*4.3. Would Environmental Impact Assessments Have Addressed Sustainability and Environmental Justice Adequately?*

Furthermore, even if the more stringent EIA requirements were closely followed, many social problems caused by the exploitation of natural resources in the ethnic regions were not going to go away, as many Mongolians are likely to view the coal and the land as theirs, that they inherited from their ancestors, and that the Chinese are outsiders coming in to take their resources away and destroy their land and lifestyle. The central government may claim that the resources are national property. Many Mongolians may believe that the nation should be the people instead of some state officials. Considering the history of settlement and the Mongolian way of thinking, the mining plans may have to incorporate the concept of environmental justice and respect the view of the local people and culture, in addition to protecting the environment. Improvement in EIAs is needed for the environment, but EIAs are inadequate for dealing with these social problems caused by resource exploitation in the ethnic regions.

#### **5. The Need to Stress Justice and Equity in Sustainability Impact Assessment**

The above discussed problems in EIA practices in China need to be dealt with. For example, public participation needs to be strengthened to allow full involvement from the beginning of the project planning. It would be worthwhile to explore ways to have EIAs conducted by an independent third party rather than by an affiliate of the coal companies, even though that may increase the operational cost of the assessment. EIA has not been taken seriously because it concerns only the environment, which is considered as a public good in China. The government, which is supposed to take care of the environment and the resources, puts economic growth first. Public participation has not been regarded as a key element in resource development as natural resources belong to the government (Officially they belong to the state, but in reality the government, rather than the people, is the state in China). Wealth from mining is mainly taken by the central government, with the rest of the wealth taken by different levels of the governments. The local government, which usually receives a third of the wealth, is left to take care of the social and economic welfare [52]. Corruption and lack of funding have meant little is done for the common people. Such injustice and inequity has led local people to organize to open illegal mines to steal and rob the resources, which they think should belong to them [52]. Li Bo, head of Friends of Nature, an environmental non-government organization (NGO) in China, believes that:

The environmental assessment of development projects should be much more open. The possible existence of risk for any project—technological and economic, or social and political—should be fully discussed before the project is implemented. Right now, according to the law, there is a process for EIA. But the people who are in charge of executing these are only responsible to their seniors, not to the people under them. So these processes aren't very open, and their discussions aren't transparent. Because of this many projects are approved, and then their problems are only discovered afterwards. An example is the recent PX incident—there's a lot of fear and rage. These things can tear a society apart [69].

Morrison-Saunders and Pope argue that there is inadequate consideration of trade-offs throughout the sustainability assessment process and insufficient considerations of how process decisions and compromises influence substantive outcomes [67]. If properly done, sustainability assessment should indicate who gets what, who loses what, how, when and why [70]. Current EIAs in China are concerned with trade-offs between the economy and the environment. They are not concerned with trade-offs among different social groups. We argue that SIA should be adopted for subtle ethnic regions in order to adequately evaluate economic, environmental and social impacts to help reduce ethnic tensions. These impacts are interrelated and cannot be mitigated successfully unless they are dealt with together. If fully enforced, SIA will ensure that the public is more involved and their interest is better taken care of when justice and equity are a matter of concern in the assessment.

As sustainability assessment is new in China, we draw below some international experiences to help with the discussion. Gibson *et al.* present the case of the assessment of the proposed major nickel mining project near Voisey's Bay on the north coast of Labrador (Canada), which is often considered the first attempt to conduct sustainability assessment within a project approval context [19]. They challenge the common conceptualization of sustainability of three intersecting pillars representing environmental, social and economic concerns, on which most practice of sustainability assessment is based [19]. Gibson reports that an innovative environmental assessment and a set of surrounding and consequential negotiations were conducted between 1997 and 2002 on the proposed project:

The proponent and other participants wrestled directly and often openly with the project's potential contribution to local and regional sustainability. The resulting agreements to proceed were heavily influenced by the precedent-setting assessment, which imposed a "contribution to sustainability" test on the proposed undertaking. Given the profound differences in background, culture, priorities and formal power involved, as well as the record of tensions in the history of this case and before, the agreements also represent a considerable achievement in conflict resolution [71].

Faced with growing environmental and social crises, China's new leader, Xi Jinping, has criticized the "grow first, clean up later" approach and given more emphasis on ecological development than his predecessors. Among other things, he recently called for stopping the GDP-based promotion of government leaders [72]. Consequently, several provinces have lowered or abandoned using GDP as the only measure of success for city or county leaders, affecting over 70 of China's poorest cities or counties [73]. Evaluation will instead be based on poverty reduction and environmental protection [74]. It remains to be seen if the new policy will be applied to larger, wealthier cities. Nevertheless, cleanup efforts have been increasing. Many interviewed officials cared about the environment and were sympathetic for the Mongolian herders. There are indications that EIA will be more stringently and widely implemented. Kahya reports that:

Concerns over water use from coal mining and gasification projects have led the Chinese government to change the rules for new schemes. Mirroring recent "national plans" to tackle air pollution the Ministry of Water resources has announced a plan to limit coal expansion based on regional water capacity. The rules mean the approval process for large-scale projects must now include an appraisal of the available water [75].

Mclauchlan and Joao oppose the use of strategic environmental assessment (SEA) to deliver environmental justice, partly because "a direct focus on the environment requires that factors associated with environmental justice are not central to SEA [14]." That was exactly the case with some projects that conducted EIAs. China should borrow global knowledge in environmental justice and SIA to help with local practices and leapfrog the EIA stage to start SIA instead. Less-developed ethnic regions should leapfrog the "grow first, clean up later" stage and start practicing sustainability, so that further deepening of injustice and sustainability disparities might be avoided [12,13]. EIA has been useful in some countries. An important reason is that these countries tend to follow the rule of law and have an independent media and democratic government. Environmental injustice is partly inherited in the undemocratic system. There are limited options China has as major political reforms are unlikely to happen soon. Within the current political system, SIA certainly seems to be more useful than EIA in dealing with justice and equity problems.

#### **6. Conclusions**

In this paper, we have explored the theoretical basis and possibility of developing SIA with an emphasis on justice and equity to meet an urgent need in subtle ethnic regions such as Inner Mongolia, China. In coal mining practices in Inner Mongolia, an EIA was often not conducted for the large number of small scale so called "illegal" mines, or might have been falsified for many other mines through corrupted officials. Our focus, however, has mainly been on those that have conducted official EIAs following government guidelines but still fail to protect the environment partly because the guidelines are inadequate. The government has tightened control over EIA along with more specific and stringent guidelines.

Our research indicates that even if the new EIA guidelines are closely followed social justice and economic equity problems will continue to exist, as EIAs do not deal with any ethnic social problems. The assessment needs to include guidelines for justice and equity, in addition to protect the physical environment. EIAs appear to be inadequate for that. Even though certain elements of environmental justice such as participation can be incorporated into EIA/SEA, these elements are not central to environmental assessments. Environmental assessments are concerned with the environment while sustainability has addition concerns such as social justice and economic equity. Consequently, EIA/SEA is in theory and practice inadequate as a tool in meeting sustainability challenges.

SIA would be in theory and practice a better tool than EIA/SIA for assessing sustainability impact. The assessment needs to involve the effected ethnic groups at the very beginning and careful negotiations are needed so that agreements can be reached. This would be an appropriate approach to conflict resolution to take care of the profound differences and complex relations in the ethnic regions. Public participation in SIA is an effective measure to ensure social and economic justice and equity. SIA should recognize and respect traditional ethnic way of life, which has often been found to be environmentally sustainable. It is important to let the local people make their own decisions concerning the use of their resources. They tend to be the people who care about the environment the most and have the knowledge for sustainability. Social and economic equity, protecting the environment, and respect for nature, culture, and autonomy of local ethnic groups should all be key elements for SIA in the ethnic regions.

However, one practical challenge for SIA is corruption which has been also responsible for the failing of EIA in Inner Mongolia. China's political system presents another challenge to promoting social and economic equity. Political reforms are necessary to enhance ethnic justice and equity. Under the current political system, China should adopt the SIA for ethnic regions while continuing its fight against corruption.

Many of the concepts discussed in this paper are contested, such as sustainability, justice, and even participation. For example, Cooke and Kothari criticize "participatory development's potential for tyranny" as "it can lead to the unjust and illegitimate exercise of power" [76]. On the other hand, Hickey and Mohan argue for transforming problematic traditional practices to citizen participation. The contested nature of the terms shows the complexity of the issues and cautions us to avoid drawing simplistic conclusions [77]. We hope that our report will provide the initial information and stimulate future research into developing an SIA with justice and equity emphasized for easing ethnic conflicts in ethnic regions.

#### **Acknowledgments**

This research was based on fieldwork partly funded by grants from the National Geographic Society (Grant # 8980-1) and University of Central Missouri. The research benefited from expert discussions at the International Conference on Sustainability Assessment, 20–21 July 2013, Dalian Nationalities University, Dalian, China. The authors also wish to thank the anonymous reviewers for their constructive comments and suggestions on the earlier versions of the manuscript.

#### **Author Contributions**

Lee Liu designed the research, conducted literature research and fieldwork, and wrote the article; Jie Liu conducted literature research and fieldwork; Zhenguo Zhang conducted fieldwork and cartographic work.

#### **Conflicts of Interest**

The authors declare no conflict of interest.

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