Pollution control systems in the United States and European Union rely heavily on permitting as a key regulatory vehicle for limiting emissions, coordinating local decisions with national targets, and ensuring compliance. Transparent and consistent operation of environmental permitting systems promote a positive climate for investment and commerce, contributing to a level playing field by bringing all covered pollution sources into a common compliance system, thereby eliminating the economic advantage of non-compliance. While unique policy and legal contexts shaped the development of air permitting programs in the United States and European Union, there are general principles learned over the course of several decades of implementation that are especially relevant to a government designing new rules today. Key principles to take into consideration in a stationary source air permitting program include:

1. Building continuity between emissions at their source and air quality goals;
2. Including mechanisms to balance economic growth and environmental impacts;
3. Assuring compliance with applicable requirements;
4. Conferring adequate management authority on the environmental agency at the national level;
5. Incentivizing compliance;
6. Providing transparency;
7. Engaging the public in the decision-making process;
8. Streamlining to balance efficiency and effectiveness; and
9. Ensuring the program has adequate and secure sources of funding.

As China establishes a strong national permitting program to control emissions from new and existing sources of pollution, prioritizing certain regulatory programs, sectors, regions, and pollutants on which to focus initially is a pragmatic approach. While the scope of permitting activities may be limited initially, as capacity is built at implementing agencies, the program can be expanded to become a fully-fledged pollution source permitting program covering all major sources. To take a phase approach, however, it will be important to have a clear understanding of the end-goal and a roadmap for achieving it, so that the information, technologies, tools, and practices put in place today by environmental agencies across the country will enable this work in the future.

This paper presents lessons and recommendations from international experience that can inform the development of China’s permitting system. A summary in Chinese is available here.