Foreign Experts Advisory Committee
Proposals Title:
Urban Air Quality



China’s severe air pollution at the start of 2013 once again made international headlines.  Smoggy weather affected a total area of 1.43 million square kilometers and a population of 800 million people.[i]  In January Beijing only saw five clear days[ii], and in many districts of the city, air quality indexes hit 500 –the highest level, meaning that the air quality was beyond the “hazardous” level.  Concentration level of multiple pollutants such as PM10, NO2, SO2 and PM2.5 reached record highs.  At some monitoring stations, instantaneous concentration for PM2.5 read 1,000 micrograms per square meter.[iii]  Beijing Pediatric Hospital provided urgent care treatment for a record 9,000 children in a single week, over 50 percent suffered from respiratory illness.[iv]


In response, the Beijing government adopted several emergency measures including ordering 30 percent of the city government’s vehicles off the road and shutting down 103 heavily polluting factories.  However, temporary solutions like these won’t be able to address the root causes of the problem.  For example in the case of PM2.5 in Beijing,  22 percent hs been attributed to motor vehicle emissions, 17 percent from coal burning, 16 from urban dust, 16 percent from industries, 4.5 percent from agriculture, with the remaining  24.5% transported from neighboring regions such as Tianjin and Hebei.[v]  While Beijing consumes 23 million tons of standard coal every year and plans to cap its coal use below 20 million tons by 2015, Tianjin and Hebei consume 73 million and 270 million tons of standard coal every year respectively.[vi]  Obviously, efforts made by Beijing alone are not enough to improve the air quality.  Actions are required at the regional and national levels to overcome the nation’s environmental challenges. Some of the specific obstacles include:

·Lack of direct links between pollution reduction targets and environmental quality and health standards.  China’s present environmental management system is focused on achieving a set of pollution control targets (Total Emissions Control for SO2 and NOx for example) which are primarily based on estimates of local reduction capacities and implemented through discharge standards.  While these targets are directionally correct in the sense that they focus on pollution reduction, there is no direct management link between pollution reductions and improvement in environmental quality and therefore protection of human health.

  • Lack of coordination between the Ambient Air Quality Standards, Vehicle Emissions Standards and Fuel Standards.  Over one-third of the nation’s total NOx emissions come from transportation sector. Automobiles are the major source of PM2.5, SO2, O3 and lead pollution in urban areas.[vii] China’s fuel standards lag behind the vehicle emissions standards, and lower grade diesel quality is  a particular challenge. Except for a few large cities such as Beijing and Shanghai, most cities in China are still using National Emission Standard III (NES III)-compliant fuel standards[viii] due to the shortage of higher quality fuel supplies.  Vehicle emissions and fuel standards must be synchronized to improve the nation’s air quality.

·Lack of co-control over multiple pollutants. Despite the reduction of SO2 emissions since 2005, traditional coal-burning pollution problems such as acid rain have not been solved (the share of total land area affected by acid rain dropped only by 1.3 percentage points by 2010) and a more complex regional air pollution challenge characterized by secondary pollutants such as ozone and PM2.5 has emerged.  Pollutants such as SO2, NOx, PM, and VOCs must be controlled together to resolve PM2.5 and ozone problems.


  • Lack of legal mechanisms to ensure compliance with the new Ambient Air Quality Standards.  The 2012 Ambient Air Quality Standards listed six criteria pollutants (SO2, PM10, PM2.5, O3, CO, NO2) and for the first time added in an eight-hour concentration limit for O3, 24-hour and annual limits for PM2.5 based on the Interim-1 targets (the lowest) set up by the World Health Organization (WHO).  The new standards, to be implemented in three phases, will come into effect nationwide in 2016 and require non-attainment regions to set up implementation plans.  However, there are no consequences for failing to meet the ambient standards.  China’s current Air Pollution Prevention and Control Law was amended in 2000 and efforts to update the law have been delayed since 2010. The legislation does not provide sufficient legal assurance for the implementation of the new air standards.  Other than requiring compliance with SO2 total emissions control target, the current law contains no provisions concerning the other pollutants. Furthermore, the law caps maximum penalty for non-compliance at 500,000RMB which is too low to deter violations since control costs are almost always higher.




The sheer scale and complexity of the pollution problems indicate that China’s air quality cannot be improved overnight.  However, substantial progress could be achieved by removing the bottleneck caused by the current focus on means rather than ends.  Reforming the current system to focus on protection of human health and environment would:

  • Establish integrated institutional mechanisms designed to deliver health and environmental outcomes
  • Create a framework of public engagement and communication that would allow everyone to understand the problem, the steps being taken to solve the problem, and the likely timeframe in which the problem could be solved
  • Require the systematic collection of information, assessment through air quality modeling, and priority setting
  • Provide a common framework for coordinating the actions of various units of government with authority over elements contributing to the problem.

1.Set protection of human health and ecosystems as the sole and ultimate goals of the environmental management system

It should be clearly articulated in all environmental laws, regulations, and any documents that comprise China’s National Environmental Management System that the sole and ultimate goals of the environmental management system are to protect public and ecosystem health. It is critical that the goals should not be tied with the stage of China’s economic development e.g., level of GDP or industrial stage.

To achieve these goals, ambient environmental quality standards should be designed based on the scientific understanding of the pollutants’ effects on human health and ecosystems, regardless of economic and technological feasibilities and costs. The goals may not be readily achievable. The point to the ambient standard setting process is to define the pollution threshold beyond which significant health damage occurs.  Discharge standards on the other hand are transitional requirements that take costs and feasibility into consideration in the process of setting technology-based discharge standards for industrial sectors.  The ambient environmental quality standards should be assessed, revised, and updated regularly (e.g., at least once every five years) so that they are in line with the latest scientific findings. Environmental monitoring standards and regulations should be developed to accurately measure ambient conditions against the health-based ambient air quality standards.

Risk-based pollutant priority assessment is needed. A standing institutional mechanism to regularly review and evaluate the scientific understanding of the relationship between pollutant discharges and health is needed to advise MEP on the scientific understanding of risks and recommended control levels.

2. Link emissions control targets directly with achieving specific environmental goals

A clear linkage must be established between ambient standards designed to maintain pollutant concentrations at environmentally protective levels and national or regional pollution caps designed to limit total pollutant loadings and control transboundary flows. The two policies must be integrated to avoid antagonistic effects especially if market-based implementation policies are applied. For example, policies to control transboundary pollution problems such as acid rain focus on reductions over broad geographic regions.  Policies such as cap and trade have been successfully applied to significantly cut SO2 emissions, the chief precursor of acid rain.  However, at the local level, SO2 can have significant health effects.  Therefore, a failure to coordinate regional and local control strategies could result in local concentrations exceeding the ambient health-based standard at the same time that regional caps are met.  Neither ambient standards nor pollution caps linked to protecting human health and the environmental may be readily achievable, but stepwise implementation policies should be established that link the interim targets and the improvement of air quality. It also needs to be clear that ambient standards and targets may change over time in relation to changing economic, demographic, and atmospheric conditions. Targets must be reviewed on a specified, recurring timeframe to determine what policy action is needed to meet the goals of protecting human health and the environment.

It is recommended the Ministry of Environmental Protection (MEP) organize comprehensive research on the environmental carrying capacity of key national development zones and preferred development zones and on the assimilative capacity of river basins. The findings should inform the formation of subnational target allocation criteria. The selection of a fixed baseline year is also critical to measure the progress made in improving air quality. In addition, effort should be devoted to developing sectoral caps (eg. a cap for total NOx emissions) for the major industrial source sectors such as electricity, cement, iron and steel and automobile industries.

3.Develop, maintain and update scientifically sound pollution inventories

Scientifically sound pollution inventories should be developed, maintained and updated as a foundation for understanding the scope and source of environmental problems and for determining and applying appropriate permit or regulatory controls and market mechanisms to pollution sources. One of the most powerful modern environmental management aphorisms is “you manage what you measure”.  Accurate reporting and inventories are absolutely key to the compliance evaluation that lie at the heart of the incentives for control.


As China expands its environmental targets to include energy intensity, carbon intensity, limits on total coal combustion, limits on the total proportion of energy use that can be derived from fossil sources, a limit on the minimum amount of electricity that must be generated from renewable energy, the statistics gathered to measure performance against these goals are also helpful in cross-checking against the reporting of more conventional pollutants such as SO2 and NOx. These databases should be coordinated for consistency.

4.Improve coordination between ambient air quality standards, vehicle emissions standards and fuel standards

More authority should be conferred to MEP for fuel quality standards development since vehicle emissions systems are designed for specific fuel quality tolerances. MEP should also be empowered to play a bigger role in overseeing the fuel’s toxic constituents. Efforts should be strengthened to speed up the development and implementation of fuel quality standards for National IV and V vehicle emissions standards and the emissions standards on hazardous substances from fuels; improve the management of gasoline detergent additives; promote low sulfur fuels for vehicles; and establish a clean fuel development strategy. In addition, continuous efforts should be made to increase incentives for low emitting vehicles and disincentives for high emitting vehicles in order to speed up the replacement or elimination of "high-emitting” vehicles (such as yellow labeled vehicles). The air quality impacts of transportation infrastructure need to be evaluated as part of the planning and permitting process. Residents should be encouraged to choose green commuting measures through fuel taxes, congestion fees or administrative orders that help keep vehicles off the road. The attractiveness of public transit system should be enhanced through subsidies and system upgrades.


  1. Improve regional coordination on air pollution control and prevention.


Air quality basins should be delineated. A special study should be launched for regional air quality management with a special focus on institutional and policy design and implementation. The lessons from the priority regional air quality management regions established by the State Council should be harvested and implemented. Air quality modeling capabilities and needs should be assessed and recommendations supporting regional air quality management made.

Alternative institutional arrangements to promote effective regional coordination on air pollution prevention and control should be tested and evaluated. For example, air quality commissions could be established for each regional air shed with representation from all local governments in the region. Local governments in the region would be required to sign a binding agreement for regional air quality assurance as has been done with the major emission sources. The commissions would be given a separate budget and take full charge of the implementation of the agreement. Regional air quality databases and monitoring networks would have to be developed to support management and decision-making. Cities that fail to meet the Grade II national ambient air quality standards would have to formulate plans for MEP’s approval to meet the air quality standards, and ensure air quality improvements on a negotiated schedule. For cities in non-compliance, MEP could withhold permit approval over new construction projects that discharge air pollutants. The effectiveness of these plans would need to be established through rigorous air quality modeling.


  1. Improve legislation, permitting, enforcement and public participation


The air law should be amended to include coverage for all major pollutants. Caps on penalty amount shall be lifted and the amount of penalties imposed on polluters must be increased significantly in order to make the cost of non-compliance higher than compliance. Adoption of a cumulative “Per Day, Per Violation Penalty” will help to achieve this goal. Additional penalties could be levied based on the severity of the damage caused. Furthermore, China should establish a penalty to capture the economic benefit of non-compliance that has accrued to violators by avoiding the costs of installation and maintenance of required control equipment and failure to meet other environmental requirements.


Connections must be established between permit issuance and total emissions control targets to ensure attainment of environmental quality standards. Approval of new projects in non-attainment regions should be suspended. New sources discharging pollutants covered by total emission control requirements must offset their added incremental discharges. Permits should contain comprehensive information on emission sources, location, amount, control methods etc. and shall be available to the public for consultation and review in a timely manner. For example, monitoring results under the new air standards should be published for the 113 key environmental protection cities in 2013 and for all cities in 2015.


Local governments should develop mid- and long-term strategies for environmental quality and emissions reductions as well as a detailed implementation plan to achieve the air standards. In case local governments fail to make a required submittal or make a submittal that is determined to be incomplete, sanctions such as restrictions on project approval and/or a MEP-developed implementation plan should be triggered. Additionally, meeting the air quality standards (or their associated interim targets) and total emissions control targets should become the key components of the environmental performance contracts signed by local government officials.

Meaningful public participation must be guaranteed in the environmental impact assessment (EIA) process. The EIA should be conducted not only for comprehensive planning, functional planning and development projects, but also on major government policies, social and economic development plans. Furthermore, public hearings should be held prior to the government’s adoption of environmental laws, regulations, and policies with significant environmental impacts.

7.Promote the use of market mechanisms

China needs to increase the use of market-based economic incentive tools such as emissions trading, taxes and natural resource pricing and establish supporting policies, institutions, and guidance for each of the market-based policy alternatives under consideration. Instead of command-and-control, more market tools should be adopted to speed up economic transformation to a service-based economy, and to promote investment in energy efficiency and clean energy.









[viii] For gas, sulphur levels below 150ppm; for diesel, suphur levels below 350ppm.

Related Information

FEAC WG5  Consulting Meeting on Urban Air Quality Minutes

Date 2013-3-26  
Venue Beijing Foreign Experts Building  
Chairperson Mr. Liu Yanguo  
Participants SAFEA Team

Ms. Li Bei

Mr. Liang Boshu

Mr. Jiao Jinghu

Mr. Zong Yan

Ms. Pei Yuhua

Foreign Expert Mr. Daniel J. Dudek
Chinese Experts

Mr. Wang Jian ( MEP)

Mr. Chai Fahe (CRAES)

Mr. Lu Shize  (MEP)

Mr. Zhang Jianyu (EDF)

Ms. Yuan Yi( EDF)

Mr. Gao Jian  (CRAES)


Participants Remarks/Points of View
Mr. Daniel J. Dudek ☆ Emphasized that his proposal is written from a systematic point of view
☆ Outlined his draft proposal
   -- PM2.5 air quality problem: challenges and obstacles
      1) Three trends that is worsening the situation
         A. Climate change
         B. Urbanization
         C. Continuation of economic growth
      2) Calls for institutional reform/multiple pollution control
   -- Recommendation
      1) Human health and ecosystem as the sole and ultimate goal of environmental management system
      2) Emission control targets be directly linked with achieving specific environmental goals
          Emission control targets should vary with the regional and industrial differences.
Mr. Daniel J. Dudek       3) Scientific and sound pollution inventories be developed, maintained and updated
          Cited the example of the cooperation between US Dept. of Energy and EPA of US
      4) Coordination between ambient air quality standards, vehicle emissions standards and fuel standards be improved
      5) Regional coordination on air pollution control and prevention necessary
         A. Cited the successful case of 2008 Beijing Olympic Games
         B. Regional air quality commission be established.
         C. Local governments abide by a binding agreement for the air quality assurance 
      6) Legislation, permitting, enforcement and public participation be improved
      7) The use of market market-mechanisms be promoted.
☆ Emphasized the importance of using offsetting measures
Mr. Wang Jian ☆ Introduced MEP's future efforts in this regard
   -- To press ahead with 12th National 5-year plan environmental protection
      * Reduce annual average PM2.5 intensity by 5% and 6% in key areas by 2015
      * Beijing to reduce by 10%
      (NB: WHO's prescribed PM2.5 intensity standard is 12 while US adopts 10, EU 25 while China 35)
   -- To kick off managing the urban air quality standard
      * Target of PM2.5 intensity of 35% to be reached nationwide by 2030 
   -- To exercise the strict legal measures 
      * Already released caps for 6 industries of 47 cities in key areas
      * Stricter cap requirements to be imposed in these areas and industries
   -- About vehicle emission standards
      * Beijing has already adopted National V vehicle emissions standards
      * National IV standards is already put into effect nationwide
      * National IV fuels will be provided nationwide by end of 2014
   -- To set up joint air pollution prevention and control mechanism
      *  To set up Beijing-Tianjin-Hebei air pollution control mechanism
   -- To set up emergency mechanism for heavy pollution weather
      * Early warning and forecasting
      * Emergency response mechanism
      * Law enforcement and supervision
      * Post-emergency analysis and evaluation
☆ Agreed with Mr. Dudek that the protection of human health and ecosystems should be the ultimate goal of the environment
management system
      * Already started a joint project of studying the relationship between human health and air pollution control with Ministry of Health
☆ Expect a breakthrough in working out economic incentives for air pollution control
☆ Expect to have further and fruitful cooperation with Mr. Dudek on formulating economic incentives to better control air pollution
Mr. Chai Fahe ☆ Suggested Mr. Dudek elaborate following points in his proposal
   -- Linking vehicle emissions standards with fuel standards
   -- "Per Day, Per Violation Penalty"
   -- Denitrification/desulfurization subsidy policies
   -- Reducing the impact of resource pricing on the environment
   -- How to develop pollution inventories by referring to US experiences
☆ Suggested Mr. Dudek include in his proposal
   -- Strategic and technical roadmap by US government to control PM2.5 intensity for China's reference
   -- How to set up early warning and forecasting mechanism
   -- Measures for emergence response mechanism for heavy pollution weather
   -- Roadmap for controlling VOCs
☆ Shared views on certain points in  Mr. Dudek's draft proposal
   -- About protection of human health and environment management system
      * The newly amended Ambient Air Quality Standards released on Feb. 29, 2012 has already taken this concern into consideration 
   -- About linking ambient air quality standards with emissions control targets
      * Efforts are being made in this regard
   -- About cap and trade policies
      * They are very effective in US but may not be so in China for there is little margin for trading in China.
Mr. Liu Yanguo ☆ Suggested Mr. Dudek in his proposal
  -- Emphasize the importance of setting emissions control targets against protecting human health
  -- Mention the difficulties MEP is facing in tackling air pollution given the country's economic growth target and ongoing urbanization 
☆ Concluded the meeting 
  -- by suggesting participants provide suggestions and comments to FEAC cyber community 
  -- by suggesting Mr. Dudek revise the draft proposal in the light of today's discussion and submit the new proposal to FEAC website on April 10
  -- by proposing the next consulting meeting on April 15
  -- by proposing the deadline of submitting proposal to the State Council, April 20 (TBC)


New Proposals
Note :
1. You are encouraged to focus on the topics by SAFEA Team which would help you make the proposal more relevant to the concerns of the central leadership.
2. The proposal is expected to consist of the background information, problem finding, analysis and resolution.
3. The problems to be addressed should be related to relevant policy and strategic development.
4. The introduction of international practice or advanced expertise is encouraged.
5. Proposed resolution should be specific and operational.
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