Environmental Advocacy Through Institutionalized Interaction with the Government

China Development Brief, No.55 (Fall 2012)

中文 English

Environmental NGOs throughout the country have launched advocacy initiatives in recent years. One such organization located in southwestern Chongqing is the Chongqing Two Rivers Voluntary Services Center (重庆两江志愿服务发展中心), hereafter referred to as the Two Rivers Center, a grassroots environmental NGO that plays an active role in environmental advocacy.

Each year the Two Rivers Center oversees an average of 20-30 projects managing pollution at specific sources and 40-50 environmental monitoring initiatives. Through these pollution control and environmental monitoring projects, the Center has been able to institutionalize a long-lasting relationship with the local Environmental Protection Bureau (EPB). The Center, therefore, has been able to achieve widespread success, whether it be in enhancing the efficiency of local EPBs or monitoring and managing a company’s environmental impact through Environmental Impact Assessments (EIAs). For example, after the Center complained about environmental monitoring stations that were not functioning effectively, staff at four of Chongqing’s nine district and county-level stations were punished. Additionally, six EIA companies that did not perform their jobs were punished and reported to city authorities. For companies like these, the Center has already become an independent, third-party source of oversight and pressure. Naturally, the Center’s independence has been attracting widespread attention for its ability to effect real change in the government and private sectors.

Institutionalizing Interaction with the Government

“We and the EPB neither cooperate, nor confront one another. We have a close, interactive relationship. The Center usually has been able to receive positive feedback and revisions from the EPB on our monitoring reports,” Xiang Chun, founder and executive director of the Center, said confidently. This type of relationship is rare in China.

Reporting on environmental problems was difficult when the Center was not well-known. “The EPB felt that we just wanted to cause trouble. When we failed, we disseminated our reports through the media and social media. It was only then that we finally developed a good relationship.” At first, Mr. Xiang posted messages on the internet to stimulate action by government departments on pollution uncovered by the Center.

He related a story about his relationship with the EPB. In July 2010, the Center found pollution coming from a landfill in Chongqing’s Shapingba District that directly discharged into the Jialing River, threatening waterworks up to 10 km downstream. The landfill was located just next to a village water pumping station. After a sampling and data investigation, the Liangjiang Center brought the matter to Chongqing’s Environmental Protection Bureau. The government eventually found that the Chongqing Agrochemical Group was responsible for this pollution by disposing 440 tons of BHC, DDT, and pesticide, into the landfill. In September 2011, the Shapingba government, District EPB, Agrochemical Group, and other work units jointly launched a restoration project and began relocating nearby residents. From that time on, at least once each season the Center asks the District and Municipal EPBs for updates on landfill disposal.

As an independent grassroots organization, the Center is not always able to maintain a cooperative relationship with the government. For instance, in May 2011 it provided a sample of soil and paid the testing fee for the Chongqing City Environmental Monitoring Center so as to supervise progress at a landfill site. The Monitoring Center, however, informed the Liangjiang Center that the sample had been destroyed and refunded their payment. Later, Mr. Xiang posted the Liangjiang Center’s efforts and government response with pictures onto Tianya (天涯), an online forum. Within two to three days there was a strong reaction online and, under pressure from the public, the Monitoring Center called Mr. Xiang to say that the sample had not been destroyed and asked if they could return the sample to the Center.

Mr. Xiang said that the Center decided to send the sample to the EPB not to determine whether there was pollution because it was already clear that the pollution was there, but rather to follow up to make the point that continuous monitoring was important. After this incident, the EPB’s attitude changed and the Center took the opportunity to communicate more directly with the Bureau. Mr. Xiang said that residents near the landfill have already been relocated and that polluted soil from the landfill will be treated by the end of August.

The Center’s pollution control goals are twofold. The more direct goal is to reduce pollution in Chongqing, protect the public’s health, and safeguard the ecosystem. The second, less overt, goal is to improve the government’s effectiveness and “advise them on how to achieve a higher level of performance” by intervening in pollution cases. At this point, they have been partially successful. Mr. Xiang quotes the words of a deputy chief at the Chongqing EPB who informed a polluting company: “it’s not just EPB enforcement authorities watching you, there are also others watching us and the efficiency of our work”. These words impressed upon Mr. Xiang and his team the value of their work.

“Quarreling is Also Part of the Process.”

Occasional confrontation is inevitable in these types of interaction; in 2010 and 2011 Mr. Xiang even hit the table in front of EPB officials. Before our interview on the morning of July 19, Mr. Xiang went to the EPB and got into an argument with the EPB’s senior staff because “a situation had arisen.” In the past, the Center had little problem applying for public disclosure of information from the EPB; this year, however, a new official had been put in charge of this duty and refused a number of recently submitted applications in the name of social stability. Upon returning to the office, Mr. Xiang again started looking for information and materials to “prod” EPB officials.

Mr. Xiang, however, seemed indifferent to the challenges posed by environmental advocacy and changing attitudes from government agencies and corporations, “We really don’t have any frustrations. Sometimes we may get angry, but we do so for a purpose. We quarrel to let you know we’re concerned and to push for further action.”

Now, Mr. Xiang and the Center have speedier communication with the Chongqing Municipal EPB because they can resolve issues directly instead of resorting to messages on the internet or mass media to exert pressure. A standard operating procedure for the quarrels has developed. At least once every month, Mr. Xiang and his colleagues meet with the EPB director to report and complain about polluting enterprises or to point out government problems and deficiencies. Even if there is no specific issue to discuss, they will find something to talk about.

Since the second half of 2011, the Center has become involved in EIA issues and has disclosed the mismanagement of EIAs by using publicly-accessible EIA information from the internet, incorrect information presented to the public, unqualified EIA companies completing EIAs, non-standardized procedures, and violations of regulations that permit public participation. The Center has also audited many EIA reports approved by the EPB. For example, in an EIA report, the Center found that among dozens of EIA reports, four had obviously been fabricated by one person. Mr. Xiang said that, in the past, there were around 40 EIA companies that had completed thousands of EIA reports and all have been given the green light and passed examinations. He also found that some EPB officials did not understand the EIA Law or the provisional regulations for public participation in environmental impact assessments.

In addition to interacting with the EPB, the Center sometimes also directly confronts and questions company owners and EIA companies in the name of an environmental NGO. While often ignored in the beginning, the Center would later follow up with the EPB and report evidence collected from their investigations into companies and projects.

The Center spent a year improving three facets of the EIAs: technical analysis, public participation, and the appropriateness of procedures. In the second half of this year they will also be working to professionalize technical analysis and audits and plan to establish an online EIA database to collect all EIAs and notices to provide information for public participation. They will also select important cases and conduct a third-party review, in accordance with statutes concerning public participation, to confirm whether an EIA company involved in the EIA process has fabricated the data.

“The EIA companies already know that people are paying attention and that they cannot casually go about their work. We hope, through this supervision, to gradually enforce local standards.” Mr. Xiang ‘s dedication has finally been rewarded.

NGOs Are a Boon to Social Stability

It is impossible to ignore the recent, and quite shocking, Shifang incident when discussing EIAs.1 Mr. Xiang said that he did not read the EIA report for the Shifang project, but assuming that the molybdenum copper project received technical approval there were still problems with the project. The regulations require that it go through four information disclosures involving the EPB, the company owner, and the EIA company from the time the contract was signed until the project’s completion. Evidently, however, the project only became public knowledge the day of the commencement ceremony. Two legally mandated public announcements, filling out a public participation survey, and the holding of public forums and hearings, either did not occur or were not carried out properly.

“Similar incidents could also occur in Chongqing, if projects are not done properly. Thus, it is the role of NGOs to mitigate social conflicts to help the government maintain stability,” Mr. Xiang remarked. In the case of Shifang, NGO and community stakeholder participation in the government’s decision-making process would have led to better communication, possibly resolving the problem before a conflict broke out.

During its existence, the Two Rivers Center has dealt with dozens of polluting enterprises, mostly from the machinery and chemical industries. As a local Chongqing organization, the Center targets local pollution matters regardless of the company’s background. They have brought cases against state-owned enterprises, private enterprises, foreign companies, companies high on the production chain, listed companies, and non-listed companies. In all these cases, the Center relies on government interaction, rather than with the media, to resolve issues.

Unlike Beijing-based organizations like Greenpeace (绿色和平), the Institute of Public and Environmental Affairs (公众与环境研究中心), and Green Beagle Environmental Institute (达尔问), there is no geographic advantage for local NGOs to use the media. Mr. Xiang points out Beijing-based organizations are more likely to rely on the media as a way to expand their influence nationwide.

Leaving Pessimism Behind

Grassroots organizations can inevitably become pessimistic as they work in an environment in which they face local pressure. Mr. Xiang and his team try to avoid this by remembering that, although they face many difficulties, their very existence is predicated on overcoming such an environment.

“We have never been pessimistic or given up on communicating with the government.” Mr. Xiang’s understanding of communication is quite broad, running the gamut from calm exchanges and conversations to quarrels, slapping the table and posting messages on the internet. Instead of “pessimism,” Mr. Xiang prefers to use “professionalization” to describe the Two Rivers Center. They have found a practical and sustainable direction and are committed to having a positive attitude and professional outlook in their work. In addition, the Center has focused on professionalizing their staff by recruiting graduates with degrees in relevant fields, such as environmental engineering, environmental sciences, law, and chemistry. Although they no longer emphasize the sacrifice and dedication required of first-generation environmental NGOs, they still recognize the importance of enthusiasm.

The Municipal Civilization Office (市文明办): a “Cross-boundary” Agency

Although the effectiveness of NGO advocacy depends heavily on its strategic positioning, there are other intervening factors that cannot be ignored . For example, I wondered how the Two Rivers Voluntary Services Center’s name brought to mind a volunteer service organization instead of an environmental protection NGO. I did not expect that, behind this question, lay an important moment in the Center’s development related to its supervisory unit, the Chongqing Civilization Office.2

“The Chongqing Two Rivers Voluntary Services Center” is the registered name provided by the Chongqing Civilization Office whose work focuses on developing volunteer services. Normally, an NGO seeking to register would have to find a supervising unit in the same professional field. For the Center, that would mean an agency like the EPB, not the Civilization Office. In this case, the Civilization Office took a chance by agreeing to sponsor an environmental NGO but asked the Center to put “voluntary services” in its name so it would appear consistent with the Civilization Office’s scope of work. Mr. Xiang said that the name “Two Rivers” stands for the two rivers that run through Chongqing, the Jialing and Yangtze Rivers. It was registered as a social organization at the Chongqing city level in August 2011 lending it an elevated status.3 Thus, what on the surface appears to be a strange name for an environmental NGO is in reality a way for the Civilization Office to justify its sponsorship of the Center.

The development of NGOs in Chongqing has been slow due to lack of support from the Civil Affairs department. The Chongqing Civilization Office wants to be more than just a document-issuing agency. It wants to be involved in managing the development and capacity building of NGOs, volunteer services and community development, and to open more opportunities for promoting the development of grassroots organizations, but is being very careful in its initial steps.

After considerable back and forth, the Two Rivers Center (formerly known as the Chongqing Youth Environment Council) was founded by Mr. Xiang as a grassroots NGO. It is the only grassroots organization in the country sponsored by a provincial-level Civilization Office.

“The Civilization Office gives us high marks,” Mr. Xiang said. In the early days, the EPB was trying to make Chongqing a National Environmental Protection Model City and saw the Center as a troublemaker. The Civilization Office, coming from a social development perspective, saw this as a trivial issue and, instead of putting pressure on the EPB, felt the problem could be solved by communicating with the EPB.

The Center’s relationship with the Civilization Office is an innovative arrangement. Normally, an environmental NGO is sponsored by a government agency in the same professional field such as the EPB. But obviously, an unavoidable conflict arises when an agency being monitored (the EPB) becomes the supervisory unit for the monitoring organization. The Center avoids this conflict of interest, and thus plays a more independent and effective role, by having the Civilization Office serve as its supervisory unit.

Like many grassroots organizations, the Center needed funds to get started. To avoid taking on too many projects, it decided to concentrate on environmental protection and NGO sector development. There is little overlap between environmental protection and NGO sector development, but the Center hopes that more local NGOs will emerge in Chongqing with help from the Civilization Office, which in turn could also help the Civilization Office to achieve its own goal. The Office would like to support NGOs and foster communication on policy so that the Center can act as a resource for organizations outside the field of environmental protection.

In the last two and a half years the Center has expanded its staff from four to seven. Currently, the Center is funded in large part by the SEE Foundation. In August, the Center and the Alibaba Public Welfare Foundation (阿里巴巴公益基金会) finalized a project agreement in which Alibaba pledged to financially support the Center’s industrial pollution prevention and control projects in 10 counties outside of the Chongqing city center.

Developing New Strategies

In addition to its own projects, the Liangjiang Center cooperates with other organizations like Green Choice (绿色选择), a nationwide environmental advocacy alliance, to provide firsthand pollution monitoring data and identify major polluting enterprises. Starting this May, it will hold its first conference together with three other local environmental NGOs: the Green Volunteer League of Chongqing (重庆绿色志愿者联合会), Chongqing Public Science Education Center of Environmental Protection for Rivers (重庆公众河流环保科普中心), and Chongqing Youth Environmental Exchange Center (重庆青年环境交流中心). Through a series of rotating, monthly meetings, these four organizations have been able to share information and create a foundation for cooperation.

The Center has also been able to engage in public interest litigation against polluting enterprises with support from the All-China Environment Federation (中华环保联合会) since Chongqing established its first environmental court this year.4 Thus, the Center has gone beyond working through administrative channels (e.g. working through the EPB) to promoting public participation in seeking environmental justice through legal means and winning compensation for past pollution violations. This past August, the Center also drafted two motions on EIAs and environmental public interest litigation, both of which have been submitted to the Chongqing Municipal People’s Political Consultative Conference5.

  1. Editor’s Note: the city of Shifang, in Sichuan, was the site of an environmental protest in the summer of 2012 against the building of a molybdenum copper factory that led to the temporary suspension of the project. 

  2. Editor’s Note: In order to register as a NGO with Civil Affairs, the Center had to find a party or government agency willing to be the NGO’s “professional supervising unit”. Normally, the supervising unit needs to be in the same professional field. 

  3. Editor’s Note: Since Chongqing city is a provincial-level municipality like Beijing, Tianjin and Shanghai, a social organization registering with the Chongqing administration enjoys the same high status. 

  4. Editor’s Note: The All-China Environment Federation is a GONGO set up by the Ministry of Environmental Protection. Environmental courts have been established at the local level since 2007 and were intended as a way to fast-track environmental litigation. The courts have jurisdiction over civil, administrative and criminal cases related to environmental matters. 

  5. Editor’s Note: The People’s Political Consultative Conference is an advisory policy-making body that meets at the same time as the People’s Congresses. 




近年来,各地环保NGO进行的倡导行动热点频出,在地处西南的重庆,也活跃着一家地方性草根环保组织—重庆两江志愿服务发展中心(以下简称“两江中 心”)。

据两江中心统计,现在该机构平均每年围绕污染点源控制完成20~30个案例,环境监督完成40~50个案例。通过介入污染控制和环评监督,两江中 心与地方环保部门建立了常态性的互动关系。无论是督促环保部门积极作为,提高工作效率,还是监督环评公司履行法定程序,纠正违规行为,均收到了较好的效 果。经由两江中心投诉,重庆主城区9个区县的环境监测支队中有4个支队的工作人员因为工作不力和不作为被处理;由于两江中心的举报督促,已有6家违规的环 评公司被环保局处罚并发文在全市范围内通报。重庆当地有违规行为的环评公司,已经开始感受到两江中心作为民间独立第三方的监督压力。两江中心以其独立鲜明 的个性、对政府和企业倡导产生的积极影响引人注目。




向春向笔者讲述了一个与环保局互动的故事。2010年7月,两江中心在重庆沙坪坝区发现了一个污染源,其渗漏液直接排入嘉陵江,威胁到下游10公里范围内 的数个自来水厂,填埋场旁边还有一个村级自来水抽水站。经过取样检测和资料查询,两江中心及时向市环保局进行了反馈,最终经政府确认这是重庆农化集团遗留 下来的440吨六六六、DDT废弃农药填埋场。2011年9月,区政府、区环保局和农化集团等单位共同启动了治理修复工程,并开始搬迁周边居民。两江中心 在此过程中,每季度至少一次向所属区环保局和重庆市环保局了解对填埋场的处置进程,督促处理进展,并曾介入协调。

作为一家草根组织,介入这个过程并非总能得到政府方面的积极配合,互动关系难免会有波动和反复。为持续跟踪治理过程,2011年5月,两江中心又向重庆市 环境监测中心提供了填埋场土壤样品并支付了检测费,但对方后来又改变主意,说取样已被销毁,要退钱给中心。在证据确凿的情况下,向春把与监测中心互动的过 程以及政府的不作为写成文字,配图片发到天涯重庆版上,2~3天后反响强烈。在网络舆论压力下,监测中心又给向春打电话,说是样品并未销毁,想予以退回。

向春说,其实有很多渠道,包括商业渠道都可以进行取样检测,因为此前已经确认了污染事实,这次送样品给环保局属于阶段性检测,目的不是要获取关键数据,而 是为了保持跟踪,给环保局一个持续监督的信号。经过这个回合的“博弈”,环保局转变了态度,两江中心也觉得时机到了,就去找他们面对面沟通。向春说,近期 填埋场已经完成了居民拆迁,随后将对填埋农药及污染土壤进行无害化处理,预计8月底处置完成。




你来我往的互动,和风细雨中难免穿插间歇性的暴风骤雨。在2010、2011年两年间,向春在环保局,当着官员的面都拍过桌子。因为近来“出了点情况”,7月19日采访向春的当日上午,他又去环保局找到副局长和办公室副主任吵了一架。原来两江中心向环保局申请信息公开都很顺利,但 今年具体负责的官员换了人,最近提交了几个申请,对方都以影响社会稳定为由拒绝了。回到办公室,又开始找资料和素材,“准备再‘刺激’一下对方。”


现在,向春和两江中心在重庆市环保局上上下下都“挂了号”,总体上打交道的反应速度变快了。通过直接沟通就能解决问题,也就不再需要频繁去网上发帖,倚重 媒体传播施压。如同将吵架做成程序,每月一天的局长接待日也是向春和他的同事必然要做的“程序”:或汇报工作,或投诉污染企业,或指出政府的不足和问题。 如果没有特别具体的事情,他们也会找点事情去谈。

从2011年下半年介入环评议题后,两江中心通过各大环评公示网站找到公示信息,将环保局审批通过的环评报告书拿过来审核,让公示信息造假、环评公司没有 资质却做环评、程序不规范,违反公众参与办法等一大堆问题无处遁形。两江中心在一份环评报告书所附的几十张调查表中,发现4张调查表全部由一人填写,这个 假造得没有任何技术含量。向春说,此前,重庆四十几家环评公司,从来都是一路绿灯,有的公司做过上千个环评,从来都没有不能通过审批的。他还发现环保局有 些官员连环评法、环境影响评价公众参与暂行办法等相关法律法规都不了解。


两江中心从技术分析、程序的合理性以及公众参与三个方面关注环评,现阶段主要集中精力主攻环评程序中的问题,在一年的努力后,这方面的问题基本得到改观和 解决。对环评报告做技术分析和审核需要较强的专业性,将在今年下半年启动。两江中心计划建立一个环评数据库网站,汇集当前的环评报告书和公示,为公众参与 集中提供专业信息平台,还将选择影响大的代表性工程做民间第三方调查,按照法定的公众参与程序取得自己的调查结果,以此印证环评公司是否走过场进行选择性 操作。



谈到环评,难免扯到不久前发生的震惊中外的什邡事件。向春说,自己没有看过这个项目的环评报告,无法具体置评,但假设什邡钼铜项目在技术上是过关的,也至 少从程序上存在一定问题:从项目签订合同到完工,按规定要求做4次信息公开,涉及环保部门、业主单位和环评单位三家。但显然这个项目只在举办开工典礼时公 众才知晓有这样一个项目。前面法定要求的两次公示,包括公众参与的程序,填写公众参与调查表,以及可供选择性举办的座谈会、听证会都没有做或者没有做到 位。


到目前为止,两江中心打过交道的污染企业有几十家,主要分布在机械加工和化工两个重污染行业。作为重庆本地的在地组织,两江中心的定位是针对和解决本地的 污染问题,因此,无论是国企、民企还是外企,产业链的上游公司,上市还是非上市公司,有问题的都要去打,但主要依靠与政府互动来实现,并未将媒体作为策略 性解决问题的方法。相比绿色和平、公众与环境研究中心,以及达尔问等北京的组织,地方NGO在媒体运用方面不具地缘优势。向春认为北京的组织要在全国范围 内实现传播效应,因此会较多依靠媒体的传播效应,与地方性NGO在倡导策略上有区别。



“我们一直没有悲情,从没有放弃去和政府沟通。”向春所理解的“沟通”,既有心平气和的交流、谈话,也包括情绪外露的吵架、拍桌子,还有更具“刺激”性的 网上发帖等公共施压方式。相比“悲情”,向春更喜欢用“职业化”来描述两江中心目前团队的状态。他们找到了一个很落地、很实在而且可持续的方向,致力于用良好的心态和职业化的方式做事。在人才招募上,两江中心已经开始注重人员的专业性,要求与项目相关的环境工程、环境科学、法学、化学化工等专业背景。当 然,作为新生代的环保组织,尽管已不像第一代组织那样强调牺牲和付出,但行业认同、工作的价值以及参与的热情仍然为两江中心所强调。


NGO倡导活动的空间固然拜机构策略定位所赐,但也无法忽略其他的影响因素。笔者曾疑惑,从两江中心的机构名称,完全无法使人联想到环保,反倒给人以一家 志愿服务组织的印象。没想到这个疑问背后,隐含着机构发展史上一段重要的插曲,这就是与业务主管单位——重庆市文明办的渊源。


重庆的公益组织发展一直非常滞后,民政口长期没有一点动静。“不想永远做发文件的机构”的重庆市文明办将民间组织发展和能力建设、志愿服务和社区建设归口 管理,希望开口子推动草根组织发展,迈出第一步非常慎重。经过反复遴选,最终确定了向春创办的这家自下而上的组织(原名“重庆青年环保协会”)。目前由省 级文明办担任主管单位的草根机构,在全国还只有两江中心这一家。 “文明办现在对我们评价很高,觉得我们的工作积极、有意义。”向春说,在两江中心成立初期的时候,环保局从创模(创建国家级环保模范城市)的角度向文明办 抱怨两江中心找了太多“麻烦”,而文明办从社会发展的角度觉得这是小事情,就对向春说,找个时间(和他们)沟通一下就好了。


像诸多草根组织一样,两江中心的发展经历过初创期资金导向,为了生存对项目不加选择的实用阶段,到多次做“减法”重新定位并最终锁定环保和行业发展两个方 向的过程,形成了比较成熟的工作思路。事实上,环保和行业发展这两个方向并无交叉,但两江中心希望重庆本地能够多发育出一些组织,同时也兼顾了市文明办的 思路。后者希望做一些NGO的扶持和政策性沟通,使两江中心在非环保领域也有一些很好的平台和资源可以用于推动行业发展。

经过2年半的时间,两江中心团队成员由最初4人扩展到7人。机构目前的核心资助来自SEE基金会。8月,两江中心和阿里巴巴公益基金会达成新的项目协议,阿里巴巴基金会将资助两江中心在重庆市主城区外 10 个区县开展工业污染防治工作。


除了机构独立运作的项目,两江中心也同其他组织开展合作,比如为全国性的倡导联盟—绿色选择提供第一手的污染监测数据,对国家重点控制企业进行经纬度定 位。从今年5月开始,两江中心同重庆本地的另外3家环保NGO,重庆绿色志愿者联合会、重庆公众河流环保科普中心、重庆青年环境交流中心举办了首次联席会 议。4家机构通过每月一次,轮流主办的会议沟通信息,建立合作基础。


Fu Tao is CDB's Senior Researcher

Translated by Natalie Wong

Reviewed by Chris Mirasola

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