Pollution: Is the Data Real?

By China Water Risk 9 July, 2014

Inconsistencies in the recording and reporting of pollution data begs the question: is the data real?

MEP says 155tn of lead discharged into wastewater but 7,823tn were carried by rivers to the sea in 2011
7,700tn is unaccounted for & points to illegal discharge; large gaps also persist for mercury, chromium & arsenic
There are systemic issues: MEP data says 4x more lead carried by rivers to the sea than the SOA highlighting

Recently, the MEP has been making public pollution data previously unpublished. Shocking soil statistics grabbed the headlines whilst the 2011 Coastal Environmental Quality Report published earlier this year saw less attention. Apart from saying that more than a third of China’s coastal waters are polluted (Dr Tan Qiaoguo shares his views on this here), the report highlights inconsistencies in the recording and reporting of pollution data, which begs the question: is the data real? Does it reflect the real state of pollution of China’s waters?

Pollution data discrepancies and inconsistencies

The 2011 Coastal Environmental Quality Report made public recently states that 7,823 tonnes of lead were carried by China’s rivers to the sea. However, according to the MEP, the total direct discharge of lead into the sea along the coast in the same year was only 3 tonnes whilst only 155 tonnes apparently were discharged into wastewater (primarily by industry). So where did the other 7,700 tonnes of lead in China’s rivers come from?
CWR - MEP Lead Discharge Discrepanices (2011) EN
Since discharge of lead into the sea and wastewater are measured at discharge points, can we assume that the unaccounted for 7,700 tonnes include a mix of natural emissions and illegal discharge? Since natural emissions are not in this ball park, this huge gap is likely due to illegal discharge.

An official MEP ‘unofficial illegal & unmonitored discharge’ estimate?

All the above numbers are “official” MEP statistics. So can we assume this discrepancy to be the “official” “unofficial illegal & unmonitored discharge” estimate? If so, is the state of environment far worse than reported?

More importantly, are target reduction yardsticks in the 12FYP based on discharge measured at discharge points then going to put a dent in China’s rampant pollution? Is this the right benchmark to use? As Dr. Tan Qiaoguo says in his article on coastal heavy metal pollution, direct discharge to the sea has been falling whilst the amounts from upstream pollution carried via the rivers to the sea has been increasing. There are obviously more questions than answers at this point.

“The key issues are still monitoring and how to force companies to treat their wastewater properly before discharging.”

industrial wastewater treatment company engineer

Regardless, a 7,700 tonne gap is embarrassingly large and shines the spotlight at monitoring efforts to date, which can be at best described as ‘turn a blind eye’.

The key issues are still monitoring and how to force companies to treat their wastewater properly before discharging” says an industrial wastewater treatment company engineer. He also confirms that factories often do not use treatment facilities except on the day of inspection. As a result, pollution levels monitored at the centralized wastewater treatment facility sometimes do not match with the level inspected/reported at the company’s discharge point.

“To protect the economy & obtain a good GDP performance, some local governments & law enforcement officers have covered up crimes or reduced punishments”

Li Zhongcheng, Deputy Director, Malfeasance & Infringement Investigation Dept, Supreme People’s Procuratorate

Last month, China Daily reported that China’s Supreme People’s Procuratorate,  the country’s top prosecuting body is getting tougher with officials who help in cover-ups.

Li Zhongcheng, deputy director under the procuratorate’s malfeasance and infringement investigation department said “To protect the economy and obtain a good GDP performance, some local governments and law enforcement officers have covered up crimes or reduced punishments”. 

The procuratorate estimate that the official dereliction of duty and malpractice in ecological and environmental protection has caused 25 deaths, 12 injuries and RMB3.1 billion (USD498 million) in economic losses in 2013.

Weak laws, low penalties, collusion with EIA assessors and mismatched discharge standards set to ensure polluters benefit have all hampered monitoring. Ministry structure, with dispersed monitoring responsibility spread among several ministries, also has not helped. All need to be tackled together – a mammoth task indeed but at least we now have an idea with an official unofficial number.

Or at least we think we do ….

MEP vs SOA: MEP data says 4x more lead carried by rivers to the sea

Under China’s Marine Environmental Protection Law (1999), the monitoring responsibility of coastal environment including river mouths is shared by the MEP and the State Oceanic Administration (SOA). The SOA also published an annual report on oceanic environmental quality that includes data on coastal pollution based on monitored pollutants carried by 72 key rivers to the sea.

When we compare the two reports (the latest SOA report is 2013, but the 2011 report is used for the sake of comparison), there are discrepancies galore:
MEP vs SOA Data - 2011 Heavy Metals Carried by Rivers to the Sea
So which Ministry’s data portrays the “real picture”?

The differences are likely due to different monitoring points, measurement frequency and methodology

The differences are likely due to different monitoring points, measurement frequency and methodology. Currently, neither the MEP nor SOA are fully transparent about their monitoring methods or sampling sizes, making it difficult to compare the data sets. So it’s not just whether or not discharge is monitored but the monitoring methodology is also questionable.

Surely neither body is doing a good job when 1,600-7,700 tonnes of lead are unaccounted for. Perhaps the failure to do so is systemic?

Under the current system, the SOA only regulates pollution sources along the coast and in the sea, and has no control over the upstream rivers; while local environmental authorities under the MEP only supervise sections of the river that fall within their jurisdiction and have no say over the upstream sections of the same river, which may cross counties and provinces.

Maybe there needs to be regulations and incentive structures to ensure local authorities work together to ensure the health of the whole river?

Maybe there needs to be regulations and incentive structures to ensure local authorities work together to ensure the health of the whole river? Otherwise heavy metal carried by trans-provincial rivers to the sea will persist.

As early as 2010, the MEP and SOA signed an agreement to collaborate on marine environment protection, including strengthening the monitoring of pollution discharge from the coastal regions as well as promoting bilateral communications and sharing of data & technologies. Clearly, we are still far from a cohesive and consistent monitoring system on pollution.

Aside from not knowing which set of data is real, we are also frustrated by yardsticks & definitions that change year-on-year making it impossible to identify trends. MEP’s latest 2013 State of Environment Report is case and point – more on incomparable data on China’s key lakes and reservoirs here.

Guesstimates of the ‘real picture’ from irreconcilable official data

Worryingly, regardless of which ministry is correct, these amounts of heavy metal in China’s rivers carried to the sea are much greater than that measured at discharge points:
Guesstimate Ranges of the Real State of Pollution
Yes, the ‘real state’ of pollution could be significantly worse.

The right to know the ‘real state’ of pollution

There is no doubt that the Chinese people are now more concerned about the environment than before. They want to know how safe their water and food are. More than 117 million social media posts mentioning “pollution” on Weibo is testament to this rising concern. However, obtaining pollution data in China is still tough, both for public interest and academic research.

More than 117 million social media posts mentioning “pollution” on Weibo is testament to this rising concern

Although there have been efforts to improve information disclosure at the national level, transparency is still lacking at the local level.

With the ‘right to obtain environmental information’ now enshrined in the new Environmental Protection Law, transparency hopefully will improve and inconsistencies highlighted here will eventually be ironed out.

Until then, the real state of the environment in China remains like the smog lingering over many cities in this country: worrying & unclear. The overall condition is bad but if these official-unofficial estimates are correct then the situation is a lot worse than we thought.

Article 53. Citizens, legal persons and other organizations shall have the right to obtain environmental information, participate and supervise the activities of environment protection in accordance with the law.

Environmental Protection Law (amendments passed in April 2014, effective 1 January 2015)

Further Reading

  • 2013 State of Environment Report Review: MEP’s 2013 State of Environment Report says the ‘overall environmental quality was average’ but a closer look reveals mixed news, whilst discrepancies found in sets of pollution data add uncertainty of the real state of the environment
  • China’s Coast: The Unbearable Weight of Heavy Metal Pollution: Environmental toxicologist Dr. Tan Qiaoguo from Xiamen University on historical trends of heavy metal pollution in China’s coastal waters & the worrying amount of heavy metals carried by China’s rivers to the sea
  • 5 Takeaways from Aquatech China 2014: How real is China’s war on pollution? Will it translate into a growing domestic water market? See what local & foreign industrial leaders have to say in Shanghai and check out our 5 key takeaways from Aquatech China 2014
  • Pollution: 5 Reasons to Remain Optimistic: Given the recent release of depressing groundwater & soil pollution statistics, Debra Tan gives us 5 reasons to stay optimistic – from changes in the law to water tariff hikes in Beijing
  • Heavy Metals & Agriculture – Check out China Water Risk’s overview of the status of heavy metals discharge into wastewater, priority provinces, overlap with agriculture sown lands, crops exposed and industries targeted for clean-up
  • The War on Water Pollution – Premier Li has just declared war on pollution. Tan expands on the government’s stratagems & offensives and fundamental changes required to shore up the MEP’s arsenal in order to wage a successful war
  • MEP Reform: From Mountaintop to Ocean? – The MEP is currently regarded as too weak to punish polluters due to dispersed authority & overlapping functions. Given the ‘war on pollution’, is reform to make a Super MEP necessary to improve China’s ‘mountains, water, forest, farmland & lakes’?

China Water Risk
Author: China Water Risk
We believe regardless of whether we care for the environment that water risks affect us all – as investors, businesses and individuals. Water risks are fundamental to future decision making and growth patterns in global economies. Water scarcity has emerged as a critical sustainability issue for China's economy and since water powers the economy, we aim to highlight these risks inherent in each sector. In addition, we write about current trends in the global water industry, analyze changes occurring both regionally and globally, as well as providing explanations on the new technologies that are revolutionizing this industry.
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