The stringent environmental regulations are not only unlikely to be relaxed but will also usher in a “fundamental” transformation—including the reform of the vertical management system for environmental protection agencies. On November 20, the Ministry of Ecology and Environment issued the "Notice on Coordinating and Promoting the Reform of the Vertical Management System for Monitoring, Supervision, and Enforcement of Ecological and Environmental Institutions Below the Provincial Level." While clearly setting out a timetable for implementing the vertical reform of environmental protection agencies, the notice once again underscores the redefinition of the relationship between "vertical" and "horizontal" authorities, with accountability being the central thread running through the reform.

　　The environmental protection vertical reform has once again been given a “speed boost.” Recently, the Ministry of Ecology and Environment issued the “Notice on Coordinating and Promoting the Reform of the Vertical Management System for Monitoring, Supervision, and Enforcement of Ecological and Environmental Institutions Below the Provincial Level,” requiring that the implementation of the provincial-level environmental protection vertical reform be fully completed by March 2019.

　　As a fundamental reform of the local environmental protection system, the vertical restructuring of environmental protection can be described as a change that affects the whole body once a single part is touched. This is not merely a reorganization of subordination relationships; rather, it involves a comprehensive reconstruction of foundational systems such as environmental monitoring, supervision, and law enforcement—a systemic overhaul of the environmental protection management framework. Unlike typical institutional reforms, the vertical restructuring of environmental protection touches not only the institutional framework itself but also the organizations and personnel involved, and it entails a complete rethinking of systems related to environmental law enforcement, supervision, monitoring, and permitting. Following the implementation of vertical management, adjustments are made to organizational affiliations, and accordingly, the division of powers among different levels of local governments, the functional responsibilities among relevant government departments, and the internal operational relationships within the environmental protection system all undergo corresponding changes.

　　The “Notice” proposes “prioritizing the adjustment of ‘horizontal’ responsibilities and corresponding staffing allocations for institutions under the ecological environment authorities, as well as monitoring, inspection, and enforcement agencies, and accelerating the implementation of the environmental protection reform plan.” Specifically, county-level environmental protection bureaus will be directly reorganized into branch offices under the municipal-level environmental protection bureau, which will assume direct management over them. All personnel, financial resources, and members of the leadership teams will be directly managed by the municipal-level environmental protection bureau. This arrangement will enable provincial-level environmental protection departments to focus primarily on the assessment and supervision of ecological and environmental quality at the city and county levels, as well as on the oversight of local governments’ fulfillment of their environmental protection responsibilities. At the city and county levels, environmental protection departments will further concentrate their efforts on local environmental law enforcement, with county-level departments primarily responsible for ensuring effective implementation.

　　Simply put, the functions of environmental inspection and environmental monitoring will be transferred to the provincial level. Correspondingly, the existing environmental inspection functions currently performed by environmental protection departments at the city and county levels will be unified under the jurisdiction of the provincial-level environmental protection authorities, which will carry out environmental inspections through mechanisms such as dispatching inspectors to cities or cross-city/county regions. At the provincial level, oversight of the fulfillment of environmental protection responsibilities by cities and counties will take the form of "supervising government actions," while the inspection activities at the city and county levels will shift toward primarily enforcement-based oversight—focusing mainly on "supervising enterprises." In this way, the reform of the vertical environmental protection system can effectively address three major shortcomings: building a new environmental inspection framework, ensuring that cities, counties, and relevant departments strictly fulfill their environmental protection responsibilities, and tackling the persistent issue of "high-level enthusiasm but low-level implementation."

　　Through the reform of vertical management, we will establish a comprehensive framework characterized by “local Party committees and governments taking the lead, environmental protection departments exercising unified oversight, and relevant departments each fulfilling their respective duties.” In the future, the focus of environmental law enforcement will shift downward to the grassroots-level cities and counties. The environmental monitoring functions of the environmental protection departments at both the city and county levels will be enhanced and will be uniformly exercised by the provincial-level environmental protection authorities. This approach will largely ensure the authority and authenticity of monitoring data and gradually help build a management model centered on environmental quality. It will also facilitate the supervision and inspection of cross-county and cross-district environmental issues. Furthermore, the streamlined staffing of environmental protection agencies at the city and county levels will be focused on strengthening the frontline environmental law enforcement teams.

　　As for how to achieve efficient allocation of human resources, financial resources, and material assets, this will undoubtedly be the most challenging aspect of the reform. To address this, the “Notice” proposes “further clarifying the direction of reform, focusing on key priorities, and promoting the integrated advancement of environmental protection vertical reform alongside local institutional reform and comprehensive law enforcement reform—ensuring that the vertical reform effectively addresses the ‘four prominent issues.’” Specifically, this involves building a comprehensive ecological and environmental protection framework, establishing a provincial-level “supervisory and administrative” system, streamlining the monitoring system, and strengthening the construction of the law enforcement system. Meanwhile, the environmental inspection functions currently performed by environmental protection departments at the city and county levels will be transferred upward and unified under the jurisdiction of the provincial-level environmental protection authorities. The provincial Department (or Bureau) of Environmental Protection will carry out environmental inspections through mechanisms such as dispatching inspectors to cities or cross-city/county regions.

　　But in fact, as early as two years ago, the “Guiding Opinions on the Pilot Work for Reform of the Vertical Management System for Monitoring, Supervision, and Law Enforcement of Environmental Protection Agencies Below the Provincial Level” were publicly released, signaling the full-scale launch of the environmental protection vertical reform. This also marked the first time that top-level design proposed drafting and implementing a list of environmental protection responsibilities. According to the timetable set at the time by the former Ministry of Environmental Protection, this “vertical management” reform was expected to be completed within two to three years—meaning that by 2020, environmental protection agencies below the provincial level nationwide would be operating efficiently under the new system. Industry insiders pointed out that the environmental protection vertical reform will undoubtedly address the longstanding problem of some local environmental protection agencies acting both as athletes and referees, and they hope it will fundamentally enhance the level of environmental monitoring. Environmental monitoring level.