Clean Air at What Cost? A Conversation with Denise van der Kamp
China’s green transition is often perceived as a lesson in authoritarian efficiency. In a mere few years, the state managed to improve air quality drastically without apparent resistance from the market. In Clean Air at What Cost? The Rise of Blunt Force Regulation in China (Cambridge University Press, 2023), Denise van der Kamp explains how the Chinese Government has tackled industrial pollution, with what effects, and what limits. The book centres on the concept of ‘blunt force regulation’ (BFR), which is examined through the extremely costly blanket factory shutdowns and demolitions that have been observed across China over the past decade. Van der Kamp is the first to provide a solid explanation for it. Drawing on two years of fieldwork in China’s industrial heartlands during which she collected significant qualitative and quantitative data, she argues that BFR is a way for the central government to force local bureaucrats to comply with environmental policies and targets that otherwise would not be implemented. It is therefore a sign not of the efficiency of authoritarianism, but of its inability to induce compliance through traditional regulatory means. This study not only sheds new light on the long-debated ‘implementation gap’ in China’s environmental policy, but also makes an important conceptual contribution to the study of regulation in authoritarian regimes.
Coraline Goron: If we try to define BFR, at what level of analysis would you place it? Would you classify it as a policy tool or would you rather call it an enforcement mechanism? In public policy, we tend to distinguish between ‘command and control’ measures, such as regulatory standards, and ‘market-oriented’ policy instruments like emissions trading. There are hot debates about their relative efficacy and efficiency. The Chinese Government also uses these instruments. We also know that China has developed its own enforcement mechanisms, such as the ‘target responsibility system’, which evaluates and sanctions the performance of local officials on specified environmental indicators, and, under President Xi Jinping, the use of central and provincial environmental inspections of local environmental issues, which have led to a wave of fines and punishments. How does BFR interact with the concomitant use of other policy instruments and enforcement mechanisms to address pollution in China?
Denise van der Kamp: I would classify BFR as both a policy tool and an enforcement mechanism. By blunt force regulation, I refer to the Chinese Government’s use of indiscriminate, inflexible methods to reduce pollution—such as rapidly shuttering companies to address local pollution problems. I argue that political leaders use these extreme measures to force local leaders to take immediate action on pollution, especially after prolonged failures in pollution control. In contrast, the target responsibility system—where central leaders use targets and promotion incentives to motivate local leaders to implement policies—is much more vulnerable to shirking and noncompliance. In other words, BFR is a response to the failures of the target responsibility system. As for the central environmental inspections that you mention—where central leaders use anticorruption-style inspection campaigns to catch noncompliance—I agree that this is also one of Beijing’s tools to overcome the weakness of the target responsibility system. However, as I discuss in more detail below (and in Chapter 6 of my book), there are some serious limitations to this approach.
While BFR may be grabbing the headlines, the Chinese Government is also using less extreme methods to reduce pollution, including market mechanisms (such as emissions trading), naming and shaming, or a more conventional, standards-based approach to regulation (such as punishing firms for failing to meet new emissions criteria). These tools have had varying levels of success but there is no doubt that the government is committed to expanding their use. Just look at how Beijing has invested in developing infrastructure that can monitor firm-level emissions or its efforts to recalibrate regulators’ authority and incentives so they are less vulnerable to local political interference. Standards-based regulation in China is not just window dressing.
However, a key point in my book is that BFR undermines these other policy tools, especially standards-based regulation. What is the point of elevating local regulators’ authority if political leaders can simply override that authority and impose a three-month shutdown to deliver blue skies? What is the point of investing in systems to build more cooperative relations between regulators and firms if these same regulators are then charged with abruptly cutting off power to factories—a common tactic for reducing emissions? One would assume that as standards-based regulation begins to take hold, Beijing would start to phase out BFR to prevent these two approaches from undercutting each other, but data I collected show otherwise: BFR and standards-based regulation are still being used with similar levels of intensity all over China. It will be interesting to see how the Chinese Government manages these conflicting policy tools as it pushes ahead with its net-zero ambitions for economic development.
CG: Your book offers a powerful theory to explain why the Chinese Government resorts to BFR: that it is a top-down coercive response to the lack of enforcement by local officials. You explain that it works by removing all local discretion from implementation. This is a credible explanation for the widely acknowledged ‘implementation gap’ in China’s environmental policy. It also debunks fallacious theories predicting that China’s ‘environmental authoritarianism’ would be more effective in addressing environmental issues because of its strong capacity to impose unpopular measures. However, you do not fully elaborate on the link between this necessity to coerce local governments into action and the nature of the political regime in China. So, what political factors contribute to BFR? Could it happen in any context where there is political will but a major implementation gap or is it distinctive to China’s political and governance system (regardless of whether we call it authoritarian, Leninist, corporatist, or state-capitalist with Chinese characteristics)?
DVDK: BFR is not unique to China. I argue that it can happen in any context where there is political will to enforce policy at the top but weak compliance on the ground. Indeed, in my book, I explore several cases outside China—in the Philippines, India, and the United Kingdom—to show that BFR is a more general political phenomenon, and one of a set of potential responses to the principal–agent problems that occur in regulatory enforcement. A state does not have to be authoritarian or lacking in regulatory capacity to engage in BFR.
However, I do show that the character of BFR—including how forceful or indiscriminate it is—is shaped by institutional features such as a state’s enforcement and coercive capacity. It may be more severe and last longer in authoritarian states because leaders can use coercive powers to sustain enforcement despite public pushback. Cases also show that weak resource capacity can limit the scale of BFR; otherwise, leaders will find that their resources are spread too thin. Thus, China’s unusual combination of high coercive power (leading to more severe BFR) and weak enforcement effectiveness (leading to a need for more frequent BFR) means it may be distinctive in the severity, breadth, and length of its blunt-force campaigns.
CG: You argue that the Chinese State’s lack of infrastructural power explains its weak capacity. You define ‘infrastructural power’, following Michael Mann, as the incapacity of state leaders to enforce binding rules across a territory. You further elaborate that this incapacity is due to a lack of credible punishments of violations of environmental norms, which stems from the lack of incentives for local officials to enforce these norms, and from the weakness of institutions—such as an independent judiciary, an empowered civil society, and a free press—capable of controlling them. But is infrastructural power necessarily stemming from the effectiveness of these rule-of-law institutions or could it be that an authoritarian regime like China’s has its own (non-democratic) types of infrastructural power—notably, through the Chinese Communist Party’s propaganda, discipline, and cadre management systems?
DVDK: By weak infrastructural power, I mean simply weak enforcement effectiveness—that is, political leaders cannot get local politicians or powerful local actors (such as large polluting firms) to consistently obey their orders. But the awkward thing about infrastructural power is that we cannot easily predict when it will be weak or strong. States with immense resources and coercive power may still lack infrastructural power, while states with limited resources and weak centralised authority may still develop strong infrastructural power—as I illustrate in Chapter 8 of my book. This is because infrastructural power is ultimately a relational outcome. A ruler’s enforcement effectiveness depends on the reactions and the power of the groups they are trying to control, and these fluctuate constantly. Thus, when both rulers and the ruled wanted economic development in China, leaders did not have to work too hard to get local officials and firms to do as they wanted (other than setting down relatively stable, profit-focused incentives). But when the rulers started pushing for more environmental protection, and at the expense of the industries that had been made powerful by years of economic development, China’s leaders suddenly found that incentives and resources were not enough to enforce policies effectively.
Does this mean that if China is to avoid BFR, it will need independent courts or powerful third-party organisations that can force both rulers and the ruled to follow through on the promises they make to each other? Perhaps. Certainly, this was key to the evolution of infrastructural power in European liberal democracies. Or maybe a more realistic alternative in China’s case would be to solve the relational problem in environmental policy implementation—that is, rulers must simply convince local bureaucrats and powerful firms that it is also in their interest to clean up the environment. And we do see some advances on this front. There appears to have been a substantive change in promotion incentives, where—in wealthier areas at least—leading cadres are being promoted for environmental performance over economic growth. Beijing has developed increasingly sophisticated data-gathering mechanisms to monitor pollution, including real-time emissions monitoring of large polluters in all Chinese cities, which makes it easier to spot when firms (or their political protectors) are violating the rules. Finally, the anticorruption campaign has spooked local officials and seems to be disrupting collusive state–business relations. This could be why anticorruption investigations are associated with decreases in pollution levels, even when central pollution inspections appear to have limited long-term effects on pollution levels (as I show in van der Kamp 2021).
Perhaps these party-based reward and punishment mechanisms—especially when backed by new real-time data—will reshape local officials’ priorities, leading them to believe that the environment is the most important goal. This way, the state would build infrastructural power in environmental policy implementation without needing independent courts or binding institutional commitments. However, studies suggest that infrastructural power built on an alignment of interests tends to be short-lived, porous, and vulnerable to shifts in how the society or the local state views their leaders’ priorities. Which brings us back to the question of what, in China’s case, constitutes a more enduring form of infrastructural power. I do not have any definitive answers on this yet, but it is something I am continuing to research.
CG: What I find very ambitious in your book is that you not only develop your theory based on fieldwork data and case studies, but also test it empirically through a combination of qualitative and quantitative methods. As a side note, I really enjoyed the fact that you open each chapter with a fieldwork anecdote or interview quote; it makes the argument so much more palatable! So, I would like to dwell on the empirical demonstration. In Chapter 4, for instance, you find that BFR is more often used in localities with low revenue per capita. Could you explain why BFR is not simply the result of a lack of implementation resources—that is, the weakness of the local environmental bureaus? Since arm’s-length regulation requires government financial and technical capacity to monitor and deter polluters, one could argue that they would undertake BFR because they cannot afford effective arm’s-length regulation.
DVDK: I entirely buy the argument that BFR is in some ways an easier solution to environmental problems when local environmental agencies lack the money and personnel to implement policies. In fact, I came across a local official who said exactly this—that BFR is sometimes preferable, not just because it is easier to shut firms than to monitor them, but also because it makes it easier for local bureaucrats to cover up past misdeeds. When a firm is found guilty of pollution violations through monitoring, this leads to investigations into which bureaucrat failed to do their duty. But when all firms are presumed to be violators and punished indiscriminately, there is no need to inquire into which regulator has been corrupt or who has shirked their responsibility. In effect, BFR allows local officials and bureaucrats to evade personal responsibility for implementation failures. Of course, these advantages might drive local officials to independently undertake BFR to meet pollution reduction targets—just as you suggest.
However, this book focuses on an adjacent phenomenon, in which higher-level leaders (provincial and above) order local leaders to shutter firms to address pollution problems. In other words, I focus on top-down implementation orders, not efforts initiated at the city or county level. For instance, the quantitative data I used focus on orders coming from top-level ministries, in which local regulators are given lists of firms that they must close or downsize by a deadline. In interviews, I confirmed that these lists constituted orders coming down from higher levels. Thus, my quantitative analysis shows a positive association between low enforcement resources and top-down orders to undertake BFR (not locally initiated BFR).
Could it be that top leaders are ordering local officials to use BFR because they know it is less resource intensive than standards-based regulation? Perhaps. Certainly, BFR is not about singling out and punishing local officials in the manner of an anticorruption campaign. However, BFR is still very painful (leading to job cuts and revenue losses), especially in the top-down form that, as I show, is directed at resource-poor regions that are least able to recover from the economic blow. This is not a decision that leaders undertake lightly. Moreover, this economic cost will also deter local officials from undertaking BFR just to overcome the resource shortages that prevent enforcement through more conventional measures. This is why I argue that top-down policies to rectify noncompliance are also part of the equation; BFR cannot be all from local initiative.
CG: To write this book, you spent several years in China and collected data in various provinces. Doing fieldwork in China has always been challenging, even though it was perhaps easier a few years ago than now. Could you tell us a bit more about your experience? What did you find most challenging and most rewarding?
DVDK: When I started my fieldwork, I had some strong hypotheses on fiscal capacity and environmental outcomes and planned to conduct case studies to test these predictions. However, the more places I visited, the more I was distracted by stories of concentrated factory shutdowns and unpredictable enforcement tactics. After a while, I realised that I could either write a boring book on fiscal capacity or investigate this more interesting question of why factory shutdowns had become so widespread.
The challenge was finding people who would talk about this phenomenon. But the rewarding part was once I did gain access, I found that many people, especially firm owners, were asking the same questions as me. Why was this happening? Why was the government setting up conventional regulation and promising firms they would be rewarded for good behaviour, only to shut greener firms as well as heavy polluters? It was also striking that local regulators—the very actors tasked with carrying out BFR—were largely sympathetic to firms, agreeing that one-size-fits-all methods were intensely frustrating for factory owners. One local official even suggested that firms would be more self-regulating and compliant if they were given the time to build up compliance after new standards were introduced. So, if both Chinese regulators and Chinese firms agreed that incentive-based methods were the better option, why were they not being used?
Once I formulated these questions, it took several more interviews and case studies to develop some answers. I also had to look for data that could tell us something about this phenomenon and relied on a lot of knowledgeable colleagues for tips on where I might find these data. Hopefully, all this has led to a much more interesting product than that abandoned book on fiscal capacity.
CG: Finally, going back to the institutional weaknesses that may underpin China’s lack of infrastructural power—especially the weakness of the judiciary and the lack of civil society—I was wondering how to square this argument with my and others’ research findings on China’s environmental civil society. I am fully on board with you on the fact that the power of civil society in China is severely constrained. In the past decade, the political, legal, and societal environments for nongovernmental organisations (NGOs) have become more repressive and those who want to continue have come under stronger pressure to ‘accommodate power’ by aligning their goals and actions with those of the state and ‘steering clear of anything understood as opposition’ (O’Brien 2022: 15–16). This unfortunate trend tends to compound your argument about civil society’s weakness and inability to control power and regulate polluting firms. However, in my research, I find evidence to the contrary. First, local officials fear the public exposure of environmental problems, which attracts the attention of higher-level regulators and therefore tremendously increases the risks of triggering BFR and political and legal punishments. I found that local environmental NGOs and activists skilfully use this fear of exposure to pressure local officials to enforce environmental standards. While this often occurs beyond public view, it can be effective. Some environmental NGOs have developed highly professional skills that make them valuable, if sensitive, enforcement partners for the government. Of course, this capacity hinges on the ‘conditional tolerance’ (Lu and Steinhardt 2020) of the central Party-State towards them, but within these boundaries, I believe environmental civil regulation has a role to play.
DVDK: I agree that environmental civil society in China is incredibly sophisticated. I am also impressed by Chinese environmental NGOs and activists and their skill in navigating boundaries or identifying pressure points, which they then leverage to get the government to cooperate. It is striking that, as you point out, there is such dense interaction and cooperation between environmental NGOs and local officials, even as the formal space for NGO activity shrinks. Going forward, one of the big debates will be whether this dense cooperation leads to some kind of cooptation, constraining the power of NGOs to monitor enforcement or keep local regulators accountable on a large scale. I look forward to seeing how your work or work by others in this area—for instance, Li Yao, the author of the seminal book Playing by the Informal Rules (2018)—pushes forward this debate.
References
Li, Yao. 2018. Playing by the Informal Rules: Why the Chinese Regime Remains Stable Despite Rising Protests. Cambridge, UK: Cambridge University Press.
Lu, Jian and H. Christoph Steinhardt. 2020. ‘Alliance Building among Environmental Nongovernmental Organizations in China: The Emergence and Evolution of the Zero Waste Alliance.’ Modern China 48(1): 105–33.
O’Brien, Kevin. 2022. ‘Neither Withdrawal nor Resistance: Adapting to Increased Repression in China.’ Modern China 49(1): 3–25.
van der Kamp, Denise. 2021. ‘Can Police Patrols Prevent Pollution? The Limits of Authoritarian Environmental Governance in China.’ Comparative Politics 53(3): 403–33.
