From the initiative of the Ministry of Ecology and Environment in 2018 to the issuance of the Notice on Recommending Pilot Projects of Eco-Environment-Oriented Development Model in 2020, the EOD model has been officially pushed to the implementation level. In 2022, the Ministry of Ecology and Environment (MEE) developed a management system for ecological and environmental protection financial support projects, and formulated and issued the Guidelines for the Warehousing of Ecological and Environmental Protection Financial Support Projects (Trial) (Huanban Kecai 2022 No. 6) (hereinafter referred to as "Document No. 6") in order to do a good job in the planning and reserve of major ecological and environmental protection projects, and as of December 2023, many provinces and cities have established their own EOD model project databases. From the initiative and guidance, the recommendation of pilots to the establishment of a storage mechanism, the EOD model has gradually matured and has become a hot project implementation concept in the field of environmental protection.
In recent years, the author has had the opportunity to participate in the overall planning of EOD projects in many regions, and fully felt the enthusiasm of various localities in planning EOD projects, but at the same time, I also felt that due to the insufficient understanding of the starting point, essence and connotation of the EOD model, and even certain misunderstandings, the overall planning of the project deviated from the original intention of Circular No. 6, and could not meet the standards of warehousing, or it was difficult to obtain the support of financial institutions after warehousing. Based on his own practical experience in participating in the overall planning and financing of EOD projects, the author summarizes that the outstanding problems in the process of project planning mainly include: the necessity of ecological environmental governance content is insufficient, the main line of governance is generalized, and the ecological environmental governance measures are not targetedPoor correlation between industry and ecological governance;The meltability of the project is poor;The ownership of the assets involved in the project is not clear;The mode of operation of the project is not clear;The project income is unreasonable, etc. In view of the above prominent problems, the author analyzes the key points that should be grasped in the overall planning of EOD projects based on practical experience, hoping to provide reference for the overall planning of EOD projects in various places.
Scientific and rational planning of ecological and environmental governance is the first priorityHow to determine which ecological and environmental governance content is suitable for inclusion in EOD projects should be judged according to the overall requirements in Circular 6. Document No. 6 requires that "in combination with the key tasks of ecological and environmental protection in the 14th Five-Year Plan for the region, focus on the accuracy, necessity of implementation, and authenticity of the content of supporting the pollution prevention and control battle, and reserve major engineering projects that have a strong supporting role in the pollution prevention and control battle, strong implementation necessity, good implementation foundation, and significant environmental benefits, focus on the key points, avoid generalization, and improve the quality of project reserves." In view of the above requirements, it is recommended to make a preliminary judgment from the following points for the ecological environment governance projects to be included in the EOD model:
1 It is a prominent ecological and environmental problem in the region that needs to be solved urgently, which belongs to the key tasks in the "14th Five-Year Plan" ecological and environmental protection plan of the region, and the feasibility study of the project has been completed. The purpose of this judgment is to ensure that the need for ecological governance is sufficient and that the preliminary work of the project has reached a certain depth. In view of the necessity of ecological and environmental governance, the latest EOD model support policies issued by some provinces have made it clear that they should be inclined to major projects, taking Jiangsu Province as an example, it is clearly stated that "ecological environmental governance sub-projects should be given priority to projects included in the "14th Five-Year Plan for Ecological and Environmental Infrastructure Construction in Jiangsu Province".
It belongs to the content of public welfare ecological environment governance. This is mainly based on the starting point that it is the main body of the EOD project, so the ecological environment should be the content of public welfare ecological environment governance. Specific to the practical level, if it involves solid waste treatment projects, if the governance responsibility is an upstream production enterprise, it does not belong to the scope of authority, and it should not be included in the EOD project as ecological and environmental governance content.
Ecological and environmental governance should not be greedy for more, not generalized, and the main line should be focuseda key direction, planning"Small but beautiful" projects. Among them, "cannot be generalized", specifically, it can be judged from whether the ecological environment elements are focused, whether the boundaries of the governance scope are clear, and whether the layout is concentrated.
The qualitative and quantitative goals for the improvement of the ecological environment should be scientific and reasonable, and have accessibility. The setting of ecological and environmental governance goals of the project should be consistent with the ecological and environmental protection goals of the "14th Five-Year Plan" in the region, and should not be blindly broken.
Ecological environment governance measures should be targeted and can support the realization of the goal of improving the ecological environment after governance. The project governance plan designed for ecological and environmental objectives should be scientific and reasonable, and the main construction content should be quantified.
Industrial development projects should be closely related to and fully integrated with the content of ecological and environmental governanceWhen planning an industrial development project under the EOD model, it is necessary to first ensure that it is in line with the actual local social and economic development, and that the industrial field meets the national and local market access standards and relevant industrial policy requirements. Regarding relevance, Circular 6 requires that "the boundaries of the project should be clear, the ecological environment governance and industrial development should be closely related and fully integrated, irrelevant projects should be avoided, and the number of single sub-projects to be implemented in a combination should not exceed 5." "In practice, the understanding of relevance is different, and the author makes suggestions based on the requirements of the document and practical experience to make judgments in the following forms:
1.In terms of spatial proximity, and through ecological governance, after the improvement and promotion of environmental quality, the development of ecological industries will be carried out by relying on the increment of the value output of ecological products, such as ecological agriculture (including "photovoltaic +" complex industries such as agriculture and photovoltaic complementation), eco-tourism, medical care and other eco-dependent industries.
2.Related industries have a strong dependence on the ecological environment, and the development of related industries through the asset appreciation brought about by ecological and environmental governance, such as closely related industries in the industrial chain, with the reuse of waste minerals after mine restoration as related industries, or eco-sensitive industries such as digital economy and clean medicine.
3.Industries with a low degree of impact on the ecological environment and a long-term sustainable effect of ecological environment support, such as scientific and technological innovation and entrepreneurship talent gathering industries.
Docking with financial institutions to ensure that the project is bankable
Circular No. 6 clarifies that "warehousing projects should be supported by appropriate financial funds". In practice, most people think that the project can be loaned when it is put into storage, but this is not the case. Compliance with the warehousing standards does not mean that it meets the judgment standards of financial institutions, and whether the projects that have been put into the warehouse can obtain financing depends on whether they meet the loan conditions and requirements of financial institutions. The loan approval of EOD projects by financial institutions is mainly based on the project implementation mode, whether the funds can be balanced, and the stability of the project's operating income and cash flow. In order to ensure that the planned project should be "suitable for financial support", financial institutions can be invited to intervene in advance during the project planning process, mainly from the following aspects, mainly from the following aspects, not only to understand the loan support conditions, but also to optimize the project input and output from the overall planning level:
1) The borrower's access conditions meet the requirements of the financial institution. When determining the implementing entity through open competition, the qualification conditions and evaluation methods shall be reasonably set up in combination with the access requirements of the financial institution to the borrower, so as to ensure that the project implementation entity has the qualifications and capabilities of the qualified entity, has a good credit status, has normal production and operation, and has a good financial status.
2) Project field and construction content: The content of ecological environment governance under the EOD model is generally in line with the support scope of financial institutions, and it is necessary to pay attention to the planning process of industrial projects, and on the basis of ensuring that the requirements of the EOD model are met, full consideration should also be given to whether the industry is in line with the support areas of the target financial institutions.
3) Implement the availability of assets and resource rights and interests: For stock assets, water resources, sand and gravel resources, mineral resources, centralized photovoltaic grid indicators, etc., the availability of assets and resources belonging to the same implementing entity should be assessed.
4) Reasonably determine the scale of project investment: the basis of investment estimation should be sufficient, in line with the local quota standards, in which the industrial project should be combined with the industry prospects, target market capacity, development prospects of the region to reasonably determine the construction content and scale of the industrial project, and combined with the comprehensive calculation of the project income level, reasonably determine the boundary scope and construction content of the industrial development project.
5) Do a good job in project cash flow planning: financial institutions generally require the project to have a stable cash flow and repayment guarantee, when considering the EOD model project loan, financial institutions allow different construction content cash flow can be coordinated and adjusted with each other, and the credit structure is effectively shared. Specific to the project planning, how to calculate the accounts, accurate accounting, involving the determination of the project operation model, whether the loan term and interest rate setting are reasonable, and whether the project operating income is stable, etc., at the same time, the calculation basis should be sufficient, and the income shall not be regarded as the project income;Unimplemented funds (e.g., ecological compensation funds, carbon sink income) shall not be used as project revenue**.
As the main body of the project, it is necessary not only to correctly understand the connotation of the EOD model and lead the planning of the specific content of the project, but also to explore the establishment of a long-term mechanism for the promotion and implementation of the project, including project co-ordination, departmental coordination, fund integration, supervision and management, etc., and to do a good job in debt risk prevention in the investment and financing planning process of the project. The project planning stage is only the starting point of the whole life cycle of the project, and based on the actual situation of the region, scientific planning and full demonstration can lay a solid foundation for the follow-up implementation of the project.