Reforming Water Permits in China

By Martin Griffiths, Cheng Dongsheng 17 November, 2014

Martin Griffiths & Cheng Dongsheng on the challenges of China's Water Use Permit & the needed improvements

Scientific & evidence based regulatory & permitting system is crucial to sustainable water resource management
China's water permit application process appears equivalent to Europe's but may not wholly protect water
Most of the building blocks are in place but implementation will require significant shift in attitude by regulators & users

A changing climate and a growing population places increasing pressure on precious water resources. The growing mega-cities of China put new and unprecedented demands on water resource allocation. Water is already scarce in China, especially in the dry Northern Provinces. Too much water in the form of floods, and too little water in the form of droughts will become significant risks for society. Water security will become one of the major challenges and urban planners must work with water resource managers to reduce risks and optimize water.

Water security definition

“The capacity of a population to safeguard sustainable access to adequate quantities of acceptable quality water for sustaining livelihoods, human well-being and socio-economic development, for ensuring protection against water-borne pollution and water-related disasters, and for preserving ecosystems in a climate of peace and political stability.”

 – The United Nations Water Department (2013)


“A scientific & evidence based regulatory & permitting system is essential to sustainable water resource management…”

A scientific and evidence based regulatory and permitting system is essential to achieve sustainable water resource management anywhere in the world.

As part of the ongoing dialogue between Europe and China through the China Europe Water Platform (see English website here and Chinese website here) we have undertaken a study to review integrated water resources permitting policy and practice in Europe and China.

A China-Europe collaborative study was conducted with a view to gaining a mutual understanding of the key regulatory components which could be adapted for use in China

This was conducted with a view to gaining a mutual understanding of the key regulatory components which could be adapted for use in China.

The review also includes an important overview of current regulatory practice in China which contributed to the European understanding of water management.

In this study, Technical Research on Integrated Permitting of Water Resources, European and Chinese regulatory practices are examined and some options for reform and future consideration are identified.


An internationally accepted model (see diagram below) of best practice in regulation and permitting has been developed by IMPEL (an informal grouping of European environment agencies and environmental regulators). This regulatory cycle was used to structure discussions and focus on issues.

Water Resources Regulatory Cycle

China’s Water Focus

In high level terms China has impressive water strategies and policy plans. The 2011 China No 1 Document, (The China No.1 Water Document 2011, published 31 December 2010, in force 1 January 2011, is a formal decision of the Central Committee of the Communist Party of China (CPC) and the State Council on accelerating the water conservancy reform and development) is the most important and signals the need for reform and improvement in the management of water resource.

At the setting of water environmental objectives China uses the function zone approach and is consolidating this with the “Three Red Lines Policy” – see box below.

China’s Three Red Lines – Water Resource Management Objectives

  • The first Red Line sets water quantity objectives in rivers, lakes and groundwater. It requires the ‘total quantity control of water abstraction’.
  • The second Red Line sets objectives for water use efficiency. This will accelerate the development of national standards regarding water use quotas for high-water-consumption industries and the service industry, including agriculture.
  • The third Red Line sets objectives for water quality and is directly related to the pollution load allocation accepted in the Water Functional Zones. It requires “control of total pollution load’ and will considerably strengthen the regulation of pollution control permits for point source discharges.


China’s water permit legislation is strong if implemented strictly

In terms of water permit legislation, Chinese water resource laws are strong and should allow adequate control and protection if implemented strictly.

China’s water permit application process seems similar to equivalent European systems…

…but may not wholly protect water

A permit application process is in place which is internet based and appears to be similar in function to equivalent European systems (for more on China’s water permitting system see here).

Permits are required and are based on the water allocations agreed with each Province as part of a five year water resource planning system. They may be amended on an annual basis depending on water resource forecasts and response to low water projections in any one year.

However, national and international commentators agree that these permits are often administrative and may not be wholly protective of the water resource.  They are not always monitored and enforced as strictly as required and reporting and communication can always be improved.  Prosecution for breach of permits is unusual.

Monitoring & enforcement will need significant improvement to give confidence that the permit standards are protective & essential

The report points out areas for improvement and more precise controls which would send out signals that permit standards need reform, based on evidence and sound science.

“Most of the building blocks are in place, but implementation and strict adherence to water regulatory conditions are essential”

“This will require a significant shift in attitude from regulators & regulated water users”

Water resources scenarios can be modelled and China has the capability and computing power to do this.  However, monitoring and enforcement will need significant improvement to give confidence that the permit standards are protective and essential.

The No 1 Document signals the need for this reform and the need for more comprehensive and sustainable management of water resources.  Most of the building blocks are in place, but implementation and strict adherence to water regulatory conditions are essential.  This will require a significant shift in attitude from regulators and regulated water users.

Recent central Government messages on adherence to law should help in achieving this end.  Ultimately continued growth and environmental sustainability will be dependent on optimising precious water resources and increasing water security for all.

Further reading

  • Water Permits: How to Get Water in China – How are water total water quotas set? How can you access water in China? China Water Risk gives an overview on these and the risks associated when China’s water permit system is reformed
  • Water Rights in China – Professor Jia Shaofeng, Deputy Director of the Center for Water Resources Research of CAS,  shares his in-depth insights on water rights in China – what they are, who owns them, how can they be “traded” & why a market trading system should be the way forward
  • 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
  • 2013-2014 Key Water Policies Review Haven’t been following China’s Three Red Lines strategy to protect water? Check out our summary of key water policies from 2013 to 2014
  • More Power to Enforcement: Debra Tan gives a run down of upcoming “institutional innovations” discussed at the 2013 Beijing Forum and why the path-of-more-enforcement is still full of “areas of confusion”
  • Fundamental Issues: Industrial Wastewater Professor Ma Zhong, dean of the School of Environment of Renmin University gives his in-depth views on the industrial wastewater standards & pricing. Is it cheaper to pollute than to treat?
Martin Griffiths
Author: Martin Griffiths
Dr Martin Griffiths is an expert in water quality strategy, regulation and policy. He was Head of Water Quality Policy in the Environment Agency and latterly Deputy Director of Regulation in the Department for Environment, Food and Rural Affairs in London. He is a Visiting Professor at Cranfield University and lectures on a number of MSc programmes. He also works as an independent consultant on water and environmental issues.
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Cheng Dongsheng
Author: Cheng Dongsheng
Dr. Cheng Dongsheng is a researcher of China Institute of Water Resources and Hydropower Research. He drafted most of the section on the current Chinese Approach to Water Permitting of the Report “Technical Research on Integrated Permitting of Water Resources”.
Read more from Cheng Dongsheng →