| 英文摘要 |
In response to the increasing complexity of pollution source processes and the close interconnection between air, water, waste, and toxic chemical processes, the Ministry of Environment is promoting an integrated environmental permit policy. This policy aims to standardize the permit review process by establishing a single service window, implementing a consultative joint-review mechanism, and mapping the overall factory pollution flow. The purpose of this project is to assist the Ministry of Environment in implementing various integrated environmental permit policies, collecting execution experiences and feedback from industry stakeholders, and providing recommendations for future improvements to the permitting system.
Starting as a pilot program in 2021, the project initially prioritized state-owned and large enterprises to mitigate the potential impacts of a formal policy rollout. The project integrates the environmental permit review units of the Kaohsiung City Environmental Protection Bureau, the Ministry of Economic Affairs’ Technology Industrial Parks, and the Southern Taiwan Science Park, establishing a single service window in Kaohsiung City. This allows efficient management of environmental permit cases within Kaohsiung’s jurisdiction, facilitating case tracking, follow-ups, and documentation for prioritized applicants. Based on the Ministry of Environment’s principles for integrated permit consultation and Kaohsiung’s current review processes, the project established Kaohsiung City’s integrated permit consultation principles, refining review procedures and timelines. The integrated permit joint-review mechanism was implemented on June 15, 2021, with ongoing adjustments. It operates through four key mechanisms: (1)Conducting joint-review consultation meetings; (2)If no conflicting review opinions arise, consultation is waived, saving time; (3)If the primary reviewer raises no objections and there are no conflicts, the permit is quickly approved; (4)Determining cases exempt from joint review. As of November 30, 2024, a total of 703 joint environmental permit reviews have been conducted in the first three years. For this year alone, 260 joint reviews have been completed by November 30, alongside 30 consultation meetings (including video conferences). Regarding the integration of overall factory pollution flows, this year the project comprehensively reviewed previously completed pollution flow maps, requiring industries to update and submit maps aligned with the latest permits for review. Simultaneously, the project expanded guidance to 95 industries for creating pollution flow maps. By November 30, 80 previously prioritized companies had completed their reviews, and the 95 expanded targets for 2024 were also reviewed. Additionally, during the execution of the project, various promotional activities, training sessions, and meetings were held to advocate for the integrated permit policy. This included 2 policy briefing sessions, 1 internal training program, and 8 pollution flow map training courses.
Since the pilot launch of the integrated permit program, the project has gathered feedback from industries and review units, and proposes the following recommendations to the Ministry of Environment:
1. Expedite revisions to relevant regulations and develop comprehensive supporting measures to clarify implementation procedures. This will enable local governments to effectively promote integrated permit processes, while industries can comply with clear requirements, achieving the goals of administrative streamlining and convenience.
2. The consultation and joint-review principles set by the Ministry of Environment are challenging to implement without complete legal and system frameworks. It is recommended that the Ministry reference local execution practices to refine its guidelines. Kaohsiung City, for example, has already established its own operating principles for integrated permit joint reviews, facilitating coordination among review units.
3. Statistical data indicates that inconsistencies in raw materials across permit documents and variations in operational time calculations are the primary issues during joint reviews. As the purpose of joint reviews is to enhance document consistency, it is recommended that the Ministry prioritize the establishment of consolidated forms for raw materials, fuels, and products to improve document uniformity, thereby streamlining reviews.
4. In practical regulatory management, quantitative data paired with overall factory pollution flow maps can more effectively analyze pollution information. Therefore, it is suggested that pollution flow maps be accompanied by tabular data for clarity and effectiveness.
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