Through my consulting work, I have had conversations with a number of officials lately who told me that EPA applications were no longer rubber stamped. I have also heard of projects that received local approval, but be knocked down by Beijing… and the recent events in Xiamen have only reinforced my conclusions.
Only comment I have relates to local enforcement of ongoing enterprises. This is not my area of expertise, so I am speculating here, but I always figured that it was much easier for the government to regulate new projects than it was for them to police existing ones. New enterprise setup procedures give the government a ready-made bottleneck, or gateway, through which they can use the setup process to review proposed environmental impact. This is the benefit of environmental impact statement requirements and why they are a good thing for jurisdictions across the world.
Sure, a government approval agency at the local level might have insufficient resources and training, or officials locally might take bribes during the setup process. Local authorities always have an incentive here to approve local projects, and this is a perennial problem.
However, once those companies are up and running, employ lots of people, pay taxes, and become part of the community, isn't the likelihood of tough enforcement that much lower?
Another important factor here is that new enterprises, by and large, should be employing newer (and greener) technology. Therefore, compared to older companies, these new setups that are being reviewed should already have less to worry about. The flip side to that are those dirty old factories sitting out there — these are the biggest polluters and the ones that the regulators need to focus on. The fact that a lot of those are SOEs certainly makes all this much more difficult.
Again, this is all speculative. I wonder if there is any data out there or even some qualitative observations on the difference between environmental impact review vs. remedial policing of big polluters.