Research On The Connection Between China’s Environmental Impact Assessment System And Pollutant Discharge Permit System

Environmental impact assessment（EIA）is the source prevention system in fixed pollution sources,and Pollutant discharge permit is the core system of ex post facto supervision.However,due to the absence of the Pollutant discharge permit system in the early stage,the relationship between the two has not been considered in the EIA system,resulting in the existence of many duplicate rules and regulations between the two independently developed systems.Therefore,linking the two has become the key to the current and future fixed pollution source environmental governance system reform.In this regard,at the national level,The State Council and the Ministry of Ecology and Environment issued several normative documents from 2015 to 2022 to preliminarily establish the connection rules between the EIA system and the Pollutant discharge permit system,including clarifying the sequence of administrative procedures and the inheritance relationships considering substantive effectiveness.However,the design of the above rules leads to the problem of repeated evaluation and also increases the unnecessary burden on the administrative counterpart.Therefore,with the dual background of the reform of the environmental management system of fixed pollution sources and the reform of the administrative examination and approval system,to improve the organizational efficiency,local governments adopt the simultaneous examination and approval of environmental impact assessment and sewage discharge permit and optimize the approval process in the connection.Based on this,through the analysis of the existing convergence norms and local pilot practices,it is found that the two systems still face many problems in the process of convergence that need to be solved.The issues include incomplete legal basis,inconsistent technical specifications,and insufficient legitimacy of simplified EIA approval at the top-level system design level;However,the construction of specific rules faced three difficulties,including differences in the classification of cohesive objects.Unified cohesion content and unclear supervision.Accordingly,specific countermeasures can be put forward from two levels to promote the deep connection between EIA and Pollutant discharge permit.At the level of top-level system design,it is necessary to construct an institutional platform of a deep relationship between the two,unify the technical standard system of connection,and strengthen the legislative supply of a simplified EIA approval scheme.Build level the rules of concrete cohesion to join the management object of classified management,enhance the content of docking management,and strengthen supervision of phase information linkage.In this way,the two systems can effectively bond and form a joint force of the system,providing strong support for deepening the battle against pollution and promoting the continuous improvement of environmental quality.