their own political career concerns (Kostka 2013). For example, while Shanxi, a province under heavy external pressure to improve air pollution in 2006, selected a candidate with the skills and credentials to effectively implement air pollution targets to head the provincial EPB, the still-developing Inner Mongolia appointed a candidate with a the experience needed to balance economic growth and environmental protection concerns. The power to select local EPB directors gives local authorities significant scope to influence the local path of environmental policy enforcement. Given these appointment procedures, EPB directors might feel sometimes more beholden to local leaders than to their duty to pursue environmental protection goals.

# **Technical capacity: Lack of equipment and know-how**

Technical capacity constraints can further hinder the implementation of national environmental mandates. Two pertinent technical constraints commonly cited in the literature are: 1) a lack of technical equipment and 2) insufficiently trained local staff (Mol and Carter, 2006).

# _1) Lack of technology_

The verification of environmental outcomes, a key component of effective environmental management, is a difficulty faced in many localities due to a shortage of advanced monitoring equipment. The available technologies and forms of monitoring systems differ for the verification of environmental targets. For the verification of forest targets, recent Global Positioning System (GPS) technologies make it somewhat easier to independently confirm reported forest coverage rates as these latest technologies can serve as “the central state’s eyes in the sky” (Shue, 2012: 24; (INT09052012).<sup>14</sup> For COD and SO2 targets, real-time monitors are usually installed in larger companies. This monitoring equipment is reported to be not very technically advanced, unreliable and too few in number (Kostka, 2014). Overall, the COD and SO2 data collected from monitors can only serve as a reference ( _can kao_ ) and many counties continue to rely more strongly on monthly or quarterly inspection visits to larger companies (INT10052012). Although it is very taxing in terms of staffing requirements and time consumption, sending frequent inspection teams is seen to be quite necessary. For example, inspection teams sent from the national Ministry of Environmental Protection to the provinces sometimes rejected 30% to 50% of claimed SO2 reductions by some provinces (Schreifels et al., 2012). Heavy reliance on inspection visits gives local officials a certain amount of discretion when it comes to verifying targets, including the decision about which enterprises to inspect or on which day to visit a lake to test its water quality (Shin, 2014).

For energy intensity targets, there is no purpose-built monitoring equipment in place and reported data rely on self-reported figures from enterprises. Self-reported online data get sent to the local statistical bureau, which then collates all these sheets. Only data from very large enterprises are shared directly with the provincial and national statistic bureaus. A government officials explains:

> Enterprises report their energy consumption through an online reporting system. Self-reporting by enterprises is problematic, because there are three “baos”. There is _luanbao_ , which refers to messy data that lacks logic. Often accountants enter the data into the online sheets but they lack training on energy bookkeeping, so they often make mistakes. There is _manbao_ , which refers to companies underreporting production figures because they fear that this information is shared with the local

> 14 Yet, even advanced GPS technologies have their limitations, as the technology cannot differentiate between first-growth and second-growth forests. To correct for this shortcoming, national forest inventories take place every five to ten years to check local field sketches of forests (INT24052012).

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