Assignment 1

1. International involvement in a country (in this case is Asian Development Bank

(ADB)) can have unintended social and political consequences. In your view, are
these avoidable or unavoidable? Why or why not? (15 marks, 1000 words)

Asian Development Bank (ADB) is a financial institution created in the 1960s to foster
economic growth and development for countries in Asia and the Pacific. Its mission is to
assist developing member countries in reducing poverty and improving the quality of life of
their people [1]. As a multilateral development finance institution, ADB’s functions include:
to promote private and public investment development, provide equity investment and
loans, facilitating policy dialogues, advisory services and support regional projects that
contribute economic growth of the region. ADB acquires its operating capital through its 67
member countries contributions and by issuing bonds on world capital markets.

ADB provides financing and technical assistance in five core areas: infrastructure,
environment, regional cooperation and integration, public finance and education. In the first
few decades, ADB operates more like a project-base lending institution, mostly for major
infrastructure projects such as highways, roads, power plants, sewage treatment plants, etc.
However, by the end of the 1920s, ADB expanded to policy based lending, which calls for
those borrowing governments to put in place systemic reforms in their economic, financial,
social and environment sectors much like the World Bank’s structural adjustment
programmes [2]. From then on, borrowing governments must agree to ADB’s loan
agreements that are regularly accompanied with policy measures and conditionalites in
order to get the loan. These can include: the elimination of subsidies, minimum wages kept
low, passing laws and regulations that favor private sector involvement in key economic
sectors and services, etc. All in all, this ADB policy reforms escalates the borrowing country’s
economy into a vulnerable, unregulated, high risk market system in order to facilitate rapid
economic growth.

Although ADB maintains that its operations in governance are non-political, its core
mandate to promote economic growth and development is deeply political. The roots of
economic development lie within the allocation of a society’s resources and opportunities,
gains and losses in different parties, and how power is distributed. In reality, it is almost
impossible to separate political and economic aspects of governance. It is seemingly
deceptive and illiberal for ADB to portray that they are able to adhere to this framework.
Constitutional rights and democratic voices of citizens are often violated because of ADB’s
projects, but has ADB ever openly acknowledge such issue? More often than not, ADB’s
reform regimes have hindered accountability in governance issues to their citizens. Another
highly controversial matter with ADB is their information disclosure policy and the absence
of public participation in project development, monitoring and evaluation. This
unaccountability, non-transparency and irresponsible practice of ADB must be revamped if
ADB is serious on achieving its primary goals.

The ADB-supported Sanjiang Plain Wetlands Restoration Project was rated as

successful as damaged wetlands are restored; relocated farmers’ income has remained or
has increased using smaller amount of land; and bird’s population has increased steadily.
However, the same cannot be said for many other ADB projects as they repeatedly failed to
deliver benefits. A study performed on ADB’s audit reports have shown that over 70 percent
of ADB-supported projects in Pakistan, Sri Lanka and Indonesia (ADB’s three largest
borrowers) are unlikely to provide long term social and economic benefits to the countries’
target beneficiaries [3]. An ill reputed example of ADB project failure is the Samut Prakarn
Wastewater Mangement Project (SPWMP) in Thailand. ADB’s official Inspection Function
revealed fundamental flaws in the internal governance structure. It was found that ADB is
non-compliance with many of its crucial policies and procedures, and that the financing loan
for the project should not be authorized in the first place.
Worryingly, many examples of ADB projects that have contributed to violation of
basic human rights, damage to the environment and even deaths can be found. During the
Asian tsunami disaster in December 2004, proper shelters were one of the pressing needs
for the survivors. Yet, the ADB-funded shelters were lacking appropriate sanitation as the
septic tanks were not buried and were placed 3 meters from the kitchen area [4]. One of the
most controversial project is Thailand’s Mae Moh coal-fired power station. In October 1992,
residents within the seven-kilometer radius of the plant fell ill due to breathing difficulties,
nausea, eyes and nasal cavities inflammations. 50 percent of the rice fields were also
damaged by acid rain. In 1996 and 2003, deaths caused by blood poisoning and high levels
of arsenic, chromium and manganese in water sources around the vicinity of the plant were
reported respectively [5]. In another example, ADB-funded railway rehabilitation project in
Cambodia has involuntarily resettled more than 4000 households. Severe hardship, loss of
income, increased debt and lack of access to basic services were experienced by the
resettled families [6]. There is truly a need for ADB and the host governments to conduct
proper environmental audits. ADB must take up the responsibility for the social and
environmental unjust that they caused, directly or indirectly.
ADB’s unwillingness to bear responsibilities for their projects and policy failures is
really holding back their mission of eradicating poverty in the Asia Pacific region. Since most
of its projects and policies are built into national and sub-national development plans, ADB
conveniently uses the government as cover for its downfalls and negligence. It is easy for
ADB to claim that decision makings are in the hands of the governments and that poor
project management and flawed policies are part of systemic flaws in national governance.
Many of these issues can be mitigated with proper due diligence, effective management
system and coordination between organizations. ADB should be: an institution that is
accountable to the public whose interests it claims to serve; open and conducive to change
based on emerging realities. ADB should not continue enjoying the high degree of immunity
it has; and must be legally liable to national laws for wrongdoings, ill policy makings,
corruption just to name a few. Its governance systems and structures must be overhauled to
allow the public to participate in planning development projects. It is also a good idea to
establish an independent, regional regulatory agency to assess the quality and effectiveness
of ADB’s operations. This agency should be able to criticize and report on ADB for poor
performance, dubious practices, questionable policies and any misconducts.

References
[1] http://www.adb.org/about/our-work

[2] The Asian Development Bank: A Problem Institution

http://base.socioeco.org/docs/doc-7212_en.pdf

[3] The Asian Development Bank: In its own Words, An Analysis of Project Audit Reports for Indonesia, Pakistan, and Sri
Lanka. Stephanie Gorson Fried, Ph.D and Shannon Lawrence, Environmental Defense with Regina Gregory, ADB Watch.
July, 2003.

[4] Large-scale ADB projects draw criticism https://www.japantimes.co.jp/news/2007/05/08/national/large-scale-adb-

projects-draw-criticism/#.WgkxpeGXc6S

[5] An ADB skeleton in the closet: Mae Moh

Available at: http://www.greenpeace.org/seasia/ph/Archives/asia-energy-revolution/adb/mae-moh/

[6] Cambodia: ADB and Australia Financed Railway Project

https://www.inclusivedevelopment.net/campaign/cambodia-adb-and-australia-financed-railway-project/

2. In your view, do international actors bear responsibility for the environmental

injustices resulting from the promotion of environmental goals? Why or why not?
(15 marks, 1000 words)

Environmental injustice is the lack of fair treatment and involvement of all humans
with respect to development, implementation, and enforcement of environmental laws,
regulations and policies. It is also a situation where the minority and low-income groups
having to bear a disproportionate share of environmental costs. Often, we see that toxic
waste dumps located in poorer communities, or toxic wastes being shipped to low-income
districts where regulations are weaker or non-existent. Environmental issues started gaining
international spotlights in the early 1970s, and eventually many environmental
organizations, policy instruments, financing mechanisms that regulate processes of global
environmental protection were born. These can be referred to as global environmental
governance (GEG). Even though environmental awareness has improved and much efforts
have been addressed globally, environmental degradation worsens. Some key challenges to
effective global environmental governance will be discussed, along with a few
recommendations for reformation of our current fragmented governance structure.
One of the key challenges of GEG is the proliferation of multilateral environmental
agreements (MEAs) and fragmentation of GEG. A great multitude of environmental
agreements, protocols, laws and geographically dispersed institutions have put global
environmental governance into a mess. Plenty of inconsistencies can be found in rules and
norms, and the fast paced activities can easily overwhelm, or even financially drain some of
the poorest countries. All of these points to suggest that our current GEG system is not
operating optimally as its agreements, institutions and resources are yet to achieve their
maximum, desired potential and is left with untapped synergies. This complex web of
incoherent system of ‘solutions’ will only worsen over time if no appropriate corrective
measures are put into practice. The following are some pointers often identified as parts of
the MEA proliferation problem. Firstly, treaty congestion is a common description for the
state of GEG as there are more than 500 MEAs registered with the United Nations for
example [1]. It is argued that the more the number of MEAs, it becomes messier, more
incoherent and confusion in GEG, which in turn encourages demands for order and central
decision-making authority. Secondly, there is the duplication and conflicting agendas due to
new treaties being negotiated from scratch on top of the presence of new stakeholders [2].
Thirdly, the role of science is found to be diminishing due to the difficulties of coordination
across the fragmented GEG and proliferated MEAs [3]. With this, we can only hope that
proliferation slows down over time, especially as treaties mature and progress from
negotiation phase swiftly into implementation phase.
Coordination in a multilateral institution is of utmost importance. Despite that, the
rapidly growing number of international environmental actors has made coordination more
important, but at the same time more difficult. The Global Environment Facility (GEF) was
established as a main financing mechanism, but many administrative offices and
commissions were detracted from their authority which led to inter-agency politics [4]. The
challenge of coordination in policies and implementation lies deep within GEG, this often
creates competing or incoherent decision-making structures, which eventually lead to
loopholes in international policies. A few common causes of coordination shortfalls can be
identified. Leadership in global environmental institutions is much needed, yet rarely
discussed in literature. The focus here is on the individuals who are able to lead institutions
or have great influence on the focus institutions. Global leaders should be able to
demonstrate the political will and invest necessary capital to raise the awareness of
environmental issues to the appropriate level. A recent example can be seen as the United
States remained persistent in leaving the Paris climate agreement under President Trump’s
leadership, leaving all other 194 countries in dismay. Within the GEG system, the lack of
leadership impedes progress. There are hardly any leaders who are able or willing to speak
for and work on behalf of the system as a whole. Most of the time, we observe leaders who
try to defend their fiefdom for their agency and programs. Besides, the connections
between science and environmental policy-making is fairly weak. There is no doubt that
solid environmental governance must be based on the best scientific knowledge available
[5]. In fact, there is an abundance of scientific information out there, it is the lack of
synthesis with international policy-making being the missing link. Information from multiple
sources, gathered in different ways are difficult to compare, not to mention indigestible for
policy-makers from non-scientific background, this often contribute to the failure of
providing a complete picture of the environmental issues [6]. Although the environment is
often put at a lower priority by the international community, the need for leaders with
ambitions of aligning the interests of the system as a whole is in great need.
Another major challenge in the current GEG system is the lack of implementation,
compliance, enforcement and effectiveness. Although negotiations on MEAs are rather
active, but few actually turn agreements into actual change on the ground [7]. There should
be clear distinctions between implementation, compliance, enforcement, and effectiveness.
And the sum of these is defined as the performance of international environmental
instruments [8]. The heart of the issue here is that the GEG system has been too obsessed
with negotiating new agreements, while performance focus is almost entirely absent from
the discourse [9]. From one perspective, environmental negotiators have the desire to
merely come to some agreement, despite those that will not bring about any effectiveness.
Reaching agreements can be seen as an achievement and may bring instant rewards, but
true success only comes about if states have the true intention and capacity to make them
work domestically [10]. Another well discussed issue is the lack of global instruments to
ensure compliance and enforcement. Consent for an enforcement body to be made to
comply with international laws is rare, simply because of worries that the costs will
outweigh the benefits. At the very least, the perceptions of sovereignty are slowly changing
as there is strong pressure to act when global commons are threatened [11]. With
innovative legislative and regulatory mechanisms, compliance with MEAs and their
implementations can definitely be improved. For example, moving away from the consensus
principle and towards qualified majorities in the Whaling Commission as well as the
Montreal Protocol [12]. Together with enhanced transparency within the GEG through the
use of formal prior informed consent procedures, government accountability and
responsiveness can be further refined.
To conclude, international actors do play a part in the many environmental injustices
caused, and they should put in prevent further damages in future projects. This can be
helped with institutional reform by changing the building blocks of decision-making
processes within institutions as well as the scope of the issues covered. First, any effort for
institutional reformation should begin with a realization that there is a need for global
environmental governance reform. Second, the reform agenda need not be drastic.
Targeting a limited number of the most critical challenges and deficiencies is preferred over
a grandiose scheme for massive overhaul of the GEG system. Lastly, the reform agenda
should be contextualized within a larger and longer-term vision of the eventual state of the
GEG system. The ultimate goal should be ambitious and clear in sight, while improving the
actual state of the global environment. This can best be achieved with a systemic approach
as opposed to fragmentary method.

References
[1] Anton, Donald. (2012). 'Treaty Congestion' in International Environmental Law.
[2] Susskind, L., 1994. Environmental Diplomacy: Negotiating More Effective Global Agreements. New York: Oxford
University Press.
[3] Najam, A., 2000. “The Case for a Law of the Atmosphere.” Atmospheric Environment, 34(23): 4047–4049.
[4] The WTO in Brief https://www.wto.org/english/thewto_e/whatis_e/inbrief_e/inbr00_e.htm
[5] Bernstein, J., 2005. “The Role of Science in Strengthening Global Environmental Governance.” In UNEO – Towards an
International Environment Organization: Approaches to a sustainable reform of global environmental governance. Edited
by Rechkemmer, A., 281–286. Baden-Baden, Germany: Nomos Verlag.
[6] Haas, P. M. 2004. “Science Policy for Multilateral Environmental Governance.” In Emerging Forces in Environmental
Governance. Edited by Kanie, N. and Haas, P. M., 115–136. Tokyo: United Nations University Press.
[7] Millenium Ecosystem Assessment, 2005. Ecosystems and Human Wellbeing: Synthesis. Washington DC: Island Press.
Accessed at www.milleniumassessment.org in March 2006.
[8] Faure, M. and Lefevere, J., 1999. “Compliance with International Environmental Agreements.” In Vig, N. and Axelrod, R.
(eds.), The Global Environment: Institutions, Law, and Policy, 138–156. Washington DC: CQ Press.
[9] Najam, A., 2006. “Challenges for MEA Compliance.” Presentation at UNEP High-Level Workshop, Colombo, Sri Lanka,
January 2006.
[10] Zaelke, D., Kaniaru, D. and Kruzikova, E. (eds), 2005. Making Law Work – Environmental Compliance and Sustainable
Development. Cameron May Ltd., International Law Publishers.
[11] Chayes A. and Chayes A. H., 1995. The New Sovereignty: Compliance with International Regulatory Agreements.
Harvard University Press.
[12] Dunoff, J. L., 1995. “From Green to Global: Toward the Transformation of International Environmental Law.” Harvard
Environmental Law Review, Volume 19, Winter, 241–300.

3. To what extent, does this case show the limits of environmentalism in China, where
decision-making remains a top-down process? Discuss. (20 marks, 2000 words)

To put it simply, economic growth cannot continue without sacrificing our ecology as
they are strongly interconnected. The conflict between economic growth and the
environment is greater today than has ever before, especially in developing countries like
India and China with high population growth and mass poverty. State governments are
often urged to control environmental pollution, clean their rivers and fight climate change.
To achieve this, stringent regulations and incentives are required. However, due to
widespread corruption in the administration, the rules and regulations concerning the use
of natural resources and environmental protection have been tainted with impunity. One
can understand when priority on environmental protection loses to the more attractive goal
of economic development. During the 1978 economic reform, China recognized the need for
another approach to state intervention, and has turned to non-state actors to share some of
the environmental protection burden. We hence aim to explore the capacity and limits of
environmental public organizations in the form of non-governmental organizations (NGOs),
to compensate for the declining central government control and influence over
environmental protection.

Decentralization refers to the transfer of functions and powers from a central

authority to regional or local authorities [1]. As local governments in China enjoy increasing
responsibility over policy makings and implementations, this does not mean that the
provinces have become independent of the centre. The centre has taken measures to
ensure that only limited resources such as information and technologies are available to
lower tiers government. More importantly, the center retains control over the appointment,
transfer or dismissal of top provincial leaders [2]. This dominant tool prevents provincial
officials from gaining too much autonomy, which otherwise might face the threat of
demotion, delayed promotion or even placed into a meaningless post. Essentially, this
means that the central government hangs on to the primary responsibilities of developing
laws, regulations and policies that are to be implemented by local governments [3]. On
paper, these policies should work well if enforced properly, and environmental degradation
could have been stopped and even reversed [4]. The question is, how well are they
implemented? To answer this, we must evaluate the Chinese environmental protection
bureaucracy.

The State Environmental Protection Administration (SEPA), established in 1988, is

the most important environmental protection unit directly under the State Council. SEPA is
responsible for the following: drafting regulations, policies, guidelines and environmental
protection development plans for all levels of government. It conducts environmental
impact assessments (EIAs) on major industrial projects, engage in international environment
protection treaty negotiations, etc [5]. Since it is required by the Chinese law that all
provincial and municipal governments must enforce national environmental protection
policies, many environmental protection units and bureaux (EPBs) were established to carry
out these environmental duties. SEPA then supervises and coordinates these units. In
practice, EPBs are meant to be subordinates to both SEPA and their local governments.
Despite of that, they tend to enjoy a greater influence than SEPA since EPB funding comes
directly from their local governments. Provincial governments were able to override and
ignore SEPA recommendations. Then, efforts to restore the balance is carried out by
requiring local EPB chiefs to receive higher-ranking EPB endorsement first. On top of that,
SEPA was granted full ministry status in 1998 and was given additional responsibilities [6].
Now, these EPBs must give attention to SEPA recommendations. China showed their
commitment to environmental protection when their (then) new secretary general and
president, Hu Jintao promised sustainable development and environmental protection at
the APEC CEO Summit in 2003 [7]. This move is important, as we already know that high
commitment levels by top officials are crucial for effective environmental policy
implementation.

Generally, authority is shared between SEPA and other agencies where interests
overlap. Even though SEPA has numerous ways of enforcing environmental protection
policies, there is the issue of insufficient independent enforcement authority. When an
enterprise violates environmental laws, very often we will find that EPBs do not apply what
they are authorized to do. On the other hand, polluting companies would go great lengths
just to save on operational costs while avoid being caught red-handed. Hence, they only
operate their water and air pollution control equipment when inspectors’ visits are due. This
loophole can be exploited easily in rural areas due to the lack of enforcement capacity, or
conflicts of interest between economic and environmental division of the administration.
Furthermore, EPB staffs often fail to withdraw operational permits for serious violation of
environmental laws, or simply decide not to charge companies for non-compliances in order
to maintain harmonious relations with them. Worse still, under the common practice of
guanxi [8], EPBs tend to be less strict towards companies that are able to provide tax
revenue to the local government and create job opportunities for the locals. Another
example is the “umbrella” schemes, set up by some local governments that prohibits
environmental authorities’ inspection and fines on firms which are considered important to
the local economy, but are significant polluters. Cases can also be found where county
governments nullify EPB decisions for applying court orders to execute administrative fines
[9]. Such interventions are what impedes environmental enforcement. This also creates a
long-term administrative culture problem where one’s career advances easier by not
carrying out their responsibilities and simply not reporting the current issues to their
superiors, rather than actively trying to rectify them. All of this prove that mere committed
leadership on environmental protection is simply not enough, therefore the system remains
weak and enforcement is highly problematic.

Enforcement authority aside, there are weaknesses in (a) the state environmental
protection system, as well as its (b) compliance promotion structure. In 1998, SEPA’s staff
number dropped from 321 to 200 due to the central government’s effort to decentralize the
government in face of constrained revenue [10]. This strongly hampers SEPA’s ability to
educate and train government officials on the importance of environmental protection. As a
result, many government officials have low awareness, skills, commitment and interest in
environment protection. Given the complex nature of environmental challenges, it is not
easy to grasp the idea behind the uncertain long-term benefits and short-term costs of
investment in environment protection. As discussed earlier, the funding and resources of
EPBs became the local government’s responsibility. This does not always bring positive
changes as this puts EPBs into a difficult situation with contradictory expectations. They are
required to implement environmental protection policies, at the same time expected to
increase economic output and employment as well. Yet, key criterion for career promotions
lies within achievements in these latter spheres. Environmental protection provides long-
term, diffused but controversial benefits. In comparison, the development of infrastructures
and employment creation offer immediate and apparent benefits. Hence, it is no surprise to
see state officials focusing most of their resources on the most rewarding sector, economic
output. On the other hand, compliance promotion is relatively weak in China as the
government rarely makes any effort to inform industries of the latest developments in
environmental regulations and standards. Not only that, technical assistance is seldom
provided for cleaning up, and there are no compliance assistance centre or experts readily
available for companies to seek assistance when they wish to come into compliance [11].
With the above limitations, China’s environmental protection efforts seem to have failed as
degradation continues. It is clear that decentralization has not strengthen environmental
protection as hoped. To fill the gap in the state bureaucracy, the central government turned
to a new partner: environmental civil society.

In the 1980s, environmental non-governmental organizations (NGOs) proliferated

and played a vital role in the political structure of the Chinese government. NGOs are civil
public organizations with two essential characteristics: first, they are formed voluntarily by
the people to protect or advance their interests and values; second, they engage in activities
without the intention of generating profits. As social organizations, NGOs are able to serve
on both sides of environmental decision-making processes and bridges the communication
between the government and society. Usually, financial support for NGOs comes from large
corporations that benefit from international partnerships. Relationships developed between
NGOs and businesses are beneficial in the following ways: reputation enhancement, brand
building, marketing opportunities, employee motivation and risk reduction [12]. This in turn
is able to create sustainability in the business. NGOs also bring about positive influences in
the Chinese government, where new directions are created for policymakers, and
introduction of new laws, regulations, and policies now have supporting views.

There are many categories of environmental NGOs, all of which aim to promote
environmental consciousness, sustainable development and public participation. Well-
established governmental environmental NGOs (also known as GONGOs) have good
relations with the government and benefit from easy access to government officials, data
and financial support. One example of Chinese GONGO is the Heilongjiang Provincial
Territory Society, established in 1994. They were able to involve policymakers and scholars
from the Forestry Bureau, the Environmental Bureau and various universities during the
development of the sustainable land use plan for the Ussuri River watershed [13]. Although
there has been numerous successes, NGOs continuously face challenges in the social,
economic, and political areas. Lack of funding is the primary hindrance for NGOs to further
and expand their activities. The dependence of NGOs on the government also limits their
capabilities, as they have to rely on the government for financial and technical help for
necessary projects. As part of the reform program, the central leadership encouraged
government agencies to transfer some of their functions to NGOs, but many were unwilling
to do so as it would reduce their power and resources [14]. Besides, the government itself
have policies that restrict the expansion of NGOs. For instance, regulations in Beijing
prohibits: (i) NGOs from establishing regional branches, (ii) any individual from serving as
the legal representative of more than one NGO [14]. Volunteer retainment and recruitment
is also a big challenge for NGOs, as the public generally are not convinced that non-
governmental affiliations have the will to bring good for the society without any self-
interested motives [15]. The government should definitely support and promote NGOs in
order to gain public trust to ensure the sustainability of the existing programs.

Although China’s central administration remains top-down, its environmental

governance is still characterized by decentralization. Decentralization was believed to be
able create a more effective and responsive government. However, it failed to deliver real
world benefits in terms of environmental protection. The government responded in two
ways. First, environmental protection bureaucracies were given more authority. Second,
civil society as part of the environmental non-state actors were drawn into the political
space. Unfortunately, both efforts only delivered limited success in China. In addition, the
present number of environmental volunteers and NGOs in China are still far below what is
required. Essentially, government support is crucial and they have to accept that in order to
protect China’s deteriorating environment, it will require a good combination and
coordination between the central government’s action and civil society activism.

References

[1] https://www.merriam-webster.com/dictionary/decentralization
[2] Peter T.Y. Cheung, “Introduction: Provincial Leadership and Economic Reform in Post-Mao China,” in Peter T. Y. Cheung,
Jae Ho Chung and Zhimin Lin, eds., Provincial Strategies of Economic Reform in Post-Mao China: Leadership, Politics and
Implementation (Armonk: ME Sharpe, 1998), pp. 10-17
[3] Sub-national governments may develop laws, regulations and policies. These must be equally or more stringent than
central government laws, regulations and policies.
[4] “The Impact of State Capacity on Enforcement of Environmental Policies: The Case of China,” Journal of Environment
and Development, vol. 12, no. 1 (March 2003), pp. 50-81
[5] http://www.chinacsrmap.org/Org_Show_EN.asp?ID=690
[6] New responsibilities include auto emissions controls and radioactive waste/nuclear safety and natural resources
conservation.
[7] Speech by President Hu Jintao of China at APEC CEO Summit
http://www.china-un.ch/eng/ljzg/zgwjzc/t85897.htm
[8] The Chinese word guanxi is frequently translated as “social connections”. Guanxi, which has long been an element of
Chinese life, is based on a blend of exchanges and mutual affection that “create feelings of responsibility and obligation on
the one hand and indebtedness on the other”. In general, guanxi is maintained by trading favours over long periods. These
exchanges are often viewed as creating a resource that can be used to “get things done”.
[9] OECD Environmental Performance Reviews OECD Environmental Performance Reviews: China 2007. Notes. Page 220.
[10] China: Air, Land, and Water “environmental priorities for a new millennium”. Table 5.1 Developments in
Environmental Administration, 1974 to 1998. Page 101.
[11] Krzysztof Michalak, Eugene Mazur. OECD Environmental Compliance and Enforcement in China. 2004. “An assessment
of current practices and ways forward”.
[12] Cheung, D. K. K. (2007). Business- GO Relationship for Environmental Conservations in Hong Kong: Capacity Building
for GOs and the Roles of Government and Business-Related
Organisations. The Asia Pacific Journal of Public Administration 3(2), 207-222.
[13] Andrew I.E. Ewoh, Melissa Rollins. (2011). The Role of Environmental NGOs in Chinese Public Policy. Journal of Global
Initiatives: Policy, Pedagogy, Perspective 6(1), 50-52.
[14] Lu, Y. (2005). The Growth of Civil Society in China: Key Challenges for NGOs. Chatham House Briefing Paper. ASP BP
05/01, 2-12.
[15] Fangqiang, Y. (2009). Challenges for NGOs in China. Asia Catalyst. Retrieved January 5, 2010. Available at
http://asiacatalyst.org/blog/2009/06/challenges-for-ngos-in-china.html