Market development is not mature enough. The third party has a long way to deal with pollution.

Pollution control of enterprises is an important part of environmental governance, but in the process of implementation, often due to financial and technical constraints, resulting in pollution control effect is not prominent, in order to solve such problems, third-party intervention is expected. However, what is the way to promote the third-party treatment of environmental pollution? What bottlenecks have been encountered and what are the points to be noted?

After more than 30 years of brutal economic growth at the expense of the environment and the overuse of resources, the central government has put forward a series of requirements and issued a number of policies for environmental protection early on, but in the process of implementation, it has been interfered by factors such as large investment in environmental protection, local protectionism and short-term political achievements, and so on. With weak supervision and lax enforcement, environmental pollution is becoming more and more serious. The driving force of this interest drive is enormous, and the momentum of this trend is enormous.

Effective third-party treatment of environmental pollution has many institutional advantages, which can significantly reduce the cost of government law enforcement and management, facilitate centralized supervision by environmental protection departments, reduce the marginal cost of treatment and emission costs, improve the rate of emission standards, greatly improve the effect of pollution control, and promote the development of environmental protection enterprises and industries.

Third party pollution control was supported by national policy

In order to break the original pattern of "who pollutes, who governs", the state vigorously promotes third-party governance at the policy level.

Following the implementation of the most stringent pollution emission policy in the history of July 1, 2014, on July 4, 2014, the Ministry of Environmental Protection of the People's Republic of China abolished the "Environmental Pollution Control Facilities Operation Qualification Licensing Management Measures" (Ministry Order No. 27), issued on April 30, 2012, to further open the market for environmental pollution control.

On December 27, 2014, the General Office of the State Council issued Opinions on Promoting Third-Party Governance of Environmental Pollution (No. 69 of the State Office).

In 2015, the State Development and Reform Commission, the Ministry of Environmental Protection and the Energy Bureau jointly issued the "Guiding Opinions on Implementing Third-party Environmental Pollution Control in Coal-fired Power Plants".

In 2016, according to the Opinions of the General Office of the State Council on Promoting the Third-party Treatment of Environmental Pollution, the Environment and Capital Department of the State Development and Reform Commission solicited public opinions on the Contract for the Third-party Treatment of Environmental Pollution (Model Text) (hereinafter referred to as the Contract (Model Text)).

Several problems encountered by the third party in pollution control　　

Although some areas have explored the implementation path of the third-party governance, the long-term administrative dominant governance mode in China has led to the immature development of the third-party governance market, the lack of specialized third-party pollution control enterprises, and the sharp contradiction between supply and demand. At the same time, the third party governance as a management system innovation, its final "landing", still need to face many new problems and challenges. Generally speaking, there are the following problems in the implementation of the third party governance model of environmental pollution in China.

First, the environmental protection investment of sewage enterprises is insufficient, and there is no willingness to discharge the initiative. Regulations and economic leverage are two important tools to internalize environmental costs. However, under the background of lax environmental law enforcement by local environmental protection departments, the profit-seeking nature of enterprises makes the construction and operation expenditure of environmental protection facilities limited. Several vicious environmental pollution incidents, such as sewage discharge from Tengger Desert Chemical Industrial Park in Inner Mongolia, which was exposed by media in 2014, are just the tip of the iceberg. Undiscovered environmental violations by enterprises are numerous.

Two, the order of environmental service industry needs to be standardized. With the implementation of the Decision on Abolishing (Measures for the Licensing and Management of Operating Qualifications of Environmental Pollution Control Facilities), the threshold for pollution control enterprises to enter relevant business fields has been lowered from the perspective of administrative examination and approval. However, China's environmental service industry as a whole is in a period of rapid development, the technical and environmental management level of small and medium-sized operators of environmental services is uneven, some enterprises deliberately lower the price of environmental services to seize the market at the cost of reducing environmental governance standards, and polluting enterprises lack of effective judgment basis when they select entrusted partners. Low-quality and low-price bidding is common, disrupting and destroying the industrial order, not conducive to the healthy development of domestic environmental services market.

Three, the responsibility of the third party and the main pollutants is clear and difficult. After the occurrence of the pollution accident, the phenomenon of mutual evasive responsibility between the polluter and the third party of pollution control often happens. The pollutant discharge enterprise thinks that the treatment of pollution has been handed over to a third party, and the third party should be responsible for the failure to discharge pollutants. The pollution control party thinks that the failure to discharge pollutants is due to the failure of the pollutant discharge party to discharge pollutants in accordance with the contract, which makes the pollution difficult to deal with.

The four is to entrust tax collection to increase the cost of pollution control in the whole society. If sewage disposal enterprises manage their own pollution, the construction and operation expenses of pollution treatment facilities can be included in the production cost of the enterprises without paying taxes. After the pollutant discharge enterprises entrust the environmental protection projects to the third-party environmental service companies, the environmental service companies have to pay VAT and other taxes, which objectively reduces the meager profit margin of the environmental service industry and increases the overall cost of social pollution control.

Three relations in the process of promoting the third party's pollution control　　

Therefore, the construction of the third-party environmental pollution control policy system must be based on the actual situation in all parts of the country, correctly handle the interests of all parties involved, so that the responsibility is clear, point-to-point integration, focus on practical results. In practice, we should grasp the following relations:

First, the relationship between government governance and corporate governance. China's environmental pollution control has always been an administrative leading mode, and capital investment is mainly dependent on the government. Corporate governance pollution is also generally supervised by the government. The implementation of the third party governance of environmental pollution is to change this traditional mode. In the process of policy-making, we should not only pay attention to stimulate the initiative of pollution enterprises, but also to mobilize the enthusiasm of third-party governance enterprises, and strive to combine administrative guidance with market guidance to build a healthy governance model.

Second, the relationship between key governance and general governance. The universality and particularity should be considered as a whole in the process of formulating the relevant policies for the third-party treatment of environmental pollution, so as to realize the unification of key control and universal control. On the one hand, the province's steel, coking, cement, petrochemical, pharmaceutical, glass, paper and other pollution industries, to introduce special incentives and supervision policies, strive to achieve breakthroughs in key industries, key areas of governance. On the other hand, we should also pay attention to the comprehensive treatment, give consideration to the overall situation of the third-party treatment of environmental pollution in other industries, and introduce a universal policy of support and guidance to ensure universal governance on the basis of key governance.

Third, the relationship between batch governance and comprehensive governance. Generally speaking, the regional distribution of environmental pollution is quite different. In the process of policy system construction, we must face up to this reality and correctly handle the relationship between batch management and comprehensive management. On the one hand, in areas where the situation of environmental pollution is relatively severe, we should give preference to the control policies and bring them into the focus of third-party control as soon as possible. On the other hand, in areas where the degree of environmental pollution is relatively light, preventive policies should be formulated accordingly, and enterprises should be encouraged to adopt more preventive technical means so as to avoid new pollution and consolidate a good ecological environment.

Conclusion: the third party has a long way to deal with pollution.

To eradicate environmental pollution and achieve green development goals, we must break the original pattern of "who pollutes, who governs", promote the marketization, specialization and industrialization of environmental pollution control, and promote the establishment of polluter-pays and third-party pollution control market by establishing a unified, standardized, orderly competition and strong supervision. The government should form a set of effective measures to promote the design and implementation of policies, establish an expert environmental protection management team and establish a set of scientific evaluation system in the practical operation level, to prevent unfair competition caused by the uneven quality of products and technologies and the confusion of fish and dragon.

However, as a management system innovation, the third party governance has to face many new problems and challenges. Based on external conditions and environmental factors, the third party governance can not be accomplished overnight, and needs to be gradual.