Centralization of Environmental Protection Institutions in the Xi Administration: A Deep Dive into Chinese Policy Documents

As the largest greenhouse gas emitter, China’s decarbonization endeavor dictates the climate goal of the world. Fortunately, the high-level officials of the Chinese Communist Party (CCP) have been showing sincere support for the global decarbonization initiative: Xi announced China’s 2030 carbon peaking and 2060 carbon neutrality goal in an address to the UN General Assembly in September of 2019. However, the political will from the top leaders has to tread through an institutional setup plagued by fragmentation and conflicting interests, two of the leading legacy issues spawned from decentralization in the reform era. Addressing these obstacles, Xi has orchestrated a series of centralization campaigns that enhanced China’s state capacity under the pretext of combating climate change. Regardless of the true motivation behind these campaigns, it is crucial that the reader understands the evolution of these institutions governing China’s climate change effort, not least because of their pivotal mediating roles in translating central climate change decrees to local actions – the institutional evolution is also a good case in point to illustrate a broader social and political tectonic shift unfolding in China right now: the drastic increase in state power percolate deep into society, transforming China at a rate unseen since the reform era. 

Central-level decrees are often met with quiet yet insidious opposition from the local-level officials, whose political survival logic differs from the central-level leaders; the fragmented and weak Environment Protection Administration (EPA) aggravated this division. Xi gradually installed new monitors and punitive mechanisms that strengthened the relative position of the central government: vertical management of monitor, supervision, and enforcement (监测监察执法垂直管理制度), as well as the central ecological and environmental protection inspection(生态环境保护督察). These new institutions retracted the supervisory and decision-making power back to the top. 

Past Institutional Shortcomings: Bureaucratic Fragmentation

Before the institutional reform, the regulatory power of environmental protection was scattered around multiple ministries under the state council, and this dispersion of authority hindered any appreciable reform on environmental protection norms. The Environmental Protection Law of 1989 established the Environmental Protection Administration (EPA) as a ministry under the state council, and the EPA oversees all affairs of environmental protection. However, the law also qualifies its power by allocating authorities to “national ocean administrative and managerial departments, port authorities, fishing affairs, fishing management, army environmental protection department, public security, transportation, railroad system, and civilian flight management department.” More importantly, the environmental protection law further diminishes the authority vested in EPA by assigning regulatory power to “county-level land use, mining, forestry, agricultural, and water management departments.” Most, if not all of EPA’s jurisdiction overlaps with other local-level departments’ domains.

The local pollution statistics, a crucial determinant of cadre evaluation and selection, can be easily manipulated by local officials. A lack of wherewithal partially causes the collusive data collection process, but the intentional self-interested manipulation of data is also a prevalent issue. For the most part, the monitoring departments are under the control of the local governments. To modify these statistics, the local officials can blatantly lie about the statistics or underhandedly tweak the methodology and baselines to massage the data into desirable outcomes. As a result, the environmental protection indicators on the performance scorecards are positively biased towards local officials’ favor. 

Centralizing Regulatory Power: Vertical Management and Supervisory Inspection

With the newly vested power, Xi speeded up the pace of implementing these institutional reforms. With the Guidelines for Reform on Environmental Protection Agency’s Vertical Management of Monitor, Supervision, and Enforcement (关于省以下环保机构监测监察执法垂直管理制度改革试点工作的指导意见), Xi addressed many of the weaknesses that have been plaguing China’s environmental protection institution. Vertical management refers to the enhancement of the connection between upper-level EPA and its lower-level subsidiaries: the head provincial level EPA, not the head of the local government, will now directly appoint the prefectural level head of EPA; the county-level EPA is now a direct subsidiary department within the prefecture-level EPA. These policies strengthened the vertical bond between EPAs, and thus the local EPAs are more independent from the influence of local governments. 

The document also addressed data manipulation by mandating a centralized monitoring infrastructure network: the prefectural and county-level monitoring team now directly answers to the provincial level EPA cadres instead of the local government cadres to prevent data manipulation. This document proposed a solution to the institutional weaknesses caused by an imbalance of power. Yet, the actual implementation of this document did not come until later. For instance, in the case of Zhejiang, the provincial government implemented this three years later in 2019, and propagating down to the city level, Hangzhou implemented this document in 2020. 

To address the assignment of responsibility, the General Office of the Central Standing Committee — the top organ of CCP and the loudspeaker for Xi’s decree — administered Measures for the Accountability of Party and Government Leaders for Damage to the Ecological Environment (党政领导干部生态环境损害责任追究办法), a document emphasizing on the severity and the collective responsibility between the party cadres and its state counterparts at the similar level. It highlights the priority of environmental protection and demarcates the responsibility shared by the head and cadre leader of the government and the party organization at the provincial and prefectural levels. The designer of this document is aware of the potential conflict between the cadre evaluation scorecard categories and draws the categorical red lines that cadre cannot surpass in the environmental protection category, regardless of the cost. 

To further implement this new division of responsibility, Xi deployed ecological supervisory inspections teams. Specifically, Xi established the Ecological and Environmental Protection Supervisory Inspection Leading Group and assigned Han Zheng as the chair of the leading group. The teams collect local complaints and conduct independent inspections to ensure that the local cadres are conforming to central-level decrees on environmental protections. 

The supervisory inspection task teams are now equipped with detailed delineation of responsibilities across the vertical and horizontal chain of local governments; their data are provided by a unified provincial-level data monitoring agency directly responsible to the central level EPA; and the supervisory inspection task force report directly to Han Zheng’s team, who is at the top of CCP’s pyramid. 

As much as this process is centralized, the effects of these supervisory inspections are still tainted by government-business ties. A recent study looked at the effect of these supervisory inspections on air pollution curtailment. The research inspected heterogeneity in the positive effects of supervisory inspections on air pollution across provinces. Overall, in the short term, air pollution was reduced. However, the long-term effects decay quickly over time. In some cases, the pollution level recovers to the pre-inspection level only after a few months. Moreover, provinces with a large percentage of manufacturing sectors can see a more prominent effect, whereas cities with a higher share of high-tech and service sectors see minor effects in these supervisory inspections.


In a country as diverse as China, local and central cadre conflict of interest is a permanent theme of contention. However, as we observe, even after implementing such a comprehensive set of centralization policies, some of the weaknesses of the environmental protection institutions remain, only receding to a lesser degree. In addition to strengthening the vertical bond, the government should expand its horizontal scope to encourage public involvement. After all, when such participatory pathways exist, the concerned citizens could very well replace the role of the supervisory inspection task team – the ordinary people are the ones who suffer from environmental degradation. If the government could open the upward flow of information, the local government would have to answer to ordinary people’s interests, whose rights are increasingly being looked after by the benevolent leader.

Image Source: CGTN

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Chi (Will) Gao

Chi Gao is a second-year MCEPA student with a concentration in Chinese Economics at the School of Global Policy and Strategy. He graduated from UC San Diego with a joint major in Mathematics and Computer Science. His research interests include the evaluation of disruptive technologies, application of Geographical Information System in Political Science, and the interaction between China’s political economy and its overseas investment.

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