Linking the Procedural and Practical Management of Environmental Protection for Construction Projects

The environmental impact assessment(EIA), the completion environmental protection acceptance check, and the pollutant discharge permit constitute the core of a chain-based management system for construction projects in China, administered by ecological and environmental departments across the pre-construction, post-construction, and operational phases. These three technical reports specify the key environmental control points for different stages, from the feasibility of site selection, planning, and processes during the initial phase, to the compliance with acceptance standards upon completion, and finally to the emission standards, total volume control, and monitoring requirements for discharge outlets during operation. In practice, however, discrepancies in technical foundations, control priorities, and responsible administrative bodies lead to a lack of cohesion among these documents. Critical issues identified in the initial EIA stage are often not effectively reflected in the subsequent completion acceptance check or the operational pollutant discharge permit. This results in a disconnect between the requirements and objectives of the early and later stages of the project's environmental management chain, which poses significant challenges to routine project management and environmental law enforcement. Therefore, it is recommended to strengthen the linkage between management requirements and content across all phases. This will prevent the weakening of preliminary environmental monitoring measures due to procedural simplifications and ultimately enhance the efficacy of environmental protection management.