The Soil Ten Plan Is in Place: How Far Are We from Soil Pollution Control?
On May 31, the State Council issued the Soil Pollution Prevention and Control Action Plan, referred to as the "Soil Ten." Together with the Air Pollution Prevention and Control Action Plan (the "Air Ten") issued in June 2013 and the Water Pollution Prevention and Control Action Plan (the "Water Ten") issued in April 2015, this marks the basic formation of our government's overall policy framework for comprehensively addressing water, land, and air pollution.
When we see black, stinking rivers, we call for sewage treatment; when we breathe turbid air, we call for the elimination of smog; when we pass garbage heaps as big as hills, we call for resource recycling and garbage disposal. But rivers can become clear, the sky can become blue, and garbage can be moved away from us. Yet where exactly does all this pollution go? Does it truly vanish into nothing thanks to human technological treatment?
The answer is no.
Matter is indestructible, and energy is conserved. Although our technology has developed greatly, to date the essence of most pollution control is the "transfer" of pollutants. For example, common sewage treatment converts water pollutants into "sludge," and common flue gas treatment collects air pollutants in solid or liquid form. Ultimately, these pollutants return to the soil in solid form. In fact, the natural world itself involves complex cycles among water, land, and air, and soil is both a sink and a source for many substances. The earth accepts all with its broad embrace and, in its own way, watches many substances leave. In other words, soil is harmed not only by various industrial wastes and household garbage; some water pollution and air pollution are also transferred into soil pollution. Conversely, pollutants accumulated in soil tend to be released slowly over the long term, directly affecting animals, plants, and people's living environment. Without integrated prevention and control of soil pollution, there can be no comprehensive, scientific, and efficient environmental governance and environmental protection.
Stinking rivers and smog are things we can see and smell, but the condition of the land beneath our feet seems to be concealed by surface concrete and greenery. Yet China's soil pollution situation is hardly optimistic. The National Soil Pollution Survey Bulletin, published in 2014 by the Ministry of Environmental Protection and the Ministry of Land and Resources, pointed out that China's overall soil exceedance rate was 16.1%, and among the most severely polluted types of land, such as heavily polluting enterprises, abandoned industrial sites, and mining areas, the exceedance rate was as high as over 30%. In other words, if such land exists near you, you have a one-third chance of being threatened by soil pollution.
The most troublesome soil pollutants are heavy metals and persistent organic pollutants, which generally have a certain biological toxicity and are difficult to degrade naturally. For example, China officially stopped producing and using the chemical pesticides DDT and hexachlorocyclohexane (HCH) in 1983, but by the time the 2014 edition of the National Soil Pollution Survey Bulletin was released, 1.9% and 0.5% of surveyed points still showed exceedances of DDT and HCH respectively - a full thirty years later, they had still not disappeared. In recent years, scientists have still detected DDT and HCH in the bodies of Chinese people, and according to toxicological research, DDT not only has a certain carcinogenic effect but may also affect human reproductive health. People living on polluted land can easily take in excessive amounts of these pollutants through the food chain, such as by drinking contaminated water or eating crops and animals raised on polluted land, thereby bringing various hidden health risks. It should be said that this is even harder to guard against than smog!
The "cadmium rice" exposed by the media many years ago has in fact already reminded us of the dangers of soil pollution, especially pollution of cultivated land. However, whether to buy rice produced in sensitive areas seems to be a matter of choice, so perhaps it was not enough to arouse the vigilance of most people. The recent "toxic land" incident at Changzhou Foreign Languages School, while exposing the current state of pollution at industrial and commercial sites, also seemed to sound an alarm for more urban residents: soil pollution may be right beside every one of us, and we may be powerless to escape it.
We can shift the blame to "the rapid development of industrialization and urbanization," but China's past deficiencies in soil environmental management are also an objective fact. You may not believe it, but until now China has not had a dedicated Soil Pollution Prevention and Control Law, and a systematic monitoring and information release system for soil quality has been basically absent - apart from rumors, you have nowhere to learn whether the community you live in is "toxic land." By contrast, for water and air, there are laws, standards, monitoring, and bulletins. As soon as people began to pay attention to smog, PM2.5 was immediately written into the 2012 edition of the Ambient Air Quality Standards. But what about the current Soil Environmental Quality Standards? Those were set back in 1995.
The "Soil Ten," issued just before World Environment Day on June 5 this year, basically covers every stage of soil pollution prevention and control work. It should be said to carry the relevant departments' attention and expectations for this issue, and it also responds to people's calls for a soil protection and supervision system.
So what exactly does the "Soil Ten" say?
As the name suggests, the "Soil Ten" has ten articles in total, with content distributed in a "two-eight" pattern: two articles focus on "treatment," and eight focus on "prevention." This tendency to emphasize "prevention" over "treatment" is related to our current practical capacity and also to the characteristics of soil pollution.
First, given the reality of China's weak soil environmental management capacity, the primary task is to establish a basic policy system, build a regulatory system, and improve the enforcement capacity of the entire system. We have in fact not yet finished the work of "taking stock" of polluted soil. The exceedance rate data mentioned in the National Soil Pollution Survey Bulletin are all point counts rather than areas, which leaves a large margin of error in describing the true situation of soil pollution in China. The relevant functional departments for land, agriculture, forestry, and environmental protection have not yet established a basic monitoring system with interconnected functions and shared data. But without such a system, we cannot avoid "toxic land" when planning housing, hospitals, and schools; we cannot temporarily prohibit "toxic land" from producing grain, vegetables, and fruit; and we cannot require industrial and commercial enterprises to remediate site pollution. This basic preventive capacity is certainly more important than treating and remediating certain specific plots, just as when a doctor treats a critically ill patient, he must first examine the patient from head to toe, install the necessary monitoring equipment, and then perform surgery.
Second, soil pollution treatment often involves long cycles and large amounts of funding, and places relatively high demands on treatment technology and project management. Once soil pollution occurs, it takes great effort to treat. Only by doing comprehensive prevention well can long-term environmental damage and treatment costs be minimized to the greatest extent.
The principle mentioned in the "Soil Ten," "whoever pollutes shall treat," is a classic principle proposed by the Organisation for Economic Co-operation and Development (OECD), but it is easier said than done. In reality, it is sometimes very difficult to determine who polluted, especially for some contaminated land left over from history, where disputes over rights and responsibilities can be as tangled as a ball of hemp. For local governments that bear the ultimate responsibility, if they encounter several heavily polluting enterprises that have closed down, gone bankrupt, or whose investors have fled, they will surely be reduced to tears. Money is a practical problem. The cost of soil remediation ranges from more than 100,000 yuan per mu at the low end to more than a million at the high end. Residential and industrial land may not even fetch such a high price at auction, let alone cultivated land that yields at most a few thousand yuan per mu per year. Although local governments can raise funds through higher-level fiscal support, public-private partnership (PPP) projects, green bonds, and other means, this is still a severe test.
End-of-pipe treatment of soil pollution is so difficult that it is absolutely not like being able to discharge domestic sewage with peace of mind just because there is a sewage treatment plant, or boldly developing thermal power just because ultra-low emissions are available. The "Soil Ten" reminds us that we must establish a strict awareness and mindset of prevention and control. Of course, it also draws on the advanced experience of many other countries and proposes market-based preventive and control measures such as establishing pollution prevention and control funds and compulsory environmental pollution liability insurance. This means that in order to prevent polluters from being unable to afford the costs after soil pollution occurs, or from finding excuses to go bankrupt or flee, when certain sensitive industries are operating normally, mutual-aid prevention and control funds should be established within the industry, or insurance products should be set up, operated by qualified financial institutions and supervised by the government. If nothing happens, investment returns are paid back; if something happens, the funds offset treatment costs. This additional input of funds or premiums is both a reminder to enterprises and a safeguard for the environmental interests of society as a whole.
Finally, the "Soil Ten" reflects policymakers' judgment of the current treatment capacity. The number of contaminated plots China has already surveyed is on the order of hundreds of thousands, while according to the Ministry of Environmental Protection, the number of practitioners currently engaged in soil remediation work is only about 10,000. Facing this enormous remediation task or market, there is a considerable shortage of talent, which will to a certain extent limit the development of the soil remediation industry. Under such realities, rushing to pursue comprehensive treatment and remediation is instead an unrealistic and empty goal. Giving priority to remediating construction land in urban areas where land-use conflicts are prominent, and giving priority to arranging planting structure adjustments or projects to return farmland to forest (grass) in rural areas short of funds, may well be a response model tailored to local conditions. Of course, merely turning "toxic land" into forest land or grassland, or merely stopping it from producing "toxic" agricultural products, is not remediation in the true sense. Some pollutants will still persist for a long time. However, we can only hope that several years from now, when the overall level of the soil remediation industry has risen and the unit cost of treatment methods has fallen overall, many soil pollution problems that were originally concealed and avoided may be thoroughly treated once again.
Overall, in the face of China's vast land, to move toward a beautiful future of green mountains and clear waters, the "Soil Ten" is only a beginning, the start of a protracted battle.
(Lu Qiong, PhD candidate in Population, Resources and Environmental Economics at Renmin University of China, special commentator for Overseas Network)