not directly part of a national bureaucratic agency. Also, only one social
association could register in the same area for a specific activity, such as
environmental protection. Overall, the 1998 regulations are a clear example
of state corporatism: the inclusion of social group activity within the
administrative purview of the state. Schwartz notes: ‘As a result, NGOs tread
carefully, avoiding strong criticism of government environmental protection
failures’.^29
Altogether, the 1998 regulations have had a dampening effect on the
development of social associations in China, especially those with no friends
in the bureaucracy. The crackdown on the Falungong in 1999 had an even
more chilling effect. As the registration requirements do not yet comprehend
foreign NGOs operating in China, their activities take place under an
administrative cloud.^30 The requirement that a new association find a sponsor
in the state bureaucracy is a daunting challenge, because few officials are
eager to take the risk of becoming responsible for events and activities
performed by an NGO. Moreover, the refusal of one agency to serve as a
sponsor typically influences other potential sponsors. Finally, few voluntary
associations have the financial means to meet the state requirements. There is
no sign that registration requirements will loosen soon. In fact, in response to
the ‘color revolutions’ in countries of the former Soviet Union, NGOs (and
particularly those with international headquarters and local organizations
receiving funding from abroad) are under increased scrutiny from the regime.^31
Our interviews with social association representatives revealed, however,
that while the registration requirements were strict, they had not prevented the
formation of social groups in the area of environmental protection. Saich
comments: ‘Broadly speaking, those groups working in the field of education
and environment have been permitted or have negotiated relatively free
space’.^32 Approximately half of the nearly 50 organizations we visited were not
registered with the government, yet had operated without mishap. Some were
INGOs which operated under a memoranda of agreement with state agencies;
others had sponsors in the elite at the national or provincial level. When we
asked the indigenous unregistered social associations what impact operating
outside the registration system had, the leader of a typical NGO said: ‘There
are two effects. First, it influences our finances, as we cannot receive foreign
contributions [or even set up bank accounts]. Second, it influences the legality
of our operations’.^33 Both inhibit organizational growth and contribute
uncertainty to associational life. Nevertheless, we estimate that a very large
number of environmental groups, and in particular those at the grassroots
levels in cities and counties, operate in such a situation. They are tolerated by
the state, which seems to recognize the value of civic associations. As
Secretary General of the State Council, Luo Gan, declared in 1998: ‘Govern-
ment has taken up the management of many affairs which it should not have
172 Governance of biodiversity conservation in China and Taiwan