Ask: Does the industry say that the production line needs to be re-evaluated and re-evaluated?
Answer: In the industry, the term "production line supplementary capacity" refers to the compliance production line whose actual capacity is greater than registered capacity, which can be supplemented according to the Measures for the Implementation of Capacity Replacement in the Cement and Glass Industry (2024). It is necessary to formulate a capacity replacement plan to
make up for the difference in capacity. The Measures stipulate that within two years from the date of announcement of the capacity replacement scheme, the project construction enterprise shall complete the formalities of filing and environmental assessment. In the policy interpretation, it is more clearly pointed out that the balance of production capacity should be completed and the relevant procedures such as filing, environmental assessment and energy assessment should be improved.
The Environmental Impact Assessment Law stipulates that after the approval of the environmental impact assessment document of a construction project, if the nature, scale, location, production process or measures to prevent pollution and ecological damage of the construction project have changed significantly, the construction unit shall re-submit the environmental impact assessment document of the construction project for approval.
According to the Notice of the former Ministry of Environmental Protection on Issuing the List of Major Changes in Construction Projects of Fourteen Industries, such as Pulp and Paper Industry, in 2018, the scale of cement clinker exceeding 10% is a major change, and the EIA should be re conducted.
If the production capacity to make up the difference reaches or exceeds 10% of the original record (approved) production capacity, the EIA shall be carried out again.
According to the Measures for Energy Conservation Review of Fixed Assets Investment Projects issued by the National Development and Reform Commission in 2016, if the construction content and energy efficiency level of fixed assets investment projects that have passed the energy conservation review have undergone major changes, the construction unit shall submit an application for change to the energy conservation review authority. Before a fixed asset investment project is put into production and use, the implementation of its energy conservation review opinions shall be checked and accepted.
In the field of energy conservation, there is no corresponding supporting document for what is a major change, so in principle, it can be compared with the EIA requirements. If the environmental impact assessment is within a major change, the energy conservation review should also be recognized as a major change.
If the EIA needs to be re-submitted for approval, the energy conservation review should also be re-submitted for approval in principle. In the specific implementation, the local energy conservation authorities may be consulted.
According to the National Development and Reform Commission's Plan for Improving the Dual Control System of Energy Consumption Intensity and Total Amount in 2021, the state will continue to take the reduction of energy consumption intensity as a binding target for the five-year plan of national economic and social development, rationally set the total energy consumption target, and decompose and issue the five-year target of dual control of energy consumption to all provinces (autonomous regions and municipalities directly under the Central Government). The state implements the dual-target management of basic target and incentive target for the reduction of energy consumption intensity in all provinces (autonomous regions and municipalities directly under the Central Government). The basic target is the binding target that each region must ensure to achieve, and the incentive target is set according to a certain extent exceeding the basic target. Reasonably determine the target of reducing energy consumption intensity and total energy consumption of provinces (autonomous regions and municipalities directly under the Central Government).
Therefore, in addition to the energy conservation review, enterprises should not exceed the energy consumption indicators issued by the local government. If they exceed the consumption indicators issued by the local government, they should apply for an increase in the energy consumption indicators. However, the probability of "two high" projects needs to be solved by enterprises themselves within the scope of policy provisions.
Ask: Is it a reconstruction and expansion project to make up the difference in production capacity?
Answer: If it is only to make up the difference in the production capacity scale of the production line, it should be regarded as a simple unified operation of the actual capacity and the filed capacity, and the relevant procedures such as filing, environmental assessment and energy assessment should be improved.
If the process flow and equipment of the production line are changed in the process of making up the balance capacity of the production line, it can not be regarded as a simple unified operation of the actual capacity and the registered capacity, but should be regarded as a reconstruction and expansion project.
According to the requirements of the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Ecology and Environment, the General Administration of Market Supervision and the National Energy Administration's Special Action Plan for Energy Conservation and Carbon Reduction in Cement Industry in 2024, the energy-saving review and environmental assessment of fixed assets investment projects should be strictly carried out. New and expanded cement projects must reach the benchmark level of energy efficiency and A-level environmental performance, and the main energy-using equipment must reach the advanced level of energy efficiency.
For such reconstruction and expansion projects that make up the difference in production capacity, after making up the difference in production capacity, the production line should be checked and accepted according to the level of energy efficiency benchmark and A-level environmental performance.
浙公网安备33010802003254号