减污降碳协同治理纳入生态环境管理体系探讨

现阶段，减污降碳协同治理纳入生态环境管理体系尚处于探索期，在现有的制度框架下，管理机制和技术方法还需完善。通过厘清各制度环节中的责任主体、边界范围、职能定位等，梳理分析了减污降碳协同治理纳入生态环境管理体系过程中面临的主要挑战以及基于生态环境管理体系的减污降碳协同治理框架。运用现有生态环境管理体系的主要制度环节中的管理和技术要素，以问题为导向，探讨了在源头防控上，根据减污降碳相关试点内容，需完善“三线一单”、规划环评和建设项目环评中碳评的边界范围、工作内容和管理机制；在过程控制上，进一步构建排污许可数据一体化管理；在执法督察上，探索建立全国碳监测网络等方式，提升监察执法运行效力，强化督察问责工作机制，推动构建减污降碳协同的制度体系。

Discussion on the integration of pollution reduction and carbon reduction collaborative governance into the ecological environment management system

At the current stage, it is still in the exploration period for the collaborative governance of pollution and carbon reduction to be incorporated into the ecological environment management system. Under the existing institutional framework, the management mechanism and technical methods are relatively lagging. The main challenges in the process of incorporating the collaborative governance of pollution and carbon reduction into the ecological environment management system were analyzed. By clarifying the responsible subjects, boundary scope and functional positioning, etc., of each institution, the collaborative governance framework for pollution and carbon reduction based on the ecological environment management system was analyzed. Applying the management and technical elements in the main institutional links of the existing ecological environment management system and aiming at the problems, some countermeasures and suggestions were put forward. In terms of source prevention and control, combined with the relevant pilots of collaborative governance of pollution and carbon reduction, the boundary scope, work content and management mechanism of carbon assessment in Three Lines One Permit (TLOP), planning EIA and project EIA should be improved; in terms of process control, the further construction of integrated management of pollutant emission permit data should be considered; in terms of law enforcement and supervision, the ways such as establishing a national carbon monitoring system should be explored to improve the enforcement effectiveness of law supervision, strengthen the mechanism of supervision and accountability, and promote the construction of a cooperative system for reducing pollution and carbon emission.