|
The
Need for Creating Framework Conditions for Cleaner Production
Casper
van der Tak
Abstract
This paper investigates policy instruments that are used in different
countries for the promotion of Cleaner Production. The paper argues that
many of the policy instruments used to promote Cleaner Production are in
the long run counterproductive, and are also distortionary, hampering
welfare. Instead I suggest an alternative approach, adjusting the
framework conditions under which economic actors make their decisions
whether or not to employ Cleaner Production techniques. This involves
focusing on a small subset of all the instruments that have been
suggested to promote CP. The paper ends with a few suggestions that
might be directly relevant to China.
Introduction
I
have a confession to make: I am not a CP specialist. Before you stop
reading, I am a development economist as well as an environmental
economist and as such, I might be able to give some relatively fresh
inputs for discussion.
When
I started to look into the CP concept and the policy instruments
proposed to promote CP, I was astounded to find many recommendations
that run counter to the basic tenets of the neoclassical theory of
welfare economics and environmental economics. Now, there is nothing in
principle against violating these tenets, provided a well-argumented
case is made. After all, neoclassical economics certainly has its share
of weaknesses. However, I did not find such a coherent case for
deviating from these tenets, nor did I find much of the argument. This
paper aims to refresh this discussion.
In
order to do so, first I will look at why CP is worthwhile promoting.
Second, I look at the reasons why policy intervention might be needed to
promote CP, discussing market failure and policy failure arguments.
Subsequently I will discuss in detail some of the policy instruments
that are often proposed to support and promote CP. In particular, I will
argue against subsidized credit and special CP funds, mandatory CP
auditing, and subsidies for CP – all instruments that are often
proposed, but miss the point that CP is supposedly worthwhile because it
is (often) cheaper than end-of-pipe (EOP) abatement efforts. I then
offer some suggestions in a general, abstract sense that would be
applicable to many countries in the world, and end with some concrete
proposals for China.
The
paper's outline follows this logic. Section 1 discusses why CP is
worthwhile promoting, whereas Section 2 discusses why policy
intervention is needed. Section 3 discusses some frequently suggested
and used CP policy instruments in detail; Section 4 offers some general
advice, while Section 5 offers some China specific advice. Section 6
concludes.
1.
Why promote CP?
First
of all: why are we interested in promoting CP? This is hardly a question
worth raising on its own, since the general idea of the answer is quite
obvious to most of us (although the wording might be different), but the
answer is key to some arguments below, and therefore it is worth going
into the issue.
CP
consists of a number of techniques that together reduce input use per
unit of product, and/or increase the product recovery. Together, this
means a reduction in raw input use and pollution per unit of production.
Based
on these characteristics, the answer as to why promote CP is:
CP
offers the potential to reduce the social unit costs of
production.
Digressing
for a moment or two, two words need emphasizing in this answer: potential
and social.
The
"potentiality" is worth emphasizing, because CP does not
always reduce social unit production costs. This is partly because some
CP options may just be too ambitious – the gain in environmental
quality is not worth the cost, but also partly because in some cases an
EOP option or a combination of EOP and CP options achieves the same
environmental objective at lower (social) costs than a "pure
CP" option.
The
emphasis on "social" is also well founded, because from a
policy perspective it is not the balance of private costs and
benefits that should guide decisionmaking. Rather, it is the balance of
social costs and benefits of different policy actions that should
determine economic policymaking.
Whereas
private costs only include the prices and taxes paid by an economic
actor, and the private benefits only include the prices and subsidies
received, social costs and benefits reflects the costs and benefits to
society. For example, in absence of any air pollution regulation, the
private costs of SO2 emission are 0, whereas the social costs (health
problems costs by SO2, damaged caused by acid rain) may be considerable.
Only when an SO2 emission trading is established, or a pollution
charge on SO2 is levied, the private costs of SO2 emissions become
non-zero, and may coincide with social costs if the charge rate (or the
cap on total SO2 emissions in an emission trading scheme) is
appropriately chosen – this is called internalization.
Coming
back to the mail line of the argument, CP options are only justified to
the extent that the marginal environmental improvements and resource
savings compensate for the marginal costs of the CP options.
Furthermore, if the same environmental improvements may be achieved more
cheaply by EOP (or by a combination of CP and EOP) than by CP alone, the
former option is preferable. There is nothing inherently great about CP
that makes it worthwhile to promote it over other options that achieve
the same (environmental) objectives at lower costs.
This
last point is worth remembering: any set of policy instrument that may
result in the selection of CP options where the same objectives could
more cheaply be achieved with EOP options is not socially optimal. The
opposite is also true: any set of policy instrument that may result in
the selection of EOP options where the same objectives could more
cheaply be achieved with CP options is not socially optimal as well.
What is needed is the creation of a level playing field for the
different options for reducing pollution and raw material inputs, with
the selection based on the merits of utilizing these different options
alone.
2.
Why policy intervention?
All
fine, but we have not yet considered the question why government should
be interested in initiating any policy to promote CP. After all, even if
we have established that under some conditions CP options would increase
welfare by lowering social unit production costs, there would be no need
for any policy intervention if economic actors would already on their
own account chose CP options precisely in these cases.
What
we need to investigate is how economic actors make their decisions, and
under what conditions these decisions coincide with the socially
optimal, and under what conditions not. Based on that, we could argue
for (or maybe against, but in this case for) policy intervention, and we
would also have a good idea about the type of policy intervention
needed.
Economic
actors, according to neoclassical theory, base their decisions on their
private interest, weighing private benefits and private costs against
each other. Neoclassical welfare theory has established some concrete
reasons why decentralized decision-making by individual economic actors
based on private costs and benefits may lead to an outcome that is not
socially optimal. Leaving aside the issues of distribution and equity,
there are two important sets of reasons why: market failure and policy
failure. Of necessity, my discussion can only be brief, and I will also
make some shortcuts from the full theory.
2.1
Market failure
Market
failures comprise the reasons why markets fail to generate prices that
reflect marginal social costs and benefits. This discrepancy implies
that the individual optimization by economic actors is based on private
costs and benefits that do not coincide with social costs and benefits,
and hence will, generally speaking, not lead to a socially optimal
outcome. Under the heading of market failures, several reasons may be
mentioned:
·
Externalities
– Actions with impacts on other people's welfare; impacts that are not
subject to market transactions. An example is pollution generated by an
industrial company. This affect welfare of others in a negative sense,
but the action of polluting itself is not subject to any market
transaction.
Hence the social production costs are higher than the private production
costs (private representing the viewpoint of the decisionmaker, the
company in this case). The answer that neoclassical theory provides to
the issue of externalities is to internalize them in order to
maximize social welfare – to create a market, either through
establishing Pigovian taxation or through emission trading.
·
Information
sets – If private actors do not have full information on production
technologies, or on the profitability and riskiness of these
technologies, decentralized decisionmaking will not be socially optimal.
·
Economies
and diseconomies of scale – The fact that unit production costs might
fall or increase with total production.
·
Market
power – The fact that monopolists and oligopolists will not set prices
according to marginal production costs, but will equate marginal
revenues with marginal costs instead.
Of
these, the first two are the most important in the case of CP. The main
externalities that are relevant are environmental pollution, and the
main information barriers are knowledge about CP options and techniques
and the ability to assess their profitability and riskiness.
2.2
Policy failure
Policy
failures consist of differences between private cost and benefits and
social cost and benefits that are actively brought about by government
actions – by taxation, subsidies and regulation. Policy failures
include:
·
Pricing
– prices of energy, water and raw materials often do not fully reflect
marginal social costs of their production, due to various government
subsidies;
·
Pre-selection
of technologies – often regulation forces enterprises to select
specific (types of) technologies, either directly (e.g. by requiring
treatment facilities to be built, forcing an EOP option) or indirectly
(by requiring compliance with certain norms within a very specific time
table, which is easier done through EOP than through process-integral CP
options).
Both
of these are relevant to CP. Subsidies for input lower the costs of
these inputs, and reduce the attractiveness of options that save on
them. On the regulation side, various wordings of rules and regulations
force and EOP approach.
2.3
The implications for promoting CP
Both
the market failures and policy failures described above as relevant for
CP provide motives for policy intervention to promote CP. These policy
interventions should be targeted towards the elimination of the market
and policy failures that hinder CP:
·
Assist
and stimulate the development and dissemination of knowledge on CP;
·
Internalize
environmental externalities;
·
Remove
subsidies in pricing of energy, water and raw materials;
·
Remove
biases in environmental regulations.
In
each of these cases, theory suggests to directly attack these problems
as close as possible at the source of the distortion, in order to
prevent that elimination of one type of policy or market failure
immediately introduces another.
These
market and policy failures lower both the supply of, and the demand for,
CP services by either internal sources within the enterprise or outside
CP service providers. Lack of knowledge of CP techniques and their
impact on costs hinders supply, whereas the other market failure and the
policy failures lower demand.
A
balanced development of CP should focus on both eliminating the failures
that cause supply of and demand for CP techniques and services to fall
below the socially optimal. Eliminating failures operating on the demand
side is not effective if supply restrictions determine the level of CP
activities, and vv.
Since
there is latent demand for CP in most countries, based on the desire to
reduce input costs and maximize product recovery, a coherent strategy
should in its initial stage focus mostly on elimination of the lack of
knowledge on CP, and building a basic capacity level to conduct CP.
Simultaneously, work can start to create the appropriate framework
conditions for CP, by gradually eliminating subsidies on raw materials,
water and energy, and by adjusting and sharpening environmental
regulation. In the later stages, work should concentrate on the latter
aspects.
This
strategy entails a focus on adjusting the framework conditions in such a
way, that CP becomes increasingly profitable for private actors if CP is
in the interest of the society at large. The overriding message to
economic actors should hence be that using CP techniques might often
increase profits. And hence, that developing in-house CP capacity or
hiring outside CP capacity makes sound business sense for enterprises. I
can see a large potential role for performance contracting in this
strategy.
This
suggested strategy is in sharp contrast with the various subsidies etc.
that are often proposed – these send the message that CP is not
profitable, does not make business sense, and need be supported by
external funds provided by the government or be mandated by the
government. I will use this
simple policy intervention framework as a point of departure for the
discussion of CP instruments that have been proposed and used in
different locations of the world.
3.
A review of instruments to promote CP
Below I provide a summary of which CP instruments are used in selected
countries.
Table
1. Cleaner production policy instruments in the European Union &
United States
|
Instrument
|
NL
|
DK
|
SP
|
UK
|
FR
|
B
|
GR
|
IT
|
EI
|
USA
|
|
Legislation
|
|
|
|
|
|
|
|
|
|
|
|
Approval scheme including
cleaner production
|
4
|
4
|
o
|
4
|
o
|
o
|
o
|
o
|
n
|
4
|
|
Voluntary agreements
|
4
|
4
|
4
|
o
|
o
|
o
|
o
|
o
|
o
|
4
|
|
Financial instruments
|
|
|
|
|
|
|
|
|
|
|
|
Tax, duties and fees
|
4
|
4
|
o
|
o
|
4
|
n
|
o
|
o
|
o
|
4
|
|
Grants and subsidies
|
4
|
4
|
o
|
4
|
4
|
4
|
4
|
n
|
o
|
4
|
|
Information and education
|
|
|
|
|
|
|
|
|
|
|
|
Demonstration projects
& processes
|
4
|
4
|
o
|
4
|
n
|
4
|
o
|
o
|
o
|
4
|
|
Demonstration projects
& products
|
4
|
o
|
o
|
o
|
o
|
4
|
o
|
o
|
o
|
o
|
|
Consultant support
|
4
|
4
|
4
|
4
|
4
|
4
|
o
|
4
|
4
|
4
|
|
Centers of expertise
|
4
|
4
|
o
|
4
|
o
|
4
|
o
|
4
|
4
|
4
|
|
Newsletters
|
4
|
4
|
o
|
4
|
o
|
4
|
o
|
o
|
4
|
4
|
|
General manuals
|
4
|
4
|
n
|
4
|
o
|
4
|
o
|
o
|
o
|
4
|
|
Industry specific manuals
|
4
|
4
|
o
|
n
|
o
|
o
|
o
|
o
|
o
|
4
|
|
Databases
|
4
|
4
|
4
|
4
|
4
|
4
|
o
|
o
|
o
|
4
|
|
Videos
|
4
|
4
|
o
|
o
|
o
|
o
|
o
|
o
|
o
|
4
|
|
Conferences and seminars
|
4
|
4
|
o
|
o
|
o
|
4
|
o
|
o
|
4
|
4
|
|
R&D programs
|
4
|
4
|
o
|
o
|
o
|
4
|
4
|
4
|
4
|
4
|
4
Yes
n
Under preparation
o
No activities or no information
NL - Netherlands DK - Denmark SP
- Spain UK - United Kingdom
FR - France B -
Belgium
GR - Greece
IT - Italy EI -
Ireland USA - United States
of America
4
Yes
n
Under preparation
o
No activities or no information
NL
- Netherlands DK - Denmark SP
- Spain UK - United Kingdom
FR - France B -
Belgium
GR
- Greece IT - Italy
EI - Ireland USA -
United States of America
This
summary is taken from ANZECC (1998:93), and gives an idea about the wide
variety of CP policy instruments used in many countries. To some extent,
this in my opinion at least also shows a "splintering of
efforts" – it would be preferable if instead of formulating
specific CP promoting instruments, other instruments, notably
environmental regulation and resource pricing, would be made more CP
conducive.
UNEP
(2000) provides the following examples of policy instruments that are
specifically designed for promoting and encouraging CP. In some cases I
have added my own comments; in other cases I have left out comments due
to space limitations.
Cleaner
Production Strategies and Programmes
National
and local governments may establish formal cleaner production strategies
or programmes, the main aim of which is to serve as a framework for the
coordinated implementation of subsequent, more specific policy
instruments. These Cleaner production strategies and programmes often
analyze the experience so far with initiatives to encourage cleaner
production, the successes and the failures. The CP strategies and
programmes analyze the barriers towards the implementation and wider
adoption of CP, and contain a number of actions to eliminate barriers or
prevent additional incentives for the implementation of CP. Cleaner
production strategies and programmes are instruments that help in the mainstreaming
of CP, so that CP is integrated in the decisionmaking of other
ministries.
For
example, the four major themes in the Australian national strategy for
cleaner production are:[2]
·
Provision of
information to
enable industry, governments and the community to make appropriate
decisions. Information recipients need data from diverse and credible
sources. Data sources are
the local and national governments, industry associations and
environmental organizations.
·
Supply of
adequate management and analysis tools and systems
to enable industry to
be able to adopt cleaner production. Effective cleaner production
adoption requires integration of management information systems,
technologies and comparative environmental data. Many of these tools and
systems are still in their infancy or, if developed, are not available
in an appropriate format to those implementing cleaner production.
Governments and industry associations, as well as community groups, have
clear responsibilities to develop and encourage their broader use, and
train staff and management in their use.
·
The design of
regulatory systems to
provide incentive structures for the adoption of cleaner production. To
be truly effective, they should also acknowledge the role of industry
self-regulation, as well as government enforcement. This corresponds
with the major theme that in order to stimulate CP, not so much
additional CP-specific measures are needed, but EOP biases in existing
regulation needs to be removed.
·
Strengthening of
the market for goods and services
by eliminating
market-distorting practices, or where this is not possible, compensating
for them. This includes most importantly the removal of subsidies on
energy, water and raw materials, a common theme.
In
my view, this provides the basis for a coherent approach to CP, by
solving knowledge constraints and providing correct framework
conditions. In a certain sense, Section 4 is a further interpretation of
the ideas expressed in the Australian national strategy above.
Product
Bans
An
authoritarian means of promoting cleaner production practices may be
through the imposition of a ban – or a defined phase-out schedule –
for a particular product or substance.
Extended
Producer Responsibility
EPR
aims for environmental improvements throughout the life-cycle of product
systems by making the manufacturer responsible for various parts of the
product's life cycle, including in particular for the take-back,
recycling and final disposal of the product.
Requiring
Cleaner Production Audits
As
part of their permitting requirements, firms may be mandated to
undertake cleaner production audits of their plants and to implement
some of the audit findings. CP audits are a structured means of
identifying cost effective waste minimization / cleaner production
improvements within a particular company.
While
the implementation of such audits is often entirely voluntary these
audits may also be stimulated by appropriate government policies. An
example of a government policy relating to CP audits is the inclusion of
major
recommendations of the audits as compliance conditions in the permits.
The next section contains an example of such an approach. Another
approach – which has been employed in the UK for energy efficiency
audits – is that the government subsidizes the cost of energy audits
to firms (in the UK, the subsidy was 50%).
In
my opinion, the main drawback of this approach is that it sends the
wrong message: that CP audits (or energy efficiency audits) need to be
subsidized or required to make them attractive to enterprises. In my
view, the whole process of CP (or energy efficiency audits) followed by
implementation of the commercially most attractive recommendations
either is expected to be profitable for the company, in which case no
subsidy nor government mandate is needed, or it is not expected to be
commercially attractive at all, in which case the whole process should
not be initiated.
Mandatory
EMS & Reporting
In
terms of integrated permit conditions, firms may be required to
implement a structured environmental management system and to make
public information on their environmental performance.
Financial
and Technical Incentives
Governments
may stimulate cleaner production measures by providing grants, loans and
favorable tax regimes, and by supplying targeted technical assistance to
relevant industrial enterprises. This is actually a family of
instruments – subsidies, favorable tax regimes to make CP investments
more attractive, special loan funds for CP projects, and targeted
technical assistance.
Subsidies
and favorable tax regimes
To
start with the first: CP subsidies and tax regimes favorable
to CP. To what purpose? Do they aim to eliminate a barrier or build
capacity? I though the idea behind CP is that it allows enterprises to
save costs in their production process and in their compliance with
environmental regulation – but if that is the case, do we need
subsidies? I think not. There are occasions where shifts in tax regimes
are warranted – for example, the elimination of subsidies for energy,
water and raw materials, and the introduction of environmental taxes
(greening of the taxation system). These changes eliminate distortionary
fiscal systems, and make sense outside their contribution to the uptake
of CP by expanding the opportunities for CP. Introduction of
environmental taxes is to be encouraged.
However,
the lack of profitability of CP is not what is hindering the uptake of
CP (at least that is the claim – we are interested in CP because it is
(often) cheaper than EOP) – so increasing the incentives (for example,
allowing accelerated depreciation of "environmental" or CP
investments) to engage in CP does not seem a logical approach. Basically
it provides the wrong message: that special treatment and government
intervention is necessary to make CP attractive.
CP
funds
UNEP
(2000) has the following to say on CP loan funds:
"Financing
cleaner production investments has been a problem in many of the
economies in transition and in developing countries. The undeveloped
credit market has not been able to provide loans with reasonable
interest rates, and the existing credits have often been closed to many
of the CP investments because of the small or moderate size of the
investment.
It
is commonly accepted that the establishment of special purpose funds for
cleaner production investments is of utmost importance in economies in
transition and developing countries. Although this is commonly accepted,
the effectiveness of such funds generally needs to be improved, in
particular on the basis of evaluation of their practical application in
various projects indifferent developing countries. A major problem has
been the inability of many companies, especially SMEs, to prepare
acceptable loan applications." (UNEP 2000:40)
Hamner
(2001) provides the following summary of findings of an OECD study,
which expresses a similar sentiment:
"A
major obstacle to trade in clean technology was the lack of access to
financing. In some cases, although stronger environmental regulations
required firms to obtain clean technology, they were unable to import
them due to insufficient funds or credit. Even when the clean technology
offered lower operating costs and were economical in the long term,
companies lacked adequate cash flow to make a significant capital
investment in the technology. This problem was most acute in the
high-debt countries of Latin America and Central and Eastern Europe, and
in those countries with limited reserves of foreign exchange. The
problem of financing appeared to be at times linked with low
environmental standards. In some countries, governments seemed to be
reluctant to strengthen or enforce environmental regulations fully
because of the realization that companies would find it financially
impossible to comply with them. This finding suggests, then, that
strengthening environmental standards alone in non-OECD countries will
not be sufficient to encourage an expansion in trade in clean
technologies." Hamner (2001:29)
I
am certainly not convinced about the need for specific CP funds in
developing and transition economies. The reason is that the absence of
credit affects all sectors of the economy, and not only CP. For example,
farmers lack absence to suitable credit, SMEs lack access to suitable
credit, all industrial sectors lack access to suitable credit – and
following the logic outlined above, this would justify the establishment
of thousands of specified credit funds?! This would hardly be conducive
to successful financial reform.
The
recommendation for the establishment of specific CP funds ignores
considerable evidence that show the general lack of successes of various
types of specialized credit funds, which makes one wonder why CP funds
are so much advocated – apparently this recommendation is made without
reference to the ample evidence in development economics literature that
such credit funds are difficult to establish successfully, difficult to
manage and sustain, and involve high transaction costs, for example to
check the eligibility of a proposal (in the case of CP funds: is the
proposal indeed a CP project?).
Lastly,
absence of credit should not really hinder CP projects in early stages
of CP development: the most attractive CP options are often housekeeping
options that require little investment (if any at all).
4.
A coherent CP strategy and its policy implications
On
the basis of the analysis in Section 2 of the reasons that explain the
lack in take-off of CP, it is possible to derive a coherent CP strategy,
based on the evolutionary stages of the development of environmental
policies. Although I describe these as separate stages, the distinction
between the different stages is quite gradual, and the strategy should
be modified in accordance with this gradual transition.
4.1
First stage – no environmental regulation or EOP focused regulation
Even
in absence of environmental regulation, or in presence of environmental
regulation that forces enterprises to use EOP measures to reduce
pollution, there will be demand for CP options and CP services driven by
the desire to reduce input costs (energy, water, raw materials) and to
increase product recovery. These are the drivers for the first batch of
CP projects.
Therefore, in this stage the focus should be on developing what has been
called the basic capacity level for cleaner production (OECD, cited in
Hamner 2001). According to the OECD, BCL is achieved when a country has:
·
An active core of CP advisors and trainers;
·
A set of demonstration projects;
·
One or more functioning CP centers;
·
Training materials available in the local language;
·
CP principles included in university curricula.
The
demonstration projects are very important, and should concentrate on the
information that will influence enterprise decisions: profitability,
Internal Rate of Return, and most powerfully, simple payback periods. A
good example of what I have in mind (though admittedly this example is
for a subset of CP, energy efficiency) is the information on energy
options generated by the State Energy Conservation Information
Dissemination Center in China. This information focuses on the
profitability for the enterprises, which is their driver for change, and
not the implications of these projects for energy efficiency (enhancing
energy efficiency is not an enterprise objective in itself).
In
assessing the impact of CP projects on enterprise profitability, it is
important to take all cost factors into account. In my own experience
(analyzing different options to increase energy efficiency in the
Netherlands), I found that it is easy to underestimate hidden costs,
like management time, resistance to change within organizations,
training time, realistic costs of capital,
etc. Some CP literature contains claims that are hard to believe (e.g. a
yearly return of 100,000 US$ on an one-time investment of 10,000 US$) at
least in absence of any indication what cost factors have been assessed,
and how.
During
this stage, the groundwork should be laid for the next batch of CP
projects, through a gradual phase-out of subsidies on water, energy and
raw materials, and the introduction of environmental regulations that
are conducive to CP.
4.2
Second stage – Emerging CP-friendly environmental regulation
In
the second stage, CP would still be partly driven by the wish to reduce
on costs for raw materials, water and energy, and the wish to have a
higher product recovery. However, CP is now also driven by the need to
comply with environmental regulation that is CP-friendly.
CP-friendly
environmental regulation has a number of characteristics. First is that
it leaves enterprises free how to address environmental targets set for
them – so the environmental regulation would need to include no biases
towards certain types of technologies (EOP) at the expense of others
(CP).
Second
is to provide enterprises some freedom in their decisionmaking on the
amount of pollution, but with clear penalties for polluting activities.
Both emission trading and pollution charge systems
have the potential of providing companies with a large degree of
freedom. Negotiated agreements, as a particular form of agreements
between industry and government, may also be successful, provided they
contain a clear "threat" as to what would happen in absence of
such an agreement, and a clear penalty on free-riders and non-complying
enterprises.
In
support, it is possible to stimulate environmental labeling initiatives
that will possibly provide marketing advantages to environmentally
responsible companies.
4.3
Third stage – Environmental regulation driven CP project
In
the third stage, it is environmental regulation only that drives CP. CP
projects are initiated in response to ever-tightening environmental
regulation. In this stage, the emphasis should be on maintaining a
flexible environmental regulation framework, providing enterprises with
freedom in how to achieve environmental objectives and in their level of
emissions, as discussed above.
However,
to allow enterprises to respond efficiently to ever-tightening
environmental regulation, several conditions need be satisfied. One is
that the tightening of environmental regulation should be pre-announced
and credible – enterprises should be satisfied that the decision to
tighten the regulation would not be reversed. In general, such a
reversal happens when too tight environmental regulation has been
proposed after an insufficient consultation with the enterprise sector.
A second factor that contributes to uncertainty about possible reversals
of environmental regulation is the lack of power of the environmental
authorities.
Indeed,
a high quality dialogue and a powerful environmental authority seem
pre-conditions for credible environmental targets. Wallace (1995) uses
these criteria in an insightful discussion of how different country
stimulate environmental innovation with more or less success. The more
successful cases are in alphabetical order Denmark, Japan and the
Netherlands – all cases in which there is powerful support for
improving environmental quality, a high-quality dialogue between
enterprises and government,
and a flexible environmental regulation system involving negotiated
agreements.
This
is not to say that these countries are already in the third stage. I
believe they are in the second stage, but that in these countries the
groundwork has already been laid for the successful entry into the third
stage.
4.4
Summarizing conclusions
For
convenience I have included a table that summarized the discussion
above.
Table
2. Summary of the CP strategy suggested
|
Stage
|
CP
Driver(s)
|
Market/Policy
failure addressed
|
Instruments
suggested
|
|
1
|
1.Cost
minimization
2.
Product recovery
|
Supply
(highest priority)
1.
Lack of knowledge on CP Techniques
|
Supply
(priority)
1.
Academic curricula containing CP
2.
Development CP centers
|
Demand
1.
Mispricing of inputs
2.
Absence of CP-conducive env. regulation
|
Demand
(start)
1.
Remove subsidies
2.
Adjust environmental reg.
Gradually
introduce
emission trading, environmental taxation, or negotiated
agreements
|
|
2
|
1.Cost
minimization
2.
Product recovery
3.
Least cost implementation
environmental
regulation
|
Supply
(possibly)
1.
Possibly remaining lack of knowledge on CP Techniques
|
Supply
(if needed)
1.
See 1. and 2. above
|
Demand
1.
Mispricing of inputs
2.
Absence of CP-conducive env. regulation
|
Demand
1.
Remove subsidies
2.
Adjust environmental reg.
Continue
to introduce and expand emission trading, environmental
taxation, or negotiated agreements
3.
Develop high quality dialogue government - enterprises
|
|
3
|
1.
Least cost implementation of
ever
tightening environmental regulation
|
Supply
None
|
Supply
None
|
Demand
To
lax environmental regulation
|
1.
Tighten environmental regulation within framework developed
above
2.
Deepen high quality dialogue government - enterprises
|
5.
Improving CP framework conditions in China – some suggestions
I
thought it might be a nice idea to provide some more concrete examples
of what I have in mind. For these examples, I have chosen China. In the
evolutionary stages described above, China is – like most other
countries – in the second stage. Considerable investments have been
made by the Chinese government and various donor organizations like
UNIDO and UNEP in the development of the basic capacity level for CP,
and subsidies on for example energy are gradually being phased out.
Other inputs might be underpriced; for example, water still seems to be
underpriced, but plans are underway to address this issue. The most
important task now seems to be to address two issues:
-
Demonstrating
more clearly the potential profitability of CP for enterprises, along
the lines discussed in Section 4.1;
-
Making
environmental regulation more conducive to CP
I
will focus my comments on the last issue, and provide some examples of
how the system of environmental regulation in China might provide better
framework conditions for CP.
In
Wang (2001), an English translation is provided of key texts of the EIA
and so-called 3 synchronizations regulations.
According
to Article 13 of the Law of Environmental Protection, “Environmental
impact assessment report of construction project should make assessment
on the pollution caused by the construction project and on its
environmental impact. It should specify pollution control measures.
The design program of the construction project may be approved by the
responsible environmental protection department after the report on
environmental impact is examined by the responsible project department
and approved by the responsible environmental protection department
through official procedures."
According
to Article 26, "Pollution control facilities of the construction
project should be designed, constructed, and run together with the main
body project on a synchronous basis. The construction project may be put
into production or use only after the pollution control facilities are
examined and accepted by the responsible environmental protection
administrative department, which has examined the original environmental
impact assessment report." (Wang 2001:17)
Wang
argues that these wordings imply an EOP bias, and I agree. A slight
rewording of the relevant regulations, and an accompanying change in the
implementation of these regulations, could help to make the investment
approval system more conducive to CP. A possible rewording could be
respectively:
"Environmental
impact assessment report of construction project should make assessment
on the pollution caused by the construction project and on its
environmental impact. It should specify for each of the pollutants
listed in Appendix A,
the maximum amount that each year will be emitted into the environment,
and the maximum amount that will be emitted in a 24-hours period.
The design program of the construction project may be approved by the
responsible environmental protection department after the report on
environmental impact is examined by the responsible project department
and approved by the responsible environmental protection department
through official procedures."
and
"Pollution
control facilities of the construction project and pollution
prevention measures integral to the production process should be
designed, constructed, and run together with the main body project on a
synchronous basis. The construction project may be put into production
or use only after the pollution control facilities and pollution
prevention measures are examined and accepted by the responsible
environmental protection administrative department, which has examined
the original environmental impact assessment report."
These
wordings might help to remove some of the biases in the Chinese
environmental regulations that seem to hinder the uptake of CP.
6.
General conclusions
In
this paper I have investigated the content of the policy instruments
that are often suggested to promote CP. I have argued against some of
the more distortionary instruments that are often proposed, such as
specialized CP funds, and argued for a strategy that focuses on
elimination of market and policy failures.
This
strategy is based on the notion to shape the framework condition in such
a way that individual economic actors, acting in their self-interest,
will produce an outcome that increasingly utilizes CP techniques when
the CP techniques indeed enhance social welfare. Following this strategy
means that profit maximizing enterprises will increasingly use CP when
that is socially optimal – when CP lower social unit production costs.
A
corollary of this strategy is that CP should be positioned as a
profitable business opportunity rather than an activity that should be
subsidized or required by environmental regulations.
The
strategy is well summarized in Table 2, which I have copied here for the
convenience of the reader.
Table
2. Summary of the CP strategy suggested
|
Stage
|
CP
Driver(s)
|
Market/Policy
failure addressed
|
Instruments
suggested
|
|
1
|
1.Cost
minimization
2.
Product recovery
|
Supply
(highest priority)
1.
Lack of knowledge on CP Techniques
|
Supply
(priority)
1.
Academic curricula containing CP
2.
Development CP centers
|
Demand
1.
Mispricing of inputs
2.
Absence of CP-conducive env. regulation
|
Demand
(start)
1.
Remove subsidies
2.
Adjust environmental reg.
Gradually
introduce
emission trading, environmental taxation, or negotiated
agreements
|
|
2
|
1.Cost
minimization
2.
Product recovery
3.
Least cost implementation
environmental
regulation
|
Supply
(possibly)
1.
Possibly remaining lack of knowledge on CP Techniques
|
Supply
(if needed)
1.
See 1. and 2. above
|
Demand
1.
Mispricing of inputs
2.
Absence of CP-conducive env. regulation
|
Demand
1.
Remove subsidies
2.
Adjust environmental reg.
Continue
to introduce and expand emission trading, environmental
taxation, or negotiated agreements
3.
Develop high quality dialogue government - enterprises
|
|
3
|
1.
Least cost implementation of
ever
tightening environmental regulation
|
Supply
None
|
Supply
None
|
Demand
To
lax environmental regulation
|
1.
Tighten environmental regulation within framework developed
above
2.
Deepen high quality dialogue government - enterprises
|
References
ANZECC
(1998), Towards sustainability: Achieving Cleaner Production in
Australia. Australia and New Zealand Environment and Conservation
Council.
Hamner,
B. (2001) Financing Cleaner Production, final draft.
Seattle, Washington, January
2001. Prepared for ADB.
UNEP (2000), Government Strategies and Policies for Cleaner Production,
Draft. Paris, France
Van der Tak, C.M. (2001), International Policy Study: Draft final
report. Prepared for the RNE funded project "Promotion of
Cleaner Production and Environmental Management in China Through Market
Forces", under a subcontract from IVAM Environmental Research BV.
Wallace,
D. (1995), Environmental policy and Industrial innovation: Strategies
in Europe, the US and Japan, Earthscan.
Wang,
H.C. (2001), A Framework Proposal for Adjusting Policies and Rules
Concerning Cleaner Production. Prepared
for the RNE funded project "Promotion of Cleaner Production and
Environmental Management in China Through Market Forces"
Dr. Casper Meeuwis van der Tak, General Director NCC
Consultancy BV, 5/F, Office Building B, East Gate Plaza, Dong Cheng,
Beijing, China, Telp: +86-10-6418-1888, Fax: +86-10-6418-2246,
Mobile: +86-1300 129 4612, E-mail: njzh@mx.cei.gov.cn.
The contents of this paper are partly based on a report I
prepared under a subcontract of IVAM Environmental Research BV, as
part of a project "Promotion of Cleaner Production and
Environmental Management in China Through Market Forces". See
Van der Tak (2001)
|