Environmental Impact Assessment: The costs of compliance – Taipei Times

Report on the Environmental Impact of Policy Design in Taiwan and Alignment with Sustainable Development Goals (SDGs)
Introduction: Policy Externalities and SDG Conflicts
An analysis of various policies reveals that well-intentioned regulations, when poorly designed, can result in significant negative environmental consequences, thereby undermining progress toward multiple Sustainable Development Goals (SDGs). A notable international example is the European Union’s 2003 biodiesel promotion, which aimed to support SDG 7 (Affordable and Clean Energy) and SDG 13 (Climate Action) but led to deforestation in Southeast Asia, conflicting with SDG 15 (Life on Land). This report examines similar instances in Taiwan where policy implementation has created trade-offs and conflicts with the nation’s sustainability objectives.
Case Study 1: Renewable Energy Localization Policy
Policy and Intended Goal
- A policy mandated that at least 60 percent of components for wind-farm projects be procured locally.
- This was intended to bolster domestic industry, aligning with SDG 9 (Industry, Innovation and Infrastructure).
Conflict with Sustainable Development Goals
- SDG 7 (Affordable and Clean Energy) & SDG 13 (Climate Action): The procurement rules were described as “problematic” and were reported to be “choking offshore wind” development. This impeded the country’s transition to renewable energy and its decarbonization efforts, directly hindering progress on these goals.
- SDG 17 (Partnerships for the Goals): The policy created international friction, leading to a complaint filed by the European Union at the World Trade Organization (WTO), highlighting a conflict between local industrial policy and global trade partnerships. The requirements were subsequently scrapped.
Case Study 2: Soil and Groundwater Pollution Remediation Act
Policy and Intended Goal
- The Act requires businesses to submit soil pollution assessment data at various stages of operation to identify and penalize polluters.
- The primary objective is to enforce accountability for industrial pollution, contributing to SDG 12 (Responsible Consumption and Production).
Conflict with Sustainable Development Goals
- SDG 11 (Sustainable Cities and Communities): To avoid the risks and potential liabilities associated with pre-existing contamination, businesses often prefer developing on pristine “greenfield” plots rather than redeveloping industrial “brownfield” sites. This practice discourages sustainable urban regeneration.
- SDG 15 (Life on Land) & SDG 2 (Zero Hunger): The preference for greenfield development contributes to the loss of valuable ecosystems and agricultural land, estimated at 3,000 to 4,000 hectares per year. This directly threatens biodiversity and undermines efforts to preserve land for food production.
Case Study 3: Urban Planning and Cycling Infrastructure
Policy and Intended Goal
- A municipal regulation in Taipei bans bicycles from parks, presumably for pedestrian safety.
Conflict with Sustainable Development Goals
- SDG 11 (Sustainable Cities and Communities): This rule creates a significant barrier to developing integrated, sustainable transport infrastructure. For example, it prevented the installation of secure bicycle storage at the LEED-certified Taipei Public Library Beitou Branch, which is located within a park.
- SDG 3 (Good Health and Well-being) & SDG 13 (Climate Action): By failing to provide necessary infrastructure, the policy discourages cycling as a viable mode of transport. This undermines national goals to improve public health, enhance urban air quality, and lower carbon emissions from the transportation sector.
Case Study 4: Labor Standards Act Amendments
Policy and Intended Goal
- The law was amended to limit working hours and mandate higher overtime pay to protect workers from overwork.
- This policy directly supports SDG 8 (Decent Work and Economic Growth).
Conflict with Sustainable Development Goals
- SDG 11 (Sustainable Cities and Communities) & SDG 13 (Climate Action): In response to the law, some 24/7 factories shifted from two 12-hour shifts to three 8-hour shifts. This change potentially increases the total number of daily commuter trips, which could lead to greater traffic congestion, noise pollution, air pollution, and associated carbon emissions, thereby conflicting with goals for sustainable cities and climate action.
Conclusion and Recommendations
The case studies demonstrate a recurring pattern where policies, while achieving their primary objectives, generate negative externalities that conflict with broader environmental and sustainability targets. A lack of integrated policy assessment can lead to setbacks in achieving the Sustainable Development Goals.
- Integrated Impact Assessments: It is recommended that a holistic assessment framework be adopted to evaluate potential policy impacts across all three pillars of sustainable development (economic, social, and environmental) before implementation. This would help identify potential conflicts with SDGs.
- Policy Coherence for Sustainable Development: Government agencies should enhance inter-departmental coordination to ensure that policies promoting one SDG (e.g., SDG 8 or SDG 9) do not inadvertently undermine others (e.g., SDG 11, SDG 13, or SDG 15).
- Adaptive Governance: Mechanisms for monitoring and reviewing the unintended consequences of policies should be established, allowing for timely revisions when negative impacts on SDG targets are identified.
Analysis of Sustainable Development Goals in the Article
1. Which SDGs are addressed or connected to the issues highlighted in the article?
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SDG 7: Affordable and Clean Energy
The article discusses Taiwan’s efforts to “switch over to renewables and decarbonize its grid,” specifically mentioning the challenges with wind-farm projects. It also references the EU’s policy to promote biodiesel to “mitigate climate change while enhancing the continent’s energy security.”
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SDG 8: Decent Work and Economic Growth
A significant section is dedicated to Taiwan’s amendments to the Labor Standards Act, designed to “protect employees from being overworked and to ensure they’re properly rewarded for doing overtime.” It details regulations on maximum work hours and overtime pay.
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SDG 11: Sustainable Cities and Communities
The article addresses issues of urban planning and transportation. It highlights the government’s encouragement of cycling to “enhance urban air quality” but notes the lack of infrastructure like bike racks. It also discusses the increase in car and motorcycle commuters resulting from changes in work shifts, impacting urban pollution.
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SDG 12: Responsible Consumption and Production
The policy requiring “at least 60 percent of the components used in wind-farm projects be procured locally” is a direct example of a production policy with unintended negative consequences. The EU’s promotion of biodiesel, leading to increased palm oil demand and subsequent “ecological catastrophe in Southeast Asia,” also falls under this goal.
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SDG 13: Climate Action
The core theme of many policies discussed is climate change mitigation. The EU’s biodiesel policy was explicitly designed to “mitigate climate change,” and Taiwan’s push for renewables and efforts to lower the “transportation sector’s carbon emissions” are direct actions related to this goal.
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SDG 15: Life on Land
The article details how soil pollution regulations inadvertently lead developers to choose “greenfield plots” over contaminated brownfield sites. This results in the loss of valuable land that should be “preserved for agriculture or for the ecosystem services they provide.” It explicitly states that “Taiwan is losing farmland at a rate of 3,000 to 4,000 hectares per year.”
Specific Targets and Indicators
2. What specific targets under those SDGs can be identified based on the article’s content?
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Target 7.2: By 2030, increase substantially the share of renewable energy in the global energy mix.
This target is directly relevant to the article’s discussion of Taiwan’s struggle to “switch over to renewables and decarbonize its grid.” The problems with the local procurement rules for wind farms, which were “choking offshore wind,” highlight the challenges in meeting this target.
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Target 8.8: Protect labour rights and promote safe and secure working environments for all workers.
The amendments to the Labor Standards Act, which limit work to “not more than 12 hours in a single day” and cap overtime at “46 hours per month,” are direct policy actions aimed at achieving this target by protecting employees from overwork.
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Target 11.3: By 2030, enhance inclusive and sustainable urbanization and capacity for participatory, integrated and sustainable human settlement planning and management in all countries.
The issue of developers avoiding brownfield sites due to soil pollution laws and instead using greenfield plots relates to sustainable land-use planning. The article notes this leads to the loss of farmland and land needed for ecosystem services like “mitigating flood risk.”
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Target 11.6: By 2030, reduce the adverse per capita environmental impact of cities, including by paying special attention to air quality and municipal and other waste management.
The article connects government policies to urban environmental quality. It mentions encouraging cycling to “enhance urban air quality” and raises concerns that changes in labor laws could lead to “more commuters on the roads, and consequently greater carbon emissions as well as air and noise pollution.”
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Target 12.4: By 2020, achieve the environmentally sound management of chemicals and all wastes throughout their life cycle… and significantly reduce their release to air, water and soil in order to minimize their adverse impacts on human health and the environment.
The Soil and Groundwater Pollution Remediation Act is a policy directly aimed at this target. The article explains that the act requires assessments measuring “arsenic, cadmium, copper, mercury and other heavy metals, as well as petroleum hydrocarbons, volatile organic compounds, solvents and pesticides” in the soil.
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Target 15.3: By 2030, combat desertification, restore degraded land and soil, including land affected by desertification, drought and floods, and strive to achieve a land degradation-neutral world.
This target is addressed by the discussion of soil pollution. The regulations, intended to manage polluted land, are having the unintended effect of discouraging the remediation and use of brownfield sites, thus hindering the restoration of degraded land.
3. Are there any indicators mentioned or implied in the article that can be used to measure progress towards the identified targets?
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Rate of Farmland Loss
The article provides a direct quantitative indicator for land degradation by stating, “Taiwan is losing farmland at a rate of 3,000 to 4,000 hectares per year.” This can be used to measure progress (or lack thereof) towards Target 15.3.
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Commuter Transportation Mode Share
The article cites data from the Ministry of Transportation and Communications: “43.7 percent of respondents had used a motorcycle the day before they were surveyed, while 26.6 percent had traveled by car.” This data serves as an indicator for transportation patterns and their associated carbon emissions, relevant to Target 11.6.
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Maximum Working Hours and Overtime Limits
The specific legal limits mentioned—”not more than 12 hours in a single day” and overtime not exceeding “46 hours per month”—are direct indicators used to measure compliance with labor laws and progress towards Target 8.8.
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Soil Contaminant Levels
The article mentions that soil pollution assessments measure specific substances like “arsenic, cadmium, copper, mercury and other heavy metals, as well as petroleum hydrocarbons, volatile organic compounds, solvents and pesticides.” The concentration levels of these pollutants are direct indicators of soil quality, relevant to Target 12.4.
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Share of Renewable Energy Components Procured Locally
The policy requiring “at least 60 percent of the components used in wind-farm projects be procured locally” is a specific, measurable indicator related to production patterns (SDG 12) and the implementation of clean energy projects (SDG 7).
Summary Table of SDGs, Targets, and Indicators
SDGs | Targets | Indicators |
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SDG 7: Affordable and Clean Energy | 7.2: Increase substantially the share of renewable energy in the global energy mix. | The article implies progress is measured by the successful implementation and expansion of renewable energy sources like offshore wind farms. |
SDG 8: Decent Work and Economic Growth | 8.8: Protect labour rights and promote safe and secure working environments. | Maximum daily working hours (12 hours/day); Maximum monthly overtime (46 hours/month); Frequency of labor inspections. |
SDG 11: Sustainable Cities and Communities | 11.3: Enhance inclusive and sustainable urbanization and land-use planning. | The ratio of development on greenfield plots versus remediated brownfield sites. |
SDG 11: Sustainable Cities and Communities | 11.6: Reduce the adverse per capita environmental impact of cities, including air quality. | Percentage of commuters using motorcycles (43.7%) and cars (26.6%); Levels of urban air and noise pollution; Carbon emissions from the transportation sector. |
SDG 12: Responsible Consumption and Production | 12.4: Achieve the environmentally sound management of chemicals and all wastes… and reduce their release to… soil. | Measured levels of soil contaminants such as arsenic, cadmium, copper, mercury, petroleum hydrocarbons, and pesticides. |
SDG 15: Life on Land | 15.3: Combat desertification, restore degraded land and soil. | Annual rate of farmland loss (3,000 to 4,000 hectares per year). |
Source: taipeitimes.com