Securing Environmental Gains Through Environmental Law: Sustainability Covenants and Green Offsets in Australia Stuart Menzies 1. Introduction While sustainability has become a common objective of environmental statutes in many countries, few legislators have been able to implement mechanisms that ensure development is truly sustainable. Usually, environmental impact assessment (EIA) processes serve only to reduce and mitigate environmental effects – rarely does the process result in an environmental gain. The inability for sustainable outcomes to be achieved is rooted in EIA laws that are narrowly focused and fail to include incentives for proponents to undertake sustainable development. Two recent initiatives in Australia, ‘sustainability covenants’ and ‘green offsets’ represent new directions in the law relating to EIA. These initiatives fundamentally change the traditional approach to EIA and seek a greater focus on achieving sustainable development but do so in a way that is still financially, technically and operationally attractive to proponents. This paper provides an overview of the principles, legislative provisions and implementation of sustainability covenants and green offsets. These initiatives, which are part of a new framework of environmental law in Australia, may provide models for Chinese legislators. But first, a context is provided by discussing sustainability and the limitations of existing EIA law. The Move Toward Sustainability The modern manifestation of sustainability stems from the The Brundtland Report (WCED 1987) where development was defined as sustainable: ... if it meets the needs of the present without compromising the ability of future generations to meet their own needs. Sustainable development is development that improves the total quality of life, both now and in the future, in a way that maintains the ecological processes on which life depends (COAG 1992). Sustainability is a situation where environmental, economic and community needs are simultaneously met. Sustainability is premised on the integration of economic and environmental processes in decision-making. In addition, decision-makers must adopt a long-term rather than short-term view (CGA 1992: 6). In the Australian National Strategy for Ecologically Sustainable Development (CGA 1992), the objectives of sustainability are: • to enhance individual and community well-being and welfare by following a path of economic development that safeguards the welfare of future generations; • to provide for equity within and between generations; and • to protect biological diversity and maintain essential ecological processes and life-support systems. In Australia, sustainability has increasingly become part of environmental law, usually included as an objective in various statutes and as a criterion in the exercise of decision-making power. Sustainability is a core component of the main environmental laws, including the Environment Protection and Biodiversity Conservation Act 1999 (Cth); Environment Protection Act 1970 (Vic); and Protection of the Environment Administration Act 1991 (NSW). The Limitations of Environmental Impact Assessment Despite sustainability being a legislated objective, the achievement of sustainable development ‘on the ground’ has been less than optimal. Unsustainable environmental impacts from new developments are still being allowed to occur. This is due largely to the continuance of old methods of EIA that fail to properly address sustainability issues. This is not to discredit traditional EIA that in the last 30 years has proved to be an effective process in terms of identifying the potential environmental impacts of proposals and providing information on alternatives or measures to mitigate those impacts. The EIA process does, however, have some limitations in that it: • is reactive, only responding to potential environmental effects rather than avoiding them in the first place; • is a ‘point in time’ assessment that does not enable modification over time accounting for changes in the environment changes or the activities associated with the development; • is heavily reliant on prediction and modeling of environment effects (which often prove to be inaccurate), and changes or conditions imposed on the development may be inadequate or ineffective; • goes as far as mitigating or ameliorating environmental effects, and sometimes environmental effects are avoided, but rarely is the environment improved or restored; and • focuses on a single operation on a single site. The assessment cannot deal well with multiple sites or regional areas, nor can it deal with whole business or industry sectors. For these reasons, traditional EIA processes cannot be expected to produce sustainable development outcomes. Sustainability and Improving Environmental Impact Assessment Sustainability requires a new objective be set for the assessment of new development. Instead of seeking to minimize environment impacts, the objective needs to be ensuring the development contributes positively to the environment. That is, creating a negligible environmental impact should no longer be acceptable, the development should actually lead to restoration of the environment. The new emphasis on sustainability requires a shift in EIA practice. This will mean greater attention to: • requiring development to contribute to an overall vision for sustainability; • anticipatory actions in regard to environmental protection; • adaptive techniques in environmental management; and • for new development to have a positive impact on the environment. Table 1: Differing characteristics of environmental impact assessment and sustainability assessment Characteristics Environmental Impact Assessment Sustainability Assessment Objective Minimise environmental impacts Ensure proposals contribute to sustainability Orientation Reactive Proactive Approach Preventative Restorative Assessment techniques Linear Standards Cost/Benefit Iterative/Systems-based Visionary Win/win Spatial scale Single site and environs Single, multiple, regional Focus Production/activity based Operator based Product/service life-cycle Sector based Outcomes Approval or refusal Agreement and strategy Sustainability, and its ascendency as part of government policy and community aspiration, presents a number of challenges for environmental impact assessment. These challenges include: • How can environmental assessment deal better with the maintenance and protection of environmental systems and ecological processes? • How will economic effects be better assessed and outcomes contribute more to improved ecological conditions? Two initiatives in Australia that are seeking to more properly address sustainability issues in the assessment and operation of new developments are sustainability covenants in the Sate of Victoria and green offsets in the State of New South Wales. 2. Sustainability Covenants The Concept of Sustainability Covenants A sustainability covenant is an agreement under which a person, company or group of companies undertakes: • to increase the efficiency with which resources are used to produce products or services; and • to reduce the ecological impact of those products or services and of the processes by which they are produced. Sustainability covenants engender a holistic approach to the management of the environment that considers the impacts of products and services through their entire life cycle, from production through to use and disposal. The environmental benefit achieved through sustainability covenants are far reaching, extending beyond the site of an operation. Sustainability covenants are an instrument that provides an opportunity to focus on issues such as resource inputs, environmental impacts and broad ranging business, social and environmental considerations, as opposed to a sole concentration on traditional point source environmental management. Sustainability covenants differ from permits, licences or approvals in that they include mechanisms to ensure environmental practice is improved over time based on improved knowledge, new techniques and better environmental data. Provisions for Sustainability Covenants The provisions for sustainability covenants are included in the Environmental Protection Act 1970 administered by the Victorian Environment Protection Authority (EPA). Industries That Fail to Create a Covenant Under the Act the EPA can require a ‘statement of ecological impact’. The statement assesses, in relation to each enterprise or process controlled by the member in the industry: • what resources the enterprise or process is using and in what quantities those resources are being used; and • how the resource use efficiency of the enterprise or process can be improved; and • the actual or potential ecological impacts of the enterprise or process and of the products or services produced by the enterprise or process; and • how those impacts can be reduced. In making such a requirement, the EPA may also require that the statement, or specified parts of the statement, be published publicly. In imposing a requirement on a member of an industry under this section, the Authority must impose the same requirement on each other member of the industry, unless, in any particular case, no purpose would be served in doing so. Plan to Reduce Ecological Impact Following the receipt of the statement from the industry, the EPA can require a member to: • produce a plan of proposed actions to implement the resource use efficiency improvements or ecological impact reductions identified in the statement; and • specify in the plan the key actions that are to be undertaken and the timeframes within which those actions are to be taken; and • specify in the plan resource efficiency or ecological impact reduction targets; and • specify in the plan a method for monitoring compliance with the plan (which may include the public reporting of the results of that monitoring); and • implement the plan; and • take any specified action under the plan that has not been taken. The EPA may also require the person, in relation to the enterprise, process, products or services: • to assess alternative practices and product stewardship approaches to improve the use efficiency of specified resources or to reduce any ecological impacts identified by the Authority; and • to take specified actions to meet specified resource efficiency, or ecological impact reduction, targets; and • to publicly report in a specified type of publication or forum specified information in relation to resource efficiency or ecological impact reduction; and • to undertake specified audits using an environmental auditor, and to report the results of those audits, in relation to resource efficiency or ecological impact reduction. Enforcing the Covenant The EPA may undertake audits of covenant signatories: • to provide an assessment of the ecological impact of an industry or part of an industry; • to provide an assessment of product stewardship approaches; • to determine where resource use efficiencies may be gained and where ecological impacts may be reduced. A signatory to a covenant that has been determined by the processes set out in the covenant not to be meeting one or more undertakings made by the person in entering the covenant can be required by the EPA to produce a statement that assesses, in relation to any enterprise or process controlled by the person in the industry: • what resources the enterprise or process is using and in what quantities those resources are being used; and • how the resource use efficiency of the enterprise or process can be improved; and • the actual or potential ecological impacts of the enterprise or process and of the products or services produced by the enterprise or process; and • how those impacts can be reduced. Case Study: VicSuper Sustainability Covenant In May 2003, the EPA and VicSuper signed what is understood to be the world’s first voluntary sustainability covenant. This sustainability covenant is an agreement between the EPA and VicSuper to work together to protect the environment and to contribute to a more sustainable Victoria. The covenant falls under section 49AA of the Environment Protection Act. VicSuper is a public offer superannuation fund. VicSuper manages superannuation investments on behalf of members and has approximately AUD$2b in assets. Under the covenant VicSuper agreed to: • increase the efficiency with which it uses resources to produce its products and services; • reduce the ecological and social impact of those products and services; • apply sustainability principles to internal operations, member services; and • conduct regular internal and external reporting. The vehicle through which responsibility for management of the covenant is discharged is via a steering committee. The committee is chaired by EPA and comprises one other EPA staff member and two VicSuper staff members. The steering committee undertakes to report and make recommendations on progress of the covenant to both the VicSuper Board and EPA Chairman (EPA 2003b). The covenant is interesting because it relates to a company involved in financial services, a sector of the economy not often subject to environmental assessment. It is different than a manufacturing industry that may commonly be thought of as the target of environmental law. But when the activities of an investment company are considered broadly it can have significant environmental impacts. Its influence through investment decisions on development covers the spectrum of industry, business, manufacturing, agriculture, transport, property and research, both at a domestic and international level. Improvements in the environmental performance of a financial company, particular in the guidance of its investment decisions, can have significant environmental implications. The take up of this sustainability investment style by leaders in the superannuation industry and the growing acknowledgment that the funds themselves should examine their own environmental and social impacts means that covenants with organisations such as VicSuper, in non traditional areas of environment protection and sustainability awareness, are expected to become more common. VicSuper, as a part of the financial services industry, can have a positive impact on society and the environment that reaches far beyond the impact of its own operations. Perspectives on the Operation of Sustainability Covenants At this point in time sustainability covenants are voluntary. In the short-term companies or industry sectors that currently have a good environment record are the most likely to submit themselves to the process. Until the time that the EPA begins to invoke the provisions of the Act whereby it can compulsorily require a company or industry sector to enter into a covenant arrangement coverage of sustainability covenants will be limited. Despite this, the provisions that enable groups of companies or entire industry sectors to enter into sustainability covenants means that the breadth of reforms can be much greater as compared to the EPA having to deal with a large number of companies on an individual basis. The work required to prepare and execute a sustainability covenant is significant - they are not simple documents. This may be a barrier to the implementation of sustainability covenants, however, as more are developed there should develop an expertise in their preparation and shorter timelines in their preparation. Covenants are active documents and require sufficient time and financial resources be dedicated to the monitoring and auditing requirements that will ensure that signatories meet the commitments to which they agreed upon signing. Many Victorian businesses have started a move towards sustainability and sustainability covenants have potential to provide many benefits for organisations that show environmental commitment and give this statutory weight. These benefits include: • empowerment of an industry to drive and shape its own environmental agenda in consultation with government and the broader community; • reduced potential for restrictions imposed by regulation; • improved long term sustainability and increased profitability of companies and industries; • opportunity for competitive advantage through product and service differentiation on the basis of environmental characteristics; • potential use of a covenant to overcome environmentally based trade barriers; and • statutory recognition of environmental leadership in efforts to achieve resource use efficiencies and to reduce the ecological impacts of commercial activities. 3. Green Offsets The Concept of Green Offsets Green offset schemes seek to ensure that there is a net environmental improvement as a result of development. Any environmental impact generated by a development must first be addressed on-site, but the scheme then requires any remaining impact to be offset by action taken off-site. Green offsets are based on the understanding that most developments will have at least some impact on the environment, even after all cost effective prevention and mitigation measures are used. Green offsets are designed to address the problem of ‘the law of diminishing returns’ where the cost of reducing an environmental impact increases dramatically as a zero additional impact is approached. Stricter controls can increase the cost of development dramatically but may only provide limited gains for the environment. The financial cost of reducing the remedial environmental impact onsite could ‘purchase’ a greater environmental benefit off-site. For example, a proposed factory may emit a certain amount of carbon dioxide contributing to the enhanced greenhouse effect. This impact could be offset by planting trees sufficient to absorb the greenhouse gases, however, the factory site may be limited in area with insufficient space to plant enough trees. The green offset scheme provides a legal mechanism for the on-site impacts to be offset at another location. The ‘receiving area’ – in this case a tree plantation – could even receive funding from many factories and undertake the tree planting and maintenance at a lower per unit cost than if each individual factory undertook the work. With an addition ‘precautionary ratio’ a greater number of trees are be planted than are required to offset the total level of emissions, thus making a positive environmental gain. Green offset schemes provide a sensible and practical alternative that enables the same environmental benefit to be achieved off-site which would have otherwise cost more to achieve on-site. The scheme recognises that although zero environmental impact from a new development is a good goal, it is not always practical. Although the individual impacts are small, in total they can lead to significant cumulative degradation. Green offsets are targeted primarily at dealing with the indivdually small, but collectively significant, impacts of development. If a developer can demonstrate that proposed on-site impact mitigation systems will not increase environmental impact, no offsets is required. Green offsets are not a means by which developers can buy their way out of their environmental obligations. Developers are required to meet standard regulatory and planning requirements, and adopt all cost effective on-site measures to minimise environmental impacts. Under this scheme a development proponent can only offset a ‘residual’ impact (such as predicted increase in pollutant load), by undertaking abatement actions, or funding others do to so. The use of offsets potentially allows developers to achieve the goal of net environmental improvement in a more flexible and cost-effective manner. Importantly it enables existing environmental issues in the local area to be addressed. Reducing the development costs to achieve this goal allows new developments to contribute to the goal of sustainability. Provisions for Green Offsets The proposal for green offsets is currently being developed in the Australian State of New South Wales. Environmental offset schemes cover environmental impacts related to water, air and land pollution, land degradation and ecosystem destruction. Consequently, the provisions will be required to operate across a number of statutes including the Environmental Planning and Assessment Act, the Native Vegetation Conservation Act, the National Parks and Wildlife Act, the Fisheries Management Act and State Environmental Planning Policy (PENGOS 2002). A number of requirements The provisions are being designed to require that offsets are: • enduring - they must offset the impact of the development for the period that the impact occurs; • quantifiable - the impacts and benefits must be reliably estimated; • targeted - they must offset the impacts on a 'like for like' basis, e.g. a measure that reduces nitrogen must be used to offset nitrogen; • located appropriately - they must offset the impact in the same area; • supplementary - they must be beyond existing requirements and not already being funded under another scheme; and • enforceable - they must be enforceable through development consent conditions, licence conditions, covenants or a contract. Offsets may be enforced through development consent conditions, licence conditions, covenants or a contract. The scheme has been drafted specifically to target new developments, and is not designed to act retrospectively (for example, by imposing conditions on existing licences). To implement the offset framework, relevant consent and regulatory processes will be amended to include offset requirements. Under the green offsets framework, all offsets will be based on a system of accountable administration. Safeguards such as advisory panels will ensure offset schemes operate transparently, so that scheme participants and members of the community can see that the offsets principles have been put into practice. Some offset schemes will include payments of contributions into offset funds. In these cases, scheme rules will ensure that contributions paid into offset funds are isolated from government revenue, and only spent on the offset scheme for which the contribution was provided. In many cases, the most practical approach will be for developers to contribute to a combined offset fund (rather than designing, implementing, maintaining and reporting on their own offset works). Pooling contributions will also allow larger cost-effective offset works programs to be put in place – streamlining overall supervision, public reporting and compliance costs. Each scheme will be required to produce a public annual report, including an offset balance sheet. On one side of the balance sheet will be information about monies received and environmental ‘credit’ granted to developers. The other side of the balance sheet would list monies expended, details of the environmental works and the estimates of the environmental impacts reduced. Each scheme manager will be accountable in the annual report to ensure that the environmental benefits achieved exceed the offset credits granted. A scheme manager could receive the payments from developers who choose to make a financial contribution, saving developers the cost of managing offset pollution reduction activities. The scheme manager would ensure that: • the offset actions reduce more pollution than is being emitted by the developments at any point in time; • the contribution schedule reflects the costs and risks involved in achieving reductions in pollution; • the money is spent in the most effective way and that programs are implemented where they are most needed; and • each offset is appropriate and is well maintained throughout its life. Case Study: South Creek Catchment The Pollution Problem in South Creek South Creek is a catchment area in Western Sydney that has significant environmental problems. There are a range of sources of pollution in the catchment. Water quality in the South Creek catchment is severely impacted by human activities, including agriculture, sewage discharges and overflows and urban stormwater run-off. There are five sewage treatment plants licensed by the EPA in the South Creek catchment (these are usually only licensed for wet weather discharge). Around 20 other activities are licensed for discharges to waterways, including the Rouse Hill development area, an abattoir, dairies, swimming pools, golf clubs and farm production. Opportunities for Improvement Large reductions in pollutant loads have already been made at point sources in the South Creek catchment. Further on-site reductions are increasingly costly, especially to further reduce nitrogen. It is possible, but costly, for sewage treatment plants to under-take even higher levels of treatment or effluent reuse. Eliminating effluent discharges through reuse would also result in a more natural flow regime for South Creek. It would, however, impact on other uses of the creek, especially irrigation. It is important to reduce diffuse sources of pollution, because: • they now account for the majority of pollutant loads in many areas - for example, diffuse sources contribute 80 percent of phosphorus and 90 percent of nitrogen pollution in the catchment; and • significant improvements have already been made to point sources - for example, Sydney Water has reduced phosphorus emissions by 75% and nitrogen emissions by 50% over the past four years in Western Sydney and further reductions are costly. It is currently difficult to quantify pollutant loads from diffuse sources of pollution due to the complexity of environmental factors involved. However, the benefits of addressing diffuse-source pollution are real, significant and cheaper to achieve than further point source reductions. For example, the cost of upgrading a sewage treatment plant to reduce phosphorus discharge is in the order of $10,000 per kilogram. But the cost of reducing phosphorus from some diffuse sources in the South Creek catchment has been estimated at up to $200 per kilogram. The sewage treatment plant currently emits 1,000 kg of phosphorus each year. Residential growth is expected to increase these emissions by 100 kg over the next few years. The licensee proposes to reduce emissions off-site to ensure it can continue to meet its load limit. The licensee suggests that there are opportunities to reduce pollution from a number of market gardens, close to the plant, which have significant phosphorus emissions. The EPA has set a precautionary ratio of 3:1, so the off-site measures need to reduce phosphorus emissions by at least 300 kg per year to meet the load limit. How the Scheme Works The licensee funds small dams at the bottom of the farms to intercept run-off from irrigation and light rain. The measures are estimated to reduce phosphorus loads by around 300 kg per year at a total cost of around $90,000. The landholders agree to maintain the dams and ensure drainage is directed to them. They also commit to paying the cost of relocating irrigation equipment and will bear the cost of production foregone. In contrast, upgrading the plant to reduce emissions is estimated to cost around $2.25m. The licensee will also save load-based licence fees of around $1,500 per year. The offset provides funds to a group of market gardeners who currently have limited technical or financial capacity to address pollution, and serves as a model for other farmers. Licensees have the option of providing funds to the EPA to generate credits or of proposing individual off-site actions they would like to implement themselves. The EPA issues credits and approves actions to reduce pollution throughout the catchment. Works to reduce nutrients is implemented directly by EPA licensees or through existing programs such as the Department of Land and Water Conservation’s land degradation program in South Creek. The scheme initially focused on loads of phosphorus and nitrogen. However, other environmental benefits can also be recognised under the scheme. For example, it is likely that some diffuse pollution reduction works (such as restoring river banks) have broad ecosystem benefits beyond nutrient export reduction. The scheme could be expanded in future to address a wider range of environmental outcomes. Additional measures for the scheme include: • reducing nutrients in run-off from market gardens - by modifying fertiliser use or installing measures for run-off detention such as dams, grassed drains, diversion banks and filter strips • revegetating areas near rivers to protect river banks and to buffer and filter pollution going into the river • sediment trapping pits and wetlands in urban areas, and • reducing nutrients in run-off from grazing lands - through changing stocking rates and fertiliser use, irrigation management, dams and buffer strips. Perspectives on the Operation of Green Offsets Concerns with the green offsets scheme include: • green offsets are merely be another impost on new development which is already burdened by a large array of taxes, levies and charges; • this impost has no relationship with the actual environmental impacts of an individual development; • the impost inequitably imposes a liability on new development for addressing the past environmental mistakes of others whereas other sectors are not subject to any liability; • the impost is highly likely to biased against large development due to the inability to assess when environmental controls are cost effective; • no recognition or credit is provided of remediation work done on the owner’s own site or their other sites. Green offsets are not simply an additional impost on developers. It is a targeted and justified scheme to enable development to be able to proceed without impacting on the environment. Development is not required to provide improvements any greater than the impacts they create. While the benefit is provided off-site it is related to the individual development in that a ‘like-for-like’ improvement is required. Offsite works are required to be located within the local area which adds a level of accountability and recognises that all developments have some degree of impact on the surrounding environment. The scheme applies to new development as it would not only be unfair but also extremely complex to apply green offsets retrospectively (sustainability covenants are a good option in this regard). The scheme is not biased against large developments – it is biased against large environmental impacts. A development that can minimise its on-site environmental impacts minimises any requirement for a green offset. The scheme does place an impost on new development for addressing past environmental mistakes but this is the reality of finding solutions to improve the environment that has become degraded. The imposts are not unreasonable as they are measured on the basis of the impact of the new development, not the state of degradation of the current environment, although the former is used to assist the latter. A precautionary ratio is included for green offset improvements reflecting the degree of risk of compensatory works. 4. Insights for China This paper has provided a general overview of two initiatives for sustainable development through new environmental laws – sustainability covenants and green offset schemes. Before attempting to apply these techniques in China, consideration should, of course, be given to the different legal, environmental, economic and political systems in each country. However, these initiatives may provide some inspiration and ideas that could be pursued to the benefit of the Chinese environment. Four key issues, relevant to China, emerge from consideration of sustainability covenants and green offsets: • Sustainability – increasingly environmental law, and in particular processes for environmental impact assessment, will have to deal with sustainability issues. This means no longer accepting environmental impacts as an inevitable cost of development. The cumulative impact of environmental damage is unsustainable in the long term. • Attitudinal Change – sustainability reorientates thinking about environmental management and planning. A change is not just required in environmental legislation and regulation but in the thinking of people that administer it. Dealing with strategies environmental issues, and seeking solutions to them, requires creativity, vision and lateral thinking. • New Economic Instruments – traditional ‘command and control’ environmental regulations will not contribute to achieving sustainability. While some for of regulation is required to control poor environmental performers new economic-based instruments are necessary to encourage and inspire development that is sustainable. • Reality Check – Environmental management frameworks and the laws that are part of them need to deal with the reality that the environment is already degraded and in some areas under extreme environmental stress. Public funding is unlikely to be provided at a scale suitable to address these problems (or, more importantly address the underlying structural causes). Mechanisms are required that use economic development to provide environmental solutions and deal with the financial and ecological reality society is currently faced with. 5. Conclusion Sustainability requires development to account for its environmental impacts. This requires new thinking about how environmental laws are structured and administered. Regulatory frameworks that are proactive in seeking environmental restoration and do this through economically astute mechanisms are more likely to be successful. For a long time mediocrity has been acceptable in environmental impact assessment. The result has been a continued running down of the state of the environment. Schemes like sustainability covenants and green offsets are initiatives that seek to reverse this trend. References Alexandra, J. (2003) Sydney Catchments Assessment: Neutral or Beneficial Effect Assessment. Alexandra and Associates, Eltham. Natural Resource Management Ministerial Council (2001) National Framework for the Management and Monitoring of Australia’s Native Vegetation. Department of Environment and Heritage, Canberra. Nature Conservation Council (2001) NCC Submission on the “Offsets, Salinity and Native Vegetation” Discussion Paper (Unpublished). New South Wales Government (2002) Green Offsets for Sustainable Development Concept Paper. New South Wales Environment Protection Authority, Sydney. Peak Environmental Non-Government Organisations (2002) Submission on Green Offsets for Sustainable Development Concept Paper. PENGOS, Sydney. Property Council of Australia (2002) Green Offsets Concept Paper – Submission to The NSW Environment Protection Authority. Property Council of Australia, Sydney. 通过环境法来确保环境利益“澳大利亚的可持续合同和绿色补偿” Stuart Menzies 1. 引言 1． 1 向可持续方向发展 1． 2 环境影响评估的限制 1．3 可持续和环境影响评估的改善 2． 可持续合同 2． 1 可持续合同的概念 2． 2 可持续合同的条款 2．3 案例研究 维克的可持续合同 2．4 有关可持续合同实施的看法 3． 绿色补偿 3． 1 绿色补偿的概念 3．2 绿色补偿的条款 3．3 案例研究 南克里克的储水池 3．4 实施绿色补偿的看法 4． 观察中国 5. 结论