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Context and Systems: Thinking More Broadly About
Effectiveness in Strategic Environmental Assessment in China
Olivia Bina
Received: 7 December 2007 / Accepted: 17 March 2008 / Published online: 18 April 2008
Springer Science+Business Media, LLC 2008
Abstract China is an illustrative—and extreme—case of
the difficulties of balancing the pursuit of economic, social,
and environmental objectives. In 2003 it adopted a form of
Strategic Environmental Assessment (SEA) for its plans
and programs (referred to here as PEIA) with the aim of
moving towards greater environmental sustainability. The
literature has explored primarily the issue of methods and
legal procedures. This research contributes to the analysis
of PEIA through a different set of interpretative lens.
Drawing on recent developments in the theory and practice
of SEA, I propose a conceptualization of SEA effectiveness
that combines direct and incremental impacts, and a need
for context-specific systems as a way to focus on the
relationship between assessment, planning, and their con-
text, and thus maximize effectiveness. This framework
underpins the analysis of China’s experience, which I
explore with the help of interview material and the litera-
ture. The result is an evaluation of the strengths and
weaknesses of PEIA in terms of its purpose, assessment
concept, process, and methods. The detailed analysis of six
aspects of the context helps explain the origin of such
shortcomings, and identify opportunities for its improve-
ment. I conclude defining elements of a context-specific
system for SEA that seeks to maximize the opportunity for
incremental, as well as direct, effectiveness in China.
Keywords Strategic Environmental Assessment
Effectiveness System Context Purpose Strategy
China
Introduction
China is making its way out of poverty and underdevel-
opment at an unprecedented pace. Its success has lifted
hundreds of millions out of poverty (Liu 2007), but it has
also led to significant environmental degradation (Day
2005; Economy 2004). The resulting challenges impose a
sense of urgency to integrating environmental concerns
into development choices, and searching for improved
environmental governance (OECD 2007). It is in this
context that Strategic Environmental Assessment (SEA)—
an increasingly popular mechanism for environmental
policy integration and the strengthening of environmental
governance (Sheate and others 2001; Wallington and oth-
ers 2007)—is attracting attention in China (China Daily
2007; Xiuzhen and others 2002). SEA is defined as a
‘‘tool,’’ and a process, for the systematic analysis of the
potential impacts of programs, plans, and policies (PPPs)
on the environment (Sadler and Verheem 1996; The
´
rivel
and others 1992). Since the mid-1990s there has been a
rapid uptake of this assessment mechanism throughout the
developed and developing world (Dalal-Clayton and Sadler
2005). In line with this growing trend, China’s State
Environment Protection Administration (SEPA) and State
Council’s Environmental and Natural Resources Commit-
tee (ENRC) began negotiating the text for an EIA Law in
1998, so as ‘‘to address the failure of development policies
O. Bina (&)
Centro de Filosofia, Faculdade de Letras, Universidade de
Lisboa, Alameda da Universidade, 1600-214 Lisboa, Portugal
e-mail: o.c.bina.92@cantab.net
O. Bina
Centre of Urban and Regional Systems, Instituto Superior
Te
´
cnico, Lisboa, Portugal
O. Bina
Geography and Resource Management, The Chinese University
of Hong Kong, Shatin, Hong Kong, SAR, People’s Republic of
China
123
Environmental Management (2008) 42:717–733
DOI 10.1007/s00267-008-9123-5
and plans in assessing the environmental consequences of
government actions’’ (Zhu and Ru 2007). Five years later,
the new EIA law of China (NPC 2002) included provisions
for an SEA-type procedure: the environmental assessment
of plans (hereafter, SEA refers to international practice and
PEIA refers to China’s experience, after Tao and others
2007).
The requirement entered into force in 2003 and expe-
rience is therefore still limited, however, scholarly debate
on this new field of environmental policy mechanisms is
growing rapidly. The analysis has focused on the nature of
legal requirements (Bao and others 2004; Gu and Sheate
2005; Wang and others 2003) and on case reviews and
methodologies (Bao and others 2004; Lindhjem and others
2007; Tao and others 2007; Xiuzhen and others 2002). In
terms of the literature on PEIA in Chinese, Che and others
(2002, cited in Zhu and Ru 2007) note that ‘‘[m]ost of [the]
research (on SEA in China) has been focused on the con-
cept, theory, and method of SEA.’’ A similar trend can be
seen for Taiwan SEA studies (Liou and others 2006). The
contribution by Tao and others (2007) introduces a new
level of in-depth analysis from a sectoral perspective: that
of landuse plans, which is a traditional area of application
for SEA around the world.
Overall, this initial focus on regulatory and technical
aspects follows the same pattern of inquiry that charac-
terized research in Europe, the United States, and
elsewhere during the early 1990s (see two prominent
examples: Sadler 1996; The
´
rivel and others 1992).
Although most of the authors mentioned above, notably
Bao and others (2004), list a number of PEIA examples
‘‘successfully carried out’’ in China since the 1990s, the
country’s experience with PEIA is still in its early days.
Zhu and Ru (2007) remark that ‘‘[t]opics such as the
adaptation of SEA concepts, the motivation and politics
underlying legally mandated planning EA [environmental
assessment], and the implications of current institutional
arrangements for the effectiveness of planning EA have yet
to be examined’’ in China’s context. Their analysis of the
political and institutional dimensions underlying the EIA
Law and its implementation marks a shift in scholarly
debate on PEIA in China. The shift is in line with discus-
sions that have characterized the SEA discourse since the
late 1990s (Bina 2003; Brown and The
´
rivel 2000; Caratti
and others 2004; James and others 2003; Owens and others
2004; Partidario 2000; Wallington and others 2007),
arguing for a better understanding of how the context of
SEA—politics, culture and society, and the organizations
and institutions therein—can influence the effectiveness of
assessment, as well as how SEA can itself influence
(improve) the context.
In fact, the SEA discourse has changed significantly
since the early idea of SEA as a development of project-
EIA (Petts 1999; Sadler 1996; The
´
rivel and others 1992). It
eventually evolved into a much wider range of approaches
and methods, but perhaps most importantly, it moved from
the so-called technical and rational domain of assessment
and evaluation, to embrace the diverse realm of good
governance, social and policy learning (Bina 2007;EC
2005; Hertin and others 2007; Vicente and Partidario 2006;
World Bank 2005). Two decades of practice have shown
that good information alone—though essential—will not
necessarily lead to better planning or better choices
(Jasanoff and Wynne 1998; Owens and others 2004). It is
the context within which planning and assessment occur,
and especially all the qualities that are commonly recog-
nized under the framework concept of ‘‘good governance’’
that makes the difference. Hence, the growing attention to
the context, and the institutions and organizations therein
(Audouin and Lochner 2000; Hilding-Rydevik and
Bjarnado
´
ttir 2007), which Zhu and Ru (2007) and Gu and
Sheate (2005) have contributed to unpack in relation to
China.
The purpose of this research is to contribute to the
analysis of China’s experience to date through a different
set of interpretative lens. While China is still new to SEA,
it may need to move rapidly to learn and adapt to the new
ideas and innovative approaches if it wants this mechanism
to help deliver more sustainable plans. Thus, I propose to
explore the purpose and practice of PEIA from a systemic
and context-specific perspective, and to suggest ways to
strengthen the effectiveness of practice—including its
strategic dimension—as it evolves. This article develops in
five sections: a conceptual proposition linking effective-
ness of SEA to its context and to the idea of SEA systems;
a critique of China’s PEIA experience to date; an analysis
of key aspects of China’s context influencing the shape and
effectiveness of the current PEIA regime; the proposal of a
context-specific system for SEA in China; and conclusions.
I base the analysis on a range of sources. In addition to
recent literature on the subject, I use primary data, in the
form of semi-structured interviews: 22 held with senior
bureaucrats from a Ministry responsible for a part of
China’s transport systems (hereafter referred to as ‘‘trans-
port ministry’’), bureaucrats from SEPA and its Appraisal
Centre for Environment and Engineering (ACEE), techni-
cal experts from specialized government agencies in the
field of transport (transport and economic planning) and
environment (often translated as ‘‘design’’ or ‘‘research’’
institutes), and representatives from consultancies; four
interviews with academics; and ten with foreign consul-
tants and officers of international organizations. The
interviews were conducted between 2005 and 2007. Some
were carried out as part of my on-going research into
China’s environmental governance capacity, and some as
part of a project into ways of institutionalizing SEA within
718 Environmental Management (2008) 42:717–733
123
the ‘‘transport’’ Ministry. Only a selection of the interview
material has been used for this article. To respect confiden-
tiality, all interviews have been coded: ‘‘CG’’ refers
to informants working within a Chinese government orga-
nization, ‘‘A’’ refers to academics, and ‘‘I’’ refers to
informants working for nonChinese agencies. I also refer to
comments made by experts during the International
Conference on Strategic Environmental Assessment (organ-
ised by SEPA, 3–4 November 2007, Beijing), and a training
course on Public Participation in EIA and SEA (organised by
ACEE and SEPA, Guiyang, China, 3–6 April, 2006).
Effectiveness and Context-Specificity of SEA Systems
Effectiveness and Context
The issue of effectiveness is central to debates on analytical
systems. SEA is meant to improve the environmental
quality of strategic initiatives, such as policies, plans, and
programmes (PPPs), so as to contribute to environmentally
sustainable development. The common understanding of an
effective SEA is one where the object of the assessment (a
PPP) will avoid damaging the environment, and will con-
tribute to sustainability (Dalal-Clayton and Sadler 2005;
Owens and others 2004; Sadler 1996; Wallington and
others 2007; World Bank 2005). Runhaar and Driessen
(2007) suggests that this form of ‘‘direct’’ effectiveness is
expressed through changes in the decision-makers’ under-
standing or awareness of environmental and sustainability
issues, and in the extent to which such issues are consid-
ered throughout planning and decision-making linked to
the PPP under scrutiny.
However, SEA’s capacity to influence PPPs is often
constrained (Runhaar and Driessen 2007). The persistent
failure of planning and decision-making to deliver envi-
ronmentally sustainable development is closely linked to
the limited environmental governance capacity of the
machinery of government, and ultimately, it is this capacity
that needs to be strengthened (Jordan and Lenschow 2008;
OECD and UNDP 2002). For this reason, a second con-
ception of SEA effectiveness has been proposed: the idea
of an incremental change in mindsets, in the level of
awareness, the institutional and organizational setups, and
the culture that drives planning (Bina 2003, 2007; Hilding-
Rydevik and Bjarnado
´
ttir 2007; World Bank 2005). As
Nykvist and Nilsson (submitted) explain: ‘‘to enhance the
potential for integrating sustainability concerns, it seems
less fruitful to develop more advanced and complex
assessment frameworks and models than strengthening
institutional arenas for social learning.’’ Learning and
changes in mindsets are more long-term impacts that refer
to the context in which SEA is applied. Here the object of
SEA moves beyond PPPs, to include the environmental
governance capacity of institutions and organizations. As a
result, in this analysis, ‘‘context’’ refers to a set of
dimensions that (1) can enable—or constrain—SEA’s
direct effectiveness on PPPs, or (2) can be considered the
complementary object of SEA—with the aim of promoting
incremental effectiveness. The latter case focuses on the
potential of repeated applications of SEA leading to a
virtuous circle of enhanced environmental governance
capacity within the different dimensions of context.
But what are the contextual dimensions involved? Ini-
tially, the interpretation of context in SEA literature was
rather narrow, focusing on aspects of planning procedures
and of policy and decision-making processes (see, for
example, Brown and The
´
rivel 2000; Clark 2000; ERM
1998; Partidario 2000; Sadler 1996b). Here I wish to
include the factors that define and influence such proce-
dures (rules and regulations) and processes. Thus, context
‘‘includes the organization and institutional location of the
decision-making process
…, which are themselves situated
within and influenced by a given society and its broader
social, cultural and political values’’ (Bina 2007). The
political and cultural dimensions are effectively the back-
drop to all other contextual elements (see Fig. 1, right). For
example, the political dimension of policy-making pro-
cesses is recognized as an often-definitive influence over
SEA’s effectiveness. The tendency to try to isolate (even
ignore) this dimension and favor a more technocratic
interpretation and analysis of the process, has shown its
limitations, not least in the policy analysis tradition. Poli-
tics plays a key role in defining the purpose of instruments
such as SEA. The cultural dimension is also critical in
determining how key activities are conducted in practice.
Most aspects, even if legislated for, will still be open to
context-specific interpretations: assessment, for example,
can be viewed as a bureaucratic phase of an administrative
procedure or as a dynamic process, and other aspects—
such as participation, consultation, co-operation, co-ordi-
nation, and knowledge management—are all subject to
cultural nuances, different constructions of reality, social
relations, and rationalities (Bina 2003).
The administrative dimension refers to the way all ele-
ments of planning and policy-making are managed on a
daily basis, including politicians’ interaction with civil
servants, and all procedures for data gathering, assessment,
planning, and decision-making. The institutional dimension
is interpreted to refer to legal and policy systems in place in
a particular context, which are of direct or indirect rele-
vance to the PPP being assessed, and to the SEA process in
particular. But it also can include the concept of ideology,
as a set of beliefs that ‘‘reflect and explain ‘reality’’’
(Jordan and Greenaway 1998 after Kuhn), of culture, as the
‘‘pattern of basic assumptions which a given group has
Environmental Management (2008) 42:717–733 719
123
invented, discovered or developed in learning to cope with
its problems of external… and internal adaptation’’ (Bate
1994 in: Cannibal and Winnard 2001). Thus, in practice
there is a strong dynamic interaction between contextual
dimensions, and it is the combination and relationship
between these dimensions that determines the capacity for
environmental governance, which in turn, influences the
design and effectiveness of assessment instruments such as
SEA.
SEA as a System
I maintain that the combination of direct and incremental
effectiveness (or impact) underscores the strategic nature
of SEA, and that for this strategic dimension to be upheld,
it is essential to adopt a systemic approach to the intro-
duction of SEA: one that goes beyond the setting of legal
requirements, processes, and tools (‘‘mechanisms’’ in
Fig. 1). Typically, bureaucrats and experts will introduce
SEA laws, processes, and tools drawing on existing
examples and notions of good practice. However, there are
limits to the transferability of notions across countries and
cultures. Conceptualizing and exploring SEA as a system,
permits us to focus on the relationship between assessment,
planning processes, and the context in which both are
shaped and implemented, and thus to maximize the
potential for direct and incremental effectiveness (Fig. 1,
bottom). Such focus is currently weak or absent. As a
result, assessment laws, processes, and tools are not
designed to actively pursue incremental-type effectiveness
such as social and policy learning. Instead, as Hertin and
others (2007) argue: ‘‘policy learning occurs despite, rather
than because of the instrumental design of the new
assessment procedures, which tends to act as a barrier to
open deliberation and knowledge utilization’’ (but see
Owens and others 2004 for a comprehensive discussion).
To define SEA’s systemic dimension, I draw on the
recent theoretical framework proposed by Wallington and
others (2007) who structured the ongoing discourse on
SEA theory and the basic assumptions underlying practice
in terms of three vital elements: ‘‘the substantive purpose
and values associated with SEA, the strategies chosen to
achieve that purpose, and the mechanisms for operation-
alizing SEA’’ (Fig. 1, left).
The first element sets the substantive purpose, ‘‘the
broad, long-term reasons for institutionalizing a system of
SEA within a legal framework, a planning context, and/or a
particular organization’’ (Bina 2007). It reflects the system
of values that is to be upheld through the application of
SEA, and Wallington and others (2007) define the sub-
stantive purpose of SEA as ‘‘a recovery of the original
intention of environmental assessment: to promote change
by inducing ecological rationality into systems of gover-
nance.’’ Here, ‘‘ecological rationality’’ is borrowed from
Dryzek’s (1987) work describing a fundamental type of
reason whereby ‘‘the preservation and promotion of the
integrity of the ecological and material underpinning of
society… should take priority over competing forms of
reason in collective choices with an impact upon that
integrity.’’ The second element, strategies, refers to the
different assumptions made about the values and rational-
ities that inform the context, and thus the formulation of
Fig. 1 SEA as a context-
specific system for direct and
incremental effectiveness
720 Environmental Management (2008) 42:717–733
123
PPPs, the process of decision-making, and of SEA itself. It
highlights SEA’s context-specificity: the idea that an SEA
system is influenced by—and can influence—the context in
which it is conceptualized and applied. Wallington and
others (2007) suggest two extremes in a continuum of
possible strategies (Fig. 1, centre). Procedural strategies,
‘‘which depict SEA as a systematically ‘rational’ process
which seeks to influence the formulation of a specific PPP
[policy, plan or programme],’’ and for which the context
normally sets boundary conditions to which SEA strategies
adapt. At the opposite end are transformative strategies,
‘‘which depict SEA as an intentionally ‘political’ process
intended to change the way decisions are made, and to
induce learning about environmental values in institutions,
organizations and civil society’’ (Wallington and others
2007). Here context becomes a target that SEA strategies
seek to improve. Thus, ‘‘strategies’’ echo the direct and
incremental conceptions of effectiveness discussed above.
Finally, the third element concerns the mechanisms rec-
ommended to operationalize SEA. Owens and others
(2004) and Wallington and others (2007) describe the
methods and tools used in SEA as a heterogeneous group
including political, dialogical and participatory methods, as
well as more traditional techno-rational instruments. Both
contributions recommend that the SEA community should
seek to maximize synergies between the ‘‘political’’ and
‘‘technical’’ methods (Wallington and others 2007), aban-
doning any attempt to polarize the debate and the practice,
since the most appropriate methods are often likely to
combine both typologies. The idea, as illustrated in Fig. 1,
is that mechanisms could be shaped to serve the purpose
and strategies. Together, these three components capture
the systemic and strategic dimension of SEA.
This interpretative framework emphasizes the impor-
tance of the relationship between assessment (as a system),
planning, and their ‘‘context’’—and the implications it has
for effectiveness. However, the details of such a relation-
ship are rarely defined in explicit terms: instead, the link
tends to underlie and influence SEA regimes, implicitly.
Wallington and others’ (2007) concept of a strategy
changes this, placing the relationship at the heart of SEA
discourses. The introduction of an intermediate step
(strategies) between the definition of why it is desirable
to introduce SEA (the purpose) and how to do so (mech-
anisms)—create the opportunity to reflect on the
relationship with the context and on the type of outcomes
(and thus effectiveness) expected of SEA.
On the basis of this interpretation I now turn to analyze
the case of China: the strengths and weakness of its current
SEA experience, the way assessment and planning relate to
each other. The analysis reveals important problems, and
highlights the constraining effect of various dimensions
of context on the direct effectiveness of assessment.
Contextual aspects (including those that can enhance
effectiveness) are discussed in the subsequent sections.
China’s Experience of SEA: PEIA
For this analysis I focus on three aspects of the PEIA
regime considered critical in SEA literature: (1) purpose of
assessment, (2) quality of the process: timing, consider-
ation of alternatives and public involvement, and
(3) methods and expertise. These aspects relate primarily to
the first (purpose) and third (mechanisms) element of an
SEA system, as illustrated above.
Purpose and Concept of Assessment
Understanding the purpose of an SEA regime allows us to
define effectiveness. Article 1 of the EIA Law (NPC 2002)
defines ‘‘purpose’’ as: ‘‘realizing sustainable development
strategy, preventing adverse impacts on the environment
from implementation of plans and construction projects,
and promoting coordinative development of the economy,
society and environment.’’
Thus, PEIA is intended to help implement sustainable
development, by coordinating its three pillars and pre-
venting negative effects. This common generic statement is
in line with international trends (Sadler and others 2008).
However, its interpretation in practice is more akin to Bao
and others’ (2004) definition: ‘‘[t]he purposes of SEA’’ is
the ‘‘prevent[ion] and mitigat[ion of] negative environ-
mental effects caused by the policy, plan and to control
environmental degradation from the sources.’’ This view
focuses on one aspect of Article 1: to prevent impacts. It is
a view supported by the analysis of practice to date (for
example, Liou and others 2006; Tao and others 2007) and
by the majority of practitioners I interviewed between 2005
and 2007 (though with notable exceptions: CG9, CG34).
But preventing impacts (and coordinating socio-economic
and environmental interests) is a means to an end—it does
not represent a substantive purpose (Wallington and others
2007). This affects the framing of PEIA’s effectiveness: it
becomes exclusively linked to direct impacts on decision-
making, ignoring incremental improvements in the capac-
ity for coordination, as well as in wider environmental
government practices (Fig. 1).
The remainder of the Law explains why Chinese prac-
titioners focus on adverse impacts. Chapters 1 (‘‘General
Provisions’’) and 2 (‘‘Environmental Impact Assessment
for Plans’’) of the EIA Law explain the concept of
‘‘assessment’’ itself, which is also crucial in understanding
effectiveness. The Chapters reveal elements typically
associated with concepts of project-EIA: the rational
objective discourse and the impact assessment mindset.
Environmental Management (2008) 42:717–733 721
123
Assessment is defined as an ‘‘analysis, projection and
evaluation [of] the potential environmental impacts’’
resulting from the plan (Article 7) or project, and the
proposal of ‘‘countermeasures and measures to prevent or
alleviate adverse impacts’’ (Article 2); it is intended to
provide ‘‘objective, open and impartial’’ information, and
‘‘thus provide scientific basis for the decision-making’’
(Article 4). The Law therefore, like many others, supports
an impact assessment mindset centered on traditional pre-
diction and evaluation ideas, and a search for solutions in
terms of prevention, mitigation and compensation.
This differs with principles of good SEA practice (for
example: IAIA 2002). Preventing and mitigating environ-
mental degradation should be seen as a mechanism of last
resort, once all else—including the shaping of objectives
and alternatives—has been tried. The need to strive for
objectivity and impartiality is acknowledged and shared in
many countries. However, there is also a need to engage
with the very significant body of work that highlights the
limits, as well as the desirability, of such objectives—and
points to the inevitable need to balance rationality with
power, to take into account values as well as data, and to
acknowledge uncertainty as an inevitable aspect of strate-
gic-level assessment (Hilde
´
n and others 2004; Owens and
others 2004; Sadler and others 2008; Vicente and Part-
idario 2006). Chinese experts and practitioners involved in
early PEIAs repeatedly acknowledge such needs and dif-
ficulties (interviews CG9, CG22, CG23, CG34, CG35, I5).
Quality of the Process: Timing, Alternatives,
and the Experts
SEA literature is replete with recommendations for the
need to start the assessment tasks as soon as possible and in
close interaction with planning (for example: Caratti and
others 2004;EC2005; Partidario 2000). Put simply,
starting SEA once a draft plan is already in place (even if
still preliminary) is tantamount to no strategic assessment
(Bina 2007). In China, current practice tends to focus on
the prediction and evaluation of impacts, and this is done
on a full draft or, not uncommonly, on a plan which has
already been approved by the designated authority (for
example, the Municipal People’s Congress), (interview
CG3, CG9, CG23, CG34—recently confirmed by the pre-
sentations at the SEA Conference, Beijing). The analysis of
land-use master plans by Tao and others (2007) confirms
the late start of PEIA, and its implication for the definition
and analysis of alternatives (the second distinguishing
character of strategic-level assessments):
‘‘[g]iven that SEA is started after a draft plan has
already been prepared, the identification of environ-
mental status and analysis of environmental impacts
would be separated from the planning preparation
process, and hence comparison of alternatives is
practically impossible. When SEA is initiated after
key decisions on the plan have already been made, it
is difficult to significantly influence the plan.’’
The same is true for the transport sector, where PEIA is
limited to the discussion of alternative routings of pre-
determined transport solutions: it can advise on sensitive
areas that should be avoided and on mitigation, but not on
the strategic choices that led to select a particular transport
mode, or infrastructure instead of demand management
(interview CG13, CG20, CG22, CG23, CG40, CG41).
The problem lies with the legal requirements, as well as
with the purpose of assessment reviewed earlier. On the
one hand, Article 7 of the EIA Law, establishes that PEIA
of several plans, including land-use master plans, ‘‘should
be conducted ‘during the preparation of a plan’’’ (Tao and
others 2007). However, for other types of plans, the law
establishes that PEIA will start ‘‘after the draft plan is
developed and before it is submitted for review and
approval’’ (Tao and others 2007). The difference is of little
consequence in practice: interviewees point out that PEIA
almost invariably starts once a full draft of the plan is
completed. Moreover, experts argue that given the current
cultural, political, and institutional context it is unlikely
that PEIAs will be initiated before a draft plan is com-
pleted, except in limited cases (interview CG9, CG34),
probably coinciding with sufficient political leadership to
do so. Thus, practice suggests that elements of the context
are constraining PEIA’s direct effectiveness (see next
section). Perhaps for this reason, SEPA is discussing the
possibility of extending PEIAs’ scope beyond plans, to
policies (and legislation) in an attempt to tackle the more
strategic layers of policy-making (comments at the recent
SEA conference in Beijing, see above, author’s own notes).
A third aspect of process is that of public involvement.
Article 11 of the Law (2002) refers to the need to ‘‘hold
expert meetings and public hearings’’ and invites those
responsible to give the resulting comments ‘‘serious’’
consideration, and to provide an explanation of how these
were adopted or rejected. Zhu and Ru (2007) argue that
‘‘Chinese laws and regulations have yet to fully address the
three prerequisites for meaningful public participation, that
is, access to information, public participation in decision-
making processes, and access to justice.’’ Here again,
timing is problematic. In terms of current project-EIA
practice, public consultation tends to occur at the late
stages of the EIA process and if it influences the decision, it
tends to be in terms of mitigation measures, the same has
been true for the limited PEIAs completed to date (inter-
views CG23, CG28, and interventions at the training course
in Guiyang, 2006—mentioned above). Even if the above
722 Environmental Management (2008) 42:717–733
123
problems were less frequent, contextual characteristics
including bias towards top-down directives and the ten-
dency is to ‘‘lectur[e]’’ the public on the need to protect the
environment, instead of informing ‘‘the public on problems
and solutions’’ and creating space for dialogue (Michalak
2005), remain an obstacle.
Methods and Expertise
Having examined the purpose and process of PEIA, I turn
to the third critical aspect of this regime: methods—the
aspect on which scholars have focused most to date (Bao
and others 2004; Tao and others 2007; Xiuzhen and others
2002). The choice of methods is influenced by most of the
issues raised above, especially the techno-rational inter-
pretations of the purpose of assessment. The literature and
fieldwork data show that there is no clear understanding of
the difference between EIA and PEIA. This, was also
common amongst practitioners in Europe in the 1990s.
However, the fact that in the Chinese system SEA is an
EIA of plans, may not be helping matters.
When asked about the biggest challenges they were
facing in applying PEIA, experts (interview CG18, CG20,
CG24) express confusion in ‘‘deciding what technological
[methodological?] background to use,’’ and admit that they
‘‘tend to do SEA as we [experts] do EIA.’’ Decisions
typically taken during scoping are posing the biggest
challenge: ‘‘what depth [of analysis] to aim for… EIA is
very specific and detailed… including issues of air and
noise pollution’’, instead PEIA ‘‘is at a much higher level,’’
requiring consideration of a larger number of projects,
more issues, and the focus on a ‘‘wider scope.’’ A senior
bureaucrat from a transport-related ministry (interview
CG3) considered PEIA ‘‘very difficult,’’ due to the high
level of ‘‘uncertainty’’ in planning: it was difficult to know
enough about the likely projects and thus produce sufficient
‘‘baseline data’’ to ‘‘quantify’’ things. Another expert
(interview CG18) explained that there was a ‘‘need to learn
how to quantify ecological impacts and other external
factors’’ and that they did not ‘‘have the skills [to do]
economic studies [analyses]’’ in PEIA.
Discussions with the experts suggest a gap between the
essence of strategic-level assessment and the way PEIA is
understood and practiced. SEA requires experts to priori-
tize strategic questions and issues, reducing complexity and
highlighting the key factors on which planning decisions
should be taken. To do so, it requires close collaboration
between planning and environmental actors—something
very difficult in the current Chinese context (discussed
below). Instead, experts are struggling to apply project-EIA
concepts to fully drafted plans, and in doing so they are
confronted with the limits of data and intrinsic levels of
uncertainty. Many informants are uneasy about the lack of
detail in PEIAs (and SEA examples), viewing them as ‘‘a
very simple description of EIAs’’ (interview CG23). The
hard science background of many practitioners makes it
difficult to accept even semi-qualitative methods (such as
for example matrices using simplified symbols to show
trends rather than exact changes), and reassurance that
these practices are widely applied internationally does not
reduce skepticism. These concerns characterize the chal-
lenges of moving to strategic-level assessments. Experience
with SEA in Taiwan reveals similar difficulties: there are
problems relating to the unfamiliar character of the meth-
odologies, and crucially, to the incompatibility between
existing ‘‘administrative frameworks’’ and requirements for
SEA’s implementation (Liou and others 2006). Most
administrations and experts have struggled with them during
the initial stage of transition from EIA to SEA.
However, the ‘‘licence system’’ that characterizes Chi-
na’s PEIA regime could be making things especially
difficult. Based on this system, ‘‘quasi-government insti-
tutions’’ (Gu and Sheate 2005), consultancies and
universities already certified to prepare project-EIAs, are
nominated as the technical agencies uniquely entitled to
perform PEIA (for details see: Gu and Sheate 2005; Zhu
and Ru 2007). The choice has its strengths. The institutes
have built significant technical, scientific, and sector-spe-
cific expertise on environmental impact concepts and
methods. However, the risk illustrated by discussions with
the directors of several such agencies (CG3, CG9, CG18,
CG20, CG22, CG23), is that such institutionalized conti-
nuity will encourage a narrow interpretation of PEIA,
essentially as an extension of EIA. In terms of expertise,
there is an urgent need to address the current bias in
favor of natural sciences and engineering. The strategic
and sustainability agenda underpinning PEIA’s purpose
demand a wider range of skills (especially in the social
sciences) and greater access to decision-makers than cur-
rently available. It will otherwise be difficult to deliver
better environmental, social and economic coordination, as
per Article 1 (discussed above).
There is a further problem with such designations. The
nature of the agencies can ensure independence and greater
transparency to PEIA; however, by being external agencies
they do cannot facilitate close process integration (of
planning and assessment), nor the benefits of social and
policy learning which results from carrying out most of the
work in-house. Experts from these agencies typically have
limited opportunities to engage, analyze, and openly dis-
cuss strategic options with planning authorities: most
experts explained their work focused on the search for
technical solutions to the environmental problems, often
narrowly defined (interview CG9, CG18, CG20, CG22,
CG23, CG34). In the transport ministry, for example, the
rigidly hierarchical structure, combined with a culturally
Environmental Management (2008) 42:717–733 723
123
and institutionally embedded divide between technical
experts, bureaucrats, and senior leadership limited the
quantity and quality of information being disseminated
from the top down. This could explain why in several
instances informants had limited capacity to see the bigger
picture in which certain measures, for which they were
responsible, would fit.
The Experience Thus Far
The overview of three key aspects of SEA-type practice
(purpose, process, and methods) produces a less-than-
bright picture. The purpose in the legislation is vague and
arguably not a purpose but a definition of means; the
related concept of assessment is essentially identical to
project-EIA; the quality of the process reveals important
weaknesses; the choice of methods reflects the previous
problems and is compounded by the choice of experts. It
can be concluded that the implicit concept of effectiveness
is a narrow (mainly due to the late start of PEIA) version of
direct impact, and that—based on the ideas of Wallington
and others (2007)—the existing mechanisms seem to be
inspired by an implicit procedural strategy (see Fig. 1).
Thus, the design and operation of all three elements of
what could be a PEIA system (purpose, implicit strategy
and mechanisms) are constrained by the context.
As I have repeatedly acknowledged, this is neither
surprising nor unique to China, which is still new to this
field of assessment. Most countries have encountered
similar problems, and have slowly progressed on a
learning-by-doing basis, and few—if any—stand up to the
combination of international good practice principles (IAIA
2002). Following the framework proposed above, I now
examine in greater detail the characteristics of the context
in which PEIA is being applied so as to further illuminate
the reasons for current difficulties, and possible ways
forward—based on the idea of a context-specific system.
The Chinese Context: Challenge or Opportunity?
The idea of context is based on the four, closely interre-
lated dimensions, illustrated in Fig. 1 above. In Fig. 2,
I summarize the aspects of the context that informants
identified as particularly relevant to PEIA. This is not a
comprehensive list, but its significance is confirmed in the
literature and by my own observation at seminars and
meetings (especially those taking place during my work on
the institutionalization of SEA/PEIA within a transport-
related Ministry).
Politics, Society, and the Environment
China is an illustrative—and extreme—case of the diffi-
culties of balancing the pursuit of economic, social, and
environmental objectives. This is the most striking aspect
of the context in which PEIA is operating. In per-capita
terms, China has limited resources, and the extent of
depletion, pollution, long-term or irreversible damage
affecting all vital resource bases in China is increasingly
Fig. 2 Critical aspects of
PEIA’s context
724 Environmental Management (2008) 42:717–733
123
well documented (see for example: CCICED 2005;
Crawford and others 2006; Day 2005; Economy 2004; Liu
and Diamond 2005; World Bank 1997; Worldwatch Insti-
tute 2006). The conflict over resources has social justice
implications (Paavola 2007) that are increasingly evident in
China: there is rising inequality between the poor and
increasingly rich Chinese (the ‘‘Gini coefficient of
inequality in household income rose by 7 percentage points
(18%) between 1988 and 1995,’’ [Liu 2007; see also: Pei
2006]), and growing inequality between urban and rural
incomes (the ratio is now 3:1). Pan Yue (Pan and Zhou
2006), SEPA Vice Minister, has been warning that envi-
ronmental problems are becoming one of the major factors
triggering social conflicts.
Ironically, the main cause of environmental degradation
is rapid economic growth that is being driven by the need
to lift hundreds of thousands of people from poverty, but
also—it is argued (Liu 2007; Pei 2006)—by the link
between growth and the legitimacy and future of the cur-
rent autocratic regime. The Government’s overarching
objective to build a moderately prosperous and harmonious
society does little to resolve tensions, as it calls for efficient
and fast economic growth to narrow the income gap, while
aiming to conserve energy and reduce energy consumption
and pollution (Hua 2007). These aims are not easily rec-
oncilable, and are bound to increase the already critical
levels of pressure on the environment. Given China’s
limited endowment of natural resources, the continued
pressure (and planned increases) poses major risks which
PEIA practitioners are asked to confront (often late) in the
planning stage.
A second aspect is the changing development policy
underpinned by fears of social unrest and scarce resources
(Cheng 2007). Top leaders have made frequent references
to China’s ecological crisis, and the worsening situation
has been cited as one of the drivers behind the new agenda
for the country’s growth model, whereby efficiency would
replace speed as the priority: ‘‘China should take substan-
tive measures to shift its focus from pursuing speed to
improving the quality and efficiency of economic growth’’
(President Hu Jintao in: Xinhua 2006). Efficiency and
‘‘scientific development’’ discourses are driving the mod-
ernization of the State (People’s Daily 2004). Efficiency is
the essence of China’s circular economy concept: the full
and efficient use of resources and the minimization of
waste discharge—leading to ‘‘low consumption of energy,
low emission of pollutants and high efficiency, through its
3-R principle: reduce, reuse, and recycle’’ (Xinhua 2006).
After more than two decades of high growth of the Chinese
economy, an unfair social policy and a looming series of
severe economic problems, started coming to the fore,
leading to the proposition—at the 16th Congress of the
Communist Party of China in 2002—of a ‘‘scientific
concept of development’’ combining the need to consider
the effects of development for Chinese people, and the
promotion of coordinated and sustainable development.
Scientific development is central to Hu Jintao’s (2007)
message at the 17th CPC Congress (October 2007), where
he links development with the need to improve environ-
mental management:
‘‘[w]e must adopt an enlightened approach to devel-
opment that results in expanded production, a better
life and sound ecological and environmental condi-
tions, and build a resource-conserving and
environment-friendly society… harmonise… eco-
nomic growth with the population, resources and the
environment, so that… our economy and society will
develop in a sustainable way.’’
However, the capacity of the Government to implement
its policies has produced mixed results. It is argued
(interview I11) that there is a specific ‘‘linearity’’ and
‘‘rationality’’ in the way the Chinese machinery of gov-
ernment operates, providing an efficient mechanism for
policy implementation. Yet this is often a misconception
(Liu 2007; Pei 2006). One of the intractable problems
affecting central Government’s environmental policy
implementation in China is precisely that Central Gov-
ernment has limited leverage over Provincial Governments
and municipalities (OECD 2007), and this makes it difficult
for PEIA practitioners to integrate such policy in provincial
or local planning (interviews CG1-CG6, CG8, CG9,
CG11). Environmental governance is further undermined
by the weakness of SEPA and its provincial and municipal
offices. SEPA lacks the authority to impose its policies and
opinions on the Ministries and bureaucracies defining
development (English 2006; Gu and Sheate 2005). The
Chinese leadership at the 17th CPC congress discussed the
possibility of strengthening SEPA but no decision had been
announced at the time of writing.
A third, related aspect, is the slow change in the per-
ception of the environment. Michalak (2005) suggests that,
‘‘[o]ver the years, the traditional view of environmental
issues as externalities has gradually been replaced by a
more proactive view of environmental management that
stresses its potential economic and financial benefits and
its contribution to establishing better governance and
sustainable development practices’’ (emphasis added).
Furthermore, Child and others (in press) argue that the
definition of ‘‘environmental protection’’ evolved ‘‘from
being a scientific and technical issue, to one incorporating
social and political considerations.’’ These are welcome
changes; however, Pan Yue (Pan 2007) remains concerned:
‘‘[i]n China, we have always looked at the environment as
an isolated subject… the state still has no systematic policy
framework on the issue of the economy’s confrontation
Environmental Management (2008) 42:717–733 725
123
with the environment, and has not developed ways of
thinking… on the issue’’ (see also: Day 2005; Economy
2004; OECD 2007).
These three areas reveal the complex picture of
encouraging progress, such as the shifting priority from
speed to efficient growth, mixed with major governance
challenges that make analysis and decisions within the
PEIA process extremely difficult. Noticeably, at the recent
SEA conference in Beijing (see above, author’s own notes),
Pan Yue criticized unequivocally the drive for growth and
the ‘‘conflicts of interest’’ that persistently influence
‘‘decision-making in development in China,’’ suggesting
that ‘‘SEA contradicts the short terms interests of local
authorities… they believe planning takes too long… pre-
fer[ring] to approve projects quickly’’ (see also: Gu and
Sheate 2005). The implications of the tension between the
growth priority and the environment, combined with weak
environmental policies and delivery mechanisms—pose
serious challenges to PEIA. Informants from the transport
sector, and environmental experts (interviews CG1-CG6,
CG8, CG9, CG11) illustrate this. They confirm that envi-
ronmental protection is essentially perceived as a ‘‘sector’’
in itself, and not a dimension of development or economic
growth. Although many viewed the new emphasis on
energy saving and environmental protection in the 11th
five-year plan as a clear priority for their sector’s devel-
opment, nevertheless the balance between these and
‘‘development’’ remains squarely in favor of the latter, and
current PEIA is unlikely to change this. In the words of a
senior transport expert (interview CG19): the new priorities
are important but they will not be ‘‘equally important as
[the priority of] increasing capacity.’’ Interviewees (CG13–
15) explained that ‘‘sometimes environmental protection
has to be compromised for economic growth.’’
Institutions, Organizations, and Actors
Figure 2 lists three more aspects of the context that chal-
lenge PEIA’s effectiveness. The first aspect embraces the
rules and culture that govern cooperation and coordination
between organizations: both between sectors (such as land-
use and transport) and between the environment and all
major development authorities. The quality of their coop-
eration is at the heart of sustainability and environmental
governance (Jordan and Lenschow 2008) and affects SEA/
PEIA practice (Caratti and others 2004; Owens and others
2004; Vicente and Partidario 2006). Informants show it
directly affects the effectiveness of PEIA in China, espe-
cially in terms of process and timing (see above).
In his general critique of governance practices of
the Chinese administration Michalak (2005) argues that
vertical and horizontal relations across levels of govern-
ment for environmental protection policy both needed
strengthening. This is further complicated by a more gen-
eral ‘‘inability [of Government departments] to speak
to each other… the bureaucratic culture is against
collaboration across departments’’ (interview I11). Most
interviewees highlight insufficient coordination between
departments as a major problem (interview CG8, CG9, I11,
I6): ‘‘getting people to talk to each other… is a difficult
quest.’’ The cultural and socio-political context in which
planning takes place leave limited space for transparency
and debate, especially between mainstream development
authorities and ‘environmental authorities’ (as defined in:
Zhu and Ru 2007). All this limits the flow of information
and the opportunity to develop common understandings of
the problems and solutions, critical to SEA’s effectiveness
(Runhaar and Driessen 2007). Encouragingly a senior
bureaucrat (interview CG3) from the environment direc-
torate of the transport ministry explains: ‘‘we think [PEIA]
is very difficult, but also very helpful… in terms of coor-
dination and integration with other departments at the
early stage of planning… [PEIA] can lead to easier
implementation.’’
The general lack of transparency combines with the
Government’s top-down approach to decision-making, to
limit the scope for openness and participatory approaches
to planning and assessment. Although some degree of
iteration from the bottom is envisaged, the result of classic
five-year plans, for example, is essentially a top-down
definition of macro objectives and targets which can limit
significantly the power of planning and decision at lower
levels of government (interviews CG2, CG12). This does
not bode well for objectives-led approaches to SEA, and
indeed they are rare in China (see below). In the transport
sector, for example, provincial administrations are told the
length of new infrastructure that needs to be built (inter-
view CG5), reducing the range of alternatives that can be
reasonably (and meaningfully) discussed. Poor coordina-
tion and transparency help explain why even in the event of
an early start, the capacity of using PEIA to help define
sustainable development objectives and solutions is often
curtailed.
A second aspect refers to the environmental authorities
involved in regulation, guidance, and training of PEIA:
SEPA, the EPBs, and ACEE (Bao and others 2004; Wang
and others 2003), as well as those leading the assessment
process. Zhu and Ru (2007) show that the law is ambiguous
in terms of their role and responsibilities, particularly in
reviewing PEIA reports or approving PEIA reports. As a
result, current practice in China is undermined by a certain
degree of confusion: environmental authorities are con-
cerned about their limited capacity to enforce the uptake of
PEIA and the respect of the assessment’s report (interview
CG9, CG23, CG34), and practitioners suggest confusion in
terms of who, which organization, takes leadership of a
726 Environmental Management (2008) 42:717–733
123
PEIA process. The example of an attempt to complete a
PEIA of a sectoral plan, part of the then forthcoming 11th
five-year plan, illustrates the problem (interviews CG3,
CG18, CG23). Initially, and fully in line with good SEA
practice, the environment experts working for the ‘‘devel-
oper’’ consulted various agencies, including NDRC, SEPA,
and various research institutes, in order to define the pur-
pose and scope of the assessment. However, soon it
became clear that there was a lack of coordination and
leadership, which meant that at least three organizations
claimed that they were leading the process (and two others
that they were leading on the economic planning). Even-
tually, the range of ‘‘priorities’’ originating from different
Government agencies made it very difficult to proceed
given the time and resource constraints (as well as the late
start of the PEIA itself).
A third aspect of the institutional and organizational
context relates to public participation. Pan Yue (Xie 2007)
has been a staunch supporter of the people’s right to know,
participate, and supervise (monitor) environmental matters.
He has promised new legislation to strengthen the role of
public participation, arguing that ‘‘[t]he ultimate impetus to
the solution to China’s grave environment issue will come
from the public,’’ and that the public should ‘‘fully imple-
ment their right[s]… so that they can engage in deeper
participation in the environmental protection campaign’’
(cited in: Xie 2007). SEPA is therefore hoping that the public
can support the Government in shifting the balance away
from blind pursuit of growth to a more balanced form of
development—the two policy shifts summarized earlier. To
this end, SEPA has proposed new Regulations on Open
Government Information (expected to take effect from May
2008), demanding that officials disclose information about
air and water quality, pollution spills, and the names and
misdeeds of violators (Reuters 2007). Furthermore, in 2006
SEPA issued a set of guidelines on public participation in
project-EIA (GOV.cn 2006), pledging that it will use this to
set up a comprehensive system which releases environ-
mental information and make procedures more specific to
ensure effective public involvement.
However, it is Hu Jintao’s (2007) Report to the Seven-
teenth National Congress of the CPC (15 October 2007)
that offers the greatest hope for change in this important
area of governance. In the Report he sets out priorities for
further strengthening of ‘‘social equity and justice’’ as the
essence of ‘‘developing socialism with Chinese character-
istics.’’ He illustrates progress in ‘‘expand[ing] people’s
democracy’’ and advocates the need to ‘‘expand the citi-
zens’ orderly participation in political affairs at each level
and in every field’’ arguing that:
‘‘[w]e need to improve institutions for democracy,
diversify its forms and expand its channels, and we
need to carry out democratic election, decision-
making, administration and oversight in accordance
with the law to guarantee the people’s rights to be
informed, to participate, to be heard, and to oversee.’’
He also stressed improvements in the legal system and
warned that: ‘‘[w]e must uphold the rule of law as a fun-
damental principle and adopt the socialist concept of law-
based governance.’’
The Context Thus Far
The six aspects of the context explored here, pose both
challenges and opportunities for PEIA’s effectiveness. The
first set relates to politics, society, and the environment. The
limited resources and increasing pressure on the environ-
ment resulting from sustained rapid growth, combined with
the resulting social tensions, represent the central challenge
for environmental management in China and thus, for the
revision of PEIA’s purpose. The changing development
discourse in favor of efficiency and moderate prosperity
(partly triggered by resources, constraints, and concerns
regarding social unrest) suggests there is political will that
can be harnessed for better management. This opportunity is
further enhanced by the changing views on environment,
away from the periphery of sectoral concern, to a more
proactive view of environmental management, although
much still needs to be done to define macro-level policies for
the environmental agenda of Government. These aspects are
crucial in defining a transformative strategy for PEIA and for
supporting changes to the existing Law. The second set of
contextual aspects refers to institutions, organizations, and
actors. The combination of poor coordination, together with
top-down structure of power and controlled flow of infor-
mation, represents a formidable challenge for PEIA’s direct
effectiveness. This is compounded by the rigid system of
certification of institutes entitled to carry out PEIAs.
However, the strengthening political support for public
participation, access to environmental information, and
general improvement of the rule of law are all encouraging
signs and opportunities for designing more effective PEIA
systems.
Pan Yue (during the SEA conference in Beijing,
author’s own notes), provided an encouraging view of the
direction discussed and agreed at the 17th Congress of the
CPC which ‘‘involves a need to change the political cul-
ture’’ of the administration, the pursuit of an ‘‘ecological
culture,’’ and the need for ‘‘environmental accountability.’’
SEA (and PEIA) represents a potentially powerful instru-
ment to help promote this change, and I now turn to
explore in more practical terms the implications of the
conceptual framework for a context-specific SEA system,
introduced above and summarized in Fig. 1.
Environmental Management (2008) 42:717–733 727
123
Taking the Opportunity: Toward a Context-Specific
System
SEA is, first and foremost, an opportunity. It can assist
governments in meeting challenges reiterated at the inter-
national level since the 1970s (notably in: UNCED 1992;
WCED 1987), and identified here in the context of China: a
complex and nuanced range of obstacles, linked to culture,
politics, society, and the institutions and organizations
operating therein. These obstacles are, essentially, those
well rehearsed in the domain of sustainable development
and environmental policy integration, and their persistence
reflects the varying degrees of failure and reticence with
which different governments have embraced the challenge
of institutional change, first set in the Brundtland Report
over two decades ago (WCED 1987). EIA and SEA have
been identified as powerful instruments for addressing
these obstacles and improving environmental management
(Petts 1999): they can operate directly on projects and
PPPs, and through systematic and repeated applications,
they can also contribute to incremental changes in the
capacity for environmental governance of the context
(politics, culture, institutions, organizations). However,
lawyers and bureaucrats defining new SEA procedures tend
to focus on direct—rather than incremental—effectiveness
(Nykvist and Nilsson submitted press). This amounts to a
missed opportunity, because direct effectiveness of SEA
depends to a large extent on the capacity for environmental
governance of the context of operation. Designing SEA
systems aimed at promoting changes in PPPs and in the
context from which they originate is essential in all cases
where Brundtland’s challenges are still to be met: because
although individual SEAs might fail to improve certain
PPPs, their systematic application can nevertheless be
designed to maximize opportunities for learning, changing
worldviews, and strengthening cooperation.
The following suggestions seek to promote a system that
can achieve both direct and indirect effectiveness by
addressing the challenges and opportunities of the context.
As argued above, this would also shift China’s practice
towards more strategic interpretations of assessment. I will
therefore use the term SEA (rather than PEIA) as I explore
the following three elements of a possible system for
China: (1) articulating the purpose of an assessment sys-
tem, thus dealing with the ‘‘why’’ question discussed in the
introduction; (2) defining a strategy for ‘‘how’’ to opera-
tionalize SEA with a focus on the contextual dimensions;
and (3) defining mechanisms, including legislation, guid-
ance, training, as well as details of the process and tools
provides further insight on ‘‘how’’ to carry out SEA in
practice, and seeks to address the difficulties of current
PEIA practice (see also earlier section). I should note that
China represents a diverse reality in terms of context and
organizations operating within it. Central government
operates differently from provincial and municipal levels,
and south-eastern provinces are substantially different
economic and social realities compared to western and
northern regions. The following suggestions are based on
observations of central government and selected provincial
authorities, and are necessarily at a large scale resolution.
More research will be needed to look at sectors as well as
governance levels in order to fine tune these initial ideas.
Purpose: More Focused
More specific wording of the purpose of SEA in China
would help interpret and substantiate Article 1’s precept of
‘‘realizing sustainable development’’ (see above). I draw on
two aspects from practice and the context to suggest a
revision: (1) the current focus on cumulative impacts and
carrying capacity, and (2) the theme that underlies most of
the issues explored within the context of ‘‘politics and
environment:’’ conflict over resource use, and resulting
problems of social justice.
Scholars (Bao and others 2004; Zhu and Ru 2007) and
interviewees (CG8) reveal a special concern for cumulative
impacts. The first PEIA guidance document, Technical
Guideline for Environmental Impact Assessment of Plans
and Programs, published in August 2003 (SEPA 2003),
refers to the need to define the ‘‘territorial scope’’ of the
assessment by combining geographical and administrative
dimensions, and emphasizing the need to consider ‘‘eco-
logically sensitive regions… habitats.’’ The guidance is
replete with direct and indirect references to the concept of
ecological sustainability and carrying capacity, and most of
the Chinese examples presented at the recent SEA Con-
ference in Beijing (mentioned above) included methods
based on ideas of carrying capacity, ecological footprint,
and cumulative impacts. However, few scholars and prac-
titioners focus on social effects, and social justice, despite
their prominence (see above). Pan Yue (China Daily 2007
;
Pan and Zhou 2006) refers persistently to the need to
consider the capacity, function, and services of natural
resources, drawing the link with rising social tensions.
The purpose could be framed in terms of maintenance of
ecosystem services and promotion of social justice. The
SEA system would operationalize notions of interdepen-
dence and social justice central to the political priorities of
the context, while building on current practice embracing
cumulative impacts and carrying capacity—a practice
consistent with the cultural dimension of context that
favors techno-rational methods. Given the current political
context, and the Party’s top leadership’s emphasis on the
need to shift the development agenda towards more envi-
ronmentally and socially friendly paths, it would seem
opportune to harness such drive through a clearer statement
728 Environmental Management (2008) 42:717–733
123
of SEA’s purpose. The Government certainly needs this
instrument to improve its poor environmental management
record (China Daily 2007).
Strategy: Thinking More Broadly About Effectiveness
and ‘‘How’’ to Achieve It
For it to be more than a mere aspiration, it is essential that
the purpose is accompanied by a broadening of the existing
concept of assessment and its effectiveness, and by the
development of a strategy that can provide a link between
the purpose and the mechanisms intended to operationalize
it. The need for wider effectiveness is already acknowl-
edged. Interviewees from SEPA reveal that there is an
expectation that SEA ought to: (1) promote incremental
technical (and short term) change, notably through the
assessment of the cumulative impacts of multiple projects
located within geographic areas with ecological coherence,
and (2) facilitate fundamental institutional (and long term)
change, whereby authorities will increasingly need to
consider the environmental dimension during the planning
process. SEPA’s Vice-Minister Pan Yue has proposed clear
criteria for SEA effectiveness, which fit with the notions of
incremental effectiveness and transformative strategies:
‘‘Conduct SEA so as to take more seriously the nat-
ural resource base and the implications of demands
on this base; as part of the assessment SEA should
contribute to the achievement of circular econ-
omy;SEA should ensure environmental policy
integration and inter-sectoral coordination; SEA
should consider cumulative impacts; SEA should
consider social impacts; SEA should consider indirect
impacts; SEA promotes the importance and practice
of public involvement’’ (interviewee CG23 translated
the text of Pan’s presentation art the Green China
Forum).
He repeated many of these in a recent interview (China
Daily 2007), where he stressed the urgent need to influence
the strategic choices of industrial development and its
location.
Given the challenges and opportunities highlighted in
the analysis of the context (previous section), it seems
reasonable to propose the development of an SEA strategy
that combines transformative elements with existing pro-
cedural ones, so as to maximize SEA’s potential to
contribute to change.
Strategy: Transformative Elements and Related
Mechanisms
In China, a transformative strategy could harness the sys-
tematic effort of carrying out SEAs on plans in order to
address all the six aspects of context discussed above, by
designing SEA as: (1) a contributor to social and policy
learning, to assist in delivering the policy shift to more
‘efficient development’ endorsed by the leadership; (2) a
policy transfer mechanism—to raise awareness about
environmental policy priorities and promote a proactive
approach to environmental management; and as (3) a
means to promote coordination within and between sectors,
and between development and environment agencies. The
strategy should also include a fourth, critical element:
leadership.
The first three elements aim to improve environmental
governance within the organizations that are responsible
for development. Torres and Preskill (2001) define orga-
nizational learning as a continuous process ‘‘that (a) uses
information or feedback about both processes and out-
comes… to make changes; (b) is integrated with work
activities, and within the organization’s infrastructure…;
and (c) invokes the alignment of values, attitudes, and
perceptions among organizational members.’’ The follow-
ing proposals, partly adapted from Torres and Preskill
(2001), can help to integrate various forms of learning with
assessment, planning, and decision-making tasks, and
should be developed by all major development organiza-
tions that are institutionalizing SEA. The first proposal is to
identify the major obstacles to the early consideration of
environmental and social issues during planning, and to
distinguish these in terms of timescale needed to address
them: short and long-term. Short-term indicators of pro-
gress toward longer-term outcomes should then be defined,
linking activities of planning and assessment on specific
initiatives to the accumulation of experience and under-
standing of environmental and social issues. A related
proposal is to use past examples of SEA to provide routine
learning opportunities through the use of seminars, meet-
ings, and informal gatherings to promote deliberation, team
building efforts, and conflict management, and ensure
collaborative reflection on the strengths and weaknesses of
planning and assessment. These efforts could also turn
SEA into a forum for questioning the current predominant
view of growth’s priority forcing reflection about the long-
term implications for society and its natural resource base.
Creating opportunities for learning through the process of
SEA could lead, in the medium and longer term, to
incremental improvement in collaboration and transpar-
ency (Hertin and others 2007; Owens and others 2004;
Runhaar and Driessen 2007; World Bank 2005), which are
highlighted above as a serious contextual challenge. Fur-
thermore, SEA could be promoted as a policy transfer
mechanism that ensures wider dissemination of macro-
environmental policy concepts among actors from sectoral
ministries, shifting their understanding of environ-
ment beyond limited to technical aspects, to include also a
Environmental Management (2008) 42:717–733 729
123
socio-political dimension. Possible techniques include
seminars and training, as well as wide dissemination of
nontechnical intermediate reports arising from the SEA
process (especially relating to scoping). These objectives
would help promote central Government’s concept of sci-
entific development (discussed above).
As for better cooperation across sectors (and Ministries)
and with environmental authorities, this has to consider
complex issues of rank and authority (English 2006)
making it difficult to generalize. The appointment of
leaders from high-ranking departments to coordinate SEAs
could contribute to better coordination. Environmental
implications of land-use choices, for example, can more
easily be discussed with other relevant ministries (for
example urban or transport related authorities) if the
request for dialogue comes from the ‘‘top’’ rather than from
internal environmental divisions. And repeated applica-
tions of SEA can help to open communication channels.
Cooperation between development and environment
agencies is still a grey area since the responsibility for the
SEA process in China awaits clarification (Zhu and Ru
2007). However, at the recent SEA conference, Pan Yue
suggested that SEPA’s priority is to ensure more effective
processes, rather than secure control, as in the case of EIAs
(author’s own notes): ‘‘it is not a matter of strengthening
SEPA’s power… we are willing to act as a supporting
institution.’’ This could lead to the creation of a formal
supporting institution within SEPA (for example inspired
by the Dutch EIA Commission).
The forth element of the strategy ought to be leadership
of the system as an agenda for change (and transformation).
Given the many challenges identified in the analysis of
context, especially in terms of the relative weakness of
environmental authorities in managing the assessment
process, it may be useful to give leadership of the SEA
system to the National Development and Reform Com-
mission (NDRC) and related provincial offices (so-called
DRCs). They have the unique capacity (and legitimacy)
among China’s institutions to develop comprehensive,
cross-sectoral overviews essential to a sustainable devel-
opment perspective. They provide an existing network of
institutions that have the benefit of overview, as well as
strong political leverage, thanks to their close links with the
State Council. Their championship of SEA would help
overcome the significant resistance by sectoral ministries.
If central Government is serious about pursuing the policy
shifts mentioned above, NDRC’s adoption of SEA as part
of its regular practices would be essential, and a leadership
role would be a major step forward. The fact that NDRC
was co-organizer of the recent SEA conference in Beijing
(November 2007, see above) suggests that the organization
is searching for instruments to address the environmental
costs of inefficient use of limited resources and of
pollution, and that its leadership of SEA might be indeed
an option. SEPA could adopt the role of quality control of
all SEAs, for example establishing review commissions
mentioned above—although this will remain difficult in a
culture of rigid hierarchies, unless SEPA is promoted to
full ministerial level (currently being discussed).
Strategy: Procedural Elements and Related
Mechanisms
The transformative elements of an SEA strategy need to
combine with revised procedural elements. In my detailed
overview of the experience of PEIA I have highlighted
the—weaknesses mainly—of its implicit procedural
strategy: currently, practice subscribes to a narrow inter-
pretation of impact assessment as a techno-rational
mechanism, identifying likely adverse effects and operat-
ing in an essentially confrontational environment, where
the interests of growth are the primary input for planning,
and those of the environment are more or less effectively
retrofitted. I now wish to focus on ways in which such
considerations can be used to re-design mechanisms,
including: legislation, skills and training, the issue of roles
and responsibilities, as well as process and tools. Some of
the suggestions will be familiar, since critical failures in the
capacity for environmental governance are common to
many countries, as witnessed by the slow progress towards
sustainability.
Legislation in China is being discussed and revised.
A new regulation is expected at the time of writing, and
based on the above reflections, the following changes are
recommended: (1) a revision Article 1, distinguishing
between the substantive purpose (the goal) and the means
to achieve it, making the purpose as specific as possible
(see above); (2) a requirement to make an early start of
SEA mandatory for all plans, linking the timing of SEA to
the initial stages of planning; (3) a requirement for a
scoping report that must be approved and adopted by both
the development and environmental authorities, as a way of
strengthening cooperation and consultation between
development and environment agencies; (4) clear standards
aimed to improve the quality and timing of the public’s
involvement. These suggestions have implications for
skills and training. Sectoral ministries could increase pro-
fessional development opportunities, including training in
basic SEA methods and processes, as well as in team
development and group process, and where necessary—
complement the strong natural science and technical
background with social sciences and capacity to address
social justice issues. Training on macro-environmental
policy (especially for sectoral ministry staff) and on more
proactive approaches to environmental management are
clear priorities based on the above analysis. In terms of
730 Environmental Management (2008) 42:717–733
123
roles and responsibilities, in addition to the recommenda-
tions on leadership, possibly by NDRC, it seems important
to revise the existing policy focusing on certified EIA
research institutes to carry out SEAs to allow for a stronger
in-house role. This is a condition without which learning
opportunities could not be maximized. If the existing pol-
icy focusing on certified EIA research institutes cannot be
revised, nominating an SEA leader or champion from
within the sectoral ministry responsible for the plan under
scrutiny would help to ensure closer integration between
planning and SEA, and thus strengthen the profile of the
assessment process amongst planning departments and
avoid confusion over roles and responsibilities.
The last set of recommendations relates to process and
tools, and is closely linked to all previous ideas. A revised
process should insist in closing the gap between assessment
and planning practices and timings, especially in terms of
the definition of the problem, the objectives, the alternatives
to be considered, and the actual evaluations. If the Gov-
ernment’s stated intention to pursue a development agenda
for a better life and sound ecological and environmental
conditions is not rhetorical, then SEA should be used to
encourage the consideration and discussion of alternatives
from these perspectives. It would therefore help to stream-
line, prioritize, and simplify the strategic levels of
assessment so as to leave the detailed analyses to project-
EIA, and two aspects of SEA experience seem relevant here:
the objectives-led approach (Sheate and others 2007) and a
balance between techno-rational and more participatory
processes and tools (Owens and others 2004).
Promoting the practice of objectives-led SEAs, where the
assessment is driven by a set of environmentally sustainable
objectives, could help to focus the analysis, reduce the need
for detailed quantification (as relative trends often are suf-
ficient) and gain legitimacy for the outcomes (if discussed
and agreed through wide consultation), (Taiwan has inter-
esting lessons: Liou and others 2006). Experts (interview
CG22) acknowledged this: ‘‘it is the objectives and [envi-
ronmental] standards that are crucial,’’ but illustrated the
difficulties and the default need for quantification: ‘‘who sets
them?… yes, we can take some from legislation and from
statements, but some of these are very vague—so how do we
quantify them?’’ The objectives-led method is also depen-
dent on knowledge of the ‘‘macro environmental policy
framework:’’ another major gap (interview CG9) that SEPA
is trying to address through training. An objectives-led
approach would include the evaluation of policy coherence
(between environmental and sectoral priorities), and would
systematize the evaluation of a proposed plan’s contribution
to environmental objectives, thus increasing the policy rel-
evance of PEIA’s findings. Focus on objectives may also
assist in cumulative impact assessment, carrying capacity
studies, and footprint analyses (mentioned in relation to the
purpose of PEIA) as it can facilitate the selection of impact
factors. The evidence presented here also supports the
greater use of participatory mechanisms. Planning, and thus
its assessment, involves dialogue and communication of
environmental, social, and economic values (Caratti and
others 2004). Not least because uncertainty is intrinsic to
strategic-level choices and it can rarely be solved through
increasingly complex quantification efforts. SEA requires
balancing data with discussion about the objectives and
values at stake, even in the case of cumulative impact
assessment or carrying capacity analyses (which inevitably
include judgments of value as to what is at stake, what is to be
counted). Guidance on how to develop carrying capacity
analyses tailored to the limited data availability and resour-
ces on the ground also seems important, given that several
Chinese practitioners have raised the problem of access and
cost of data. A policy of reasonable (if not free) access to
baseline datasets would be essential to enable SEA to serve
the priorities outlined at the recent 17th CPC Congress.
Conclusion
The purpose of this research has been to contribute to the
analysis of China’s experience through a different set of
interpretative lens. Drawing on recent developments in the
theory and practice of SEA, I have proposed a conceptu-
alization of SEA effectiveness that combines direct and
incremental impacts, and a need for context-specific sys-
tems as a way to focus on the relationship between
assessment, planning, and their context, and thus maximize
effectiveness. This framework has allowed me to examine
current practice in China, illuminating the challenges it
faces and proposing elements of a new approach.
PEIA in China operates at the point of greatest tension
between rapid environmental degradation and persistently
high growth targets. China’s spectacular growth is under-
mining the environmental basis on which the health, well-
being, and the future of its 1.3 billion people depend. The
country’s leadership is well aware of the challenges it faces
and is searching for a broader perspective of the interaction
between man and its environment. It has proposed coura-
geous policy changes, but the pace and scale of growth and
deterioration requires even more decisive action to protect
peoples’ health and the environment they live in. PEIA and
SEA can help in different ways, depending on what purpose
and effectiveness are sought. This contribution has set out the
main challenges and opportunities that need to be considered
as the Government revises its approach. If the Government
intends to invest further in strategic-level assessment, it
should take the opportunity to redesign the system so as
to introduce SEA as a transformative force which can
improve individual plans in the short term, as well as
Environmental Management (2008) 42:717–733 731
123
promote longer-term change in the socio-political, cul-
tural, institutional, and organizational context, through the
strengthening environmental governance practices. The
three-part system of course has an order of priority: effec-
tiveness cannot be improved unless the first two (purpose and
strategy) are in place; mechanisms will continue to be con-
strained by the context. Beyond the details, stronger political
support for the purpose and functions of PEIA (or future
SEA) seems essential. The leadership’s concern with scarce
per capita resources and with the discontent of rural poor
might help raise the issue on the agenda.
Acknowledgments I gratefully acknowledge the support of the
Portuguese Fundac¸a
˜
o para a Cie
ˆ
ncia e a Tecnologia and the Chinese
University of Hong Kong for Visiting Scholar status in 2007. I would
like to thank Andrea Ricci for his insightful comments, as well as the
three anonymous reviewers for their many useful suggestions. Any
shortcomings remain my own responsibility.
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