Making central-local relations work: Comparing America and China environmental governance systems

The challenge of making central requirements work at local levels is a common problem for environmental governance throughout the world. Countries can learn from one another's approaches, but must understand the local context in which they are set. This paper compares the features of the China and US environmental governance systems that need be understood by those working between the systems. Key features include: (1) common values which shape the environmental governance choices in both countries, but which may have different practical meanings in each country; (2) America's common law-based environmental governance system, and China's civil law system, which involves plan(s) as well as law; (3) America's Federal central-local system, and China's unitary central local system. This paper concludes by suggesting areas in which further comparative understanding may be of value, including: (1) better understanding of the role of plan and law in China's governance system; (2) comparing the American Federal-state agreement system for implementation of environmental law with the China central-local system of target responsibility agreements for plan implementation; (3) improving understanding of nongovernmental resources needed to assure compliance with environmental laws and plans; (4) identifying institutions that can coordinate central-local and cross-border environmental governance.