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This thesis focuses on the role of non-state actors in environmental governance and the ways in which authority is shared horizontally with companies, think tanks, academic institutes, NGOs and foreign partners. While these actors are important, government organizations continue to play a central role in formulation and delivery of environmental policy. The member check interviews emphasize that traditional forms of steering are central to local environmental action in China. The interviews show that companies perceive government authorities primarily as an actor formulating regulation, standards and emission requirements. Much of the energy saving and emission reduction actions taken by local companies are carried out in response to binding regulation. In this section, statements from key respondents illustrate this tendency. In an interview with a department in charge of climate change issues at China’s Ministry of Environmental Protection (MEP), an official confirms that introducing increasing emission standards is their key strategy to reduce emissions in the industrial sector. The respondent sees continuously rising emission standards as a key tool for forcing companies to improve equipment or otherwise to shut down (Interview with domestic environmental authority, 2016.05.28, Beijing).

Respondents from industrial units and industry associations point in a similar way to environmental legislation as a key driving force behind their pollution reduction activities. A manager at a paper and pulp company in Shandong Province describes the increased pressure on small, polluting units over the past few years as follows:

For example in COD [emissions25], we have made extremely fast progress. 3-5 years ago … the

limit in Shandong was around 300 ppm, and then suddenly they cut it to 40 ppm! This meant that a lot of the small factories had to close. The investment in equipment to meet that kind of standards was very high. Our leadership had been proactive in that area, so it was quite easy for us to reach that target. But for all the household size units in Shandong there were really a lot that had to close down. They were rather accepting the fines for pollution than installing that kind of waste control equipment, because it was just too expensive (Interview with domestic paper group, 2016.06.18, Shandong)

A representative of another paper and pulp company in the province makes a similar statement, pointing out that rising emission standards has contributed to closure of small plants and consolidation of the paper industry. The respondent states that their company consistently stayed above the standards, but while they invested massively in new equipment, the local government kept rising the emission control levels. After the most recent upgrade, the company found that their emission levels were lower than an American cooperation partner (Interview with domestic paper company, 2016.06.13, Shandong).

Representatives of the iron and steel industry point to the importance of government regulation as a driving force behind energy saving measures. Within this sector, the most important policy pressure has been local government requirements to shift from coal to gas boilers, in

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combination with rapidly raised emission standards and performance targets for energy efficiency. Many small, inefficient units have been shut down in this sector as well. A representative from Shandong Iron and Steel Industry Alliance states that recent environmental improvements in the sector definitely were incited by government regulation (Interview with Iron and Steel Industry Alliance, 2016.03.04, Shandong). A manager of a large steel enterprise notes that investment into gas boilers were made specifically due to government pressure: “companies have been forced to shut down coal boilers and replace them with gas units. This was an expensive investment for us, which generated no economic benefit. Of course, it is good that they are cleaner, but I doubt that companies would have made this type of investment without the government pressure, it made no economic sense” (Interview with steel company, Shandong, 2016.04.19).

Respondents also observe that the pressure of raised pollution emission standards will continue to affect industrial activities in the coming years. A representative of China Paper Industry Alliance states that “the key thing right now is the recently introduced environmental law, which has very high standards for certain types of emissions … A lot of small factories will have to shut down in the coming years” (Interview with China Paper Industry Alliance, 2016.05.22, Beijing). A representative of a pulp and paper company states that all industrial sectors will be under high pressure during the 13th FYP due to government regulation. The

intention of the central government is to consolidate the sector and only allow high performing units and companies with economies of scale to remain in the market (Interview with domestic paper group, 2016.06.18, Shandong). Another round of shut-downs is expected in the iron and steel sector as well (Interview with Iron and Steel Industry Alliance, 2016.03.04, Shandong). Other policy strategies also affect company activities, but to a more limited extent. Overall, the member check interviews suggest that the most important tool is economic incentives: subsidies and tax benefits. A respondent from MEP confirms that use of locally issued subsidies is an important policy support. However, capacity to rely on these tools is connected with economic strength of local authorities, which means that economically weaker areas ted to fail implementation of such strategies (Interview with domestic environmental authority, 2016.05.28, Beijing). According to representatives of the steel and paper industries, beneficial tax policy is the type of incentive that has the largest effect on their activities (Interview with domestic paper group, 2016.06.18, Shandong; Interview with paper industry alliance, 2016.05.22, Beijing; Interview with domestic paper company, 2016.06.13, Shandong). A related observation is that many private sector actors continue to have a reactive approach towards energy savings and emission reduction activities. The interview material suggests that respondents from the industrial sector perceive government authorities as the actors primarily responsible for the quality of the environment. Empirical material presented in other chapters of the thesis points to a similar tendency. For example, the comparative study included very few companies that had taken independent climate mitigation action – almost all initiatives in the industrial sector appeared to be measures adopted in response to government regulations or guidelines. In the case study in Rizhao, key industrial actors did not agree to participate in interviews. If these actors had seen themselves as leaders in climate action, it is possible that they would have been more enthusiastic about the opportunity to promote their efforts online or through discussions with researchers.

These accounts demonstrate that traditional “government” (rather than governance) still plays an important role in environmental protection efforts in China. These accounts indicate that authorities in charge of environmental actors remain the most important actors addressing environmental issues on a local level. However, environmental government authorities are not the only actors shaping and delivering environmental policy.

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