Pollution data discrepancies and inconsistencies

The 2011 Coastal Environmental Quality Report made public recently states that 7 823 t 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 t whilst only 155 t apparently were discharged into wastewater (primarily by industry). So where did the other 7 700 t of lead in China's rivers come from?

Since discharge of lead into the sea and wastewater are measured at discharge points，can we assume that the unaccounted for 7 700 t 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.

Regardless，a 7 700 t 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.

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.

國有農(nóng)場辦社會職能改革和農(nóng)墾國有土地使用權(quán)確權(quán)登記發(fā)證任務(wù)基本完成。全國35個墾區(qū)中，21個墾區(qū)已全面完成國有農(nóng)場辦社會職能改革。全國農(nóng)墾國有農(nóng)場中已完成辦社會職能改革任務(wù)的超過80%。公檢法、基礎(chǔ)教育機構(gòu)、基本醫(yī)療和公共衛(wèi)生機構(gòu)等三項改革任務(wù)已基本完成。農(nóng)墾國有土地確權(quán)率、發(fā)證率基本達到預(yù)期目標(biāo)。

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 RMB 3. 1 billion (USD 498 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:

So which Ministry's data portrays the“real picture”?

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 t of lead are unaccounted for. Perhaps the failure to do so is systemic?

Source:CWR，MEP Coastal Environmental Qualilty Report 2011 (except for Chromium 2010)，SOA State of the Oceanic Emironment Report 2011

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?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 (tonnes)

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.

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.

(本文的紙媒出版與網(wǎng)絡(luò)傳播由China Water Risk 授權(quán)《凈水技術(shù)》雜志社發(fā)布，未獲得China Water Risk 授權(quán)，第三方媒體不得轉(zhuǎn)載)

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