基于污染类建设项目全过程管控的行业环境准入指引构建及应用

Construction and application of industrial environmental access guidelines based on whole-process control of polluting construction projects

  • 摘要: 生态环境分区管控制度确立,强化了污染源头预防体系宏观管控,以行业环境准入指引替代部分项目环评,成为强化宏观管控、简化微观管理,提高源头预防制度整体效能的重要手段。剖析了环境准入指引与环境准入的异同点,界定了环境准入指引功能定位与内涵属性;采用文献分析、专家打分等方法,筛选关键指标,构建环境准入指引指标体系;并选取长三角某园区汽车制造行业(C36)开展示范研究,进行方法验证。结果表明:1)环境准入指引具有非强制性引导规则、源头预防重要手段的内涵属性,承担事前指导建设项目准入研判、事中指导建设项目自主落实环保要求、事后指导生态环境部门开展建设项目环境监管的功能。2)构建了包含污染源头预防、污染过程管控、污染有效监控3个维度的环境准入指引指标体系,并建立“三维目标需求—差异化指引内容—多样化指引方式—多维应用场景”的环境准入指引应用框架体系。3)示范应用结果表明,依托示范园区“环保水务一体化平台”,因园制宜构建的汽车制造行业(C36,仅涉及分割、焊接、组装工序)环境准入指引指标体系及应用框架体系,指导了示范园区3个豁免环评项目的选址、行业准入符合性的智能研判、项目建设运行过程环保要求的落实及固定污染源排污许可填报、生态环境部门的常态化监管等,有效防控了豁免环评的建设项目环境污染风险防控,说明所建立的环境准入指引指标体系具有较好的科学性和实用性。鉴于环境准入指引具有非强制性特点,建议将污染物排放标准、治理措施、清洁生产指标等关键内容补充载入固定污染源排污许可证或排污登记表,以强化约束力。

     

    Abstract: The establishment of the eco-environmental zoning control system has strengthened the macro-control of the pollution source prevention system. Replacing some project environmental impact assessments (EIAs) with industrial environmental access guidelines has become an important means to strengthen macro-control, simplify micro-management, and enhance the overall effectiveness of the source prevention system. The similarities and differences between environmental access guidelines and environmental access were analyzed, and the functional positioning and connotation attributes of environmental access guidelines were defined. By using methods such as literature analysis and expert scoring, key indicators were selected to construct an indicator system for environmental access guidelines. Additionally, a demonstration study was conducted on the automotive manufacturing industry (C36) in a certain industrial park in the Yangtze River Delta region to validate the methodology. The results showed that: 1) Environmental access guidelines had the connotative attributes of being non-mandatory guiding rules and an important means of source prevention; they served the functions of providing pre-project guidance for access assessment, in-process guidance for the independent implementation of environmental protection requirements by projects, and post-project guidance for ecological and environmental departments in supervising construction projects. 2) An indicator system for environmental access guidelines was constructed from three dimensions of pollution source prevention, pollution process control, and effective pollution supervision. An application framework of "three-dimensional goal demand - differentiated guidance content - diversified guidance methods - multi-dimensional application scenarios" for environmental access guidelines was established. 3) Relying on the "environmental protection and water affairs integrated platform" in the demonstration park, the constructed park-specific environmental access guidelines indicator system and application framework for the automotive manufacturing industry (C36, only involving cutting, welding, and assembly processes) guided the site selection, intelligent assessment of industrial access compliance, implementation of environmental protection requirements during project construction and operation, and fixed pollution source emission permit filling and reporting, as well as regular supervision by environmental protection departments, for three EIA-exempt projects in the demonstration park. This effectively prevented and controlled the environmental pollution risks of EIA-exempt projects, indicating that the environmental access guidelines indicator system established had good scientific validity and practicality. Given the non-mandatory characteristics of environmental access guidelines, it is suggested that key elements such as pollutant emission standards, control measures, and cleaner production indicators be incorporated into fixed pollution source emission permits or emission registration forms to strengthen their binding force.

     

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