taxation bureau. Because they are afraid that they would have to pay more taxes, companies do not report real production numbers. Finally, there is _tuobao_ , where companies simply delay reports (INT24052012).

Because the self-reported data from enterprises collected by the statistical bureau are so poor, one official admitted that he collects his own data from the town level, including data for both large and smaller enterprises. According to him, his independently collected data are more accurate, but for official purposes he still has to use the data from the statistical bureau (INT25052012).

For some environmental targets, monitoring equipment is also sometimes entirely absent. The EPB in one county in Shandong, for example, lacked monitors to keep an eye on electroplating factories that emitted high concentrations of heavy metals (e.g., Cd and Pb) (Kostka, 2014). In sum, the difficulties in measuring certain environmental policies make them easier to sidestep. In China, as in many political systems, there is a structural bias toward policy implementation of readily measurable goals. While assessment of a locality’s performance in raising forest coverage rates is relatively straightforward, technological and organizational challenges make accurate measurement of energy and carbon expenditure extremely difficult.

# _2) Lack of technical staff_

The environmental bureaucracy is also in chronic need of well-trained staff to strictly monitor the accuracy of reported figures and targets. Such skills are needed, for example, in deciding which method is appropriate to the estimation of energy intensity levels, defined as energy consumption per unit of GDP. Interviewees working in local EPBs frequently admitted that sector-specific technical knowledge is needed to be able to critically check enterprises’ selfreported energy consumption reports. A county-level EPB head in Shanxi complained about the lack of trained staff in the local EPB: For the past ten years, our bureau did not receive any additional staff despite rising environmental regulations and new responsibilities. We have continuously requested new staff trained as environmental specialists but the upper government did not send us any. It is frustrating because without qualified personnel we cannot do our work well (Interview, September 2011, Shanxi).

The lack of formal and informal training of EPB staff in environmental sciences is also visible among the top leaders in the EPB bureaucracy. Among all 31 provincial EPB heads as of 2010, only one director has undergone university training in environmental sciences and only 25% were promoted to their leadership position from within the EPB (Kostka, 2013).

In summary, the combination of shortages in advanced technical equipment and officials’ limited technological know-how leaves ample room for business managers to play the “game about numbers” with the local environmental bureaucracy (Ran, 2013).

# **Financial capacity: Insufficient funding**

At the national level, China has recently increased funding for environmental protection and is planning major future investments. According to the China Daily (2013a), the total government spending on environmental protection in 2011 was 419 billion RMB, or about 0.9% of GDP. Although this figure is a significant step up from previous years, it is still below the 2% to 4% of GDP that is estimated as necessary to tackling environmental damage (China Daily, 2013). Further investments are planned at the national level. For instance, the Ministry of Environmental Protection budgeted a further 200 billion RMB for cleanup projects and 350 27