet the mandate for real-time information disclosure. We believe this problem limits the effectiveness of the new law and needs to be urgently addressed.

We recommend drawing from the best practices of Beijing and other cities, namely: either building a platform for environmental information disclosure or using the platforms for automatic monitoring data disclosure of Key State-Monitored Enterprises that are already in place. These platforms should be used to disclose environmental monitoring data of Key Polluting Entities, including data from automated monitoring, to meet the mandates for automated monitoring and disclosure laid out in the new Air Pollution Prevention and Control Law.

Key Polluting Entities that fail to comply with the Air Law’s requirements should be punished strictly in accordance with the law, and individual administrators who defy the law’s enforcement requirements should be investigated and punished.

1.

2.

PolicyRecommendations


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3.

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Urge the publication of complete and comprehensive directories of Key Polluting Entities.

Although the Measures on Environmental Information Disclosure for Enterprises and Public Institutions—a set of policies that buttresses the new Environmental Protection Law—have been in effect for two years, some cities still have yet to release directories of Key Polluting Entities. Many more cities have released directories, but they contain information that is incomplete and outdated. Out of the 338 prefecture-level cities, 230 cities disclosed directories of Key Polluting Entities in 2016. Apart from the three with unclear disclosure times, 90 cities disclosed their directories before the March timeline, accounting for 39.1%, while 137 exhibited delayed disclosure, accounting for 59.6%.

The MEP should push these 70 cities that have yet to produce these directories for 2017 in a rigorous manner consistent with the new Environmental Protection Law’s requirements. The MEP should then ensure that these directories are released to the public.

For cities that have produced these directories, the MEP should ensure that they record and disclose—by late March of every year—thetypesandclassificationsofpollutantsthattheydischarge.

We also recommend that the MEP draw from the experience of Shenyang and other success stories to set standards with a quantifiedmethodologyfortheproductionofthesedirectories.Thiswillhelpensurethatdirectories includeallofthekeypollution sources that they are designed to cover.

Establish a Pollutant Release and Transfer Register (PRTR) system.

With the new Water Pollution Prevention and Control Law coming into effect in 2018, and the successful international experience of PRTR, we believe China should move to establish its own PRTR system.

We recommend requiring pollution sources to register and disclose the pollutants that they discharge. These pollutants would include conventional pollutants and dangerous chemicals. Companies would be required to disclosure the use and transfer of such pollutants.

We recommend that the scope and depth of required disclosure be no less than the level of characteristic pollutants identifiedinenvironmentalimpactassessments.

We recommend that environmental agencies should work to establish a unified platform for environmental information disclosure. This platform will allow the public to view information on dangerous chemicals including relevant data on their discharge and transfer. We also recommend that agencies should increase penalties for failing to register and for lying during registration. At the same time, agencies should strengthen supervision and ensure that polluters accurately and promptly report the release and transfer of toxic pollutants.

Finally, we recommend setting strong disclosure requirements for public companies to both strengthen public supervision andtopromotethetransparencyrequiredforgreenfinanceandgreenfinancialproducts.

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1. Assessment Subjects

This PITI evaluation covered 188 cities. We evaluated 1204 cities designated by MEP as key environmental

protection cities.

Our partner organizations, including Green Anhui, Shandong Green Qilu, Green Home of Fujian, Green

Jiangxi, Green Jiangnan Public Environment Concerned Center, Green Taihang, Hubei Xingchejingchu and

Nanjing Universities evaluated 68 other cities in addition to the 120 cities.

Figure 13. Distribution of Assessment Sites

Assessment Subjects, Scope and ProcedureChapter 1

4. Including 111 key environmental protection cities (among the 113 key environmental protection cities, Lhasa and Haikou were not included in the evaluation), as well as seven cities that are not key environmental protection cities: Ordos, Daqing, Yancheng, Jiaxing, Taizhou, Weihai, Foshan, Zhongshan, and Dongguan.

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Indicators

Environmental Supervision Information(30 points)

Pollution Source Self-Disclosure(26 points)

Interactive Response (15 points)

Enterprise Emission Data

(14 points)

EIA Information(15 points)

Disclosure of Excess Emissions and Other Daily Violation Records

Disclosure of Enterprise Environmental Performance/Credit Ratings

Disclosure of Discharge Fee Breakdown

Disclosure of Automatic Monitoring Data

Disclosure of Key Polluting Entities Information

Disclosure of Complaints & Reports Information

Disclosure Upon Request

Disclosure of Emission Data of Key Enterprises

Disclosure of Cleaner Production Audit Data

Disclosure of EIA Information

Score Distribution

23points

5 points

2 points

20 points

6 points

7 points

8 points

12 points

2 points

15 points

2. Assessment Scope The current evaluation scope follows the same methodology as past evaluations, with five primary

indicators: “Environmental Supervision Information”, “Pollution Source Self-Disclosure”, “Interactive Response”,

“Enterprise Emission Data”, and “EIA Information”, and ten secondary indicators. For specific decisions made

with regards to the evaluation scope and data collection deadlines, please see Appendix 1.

Figure 14. Assessment Indicators

Every indicator is measured using four dimensions: systematic, timely, complete, and user-friendly

presentation.

Figure 15. Assessment Dimensions


3. Assessment ProcedureThe PITI evaluation procedure includes general data collection, preliminary evaluation, cross-checking,

initial evaluation of assessment results, feedback and final scoring. Data collection takes place over 16 months,

followed by focused evaluation, which takes places over four months.

Figure 16. Assessment Procedure

Public

Release

of Prel

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Evalu

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Results

for 10

Days

July

1, 20

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Data Collection

January 1, 2016

Disclos

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n

Reque

st

Febru

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, 201

7

Preliminary

Assessment Begins

March 1, 2017

Data Co

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ds

April 3

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Cross-Institutional

Investigations

BeginJune 12, 2017

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Assessment ResultsChapter 2

Section 1 Overall Scores and Rankings

Figure 17. 2016-2017 PITI Assessment Results and Rankings for 120 Cities

Rank City Total Trend Rank City Total Trend

1 Wenzhou 78.1 24 Chengdu 65.72 Guangzhou 76.9 25 Handan 65.43 Beijing 75.7 26 Lianyungang 64.84 Qingdao 75.1 27 Taian 63.95 Shenyang 74.8 28 Yancheng 63.96 Zhongshan 73.4 29 Hohhot 63.77 Xiamen 73.3 30 Nanjing 63.68 Jinan 72.6 31 Changzhou 639 Hangzhou 72.5 32 Xuzhou 62.710 Suzhou 72.2 33 Zhuhai 62.111 Shanghai 71.6 34 Nantong 61.612 Shaoxing 70.7 35 Nanchang 6113 Dongguan 70.2 36 Jining 60.414 Ningbo 70 37 Wuhan 60.315 Jiaxing 69.9 38 Huzhou 60.216 Foshan 69.8 39 Wuxi 59.317 Shenzhen 69 40 Weifang 59.218 Hefei 67.3 41 Tianjin 59.219 Zibo 67 42 Zaozhuang 58.620 Dalian 66.9 43 Beihai 58.521 Taizhou 66.5 44 Fuzhou 57.622 Rizhao 66.2 45 Liuzhou 56.923 Yantai 66 46 Shijiazhuang 56.6


Rank City Total Trend Rank City Total Trend47 Changchun 56.5 84 Zigong 44.648 Wuhu 56.4 85 Changzhi 43.549 Xi'an 55.7 86 Anshan 43.450 Baoding 55.5 87 Zunyi 43.451 Weihai 55.2 88 Tangshan 4352 Zhanjiang 55.1 89 Mianyang 42.953 Shantou 55 90 Sanmenxia 42.654 Qinhuangdao 54.3 91 Yuxi 42.355 Ma'anshan 53.8 92 Xining 4256 Quanzhou 53.1 93 Panzhihua 41.957 Zhenjiang 52.4 94 Guiyang 41.758 Urumqi 52.1 95 Pingdingshan 4159 Yangzhou 51.4 96 Jingzhou 4160 Chifeng 51.4 97 Qiqhar 40.861 Zhengzhou 51.2 98 Fushun 40.762 Jiujiang 51.1 99 Weinan 39.463 Chongqing 50.1 100 Harbin 39.364 Guilin 49.8 101 Deyang 38.965 Baotou 49.3 102 Xianyang 38.866 Xiangtan 49 103 Yichang 38.667 Kunming 48.7 104 Taiyuan 38.168 Nanning 48.6 105 Jiaozuo 36.769 Yinchuan 48.2 106 Erdos 36.670 Luzhou 48.1 107 Yan'an 35.771 Luoyang 48 108 Anyang 35.372 Yibin 48 109 Yangquan 34.473 Shizuishan 47.9 110 Jinchang 33.774 Shaoguan 47.8 111 Zhangjiajie 33.675 Changsha 47.6 112 Lanzhou 3376 Qujing 46.9 113 Daqing 32.877 Jilin 46.1 114 Kaifeng 32.678 Changde 45.5 115 Jinzhou 32.279 Yueyang 45.2 116 Benxi 31.580 Baoji 45.1 117 Karamy 3081 Tongchuan 44.8 118 Mudanjiang 2982 Zhuzhou 44.7 119 Datong 24.283 Nanchong 44.7 120 Linfen 23.6

20

Figure 18. 2016-2017 PITI Assessment Results and Subcategory Scores

NO. City

Total Score (101

points)

Environmental Supervision Information (30 points)

Pollution Source Self-Disclosure (26 points)


Enterprise Emission Data (14 points)

EIAInformation(15 points)

Additional Points

(1 point)

Disclosure of Excess Emissions and Other Daily

ViolationRecords

(23 points)

Disclosure ofEnterprise

Environmental Performance

/Credit Ratings(5 points)

Disclosure of

Discharge Fee

Breakdown(2 points)

Disclosure of

Automatic Monitoring

Data (20 points)

Disclosure of Key

Polluting Entities

Information (6 points)

Disclosure of

Complaints& Reports


Disclosure Upon

Request (8 points)

Disclosureof

Emissions Data of Key Enterprises (12 points)

Disclosure of Cleaner Production Audit Data (2 points)

1 Beijing 75.7 21.4 1 1.7 16 5.4 3.8 7.2 8 0.6 9.6 1

2 Tianjin 59.2 4.6 1 1.6 18 2.4 6 7 8 0 9.6 1

3 Shijiazhuang 56.6 9.2 1 1.7 17 1.2 6.4 6 6.4 0.7 6 1

4 Tangshan 43 4.6 1 1.8 14 1.2 5.6 7.4 6.4 0 0 1

5 Qinhuangdao 54.3 9.2 1.8 1.6 17 1.2 1.4 7 6.4 0.7 7 1

6 Handan 65.4 13.8 1 1.7 17 1.2 6.4 7.8 5.6 0.7 9.2 1

7 Baoding 55.5 9.2 1 1.6 17 1.2 3.6 7.8 6.4 0.7 6 1

8 Taiyuan 38.1 9.2 0 1.3 5 0 6.4 0.6 6.2 0 8.4 1

9 Datong 24.2 4.6 0 1.6 0 0 2.8 0.8 6.4 0 7 1

10 Yangquan 34.4 18.4 0 1.6 5 0 0 0.8 0 0.6 7 1

11 Changzhi 43.5 9.2 0 1.5 9 0 4.8 1.2 6.4 0.6 9.8 1

12 Linfen 23.6 9.2 0 1.8 5 0 3.4 0.8 0 0 2.4 1

13 Hohhot 63.7 18.4 1 1.7 14 1.2 3.8 6.8 7.2 0.4 8.2 1

14 Baotou 49.3 13.8 0 1.6 13 0 0 7 7.2 0.7 5 1

15 Chifeng 51.4 16.8 0 1.6 13 0 5.6 7 6.4 0 0 1

16 Ordos 36.6 9.2 1 0 13 1.2 0 0.6 4 0 6.6 1

17 Shenyang 74.8 18.4 3.6 1.7 16 2 4.2 7 10.4 1.3 9.2 1

18 Dalian 66.9 18.4 0 1.7 16 0.8 6.6 8 4.8 0 9.6 1

19 Anshan 43.4 13.8 0 1.7 12 1.2 1.4 0.8 2.4 0.7 8.4 1

20 Fushun 40.7 4.6 0 1.2 16 1.2 2.2 6 0 0.7 7.8 1

21 Benxi 31.5 4.6 0 0.9 8 0.8 1.4 6.2 0 1.6 7 1

22 Jinzhou 32.2 4.6 0 1.5 16 0 0 6.8 1.6 0.7 0 1

23 Changchun 56.5 12.2 0 1.6 14 1.2 6.4 6.8 5.6 0.7 7 1

24 Jilin 46.1 9.2 0 1.6 14 1.2 2.4 2.6 6.4 0.7 7 1

25 Harbin 41.7 9.2 2.4 1.6 13 2.8 0 7 4 0.7 0 1

26 Qiqihar 40.8 4.6 0 1.7 13 1.2 1.4 7.2 2.4 0.7 7.6 1

27 Daqing 32.8 4.6 0 1.5 13 1.2 0 6.8 4 0.7 0 1

28 Mudanjiang 29 13.8 0 1.7 4 0.8 0 7 0 0.7 0 1

29 Shanghai 71.6 19 0 1.7 17 1.2 6.2 8 6.4 0.7 10.4 1

30 Nanjing 63.6 18.4 1 1.7 18 1.2 6.2 7 0 0.7 8.4 1


NO. City

Total Score (101

points)






Additional Points

(1 point)


ViolationRecords

(23 points)




Disclosure of

Discharge Fee

Breakdown(2 points)

Disclosure of


Data (20 points)

Disclosure of Key

Polluting Entities


Disclosure of

Complaints& Reports


Disclosure Upon

Request (8 points)

Disclosureof



31 Wuxi 59.3 15.2 2.6 1 18 1.2 4.2 7 0 0.7 8.4 1

32 Xuzhou 62.7 13.8 2 1 18 1.2 2.4 7.2 5.6 0.7 9.8 1

33 Changzhou 63 18.4 2 1.7 18 1.2 6 5.6 0 0.7 8.4 1

34 Suzhou 72.2 18.4 2.8 1.7 18 1.2 5.6 7.2 7.2 0.7 8.4 1

35 Nantong 61.6 18.4 3.6 1.5 18 1.2 2.4 1 7.8 0.7 6 1

36 Lianyungang 64.8 13.8 2.8 1.7 18 3.6 2.8 7.2 5.6 0.7 7.6 1

37 Yangzhou 51.4 13.8 2 1.3 18 1.2 6.4 1 0 0.7 6 1

38 Zhenjiang 52.4 13.8 2 1.7 18 1.2 4.2 0.8 4 0.7 5 1

39 Yancheng 63.9 18.4 1 1.6 18 3.6 2.8 6.8 2.4 0.7 7.6 1

40 Hangzhou 72.5 20.6 1 1.5 18 1.2 6 7 7.2 0.6 8.4 1

41 Ningbo 70 18.4 1 1.9 18 1.2 6.6 7.2 7.2 0.7 6.8 1

42 Wenzhou 78.1 21.4 2 1.8 18 3.4 6.2 8 7.2 0.7 8.4 1

43 Jiaxing 69.9 18.4 1 1.8 18 3.4 2.2 7.2 8.6 0.7 7.6 1

44 Huzhou 60.2 15.2 1 0 18 1.2 0 7 8.6 0.6 7.6 1

45 Shaoxing 70.7 18.4 0 1.9 18 2.4 5.6 7.8 7.2 0.6 7.8 1

46 Taizhou 66.5 18.4 2 1.4 18 2.4 4.8 7 4 0.7 6.8 1

47 Hefei 67.3 13.8 1.8 1.3 19 2.4 5.6 7 7.2 0.6 7.6 1

48 Wuhu 56.4 4.6 1.8 1.3 19 1.2 6.6 7 5.6 0.7 7.6 1

49 Ma'anshan 53.8 4.6 1 1.5 19 0 5.6 7.2 5.6 0.7 7.6 1

50 Fuzhou 57.6 9.2 0 1.7 13 2.2 6.2 7.2 8 0.7 8.4 1

51 Xiamen 73.3 23 1 1.3 13 3 6.2 8 6.4 0.6 9.8 1

52 Quanzhou 53.1 13.8 0 0.2 13 1.2 6.2 6 5.6 0.7 5.4 1

53 Nanchang 61 13.8 0 1.7 19 2 1.4 7.2 6.4 0.7 7.8 1

54 Jiujiang 51.1 9.2 0 0 19 1.2 4.2 1 6.4 0.7 8.4 1

55 Jinan 72.6 18.4 0 1.7 20 3.6 6 7.2 6.4 0.7 7.6 1

56 Qingdao 75.1 19.8 1 1.6 20 3.6 6.2 7.2 6.4 0.7 7.6 1

57 Zibo 67 13.8 0 1.7 20 3.6 6.2 6.8 5.6 0.7 7.6 1

58 Zaozhuang 58.6 9.2 0 1.7 20 2.4 4 7 5.6 0.7 7 1

59 Yantai 66 13.8 0 1.7 20 0.8 5.6 7.8 6.4 0.7 8.2 1

60 Weifang 59.2 9.2 0 1.7 20 1.2 4.8 7.2 6.4 0.7 7 1

22

NO. City

Total Score (101

points)






Additional Points

(1 point)


ViolationRecords

(23 points)




Disclosure of

Discharge Fee

Breakdown(2 points)

Disclosure of


Data (20 points)

Disclosure of Key

Polluting Entities


Disclosure of

Complaints& Reports


Disclosure Upon

Request (8 points)

Disclosureof



61 Jining 60.4 12.2 0 1.7 20 0 6.6 7.2 8 0.7 3 1

62 Tai'an 63.9 13.8 0 1.6 20 3.6 6.6 7.2 6.4 0.7 3 1

63 Rizhao 66.2 18.4 0 1.3 20 1.2 4.8 7.2 4 0.7 7.6 1

64 Weihai 55.2 4.6 0 1.7 20 1.2 6.4 7.2 4.8 0.7 7.6 1

65 Kaifeng 32.6 4.6 0 1.5 18 1.2 0 0.8 2.4 0.7 2.4 1

66 Zhengzhou 51.2 4.6 0 1.7 16 1.2 2.4 6.8 6.4 0.7 10.4 1

67 Luoyang 48 9.2 0 1.1 18 1.2 4.8 7.2 4.8 0.7 0 1

68 Pingdingshan 41 4.6 0 1.3 18 1 0 6.6 4.8 0.7 3 1

69 Anyang 35.3 4.6 0 1.6 12 1.2 4.4 2.4 2.4 0.7 5 1

70 Jiaozuo 36.7 4.6 0 1.6 18 1.2 2.4 7.2 0 0.7 0 1

71 Sanmenxia 42.6 4.6 0 1.7 18 1.2 1.4 0.2 6.4 0.7 7.4 1

72 Wuhan 60.3 13.8 2 1.8 13 1.2 6.6 7.8 4 0.7 8.4 1

73 Yichang 38.6 9.2 2.6 1.3 13 1.2 0 7.2 2.4 0.7 0 1

74 Jingzhou 41 4.6 2.6 1.7 13 0 6.4 7 4 0.7 0 1

75 Changsha 47.6 4.6 2 1.3 13 2.2 6.2 5 4 0.7 7.6 1

76 Zhuzhou 44.7 4.6 1 1.4 13 0 4.8 7.2 5.6 0.7 5.4 1

77 Xiangtan 49 4.6 2 0 13 1.2 6.2 7 5.6 0 8.4 1

78 Yue Yang 45.2 4.6 1 1.6 13 0 4.8 7 4 0 8.2 1

79 Changde 45.5 9.2 2 1.5 13 1.2 0 6 5.6 0.6 5.4 1

80 Zhangjiajie 33.6 4.6 1 0 13 0 0 6.8 5.6 0 1.6 1

81 Guangzhou 76.9 22.2 2 1.6 17 3.4 6.6 5.6 9.8 0.7 7 1

82 Shaoguan 47.8 11.4 1 1 17 1.2 2.6 4.6 8 0 0 1

83 Shenzhen 69 18.4 1 1.7 17 4.4 6.6 2.8 6.4 0.7 9 1

84 Zhuhai 62.1 13.8 1 1.7 17 0 4.8 5.6 8 0 9.2 1

85 Shantou 55 9.2 1 1.7 17 1.2 2.4 6.8 8 0.7 6 1

86 Foshan 69.8 23 2 0 17 1.2 6.4 6 4.8 0 8.4 1

87 Zhanjiang 55.1 4.6 1 1.7 17 1.6 6 5.8 8 0 8.4 1

88 Zhongshan 73.4 18.4 3.6 1.7 17 0 6.6 6 8 0.7 10.4 1

89 Dongguan 70.2 18.4 2 1.7 17 1.2 6 7.2 8 0.7 7 1

90 Nanning 48.6 9.2 0 1.6 14 1.2 5.6 2.8 5.6 0 7.6 1


NO. City

Total Score (101

points)






Additional Points

(1 point)


ViolationRecords

(23 points)




Disclosure of

Discharge Fee

Breakdown(2 points)

Disclosure of


Data (20 points)

Disclosure of Key

Polluting Entities


Disclosure of

Complaints& Reports


Disclosure Upon

Request (8 points)

Disclosureof



91 Liuzhou 56.9 13.8 0 1.7 18 1.2 1.4 5 6.4 0 8.4 1

92 Guilin 49.8 9.2 1 1.8 18 1.2 0 4.4 4.8 0 8.4 1

93 Beihai 58.5 13.8 0 1.9 18 0 2.8 6.8 6.4 0 7.8 1

94 Chongqing 50.1 13.8 0 1.6 7 0 6 6.8 4.8 0.7 8.4 1

95 Chengdu 65.7 18.4 1 1.6 13 1.2 6 7.2 7.2 0.7 8.4 1

96 Zigong 44.6 13.8 1 1 13 0 5.6 0.6 5.6 0 3 1

97 Panzhihua 41.9 8.4 2 1.7 10 0 4.2 1.4 5.6 0 7.6 1

98 Luzhou 48.1 4.6 0 1.7 14 2.2 2.8 7 7.2 0 7.6 1

99 Deyang 38.9 4.6 0 1.3 13 0 1.4 3.6 5.6 0 8.4 1

100 Mianyang 42.9 4.6 2 1.7 13 0 6 1.4 5.6 0 7.6 1

101 Nanchong 44.7 9.2 0 1.3 14 0.8 4 0.4 5.6 0 8.4 1

102 Yibin 48 4.6 0 1.6 13 1.2 4.2 6.8 7.2 0 8.4 1

103 Guiyang 41.7 9.2 1 1.6 7 0 0 7.2 5.6 0.7 8.4 1

104 Zunyi 43.4 9.2 1 0 7 0 5.6 7.2 5.6 0 6.8 1

105 Kunming 48.7 4.6 0 0 18 0 6 6.2 4.8 0.7 7.4 1

106 Qujing 46.9 4.6 0 0 18 0 3.8 5.4 5.6 0.7 7.8 1

107 Yuxi 42.3 4.6 0 1.5 18 0 0 7 4 0 6.2 1

108 Xi'an 55.7 9.2 0 0 17 0 6 7 6.4 0.7 8.4 1

109 Tongchuan 44.8 9.2 0 1.3 17 0 2.4 1.4 5.6 0.7 6.2 1

110 Baoji 45.1 9.2 0 1.6 17 0 6 4 5.6 0.7 0 1

111 Xianyang 38.8 9.2 0 1.3 17 0 0 4 5.6 0.7 0 1

112 Weinan 39.4 9.2 0 1.7 17 0 2.8 1.4 5.6 0.7 0 1

113 Yan'an 35.7 13 0 0 17 0 1.4 2.6 0 0.7 0 1

114 Lanzhou 33 4.6 0 0.7 14 0.8 0 6.4 4.8 0.7 0 1

115 Jinchang 33.7 4.6 1 1.6 11 0.4 1.4 7.2 4.8 0.7 0 1

116 Xining 42 4.6 1.8 0 18 0 4.2 2.4 2.4 0 7.6 1

117 Yinchuan 48.2 9.2 0 1.7 17 1.2 6 5 6.4 0.7 0 1

118 Shizuishan 47.9 12.2 0 0.2 17 0 6.4 0.4 4 0.7 6 1

119 Urumqi 52.1 13.8 0 1.7 17 0 5.8 6.4 6.4 0 0 1

120 Karamay 30 1.4 0 1.6 14 1.2 1.4 3.8 5.6 0 0 1

24

Section 2 PITI Score Comparison for Similar Regions and Cities

In this evaluation, 38 cities scored more than 60 points. Wenzhou once again topped the rankings, with

the highest score of 78.1. Eighty cities improved their scores since the 2015-2016 evaluation, including 195

cities that improved their scores by over 10 points.

1. Comparison of Average Provincial ScoresOf the 256 provinces evaluated, Zhejiang ranked at the top of the list with an average score of 69.7.

Shandong and Guangdong took second and third place, respectively. Shanxi, which earned the critique of

“frequent inaction or slow action” during the central inspections, scored 32.76, placing it at the bottom of the list.

Figure 19. Comparison of Annual Average Scores for Provincial-Level Administrative Area

Of the 25 provinces and provincial-level areas evaluated, 20 improved their average scores. Guangdong,

Qinghai, Yunnan, Fujian, Jiangsu, and Sichuan all increased their average scores by more than five points each.

Guangdong improved by the greatest amount, with a 7.9-point increase since the last evaluation period. The

5. Hohhot, Lianyungang, Yancheng, Taian, Nanchong, Dongguan, Xi'an, Hefei, Liuzhou, Luzhou, Shenyang, Changchun, Dalian, Panzhihua, Baoding, Qujing, Handan, Foshan, and Tianjin.

6. Tibet, Hainan, Hong Kong, Macau and Taiwan are not included in this evaluation.


average scores of Shanxi, Inner Mongolia, Heilongjiang, Gansu, and Guizhou all declined slightly. Guizhou

experienced the greatest decline, with its provincial average falling by 12.1 points since the last evaluation

period. The primary reason for this decline was Guizhou’s poor management of its self-monitoring platform,

where a considerable number of key state-monitored enterprises did not disclose all or part of their self-

monitoring data.

Figure 20. Top Five Provinces with Most Improved Scores & Largest Score Reductions

Of the 25 provinces evaluated, eight improved their relative ranking, seven remained the same in rank,

and ten fell in rank as compared to last year. Guizhou fell 12 spots from 7th place last year to 19th place in this

evaluation, experiencing the greatest relative decline of any province.

Figure 21. Top Five Provinces with the Biggest Increase and the Biggest Decrease in Ranking

26

2. Score Comparison for the Four Provincial-Level MunicipalitiesFollowing the 2013 revisions to the evaluation standards, there has been no significant change in the

relative rankings of the provincial-level municipalities. Beijing’s score of 75.7 points has topped the list of

provincial-level municipalities for four consecutive years and holds third place among all 120 cities.

Chongqing ranks lowest among the municipalities with a score of 50.1. The significant point difference

is due to Chongqing’s inadequate disclosure of self-monitoring data for key state-monitored enterprises.

According to statistics, 70% of Chongqing’s key state-monitored enterprises7 still do not comply with the

requirements for public disclosure of real-time automatic monitoring data stipulated by the Measures for Self-

Monitoring and Information Disclosure for Key State-Monitored Enterprises (Trial). Chongqing’s acquisition rate

for automatic monitoring data stands at only 21.45%. Furthermore, Chongqing has yet to fully implement the

Environmental Protection Law and Air Law requirements for the disclosure of information on key pollution-

discharging entities.

Figure 22. Comparison of PITI Scores for the Four Provincial-Level Municipalities

3. Score Comparison for Provincial CapitalsOf the 25 provincial capital cities evaluated, Guangzhou ranks at the top with a score of 76.9. Ten

provincial capitals received over 60 points. Guangzhou, Shenyang, Jinan, and Hangzhou all received over

70 points. Compared to last year’s evaluation, Hohhot, Xi’an, Hefei, Shenyang, and Changchun achieved

substantial score improvements. The score of Hohhot increased the most, by 17.3 points, followed by the

improvements of Xi’an and Hefei.

7. Wastewater companies, emissions companies, and sewage treatment plants


Figure 23. Comparison of PITI Scores for Provincial Capitals

4. Top-Scoring Cities by Province Among the 25 provinces evaluated, 14 provincial capitals ranked first among cities in their respective

provinces.

Figure 24. Top Scoring City for Each Province

28

5. Score Comparison for Major Geographic Regions Of the seven major geographic regions, eastern China continues to rank at the top with an average score

of 63.67, now leading for eight consecutive years. All seven regions improved their scores since last year.

Southern China has improved for two consecution evaluations, with an average score increase of 5.7 points

since the previous evaluation period.

Figure 25. Score Comparison of Average Scores for Major Geographic Regions

6. Score Comparison for Cities within Provinces To see the score comparison of cities within each province, please refer to Appendix 2.


Assessment FindingsChapter 3

Section 1. Subcategory Assessments I. Disclosure of Pollution Source Supervision Information1. Disclosure of Excess Emissions and Other Routine Violation Records

This section evaluates the disclosure in selected cities of records on excess emissions from pollution

sources and other routine violation records.

1.1 Key Improvements: The disclosure of administrative penalties and the channels for disclosure are becoming increasingly standardized

During this PITI assessment period, we observed that the disclosure of pollution source supervision

information, particularly administrative penalties and the channels of disclosure, are becoming more

systematic. Jiangsu, Anhui and some other provinces have established systems for the disclosure of

administrative permits, penalties other environmental credit information across all departments, cities, districts

and counties.

Figure 26. Bulletin of administrative penalties, licenses and other credit information in Changzhou City (image source: http://www.cxcz.org.cn/credit/jianyxc/sgsxk_gd, 2017/8/15)

30

In addition to standardization, we also noted the comprehensive quality of pollution source supervision

information disclosure. More cities disclosed administrative penalty decisions, including complete information

regarding violations and the basis for punishments and penalties. According to our statistics, out of 120

evaluated cities, 104 disclosed all of their administrative penalty decisions in 2016, a 48.6% increase from only

70 cities last year.

Thanks to the complete and systematic disclosure of pollution source supervision information, Xiamen

and Foshan achieved full scores for the “disclosure of excess emissions and other routine violation records”

section in this year’s assessment.

Figure 27. Number of Cities Disclosing Administrative Penalty Decisions Over the Past Three Years

1.2 Key Shortcomings

Although some cities such as Beijing, Wenzhou, Guangzhou, Qingdao, and Xiamen have made great

strides in releasing pollution source supervision data, this information remains inaccessible in many places.

According to data from the MEP, some 137,800 environmental law violations were investigated and addressed

in 2016. Our Blue Map Database, however, which draws from online public information disclosure, identified

only 62,000 violations, 45% of those recorded by MEP. MEP data also indicate that daily penalties were

imposed in 1,017 cases nationwide in 2016, while the Blue Map identified only 273, 26.8% of all cases. Three

MEP inspection campaigns made initial filings against 15,586 emitters, imposed fines totaling 775 million yuan,

investigated 1,154 pollution cases, and detained 1,075 individuals. Yet, detailed corresponding records were

not systematically and fully disclosed to the public.

In order to assess the comprehensiveness of pollution supervision information disclosure, our project team

estimated how many violation records each city should disclose. This methodology used a statistical coefficient


based on the amount of information disclosed by the top 20 cities regarding supervision information and

industrial pollutants, including SO2, NOX, COD, and ammonia nitrogen. We then compared the actual amount

of pollution source supervision information disclosed in 2016 to the projected number of violation records

to calculate the disclosure rate of violation records for all 120 evaluated cities. We found that only 9 cities

reached 80% of expected disclosure, while 42 cities’ disclosure rates were less than 10%.

Figure 28. Disclosure Rate of Excess Emissions and Other Routine Violation Records for 120 Cities

1.3 Case Study: Hefei Achieves Comprehensive Penalty Information Disclosure at City and County Levels, Improving its Ranking by 28 Places

In July 2016, Hefei Environmental Protection Bureau (EPB) started operating an online system for the

comprehensive disclosure of administrative penalties. By the end of our data collection period (March 1,

2017), our project team gathered violation records for more than 210 enterprises from this online system and

other channels. Compared to only 36 enterprises listed in 2015, and 41 listed in 2014, Hefei’s information

transparency in 2016 demonstrates breakthrough progress. As a result, Hefei’s final score for this year’s

assessment reached 67.3 points, ranking in 18th place, with a 28-place improvement.

32

Figure29.AdministrativePenaltySectionofHeifeiMunicipalEPBWebsite(ImageSource:http://hfepb.gov.cn/cflist.aspx,2017/8/15)

2. Disclosure of Corporate Environmental Performance & Environmental Credit Ratings

The section evaluates whether the 120 key cities have conducted assessments of enterprise environmental

performance and environmental credit ratings according to the Measures for Corporate Environmental Credit

Ratings (Trial) and the Guiding Opinion on Strengthening the Construction of a Corporate Environmental

Credit System,8 and disclosed their assessment results to the public.

2.1 Key Improvements

This year’s evaluation considers the 2016 publication of environmental performance results from 2015.

Out of 120 cities, 58 cities published corporate environmental credit ratings, demonstrating an increase of 13

cities since last year.

8. Published provincial-level and district-level credit rating information is included in the evaluation.


Figure 30. Comparison of Evaluation Results for Disclosure of Corporate Environmental Performance &

Environmental Credit Ratings Over the Past Three Evaluation Periods


Based on our assessment team’s findings, only one third of 30 provinces (excluding Hong Kong, Macao,

Taiwan and Tibet) disclosed their provincial assessment results. Out of 338 administrative regions, only 86

conducted credit assessment work. Only 77 cities disclosed data on enterprises rated with “warning” or

“poor-performance” levels of environmental performance ratings, accounting for 22.8% of the 338 cities.

Consequently, there is still plenty of room for improvement in the disclosure of corporate environmental

performance ratings.

Figure 31. Summary of Disclosure of Corporate Environmental Performance & Environmental Credit Ratings

34

2.3 Examples of Innovation

Shandong province established an online management system for corporate environmental credit ratings,

fully disclosing the entire ranking criteria and procedures.

In October 2016, Shandong province released the Shandong Province Measures on Corporate

Environmental Credit Ratings, which requires the completion of environmental credit assessment work, and

concurrently established an online system for managing corporate environmental credit ratings. Enterprises

can log in to this online management system to search for their violation records and rating information.

Enterprises that receive administrative punishments can adjust their performance ratings if they rectify their

behavior based on requests from local EPBs, then submit new reports on corrective actions and related

verification materials.

Figure 32. Shandong’s Online System for Corporate Environmental Performance Ratings (Source: http://123.232.114.99:8088/SDXY/index, 2017/08/01)

Jiangsu province implemented differential pricing for electricity and sewage treatment fees to promote

enterprise compliance.

In 2015, Jiangsu province released the Notice on Differential Electricity Pricing and the Notice on Sewage

Treatment Fees. These notices increase the cost of electricity and waste treatment for highly-polluting

enterprises using a differential pricing strategy based on corporate environmental credit ratings.

According to the Notice of Differential Electricity Pricing, highly-polluting enterprises rated as “red” and

“black” should pay different power prices. For instance, enterprises rated as red shall pay an extra 0.05 RMB/

kWh and enterprises rated as black shall pay an extra 0.1 RMB/kWh in addition to the regular price.

Based on the Notice on Sewage Treatment Fees, Jiangsu encouraged regions with sufficient capacity to

monitor corporate environmental credit ratings and set up their own charging standard based on different

credit ratings. For instance, the extra price of sewage treatment for enterprises with a “red” rating should be

no less than 0.6 RMB per cubic meter, while the extra price for enterprises with a black or red rating for two

consecutive assessments should be no less than 1.0 RMB per cubic meter.


3. Disclosure of Discharge Fee BreakdownOf 120 evaluated cities, 108 cities disclosed information about the breakdown of discharge fees. This

year’s situation is almost the same as last year, in which 107 cities disclosed this information. However, the

quality of disclosure of discharge fee breakdowns is slightly worse, because the number of cities that disclosed

specific pollutant and emission volumes decreased as compared to last year.

Figure 33. Cities with publicly announced discharge fees

Figure 34. Comparison of publicly announced discharge fees for two evaluation periods

Project City

Sewage Treatment Fees Fushun, Anshan, Tangshan, Linfen, Datong, Wenzhou, Ningbo, Shaoxing, Jiaxing

Actual Emissions/Concentration Datong, Ningbo, Shaoxing, Jiaxing

Excess Sewage Fees Beihai, Wenzhou, Wuhan

36

II. Pollution Source Self-Disclosure1. Disclosure of Automatic Monitoring Data

This section evaluates whether key state-monitored enterprises disclosed their automatic monitoring data

in real-time based on the requirements of the Measures for Self-Monitoring and Information Disclosure for Key

State-Monitored Enterprises (Trial).

This evaluation assessed information collected from 120 cities in December 2016 regarding the disclosure

of automatic monitoring data for key state-monitored enterprises for wastewater and air emissions, as well as

designated sewage treatment plants.

Figure 35. Automatic monitoring data acquisition rate for 120 cities

Rank City Acquisition Rate (%) Rank City Acquisition Rate (%)

1 Foshan 210.3 25 Hefei 139.8

2 Nanchang 184.6 26 Dongguan 139.8

3 Taizhou 179.5 27 Zhuhai 138.4

4 Shaoxing 171.3 28 Zhenjiang 137.9

5 Quanzhou 167.9 29 Shijiazhuang 136.3

6 Nantong 166.3 30 Yantai 135.7

7 Wenzhou 166.1 31 Zhanjiang 134.5

8 Huzhou 163.4 32 Baoji 134.3

9 Yangzhou 160.5 33 Xianyang 133.3

10 Lianyungang 159.1 34 Tai'an 132.1

11 Shantou 156.8 35 Weinan 131.2

12 Jiaxing 156.0 36 Ningbo 131.1

13 Fuzhou 153.4 37 Qingdao 130.4

14 Yancheng 152.8 38 Shaoguan 129.7

15 Hangzhou 151.4 39 Yinchuan 128.6

16 Wuxi 150.2 40 Guilin 128.3

17 Xiamen 150.2 41 Rizhao 127.6

18 Shenzhen 149.7 42 Weifang 123.6

19 Nanjing 147.9 43 Zaozhuang 123.0

20 Suzhou 147.7 44 Baoding 122.9

21 Zhongshan 146.2 45 Yan'an 122.3

22 Jiujiang 143.4 46 Jilin City 122.2

23 Xi'an 141.4 47 Wuhu 121.4

24 Wuhan 140.8 48 Kunming 119.9


Rank City Acquisition Rate (%) Rank City Acquisition Rate (%)

49 Changchun 119.4 85 Beijing 76.5

50 Ma'anshan 114.9 86 Changsha 76.0

51 Guangzhou 114.1 87 Baotou 75.7

52 Xuzhou 111.3 88 Tangshan 74.8

53 Yichang 109.2 89 Mianyang 72.4

54 Qujing 108.7 90 Chifeng 70.9

55 Tongchuan 108.4 91 Karamay 70.6

56 Changzhou 103.8 92 Deyang 69.1

57 Beihai 103.1 93 Ordos 68.3

58 Lanzhou 100.7 94 Nanning 68.3

59 Jiaozuo 100.6 95 Changzhi 68.2

60 Urumqi 99.7 96 Zhuzhou 64.7

61 Handan 97.9 97 Shenyang 63.0

62 Jinan 97.2 98 Yibin 62.7

63 Shizuishan 96.7 99 Zhengzhou 62.5

64 Qinhuangdao 96.7 100 Fushun 61.2

65 Pingdingshan 96.2 101 Daqing 61.1

66 Kaifeng 96.2 102 Jinchang 61.0

67 Jining 95.2 103 Anyang 59.0

68 Sanmenxia 94.6 104 Anshan 57.3

69 Jingzhou 94.1 105 Changde 53.9

70 Xining 93.8 106 Harbin 53.5

71 Shanghai 93.7 107 Zigong 51.9

72 Luoyang 93.7 108 Panzhihua 48.9

73 Yuxi 92.8 109 Yue Yang 48.3

74 Liuzhou 92.5 110 Qiqihar 45.1

75 Weihai 90.7 111 Jinzhou 41.5

76 Zibo 90.6 112 Taiyuan 39.6

77 Tianjin 89.7 113 Guiyang 39.2

78 Hohhot 87.4 114 Benxi 37.7

79 Zhangjiajie 86.1 115 Zunyi 21.7

80 Nanchong 82.2 116 Chongqing 21.5

81 Luzhou 81.8 117 Yangquan 15.5

82 Xiangtan 78.2 118 Mudanjiang 14.4

83 Dalian 77.4 119 Linfen 0.1

84 Chengdu 76.6 120 Datong 0

38


More regions and enterprises have given rise to positive interaction with the general public by responding

to questions online regarding excess emissions shown by online data. Some even released information on

downtime, maintenance and other disruptions to regular operations ahead of time.


This evaluation assessed the disclosure platforms of 299 provinces. Among them, Chongqing stood out

with 70% of key state-monitored enterprises10 not disclosing their self-monitoring data on time based on

the requirements of the Measures for Self-Monitoring and Information Disclosure for Key State Monitored

Enterprises (Trial). The data acquisition rate for Chongqing was only 21.45%. Datong disclosed zero data and

data obtained for Linfen found a disclosure rate of only 0.1%, highlighting their contrast to Shandong and

Zhejiang provinces, which both had relatively good performance in self-monitoring data disclosure.

Additionally, Guizhou demonstrated poor platform maintenance, with late updates or none at all.

Figure 36. Cities with automatic monitoring data acquisition rates below 30%

9. Hainan and Tibet are not included in our evaluation.

10. Enterprises discharging wastewater and/or air emissions and sewage treatment plants that are monitored at the national level.


2. Disclosure of Information on Key Pollution-Discharging EntitiesThis evaluation area primarily assesses whether cities disclosed their directories of key pollution-

discharging entities based on the new Environmental Protection Law; whether the quality of these directories

met the new requirements of the law11; whether the key pollution-discharging entities followed the new

requirements for environmental information disclosure under the Measures on Environmental Information

Disclosure by Enterprises and Public Institutions; and whether the key emitters in the directories disclosed their

online monitoring data under the new Air Pollution Control Law.

2.1 Key Improvements: The number of cities that published their directories of key pollution-discharging entities has increased substantially

In the second year of implementation for the new Environmental Protection Law, the project team

collected data on the information disclosure of directories of key pollution-discharging entities for 338

prefecture-level cities across the country. We found that 230 cities disclosed their directories, accounting

for 68% of all evaluated cities. Compared to the 146 cities that disclosed their directories in 2015, this year’s

number increased by 84.

Of the 120 key cities evaluated in this report, 91 cities disclosed their directories, accounting for 75.8%

of the total and increasing by 31.9% compared to 69 cities last year. In general, evaluated cities demonstrate

better performance than cities excluded from this evaluation.

In February of this year, our project team discussed the information disclosure of key state-monitored enterprises in Linfei with the municipal EPB. Through two requests for information disclosure and one reconsideration, we facilitated the information disclosure of some key state-monitored enterprises. As of April of this year, out of 60 key state-monitored enterprises, excluding 13 enterprises that suspended their production and 32 enterprises under manual monitoring, 15 enterprises had disclosed their automatic monitoring data.

11. The requirements for this evaluation item are slightly more stringent than those under the law, meaning that if an evaluated city has disclosed its directory of key pollution-discharging entities, then it is also scored based on how many non-state-monitored entities that discharge air pollution are included in the published directory.

40

The increase in the number of cities that disclosed their directories is due not only to the cities themselves,

which successfully followed the requirements of the new Environmental Protection Law, but also to the

catalytic efforts of local environmental organizations. In December 2015, 30 environmental organizations

jointly launched the Initiative to Promote Regional-Level Information Disclosure of Key Entities for Air and

Water Pollution Control. The initiative calls for all provincial and municipal environmental protection bureaus

to promptly determine and publish lists of key pollution-discharging entities within their respective jurisdictions

according to China’s Air Law. The initiative also requires the installation and use of air pollution self-monitoring

equipment by entities designated for air emissions monitoring, and that these devices be connected to

the environmental protection authorities’ monitoring networks, as well as confirmation that this equipment

operates normally and discloses data and information according to law.

In 2016, IPE, together with Green QiLu Action Research Center in Shandong, Green Hebei, Wuhu

Ecology Center, Green Jiangxi Nanchang Environment Exchange Center, Green Shaanxi, Chengdu

Jinjiang District Ecological Environment Conservation Center of Lvyang, Hubei XingChe Environmental

Commonweal Development Center, Shiyan Canglang Greenway Environmental Protection Service Center,

and other local environmental NGOs sent requests for the directories of key pollution-discharging entities

to 168 cities, submitted appeals for administrative reconsideration to Linfen and Handan, and sent letters

with recommendations for information disclosure to 13 provinces. As a result, with the support of local

environmental NGOs, 46 cities disclosed their directories of key pollution-discharging entities.

Figure 37. Publicity of key polluting entity directories in 2015 and 2016


2.2 Key Challenges: Directories of key pollution-discharging entities demonstrate varying degrees of disclosure; enterprises that discharge air pollutants have yet to fulfill the requirements of the new Air Law

This evaluation item is weighted 6 points in total. Among the 120 cities included in the evaluation, 84

cities received points in this area, yet the average score of the 120 evaluated cities was only 1.168 points, with

a scoring rate of 19.5%. These figures indicate a long road ahead for the comprehensive disclosure of key

pollution-discharging entities. The primary reasons for the low scores are as follows:

• Quality of directories of key pollution-discharging entities is insufficient

One key problem is the quality of directories that cities have produced. Some directories included only

key state-monitored enterprises—which have already been marked for special supervision—or only added

several laboratories or hospitals in addition to these enterprises. At the same time, they failed to include

significant emitters such as waste incineration and waste treatment and disposal companies. Elevated pollution

sources such as chimneys and smokestacks are likewise missing.

To evaluate the quality of the directories, we calculated the number of enterprises for air emissions

monitoring that should be included in each city’s directory. The calculations considered the annual SO2 and

NOX emissions data from 2015 in each city and the number of enterprises for air emissions monitoring in

the directories of cities including Shenyang, Lanzhou, Jinan, Zibo, Shenzhen, and Xiamen. According to these

calculations, of the 91 cities that released directories, 54 failed to include more than a third of the estimated

number of enterprises that were not already classified as key state-monitored enterprises. These include

cities with heavy air pollution such as Shijiazhuang, Jining, Tangshan, Handan, Pingdingshan, Anyang, Rizhao,

Weihai, Weifang, and Baoding.

• Enterprises that discharge air pollutants have yet to implement the requirements of the new Air Law for automatic monitoring data disclosure

The 2016 Air Pollution Prevention and Control Law stipulates that key pollution-discharging entities shall

install and operate automated air pollution monitoring equipment, integrate it with environmental protection

department systems, ensure that it operates regularly, and disclose emissions information according to law.

Of the 120 cities evaluated, 91 cities developed and released directories of key pollution-discharging

entities. 88 of those directories disclosed key air pollutant emitters, encompassing some 2,410 enterprises.

However, public emissions data is available only for 284 of those companies. Most companies have thus far

failed to comply with the Air Law’s information transparency requirements, either failing to disclose their data

outright or displaying data only on their own premises, where the data cannot be readily accessed by the

public.

42


• The Yichang Municipal EPB accepted public opinions and incorporated chemical industries with accidents into its directory of key pollution-discharging entities

On the evening of June 1, 2016, Hubei Yichang Zhongxing Chemical’s organic silicon by-product

treatment site triggered a fire that burned for three hours before it was brought under control.

Yichang Zhongxing Chemical Co., Ltd. was listed as the entity responsible for discharging hazardous

waste. In 2014, an investigation into the company found a series of problems, such as substandard

hazardous waste storage, hazardous waste released into open air, and a complete lack of hazardous material

identification tags.

The supervisory office of the Hubei Provincial EPB subsequently ordered Yichang Zhongxing to suspend

production for corrections to be made. Based on the requirements of the Hubei EPB, “enterprises discharging

or storing hazardous waste, as well as those with annual hazardous waste production above 500 tons, shall

be included in the directory of key pollution-discharging entities.” However, according to the information

made public by the Hubei EPB in the Public Notice of the Approval of the Operating Permit for Yichang

Zhongxing Chemical Industry’s Business Operations with Hazardous Waste, “this company’s registered address

and the address of business operations using hazardous waste are both located as No. 6 Kangyonglu Road,

Economic Development Chemical Industrial Park, Xiaoting District, Yichang. It is approved to collect, store, and

utilize HW45 organic halide wastes (261-084-45). Its approved business operation scale is 10,000 tons/year.”

However, Zhongxing Chemical Industry LLC was not included in Yichang’s 2016 directory of key pollution-

discharging entities.

Based on the above information, IPE sent an official letter to Yichang EPB to request the reexamination

of the original selection principles for their key pollution-discharging entities and the amendment of the 2016

Directory of Yichang Key Pollution-Discharging Entities to include Yichang Zhongxing Chemical Co., Ltd.

and other missing polluters. On July 5, 2016, the Yichang EPB formally replied to say the 2016 directory was

revised to include Yichang Zhongxing Chemical Co., Ltd. as well as other key pollution-discharging entities

that ought to be included.

• Beijing actively implemented the Environmental Protection Law and Air Law to promote disclosure of information on key pollution-discharging entities

In last year’s report, we mentioned that Beijing built a platform to release environmental information from

key supervised enterprises in the city.

In December 2016, our project team evaluated 172 key pollution-discharging entities in Beijing on their

disclosure of automatic monitoring data. We found that 141 entities disclosed their pollutant emissions data,

while 31 entities had not yet disclosed their automatic monitoring data. Among the air-polluting entities,

including 20 heating companies and three cement plants, 13 entities did not disclose their automatic

monitoring data based on the Air Law. To address this problem, our project team sent an official letter to the

Beijing EPB seeking further communication on the matter.


Figure 38. Beijing implements the Environmental Protection Law and Air Pollution Law, which require penalties

for undisclosed business practices

In response to our letter, the Beijing EPB took stock one by one of companies that did not disclose their

environmental information based on the Environmental Protection Law. They excluded “eight companies

that did not need to disclose their information because they did not discharge any pollutants; and two more

companies because of business adjustments, network failure, and other complications they are working to

resolve.” The Beijing EPB therefore focused on four companies for their incomplete information disclosure and

placed them on file for handling and punishment. The Beijing EPB also investigated companies that did not

disclose their automatic monitoring information, excluding three because they lacked the conditions for public

monitoring due to their coal-to-gas operations, and three because they were in the process of changing

their online monitoring equipment, although they were asked to disclose their monitoring data after the new

systems come online. As a result, the Beijing EPB confirmed three entities that discharged air pollutants but did

not disclose their automatic monitoring data and also put these entities on file for handling and punishment.

44

III. Interactive Responses1. Environmental Complaints and Reports


Du Shaozhong, former spokesperson for Beijing’s Environmental Protection Bureau, mentions in his

book, Environmental Small Talk: The Online-Offline Story of a Media Spokesperson, that government Weibo

accounts provide the opportunity for direct dialogue with the public. They create “peer-to-peer” and “group-

to-group” styles of communication, which change the public’s passive “listening” approach to government

information from traditional media.

Fortunately, since government authorities began to join Weibo in 2011, 208 accounts12 have been created

by the environmental protection bureaus of prefecture-level cities, 52 more than the 156 listed in 2015.

Among these accounts, 82 cities accept environmental complaints and reports through Weibo, an increase of

12 cities as compared to only 70 in 2015.

Figure 39. Regional Distribution of Environmental Government Weibo Accounts

More and more environmental protection bureaus have opened Weibo accounts and use them to

accept environmental complaints, reflecting the current government’s increasingly open online approach. This

strategy mobilizes community enthusiasm through public participation in supervision and collective solutions

to environmental issues.

12. However, 21 of these WeChat accounts have not posted since their opening announcement, or last posted over a year ago, a phenomenon known as “ghost” WeChat accounts.


1.2 Key Challenges: Average Score Decreased; Increase in Number of Cities Failing to Earn Points

This year’s “environmental complaints and reports” section found an average score of 3.945, with a

scoring rate of 56.36%, which is slightly lower than that of the previous period.

Figure 40. Scoring Rate of Environmental Complaints and Reports by Province

The decline in scoring rate is primarily reflected in the following:

The following 18 cities scored zero: Yangquan, Baotou, Ordos, Jinzhou, Harbin, Daqing, Mudanjiang,

Huzhou, Kaifeng, Pingdingshan, Yichang, Changde, Zhangjiajie, Guilin, Guiyang, Yuxi, Xianyang, and

Lanzhou. This situation increased the quantity of non-scoring cities by nine as compared to last year.

The MEP’s Environmental Emergency and Accident Investigation Center developed the “12369

Environmental Reporting” public WeChat account, which officially came online on World Environment Day

on June 5, 2015. Since then, many people have reported environmental issues and some issues have been

solved through this WeChat platform. As the former Minister of MEP Chen Jining predicted, “If every cell

phone becomes a mobile monitoring device, every member of the public will become an environmental

supervisor.” According to the MEP’s latest statistics, “In July 2017, China’s 12369 environmental hotline

received 4,860 fewer complaints than it did the month before, representing a 13.3% reduction in volume.

China’s online reporting also decreased by 304 complaints, some 4.2% less than the previous month.

However, the volume of China’s WeChat reporting increased by 2,353 complaints, demonstrating an

increase of 19.8% since last month and 109% since last year, with a total of 7,440 more complaints filed.”

The WeChat platform, because of its convenience, has the potential to surpass “phone reporting” to

become the primary channel for environmental complaints.

Unfortunately, the project team did not find any “12369” WeChat reporting information that was available

to others beyond the complainant, which defeats the potential for joint supervision.

46

Figure 41. 12369 Internet Reporting Platform

(Source: http://1.202.247.200/netreport/netreport/index, screenshot on 2017/8/31)


Case 1: Public Information Platforms Help the Public Supervise Emissions

In June 2014, the Blue Map app went live, featuring 14,000 key pollution sources with real-time online

monitoring data and providing a powerful database for the public oversight of pollution. By sharing online

monitoring data and excess emissions with Weibo and other social media platforms, the Blue Map’s three

million users have successfully advocated for more than 700 key state-monitored enterprises, including some

large-scale state-owned enterprises and central government enterprises, to respond to violations of emissions

standards as revealed by online monitoring data.

Figure 42. Distribution of Blue Map Corporate Feedback


Case 2: Multi-stakeholder Roundtables Collaboratively Solve Environmental Issues

SIP Lvse Jiangnan Public Environment Concerned Center (“Lvse Jiangnan” for short) is an environmental

public interest organization in Suzhou. Since its establishment in 2012, Lvse Jiangnan has been committed

to building constructive communication and dialogue platforms that promote solutions to environmental

pollution through multi-stakeholder collaboration between the government, industry, and the public.

Since its establishment five years ago, Lvse Jiangnan has already successfully organized eight roundtable

dialogues in Suzhou, regarding issues with foul-smelling emissions from Samsung Electronics, Dingxin

Electronics, and Phoenix Electronics; river water pollution in Qianjiatang village of Zhangjiagang city; Liufeng

Machinery’s exhaust emissions; Mondelez’s foul-smelling emissions; Sumitomo Rubber’s exhaust emissions;

and Taicang Huaqi Electronics’ exhaust emissions. Roundtable discussions with government, industry, and

community members enhance local residents’ understanding of the industrial emissions situation and help

companies clarify the environmental demands of residents, all on the basis of equal dialogue and rational

multi-stakeholder solutions. Afterwards, the establishment of WeChat groups with representatives from

business, government, brands, NGOs, and the community provide continuous communication and steady

improvement for the problems at hand.

Figure 43. June 2017 Sumitomo Rubber Roundtable Dialogue (Photo by Lvse Jiangnan)

48

2. Disclosure Upon RequestAccording to China’s Regulations on Government Information Disclosure, citizens, legal entities, and

other organizations may, in accordance with their production, life, research, and other special needs, apply for

relevant government information in addition to abiding by the active disclosure requirements of government

information from the State Council or the local government at all levels.

To verify whether or not environmental protection bureaus (EPBs) receive applications for information

disclosure, the project team has sent applications to evaluated cities every year since 2009 through such

means as government website application systems, by telephone and fax, and via email and letters. Scores

are determined by the receiving entities’ responses to the applications for information, together with the user-

friendliness of channels to apply for information disclosure.

In February 2017, the project team applied for information disclosure from all 120 evaluated cities. They

sought the disclosure of the following four items:

The number of environmental impact assessment (EIA) reports on construction projects accepted by

the city in 2016

The names of EIA hearings regarding construction projects held by the city in 2016

The number of penalties for environmental violations enforced by the city EPB in 2016

The number of written decisions of administrative penalties issued by the city EPB in 2016

Out of 120 applications, four were sent via express delivery, 16 by fax, 30 by e-mail, and 70 through

government website application systems. The proportion of these application methods is as follows:

Figure 44. Application Method Statistics



During this evaluation of disclosure upon request, applications were successfully delivered to all 120 cities.

Accessibility for applications has improved since last year, when seven application submissions failed, and

moreover since the year before, when 16 application submissions failed.

Additionally, the proportion of applications filed through government websites was only 46 in 2014,

but rose to 70 this year. This finding reflects the new information age, wherein government services use an

interactive approach to the internet and explore innovative service models.

Figure 45. Application Method Statistics for the Past Three Years13

2.2 Key Challenges

After issuing 120 applications, the project team received 99 responses, including:

70 applications issued online; 56 replies: 80% response rate

16 applications faxed; 13 replies: 81% response rate

30 applications e-mailed; 26 replies: 87% response rate

Four applications delivered via post; four replies: 100% response rate

The lowest rate of response came from government website application systems. Online application

systems must therefore sustain better management and maintenance in order to become more convenient

and efficient.

13. The figure includes the following periods, from the inside out: 2013-2014, 2014-2015, and 2015-2016, respectively.

50

IV. Disclosure of Key Enterprise Emissions Data1. Disclosure of Key Enterprise Emissions Data

In April of this year, the environmental organization Chongqing Liangjiang Voluntary Service Center

disclosed the existence of several “super” industrial wastewater seepage pits in two locations: Dacheng County

of Langfang City in Hebei Province; and Tianjin’s Jinghai District. The largest one of these pits measured up

to 170,000 square meters, causing widespread societal concern. Officials from the MEP stated that these

seepage pits involved at least two illegal acts: using seepage pits to evade pollution regulations, and the illegal

discharge of hazardous waste.

Figure 46. Sewage Sites in Northern China (Photos by Chongqing Liangjiang)

Tracing the timeline of events, it is not difficult to see that the northern China sewage sites expose major

flaws in China’s current environmental legislation and significant loopholes in regulation, namely, the lack of

sufficient regulations for toxic and hazardous pollutants. This in turn highlights the conflict between economic

development and environmental governance.

When the PITI project began in 2009, the project team proposed that China should learn from the

experiences of Europe and the United States, establish and implement a PRTR (Pollution Release and

Transform Register) system, and urge industry to publicly disclose the discharge, use, and transfer of

hazardous chemicals, especially heavy metals, volatile organic compounds (VOCs), and other contaminants,

thus promoting pollution reduction.


After eight years of promotion, the annual disclosure of industry emissions information has improved

slightly under the new Environmental Protection Law, the new Air Law, the Measures for Self-Monitoring and

Information Disclosure of Key State-Monitored Enterprises (Trial), and other regulations. But the requirements

are neither comprehensive nor complete. Heavy metals, VOCs, hazardous waste, and other pollutant

emissions are not publicized, and information regarding the use and transfer of hazardous chemicals remains

hidden from the public.

Figure 47. Score Distribution of Key Enterprise Data Disclosure in 120 Cities


Compared to the previous evaluation period, the publication of conventional pollutant emissions data and

specific pollutant emissions data, as well as the disclosure of hazardous waste transfer, disposal, and emissions,

have all improved significantly. Among 120 cities evaluated, the proportion that published conventional

pollutant emissions data reached 90%; the proportion that published specific pollutant emissions and

hazardous materials data grew only slightly, up to 50%, but maintained upward momentum. The increased

amount of basic data published is likely due to the establishment and optimization of information disclosure

systems for enterprises.

52

Figure 48. Statistics over the Past Two Years Regarding the Completeness of Annual Enterprise Emissions Data

1.2 Key Challenges

Information regarding hazardous chemicals – especially key hazardous chemicals, their names,

characteristics, use, transfer, disposal, and emissions – remains severely lacking. Of the 120 cities evaluated,

only Shenyang’s environmental information disclosure system for enterprises included information related to

hazardous chemicals and accident contingency plans.

By comparing industrial wastewater, air emissions, hazardous waste generation, and PITI scores by

province, one can find that some provinces with high industrial waste production also exhibit low scores for

the disclosure of key enterprise emissions data, demonstrating the lack of disclosure and public supervision for

annual pollutant emissions data.

The northern China sewage site case in April raised widespread concern both within and outside the

environmental community. As an incident caused by noncompliant enterprises evading regulations for so

long, the exposure of seepage sites reflects reflects insufficient regulation for pollutant release, especially

toxic substance control. China’s current environmental legislation lacks management of hazardous chemicals;

meanwhile, the Measures on the Environmental Management and Registration of Hazardous Chemicals

(Trial), published in 2013, was abolished in June 2016 due to reasons including industry resistance and a lack

of relevant supporting documents. The extensive data regarding the management of hazardous chemicals

remain inaccessible to the public.


Figure 49. Hazardous Waste Generation and Average Scores for the Disclosure of Key Enterprise Emissions Data by Province

54

2. Disclosure of Cleaner Production Audit DataDuring this evaluation, 89 cities released lists of companies subject to mandatory cleaner production

audits, demonstrating further decline from the past two evaluations. Of the 89 cities with open lists, only two

cities, Shenyang and Benxi, expressed that their published information about the “violation of both emissions

standards and total emissions limits, [and the] inclusion of toxics in both production and emissions” complied

with corporate disclosure requirements, and released enterprise emissions data through their EPB websites.

Figure 50. Cleaner Production Audit Scores


V. Environmental Impact Assessment Information Of the 120 cities evaluated, 100 cities opened environmental impact assessment (EIA) reports to varying

degrees during the EIA assessment period, reflecting little change from the previous period, during which 101

cities did so.

1. Key ImprovementsThe average EIA information disclosure score across all 120 cities is 6.14, with an average scoring rate of

40.9%, increasing slightly from the previous period’s score of 5.9. The slight increase was due to the following:

During the acceptance and review period for EIA reports by environmental bureaus, the times allotted

for public participation were slightly longer. According to statistics, the six cities of Beihai, Liuzhou, Guilin,

Zhuhai, Xi’an, and Zhengzhou all received EIA reports with public consultation periods of 20 to 30 days.

The number of cities that did not set a public consultation period or held one for less than ten days

during the assessment period fell from last year’s 13 to only 9 cities in this evaluation.

Figure 51. EIA Report Public Consultation Period Statistics

2. Key ChallengesPublic participation in environmental impact assessments still essentially consists of posting

announcements and questionnaires. In very few areas is there is effective communication regarding the

influence of construction projects on the environment and surrounding community, including through

seminars and hearings.

56

With traditional questionnaire forms, the public is only “passively involved.” In November 2015, the MEP openly

criticized 15 projects, stating that: “In public opinion surveys, many respondents were not contacted or did not fill

out the questionnaire; some respondents changed their views from initial support to opposition. Considering the

methods of incorporating public participation into the environmental impact assessment of construction projects,

formalistic public participation fails to guarantee the legitimate rights and interests of the public.”

Figure 52. List of 15 Criticized Construction Project Developers and EIA Providers14

Name of Construction Project EIA Agency

CLP Investment Inner Mongolia Tumote Youqi Coal-fired Air-cooled Power Plant Phase I (2 × 1000MW)

China Power Engineering Consulting Group North China Electric Power Design Institute Engineering Co., Ltd

Baotou Guyang Jinshan Industrial Park Thermal Power Plant (2 × 350MW)

Inner Mongolia Electric Power Survey and Design Institute

Nickel Iron Alloy and Deep Processing (supporting three projects) Fujian Provincial Environmental Science Research Institute

Fujian Qimen Power Plant Phase IIIChina Power Engineering Consulting Group North China Electric Power Design Institute Co., Ltd

Puyang Shengbao Project (annual output of 30,000 tons of mixed methylamine)

Guangzhou Environmental Protection Engineering Design Institute Co., Ltd

Zhengzhou Weiner Beer (annual output of 200,000 liters/year) Yellow River Water Resources Protection Research Institute

Hunan Tongli (dissembling small household appliances, plastic recycling granulation, circuit board processing, and conical glass crushing treatment, resource recycling)

Shenzhen Environmental Engineering Science and Technology Center Co., Ltd

Hainan Yingli Production Line Upgrade Hebei Normal University Environmental Technology Co., Ltd

Aviation Piston Engine Fuel Production and Support (Phase I)

Sichuan Province Environmental Science and Technology Advisory Co., Ltd

Zhujiaba Copper Mine Expansion Yunnan Province Building Materials Science and Design Institute

J inchuan Project (second workshop to expand energy consumption)

China Enfei Engineering Technology Co., Ltd

Fangda Carbon New Electrode ( joint processing line) Beijing Zhongan Weikuan Technology Evaluation Center Co., Ltd

Ningxia Bauhinia Straw Paper Recycling Economy Demonstration Project - Clean Production Paper, Organic Fertilizer

Beijing Branch in the Environmental Technology Co., Ltd

Changji Huasheng Source (annual output of 3,000 tons of dry red wine and byproducts)

Xinjiang Jintian Kun Environmental Technology Co., Ltd

Xinjiang Xinlian (180,000 tons/year) Tar Processing Renovation Projects Xinjiang Chemical Design and Research Institute Co., Ltd

14. Notice regarding Public Participation and Rectification Efforts in the Environmental Impact Assessment of Construction Projects, General Office of the MEP, 20 November 2015, http://www.mep.gov.cn/gkml/hbb/bgth/201511/t20151126_317789.htm


Section 2: All-Star LineupConsidering the highest and average scores for each evaluation indicator, the all-star line-up score

reached 90.9 points, and the average score is 52.3 points. The transparency of pollution information has

indeed grown significantly.

Among the ten indicators, “Disclosure of Excess Emissions and Other Routine Violation Records,” “Disclosure

of Automatic Monitoring Data by Key Monitored Enterprises,” and “Disclosure Upon Request” all earned the

highest scoring rate of 100%. In this year’s evaluation, Zhongshan City achieved the highest score for three

evaluation indicators.

Figure 53. Top-Ranking Cities for Each Assessment Criterion

Assessment Criteria

Environmental Supervision Information Pollution Source Self-Disclosure Interactive Response Enterprise Emissions

EIAInformation

Disclosure of Daily Excess Emissions and Other Violation Records

Disclosure ofEnterprise Environmental Performance/Credit Ratings

Disclosure of Discharge Fee Breakdown

Disclousre of Automatic Monitoring Data

Disclosure of Key Polluting Entities Information

Disclosure of Compliants & Reports Information

Disclousre Upon Request

Disclosure of Key Enterprise Pollution Discharge Data

Disclosure of Cleaner Production Audit Data

Top Scoring

Cities

Xiamen,

Foshan

Shenyang,

Nantong,

Zhongshan

Ningbo, Sha-

oxing, BeihaiShandong15 Beijing

Shenzhen,

Taian, Guang-

zhou and oth-

er 3 cities16

Dalian,

Wenzhou,

Xiamen,

Shanghai

Shenyang Benxi

Zhongshan,

Shanghai,

Zhengzhou

Points Achieved 23 3.6 1.9 20 5.4 6.6 8 10.4 1.6 10.4

points Possible 23 5 2 20 6 7 8 12 2 15

Scoring Rate 100.00% 72.00% 95.00% 100.00% 90.00% 94.29% 100.00% 86.67% 80.00% 69.33%

15. Jinan, Zibo, Yantai, Jining, Zaozhuang, Weifang, Weihai, Qingdao, Tai’an and Rizhao

16. Wuhu, Ningbo, Wuhan, Dalian, Jining and Zhongshan

58

Figure 54. Average Score and Highest Score Comparison Graph for 2016-2017

Figure 55. Complete Lineup of Top-Ranking Cities (Highest Score Scenario)


1. Summary of Assessment Criteria The PITI assessment’s standards are predicated upon three key dimensions: first, the existing requirements

of the latest environmental laws; second, example models and best-practices from international experience;

and third, the public’s right to a safe and healthy environment. The changes made to the PITI assessment

criteria over the years are the result of frequent discussions with field experts who have sought to keep the

PITI assessment consistent with the state of China’s rapidly changing and improving environmental laws and

regulations, as well as the current state of China’s environmental crisis. The assessment criteria found below

are the fruit of these discussions; these evaluation criteria seek to incorporate China’s existing environmental

laws and regulations, as well as standards supporting a long-term vision of strict environmental regulation and

sustainability.

Appendix Graph 1-1. Assessment Criteria and Principal Laws and Regulations

Assessment StandardsAppendix 1

Assessment Item Assessment Subject Principal Laws and Regulations

Environmental Supervision Information(30 points)

Disclosure of Daily Excessive Emissions and Other Violation Records (23 points)

The disclosure status of data on enterprise excessive violations and other violation records, including administrative penalties, reports on actions for environmental enforcement, supervisory notices urging violators to come into compliance within a given timeframe, etc. The EPB’s monitoring of pollution sources as well as the publication of these monitoring results, particularly the disclosure of data regarding excessive emissions from polluters. (Access Date: February 29, 2016)

• Measures for Environmental Information Disclosure (Trial) 2007

• Measures on Self-Monitoring and Information Disclosure for Key State-Monitored Enterprises (Trial); and Measures on Supervisory Monitoring and Information Disclosure for Key State-monitored Enterprises (Trial) (MEP Publication [2013] #81)

• Notification Concerning the Reinforcement of Pollution Source Environmental Supervisory Information Disclosure

(MEP Publication [2013] #74)

60

Disclosure of Enterprise Environmental Performance/Credit Ratings(5 points)

MEP’s published results from their evaluation of corporate environmental performance: Corporate environmental performance ratings, which are evaluated on the basis of industry environmental activity as well as the publicized results of disclosure for enterprises rated ‘yellow’ or lower. (Translator note: Enterprises not performing well. (Access Date: February 29, 2016)

• Opinion on Accelerating the Implementation of the Enterprise Environmental Performance Assessment System (MEP Publication [2005] #125)

• Enterprise Environmental Credit Evaluation Measures (Trial)

(MEP Publication [2013] #150)• Notification Concerning the

Reinforcement of Pollution Source Environmental Supervisory Information Disclosure


Discharge Fee Breakdown Disclosure (2 points)

The publication of emissions fees levied against polluters, including pollution fee incidents, specific pollutants emitted, emission concentration, emission volume, etc. (Access Date: April 30, 2016)

• Measures for Environmental Information Disclosure (Trial), 2007

• Notification Concerning the Reinforcement of Pollution Source Environmental Supervision Information Disclosure


PollutionSource Self-Disclosure (26 points)

Automatic Monitoring Data Disclosure(20 points)

This assessment area focuses on the information obtained through provincial-level environmental agencies self-monitoring platforms and their subsequent platform development through the evaluation of the disclosure for total volume of effluent emissions into air and water, pollution concentration, applicable emission limit, as well as the status of compliance, etc.




Disclosure of Key Pollution-Discharging Entities(6 Points)

The disclosure of every city’s Directory of Key Pollution-Discharging Entities; whether or not key air emissions pollution sources follow the Air Pollution Law’s requirements for online disclosure of monitoring information and if other enterprises adhere to the requirements for environmental information disclosure under the Measures for the Disclosure of Environmental Information by Enterprises and Public Institutions. (Access Date: February 29, 2016)

• Law on the Prevention and Control of Air Pollution of the People’s Republic of China

• Measures for the Disclosure of Environmental Information by Enterprises and Public Institutions (Ministerial Order No. 31)

• Measures on Self-Monitoring and Information Disclosure for Key State-Monitored Enterprises (Trial) (MEP Publication [2013] #81)

• Environmental Protection Law of the People’s Republic of China


Interactive Response (15 Points)

Complaints & Reports Information Disclosure(7 points)

This area examines the disclosure of information on the handling of environmental reports and complaints received by EPBs and their resolution results, including the subject of the reports and complaints, the object of the complaint (the enterprise), whether or not the case has been accepted by the EPB, the status of the investigation, disclosure of the resolution results, etc. (Access Date: February 29, 2016)


(MEP Publication [2013] #74)• Measures for Environmental

Information Disclosure (Trial), 2007

Disclosure upon Request(8 points)

Whether or not the EPB has set up a regular and complete system for response. The assessment group will score the EPB on the basis of their process and responses to requests for information.


Enterprise Emissions Data(14 points)

Disclosure of Key Enterprise Pollution Discharge Data (12 points)

The assessment of annual pollutant emissions disclosure. (Access Date: February 29, 2016)


• Measures on Environmental Management and the Registration of Hazardous Chemicals (Trial) (MEP Order #22)


Cleaner Production Audit Data Disclosure(2 points)

EPB disclosure of the mandated cleaner production audit enterprise list, as well as disclosure on the status of whether or not enterprises have released their key pollutant emissions. The EPB should have released the key pollutant emissions data for enterprises if the enterprise themselves failed to disclose this data. (Access Date: February 29, 2016)

• Provisionary Measures for Clean Production Audit (2004)



EIA Information Disclosure(15 points)

The disclosure status of the full text of EIA reports, as well as the level of effort made at all levels of the environmental protection bureaus, to gather public opinions and notify interested parties of their rights to administrative reconsideration and administrative litigation through media channels, community assemblies, public hearings, or other methods. These measures should be taken before there is an acceptance or rejection of the construction project’s EIA. (Access Date: February 29, 2016)

• Notification to Issue the Construction Projects’ Environmental Impact Assessment Government Information Disclosure Guidelines (Trial),

(MEP General Affairs Office Announcement [2013] #103)• Measures for Environmental

Information Disclosure (Trial), 2007• Provisionary Measures for Public

Participation throughout the Environmental Impact Assessment Process for Construction Projects


62

Four metrics are used to evaluate each assessment item:

Systematicness: How systematic is the data we collected?

To determine how “systematic” our data is, our team primarily considers two factors: how comprehensive

pollution-source information is, and how regularly this data is disclosed.

We analyze how comprehensive data disclosure is by evaluating the amount of pollution-source data that

was actually published in comparison to the amount that should have been published.

We also analyze how regularly data is published by evaluating the extent to which pollution-source data

disclosure followed a consistent schedule for disclosure.

Timeliness: How timely was the collected data published?

To assess how “timely” our data is, our team assesses how promptly local pollution-source information is

disclosed.

Completeness: How complete is the data we collected?

To assess how “complete” pollution-source data is, we evaluate the content of information published

regarding local pollution sources, as well as whether or not all essential figures have been included in this

disclosure of information.

User-Friendliness: How user-friendly is the data we collected?

To assess how “user-friendly” our data is, we investigate whether or not it is convenient for an internet user

to obtain information on pollution-source pollution.

To determine the scores, we primarily analyze online data sources, and investigate information collected

from “disclosure upon public request” applications and other evaluation results.

2. Assessment Methodology SummaryThe grading system for each assessment criteria is based on a 100-point scale. The four metrics used

to analyze our data—“Systematic,” “Timely,” “Complete,” and “User-friendly”—are given one of six grades:

“Excellent,” “Good,” “Moderate,” “Fair,” “Poor,” and “Very Poor.” If the raw score of an assessment aspect is

between two scoring grades, it can be either rounded up or down in accordance to the “rules for raising and

lowering of grades.” 17

17. For more information on these rules please refer to: http://www.ipe.org.cn/about/notice_de.aspx?id=1347.


The “Systematicness”-Restricted Scoring Rule:

The “systematicness”-restricted scoring system is used throughout the entire data evaluation process. Under this rule, a given assessment item’s “systematicness” aspect score is used to limit the other aspect scores (i.e. how timely, how complete, and how user-friendly data is). As a result, an assessment item’s final scores for the other three metrics (“timely,” “complete,” and “user-friendly”) are not allowed to exceed that data indicator’s “systematic” ranking. The specific “systematic” metric-restricted scoring system’s control guidelines are shown below:

Appendix Graph 2-2. Grading Rules for Systematic Disclosure Control

Systematic Metric

Timely, Complete, User-FriendlyExcellent Good Moderate Fair Poor

Excellent Excellent Good Moderate Fair Poor

Good Good Good Moderate Fair Poor

Moderate Moderate Fair Fair Fair Poor

Fair Fair Poor Poor Poor Poor

Poor Poor Poor Poor Poor Poor

The “systematicness”-restricted scoring system has been implemented because the “systematicness”

metric evaluates how regularly and continuously data is published. This metric also investigates how complete

the data is; this metric primarily looks at the quantity of data published. On the other hand, the metrics “timely”

and “complete” primarily assess the quality of data disclosed, while “user-friendly” measures the quality of the

publication of data itself. Since these three aspects are assessed based on published data, when scoring the

last part we must emphasize the importance of the amount of information published compared to the amount

which should have been published. The score for the “systematic” metric includes a section on how complete

data is, so it reflects to a greater extent the quantity of information published. There are exceptions to rules

for the “systematic metric”-restricted scoring system.

The following data evaluation criteria are not considered under the “systematic” metric: “information

disclosure upon request,” and whether data is “timely,” “complete,” and “user-friendly”.

64

Visual Comparison of the Annual Scores for All Evaluated Cities (Organized by Province)

Appendix 2


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PITI Partner Score GraphsAppendix 3


72

Thank you to the SEE Foundation for funding this report.

The original text and suggestions are those of the authors of this report

and are not necessarily representative of the SEE Foundation.

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