Critics call for personnel changes and ethical accountability. Members of
working groups and task forces play multiple roles in Taiwan’s society, which
may influence their integrity and professionalism. Furthermore, environmental
laws, regulations, and executive orders may be ‘as numerous as the hairs of the
cow’. For instance, since the approval of the Environmental Impact
Assessment (EIA) Law in 1995, there have been at least 69 supplementary
regulations and executive orders. The continuous process of revision and
amendment confuses bureaucrats as well as enterprises. Most members of the
EIA review committees are engineers who focus only on the scientific
treatment of environmental problems. Review committees lack members with
broad, society-wide perspectives.^82
Our interviews indicated that the fragmentation of the bureaucratic
framework causes major problems of policy implementation. The NCSD is
mainly an advisory body, with the EPA serving as its agent for policy
coordination and integration. However, since the EPA is a weak and small
institution in Taiwan’s bureaucracy, it has no power to ‘order’ other
institutions to implement policy. Moreover, many issues of biodiversity
conservation are under the jurisdiction of other governmental agencies. The
COA is responsible for biodiversity preservation, and the Ministry of Interior
is in charge of national parks and land planning. Furthermore, the EPA fails to
manage the ‘sources’ of environmental deterioration. Its focus is at the ‘end-
of-the-pipe’, that is, it initiates solutions or treatment when the pollution event
has already caused severe environmental damages.^83 These tasks of
remediation and mitigation are very detailed and time consuming. However,
the budget of the EPA is among the lowest of the central ministries. In reality,
the administrative level of EPA is lower than a normal ministry.
Devolution to Sub-national Governments
There is a large gap between central planning agencies and local
implementation bodies in Taiwan. For instance, EIA review at the central level
is conducted in a relatively disinterested fashion. Local governments, beset by
frequent elections and economic crises, are in general pro-development. The
Self-Governance Law for counties and cities stresses autonomy of the local
government; it constrains supervision capacities of the central EPA toward
local EPAs. The central EPA may refuse to provide financial assistance to the
local EPA if the latter fails to implement environmental regulations. However,
without financial support, the local EPA has a good excuse to remain idle. This
creates a downward cycle of environmental deterioration.^84
Another explanation for a weak local capacity in implementing biodiversity
conservation is the worsening fiscal situation of local governments in Taiwan.
Some local governments have debts, equivalent to millions of US dollars. In
92 Governance of biodiversity conservation in China and Taiwan