China Cement Network published an article entitled "Unreasonable capacity replacement touches the red line of strictly prohibiting new cement clinker production capacity". According to the article, the output capacity is a Φ4.0 m cement clinker production line. The line was built in May 2007, according to the list of the province (where the line is located). At that time, the production capacity approved by the provincial investment authorities was 4000t/d. It is obvious that the production capacity of the main equipment of the production line is seriously out of line with the approved capacity (at that time), and the approved capacity is out of line. The conclusion of the article is that for those who know that the approved capacity is unreasonable, but also put on the coat of legal capacity replacement to implement capacity replacement, resulting in the actual new capacity, it can be concluded that the capacity replacement has touched the red line of prohibiting new cement clinker capacity.
It is necessary to review the process of cement clinker capacity replacement. In July
2014 (the first), the Measures for the Implementation of Capacity Replacement in Some Industries with Serious Overcapacity made it clear that the so-called equivalent capacity replacement refers to the elimination of backward or excess capacity equal to the capacity of the new (re formed and expanded) construction projects; Reduction replacement means that new (renovation, expansion) construction projects should eliminate backward or excess capacity that is greater than capacity of the construction project. The production capacity of the eliminated project shall be verified in accordance with the capacity conversion table. The concept of capacity conversion is put forward for the first time, and the method of determining the capacity of eliminated projects is clarified. In April
2015, the Measures for the Implementation of Capacity Replacement in Some Industries with Serious Overcapacity (2015 edition) was issued to further clarify that the number of capacity of construction projects and the number of capacity to be eliminated after 2015 shall be approved in accordance with the conversion table. The production capacity of construction projects is also included in the approved scope according to the conversion table. In December
2017, the Measures for the Implementation of Capacity Replacement in the Cement and Glass Industry were issued. Replacement capacity has basically changed from elimination to replacement between normal capacity. For the first time, the Measures put forward that the capacity indicators for replacement should be determined according to the design capacity on the project record or approval documents. If the actual capacity is less than registered or approved capacity, it shall be determined according to the actual capacity. The actual production capacity of the project is calculated and determined according to the cement clinker production capacity conversion table. In the interpretation of the competent authorities, it is said that in view of the phenomenon of "approving small and building large" in the construction of cement clinker projects, in order to advocate trustworthiness and compliance with the law, the capacity indicators for replacement are determined according to the design capacity on the project filing or approval documents. If the actual capacity is less than registered or approved capacity, it shall be determined according to the actual capacity. For the first time, the Measures put forward the method of how to verify the capacity replacement of "batch of large and small" projects. In July
2021, the Measures for the Implementation of Capacity Replacement in the Cement and Glass Industry (2021 edition) was issued. When the competent authorities interpreted how to verify the withdrawal of production capacity, they said that the verification of production capacity involves two aspects of withdrawal and new construction, which is an important work to promote scientific and fair replacement. There are clear criteria for approval in the new approach. The capacity index used for replacement shall be determined according to the design capacity and the actual built capacity on the project filing or approval documents, and the smaller one shall be approved by the smaller one. The production capacity of JT kiln is determined according to the project approval or filing documents, and the documents do not specify the actual production capacity of the previous year.
It can be said that the "batch of large and small" projects can not get any "cheap" in the implementation of capacity replacement. In October
2024, the Implementation Measures for Capacity Replacement of Cement Glass Industry (2024 edition) was issued. Instead of the previous method of conversion capacity verification, the new method is clear that the number of capacity used for replacement is determined strictly according to the capacity specified in the project filing (approval) documents, and the number of days of annual capacity is calculated according to 300 days. According to the interpretation of the competent authorities, we should improve the way of capacity verification, cancel the regulation of capacity verification based on the diameter of cement rotary kilns, and promote the unification of registered capacity and actual capacity.
After canceling the way of converting the approved capacity, there are two new situations under the promotion of the unification of the registered capacity and the actual capacity. One is to put on record production capacity and release oneself. In the past, when the kiln diameter was converted by (replacement) capacity, the "pheasant" kiln diameter appeared frequently. Now, from the filing (approval) capacity to the equivalent or reduced replacement ratio, the filing capacity is decided independently, and the scale of production capacity is full of patterns. Second, when the original project was put on record (approved), some of the projects that were obviously "large and small" were able to participate in the replacement of "large" production capacity, and the project has been "cheap" until now. These projects will not be "cheap" if they are replaced according to the previous method. Production capacity, such as "food stamps" on the market, is of great value at present, and the profits are considerable!
Recently, we have seen such cases of "large-scale construction of small projects" participating in capacity replacement. The production capacity of a Φ3.6m kiln in a southern province was sold, and the approved production capacity of the previous project was 2500 t/d. If converted according to the old replacement method, the replaceable capacity should be 1700 t/d. According to the current method, the approved production capacity is increased by 800 t/d. The list of 2023 cement clinker production line in the province (where the production line is located) shows that the operation status is "in production". The data in the column of cement clinker output in 2023 is 156,900 tons. In the list, most of the Φ4.0 m kilns in normal production have an annual clinker output of more than 630,000 tons, and 7 kilns have an annual clinker output of more than 700,000 tons, of which 5 kilns have an annual clinker output of more than 900,000 tons. If the capacity of JT kiln is determined according to the project approval or filing documents in this 2021 replacement method, the document does not specify that it is calculated according to the actual capacity of the previous year. Here, the "actual capacity" is less than 600 t/d, which is far from the actual replacement volume. What is
more amazing is that there is a case of supplementary production capacity recently. The capacity of one Φ4.0 m kiln in a province was transferred to two Φ4.8 m kilns at a rate of 4000 t/d. The plan is to transfer 2500 t/d to a production line with a kiln diameter of Φ4.8 m and a capacity of 4000 t/d in the same plant area, and the capacity will be 6500 t/d after supplement. 1 500 t/d is replaced to a production line with a capacity of 5 000 t/d and a kiln diameter of Φ4.8 m in another place of the province by a reduction of 1. 5:1, and the capacity is 6 000 t/d after the replacement. The status of the production line of the transferred production capacity is closed (the time of closure is not marked).
Compared with the provincial cement clinker production line list, this transfer production line is not included in the 2020 annual list. Later, in the annual list of 2023, the capacity of Φ4.0 m kiln is 2500 t/d. However, the remarks column shows that it has been announced in November 2020. In the replacement plan of this announcement, it is indicated that the kiln diameter is Φ4.0 m, the capacity is 2500 t/d, and the demolition time is May 2024. Combined with the analysis, that is to say, if the production line is not dismantled, even if it is in the "shutdown" state, it can still be regarded as the "waiting for production" state, and it will not be replaced again because the replacement plan has not been implemented. If the replacement is carried out again, the current replacement method can be implemented to avoid the stipulation that the cement clinker production capacity that has been shut down for two consecutive years or more since 2013 can not be used for capacity replacement. In addition, it "shows up" again in the list, which can also avoid the stipulation that cement clinker production capacity can not be used for capacity replacement within the scope of the compliance list submitted by the provincial industry and information technology authorities to the Ministry of Industry and Information Technology every year. The closed kilns that have not been seen for
many years suddenly appear on the list (although there is a remark that they have been replaced), and suddenly appear in the replacement plan of supplementary capacity (there is no statement that the original plan has not been implemented), and the capacity of Φ4.0m kiln jumps from 2500 t/d to 4000 t/d. This 4000 t/d is split into 2500 t/d (1:1) + 1500 t/d (1.5: 1) to supplement the two Φ4.8 m kilns. A total of 3500 t/d was actually supplemented. It is said to be "a batch of big and small", but it is not. The production capacity of Φ4.0 m kiln has always been 2500 t/d. Why did the "batch of big" 4000 t/d jump out when the production capacity was supplemented? What was the capacity scale approved by the project at that time? This wave of operation is simply too "God", people really do not understand. Is it in line with the requirement of "strictly controlling the construction of" two high "projects" in the "Measures for the Implementation of Capacity Replacement" to
let the production capacity of "large-scale construction and small-scale construction" be self-released? Does it meet the requirement of prohibiting new cement clinker production capacity? Obviously not!
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