Still accurate to call it ‘Campaign-Style’? The standardization of campaign-style governance in China's environmental management, with the water Cleanup Project in the Huai River Basin as a case study Open Access

Like many other developing countries, China faces significant environmental challenges due to its rapid economic development. Despite the Central Government's efforts to establish strict environmental laws and policies for pursuing sustainable development, China is relatively weak in implementing and enforcing them nationwide. This weakness can be attributed to China's vast size, limited administrative resources, and fragmented institutional arrangements (Lieberthal & Lampton, 1992, 2018; Biddulph et al., 2012; Kostka & Hobbs, 2013). Since Xi Jinping became president in 2012, it is noticeable that China's Central Government has taken a more proactive role in addressing the implementation of, compliance with, and enforcement difficulties in environmental regulation. Over the past decade, a distinctive approach known as ‘campaign-style governance’ (CSG) has been developed and applied, attracting increasing attention from scholars and policymakers.

CSG represents a non-conventional governance approach that operates differently from conventional governance approaches. When conventional governance approaches are adopted, authorities must operate within institutionalized arrangements – formal rules that define decision-making powers, procedural requirements, and resource allocation at each administrative level. In contrast, CSG allows authorities to break through these institutional constraints under the strong sponsorship of the Central Government – for instance, authorities can receive additional administrative resources (such as personnel and funds) through ad hoc mobilization and delegated powers from higher-level authorities to achieve specific policy objectives (Andreas, 2007; Tang, 2009; Feng, 2011; Liu et al., 2015). This distinctive capacity to transcend institutional constraints makes CSG particularly effective in environmental management, where the application of conventional governance approaches often proves inadequate (Zhao et al., 2020b).

However, this capacity of CSG, which distinguishes it from conventional governance approaches, has sparked significant criticism and concern. Researchers question whether applying CSG can meet the standards of good governance – a process where decisions are made and implemented following clear, consistent rules, ensuring transparency, accountability, and reliability over time (Yu, 2018). When authorities apply CSG to bypass the constraints of existing institutional arrangements, their decisions and actions often appear unpredictable and inconsistent to the public. This can erode public trust in the government and its institutions, raising doubts about their legitimacy and effectiveness (Rothstein, 2012).

To address these concerns, the Central Government has promoted reforms over the past decade to standardize CSG. This standardization involves establishing formalized procedures and guidelines to make the application of CSG more predictable and consistent across regions or contexts. The goal is to encourage the public to view CSG as a more reliable governance approach by making its application more consistent and easier to anticipate.

However, this standardization effort raises a series of interrelated questions regarding CSG's distinctive capacity and future development. The primary concern is whether these standardization efforts have already set CSG on a path toward institutionalization – a process where the formalized procedures and guidelines created through standardization start to evolve into structured operational frameworks, integrating what were once temporary and ad hoc measures into more stable and enduring elements of the broader institutional arrangements. More fundamentally, if CSG is indeed undergoing institutionalization, is it gradually losing its distinctive capacity to overcome institutional constraints, thereby becoming less unconventional and more aligned with conventional governance approaches?

These interrelated questions about the relationship between standardization and institutionalization of CSG, though crucial for understanding its future development, remain largely unexplored in current research. This paper seeks to address these questions through a case study of the Cleanup Project in the Huai River Basin. Section 2 reviews the literature on CSG in China's environmental management, focusing on concerns and criticisms about its application. Section 3 introduces the method and case selection, explaining why the Cleanup Project was chosen as a representative case for studying the standardization of CSG and detailing the case study process. Section 4 investigates the three successive periods of the Cleanup project to identify the two major revisions of CSG. Section 5 compares these two revisions, analyzing whether the standardization of CSG has induced its institutionalization and discussing the associated consequences. The final section summarizes the findings and reflects on their implications for the future of CSG in China's environmental management.

Before proceeding with the analysis, it is essential to distinguish between two types of changes: the refinement of conventional governance approaches and the institutionalization of non-conventional governance approaches. The former refers to adjustments within existing institutional frameworks, such as environmental agencies refining their monitoring procedures, while the latter describes how non-conventional approaches like CSG might evolve into formal institutional arrangements, potentially losing their distinctive capacity to bypass institutional constraints. This distinction highlights our central concern about CSG's standardization: whether making it more predictable and consistent through standardization would inevitably lead to its institutionalization, thereby compromising the distinctive capacity it inherently possesses as a non-conventional governance approach.

CSG has been employed in various countries, such as the United States and Canada, to address specific regulatory issues. While CSG is not unique to China and did not originate there, its application in China is a major focus of existing literature. Van Rooij summarized the essential characteristics and multiple influences of CSG from an environmental management and comparative perspective (Van Rooij, 2002, 2006). Other researchers have discussed the performance of CSG since 2012, either in the broad context of China's environmental management (Liu et al., 2015; Kostka & Zhang, 2018; Van Der Kamp, 2021) or in specific fields such as air pollution control (Meng et al., 2019; Wang & Wang, 2020), environmental protection interviews (Zhao et al., 2020b), and Central environmental protection inspection (Jia & Chen, 2019). Beyond environmental management, CSG has also demonstrated its effectiveness in other domains, including public health and disaster relief (Cai et al., 2022; Zeitz et al., 2023).

Although these studies have not formulated a uniform definition of CSG to cover all its dimensions, there is a consensus on two fundamental aspects that make CSG a non-conventional governance approach. The first aspect is resource reallocation: the Central Government can help relevant authorities accelerate resource gathering by announcing specific projects with clear targets in designated regions (Van Rooij, 2002). The second is power redistribution: the Central Government can temporarily grant special authority to local governments, giving them the power to coordinate and use these reallocated resources across different administrative levels and departments. These two aspects together enable authorities to overcome existing institutional constraints when addressing pressing issues.

However, this distinctive capacity of CSG to break through institutional constraints creates significant challenges throughout the governance process. At the planning stage, the Central Government faces difficulties in establishing clear guidelines for when and how to announce special projects in designated regions and apply CSG, as these decisions typically arise from urgent circumstances requiring immediate action. When the public cannot see that these decisions follow established criteria and procedures, they may view such decision-making as contradicting the basic requirements of good governance for predictable and consistent decision-making processes. During implementation, authorities face similar challenges in utilizing their reallocated powers and resources. Without clear operational guidelines, relevant authorities often exercise broad discretion in implementing policies and enforcing laws. Their actions tend to be accompanied by excessive measures, as officials prioritize achieving quick compliance over evaluating whether these measures are reasonable and necessary (Chen et al., 2002; Peerenboom, 2002; Mathews, 2017). The supervision stage presents even greater challenges. First, as CSG allows relevant authorities to break through existing institutional constraints, the Central Government lacks effective supervision mechanisms to supervise how these authorities exercise their expanded resources and powers. This deficiency makes it particularly difficult to detect when such resources and powers are misused for short-term gains or personal promotion (Zhao et al., 2020a; Wang, 2021). Moreover, even when such misuse is discovered, the Central Government faces a difficult choice: halting ongoing projects wastes invested efforts, while continuing them may maintain current results but fails to achieve favorable long-term outcomes (Martilla & James, 1977; Zhou, 2012b). Second, from the public's perspective, when observing authorities exercising broad discretion in policy implementation and law enforcement, questions arise about whether the adopted measures are necessary for achieving corresponding goals or are excessively harsh. These concerns about proportionality, combined with the Central Government's limited supervisory capacity, intensify public doubts about whether applying CSG aligns with the basic requirements of good governance (Trevaskes, 2007, 2010).

Existing research has thoroughly examined why CSG, as a non-conventional governance approach, generates various challenges and how these challenges impact its application. However, an important development remains underexplored: the Central Government's efforts over the past decade to address these challenges by standardizing CSG. The following section explains why the Cleanup Project in the Huai River Basin serves as an ideal case for studying this development and outlines the methods used to analyze how standardization has progressed in this project.

To examine how the standardization of CSG has progressed and its implications, this paper conducts a longitudinal case study of the Comprehensive Water Cleanup Project (hereafter the Cleanup Project) in the Huai River Basin (hereafter the Huai) from 1995 to 2020. This case is chosen for two primary reasons.

First, the Cleanup Project marks the beginning of CSG in China's environmental management, making it a foundational example for understanding the evolution of this governance approach (Liu, 2004). Following the Cleanup Project, CSG has been applying environmental initiatives across China. For instance, the ‘Battle for Blue Skies’ campaign launched in 2018 aimed to reduce air pollution in major Chinese cities by enforcing stricter emission standards, shutting down high-polluting factories, and promoting cleaner energy sources (Shen & Ahlers, 2019). Similarly, the Tai Lake Basin saw CSG tackle severe water pollution by shutting down polluting industries, improving sewage treatment facilities, and promoting ecological restoration projects (Dai 2019). These subsequent applications demonstrate how the principles and measures developed in the Cleanup Project have been adapted and refined to address diverse environmental challenges, making it a critical case for tracing the origins and development trajectory of CSG (Shen & Ahlers, 2019).

Second, the Cleanup Project's 25-year duration provides a unique opportunity to understand how the standardization of CSG interacts with its institutionalization. This extended period allows us to identify three key developments that illustrate this relationship: (1) the gradual introduction of formal guidelines and procedures for applying CSG through standardization, (2) the potential transformation of these standardized practices into permanent institutional arrangements, and (3) the ways these changes have influenced CSG's distinctive capacity to break through institutional constraints and address urgent challenges.

The method for this case study combines archival research and fieldwork. Archival materials include government documents, statistical yearbooks, and official websites. Fieldwork consists of eighteen in-depth interviews conducted with researchers from Chinese universities, environmental protection practitioners, and government officials across different administrative levels. To ensure confidentiality, interviewees are identified by year and interview number rather than by name. Additional interview insights are available in the Supplementary Material. This comprehensive approach allows for a detailed examination of changes in CSG application over time and provides a solid foundation for understanding the broader implications of standardizing CSG.

The Huai River Basin, located between the Yangtze River Basin and the Yellow River Basin in eastern China, is the country's sixth-largest river basin. It has the highest population density in China and is notorious for severe flooding and water pollution. Although the Chinese Central Government began addressing these issues in 1950 (State Council, 1950), its focus gradually shifted from flood prevention to water quality improvement. A severe pollution incident in 1994 triggered the launch of the Cleanup Project in Huai (Tyler, 1994).

When the Central Government launched the Cleanup Project, it marked the first application of CSG as a non-conventional governance approach. During this period, the Central Government initiated the country's first basin-wide pollution control project, requiring cooperation across multiple sectors and administrative levels (Bai & Shi, 2006). To support this project, the State Council enacted its first and, to date, only administrative regulation specifically targeting water pollution control (State Council, 1995). Additionally, a river basin management commission was established under the leadership of the Ministry of Water Resources (MWR) to enhance inter-sectoral and inter-regional cooperation. Financial support from the Central Government was also provided to facilitate the accomplishment of the project.

The ‘Zero Hour Operation’ campaign, launched on January 1, 1998, was designed to achieve the water pollution control goals outlined in the Ninth Five-Year Plan (Congress, 1996). It exemplified how CSG fundamentally deviated from conventional governance approaches. When conventional governance approaches are adopted, relevant authorities typically allow industries time to comply with new standards. In contrast, this campaign demanded immediate compliance: highly polluting factories that failed to meet wastewater discharge requirements were shut down until they met the required standards. This swift and uncompromising enforcement style demonstrated CSG's capacity to break through institutional constraints and deliver immediate results. Shortly after the campaign started, a total of 1,139 industries in four provinces along the Huai had improved their sewage treatment equipment. In January 2001, the former head of the environment department claimed that the water pollution control goals set in the Ninth Five-Year Plan had been largely achieved (Anhui Provincial Library, n.d.).

Despite these achievements, the application of CSG in Huai remained controversial. Reports indicated that many polluters only temporarily ceased discharges during periods of intensive supervision (Becker, 1999). Some small factories banded together to increase their size and evade the government's regulations on the ‘fifteen types of small factories’ (State Council, 1996), and many polluting industries continued operating illegally. Moreover, local governments often pressured officials to avoid strict enforcement due to economic concerns (Bai & Shi, 2006). As a result, by 2005, water quality in Huai remained alarmingly poor (Xia et al., 2008). This outcome prompted the Central Government to reconsider how CSG should be applied in the second period.

The year 2005 marked a turning point in debates over whether it was appropriate to apply CSG. Different government departments presented conflicting assessments: the Ministry of Ecology and Environment (MEE) highlighted CSG's success in reducing the total pollution load, while the MWR emphasized that pollution levels quickly rebounded after campaigns ended, with long-term monitoring data showing no lasting improvements in water quality (Ou & Cai, 2004; Miao, 2006). This debate intensified as critics raised additional concerns about CSG's limitations. Opponents argued that CSG was by no means an effective approach and pointed to negative results based on cost–benefit analysis (Wang, 2013). They highlighted that by May 2004, the central and local governments, together with enterprises, had invested over $9.28 billion in supporting the Cleanup Project in Huai (Ou et al., 2004). Despite these investments, costs continued to rise. Opponents contended that without addressing the root causes of pollution, this Cleanup Project could not achieve lasting improvements in water quality. Additionally, the severe penalties imposed by environmental agencies under CSG may violate administrative procedures and the principle of proportionality (Trevaskes, 2007; Van Doeveren, 2011).

Despite these concerns about CSG, the Central Government continued to use and expand it during the second period of the Cleanup Project. This expansion manifested in two ways: CSG was applied more frequently and across a wider range of regions. For instance, the practices deployed in the Huai were replicated in campaigns targeting other major waterways, such as the Liao and Hai rivers, as well as Tai, Chao, and Dianchi lakes (Li & Foster, 2008). Additionally, the application of CSG in water quality management extended to other environmental domains, including air and soil pollution control (Zhao & Ortolano, 2010). Most existing analyses interpret this expansion as the Central Government's pragmatic compromise in the face of environmental crises, as noted by interviewee no. 17-202107, who stated that CSG was still the best crisis-reactive solution to environmental issues. Interviewee no. 18-202107 remarked that the national governors chose to fully embrace CSG, as it must be a strong medicine even if it had not yet become a good one.

However, our analysis suggests that characterizing the expansion of CSG as merely a pragmatic compromise overlooks a critical development. We argue that the explosive growth of CSG after 2005 – in terms of its increased usage, broader application across various domains, and larger-scale implementation nationwide – represents the Central Government's efforts to make the application of CSG more predictable and consistent. These efforts are encapsulated in what we term the ‘campaign package restrictions,’ a strategy that involves conducting different but interrelated campaigns simultaneously to impose mutual constraints and enhance coordination.

Our analysis of these documents revealed an important shift in how CSG was applied. Of the 223 documents identified, 22 were directly related to water quality management in the Huai, while 124 addressed broader measures within national campaigns related to water quality management (including the Huai). These measures include, but are not limited to, combating water pollution, strengthening accountability mechanisms, and standardizing procedures for policy implementation and law enforcement. A notable change occurred after 2005 (i.e., the start of the second period). While campaigns in the first period focused primarily on water quality improvement and pollution reduction, the second period introduced complementary campaigns designed to make the application of CSG more predictable and consistent. After 2005, the same campaign within a single project involved a greater number of departments, and the coordination of these campaigns became more centralized and rigorous, often overseen directly by the General Office of the State Council. Key examples included the verification campaign to ensure data quality and reliability, the special rectification campaign to address specific pollution issues, and the bureaucratic personnel evaluation campaign to enhance local implementation of central directives and restrict the exercise of administrative powers. The most renowned of these was the river chiefs target allocation campaign, during which an agreement was signed by the provinces of Jiangsu, Anhui, Shandong, and Henan in conjunction with the MEE (MEE, 2005). This agreement outlined specific requirements for targets, procedures, methods, and responsibilities relating to Huai's water quality management from 2005 to 2010. Moreover, leading cadres were appointed as river chiefs to be held accountable for meeting the aforementioned requirements (Zhuang, 2020). Through this comprehensive campaign package, the Central Government developed a more structured approach to CSG application, introducing clearer guidelines to govern and supervise how local governments and environmental agencies exercise their delegated powers and manage resources under CSG.

These findings suggest that after the first period of the Cleanup Project, the Central Government not only continued but also refined CSG as a key governance approach in environmental management. Through the campaign package, which combined substantive campaigns with new procedural ones, the Central Government progressively established clearer operational guidelines for CSG, particularly by standardizing its implementation and supervision processes. While the restrictions embedded in the campaign package contributed to the standardization of CSG, coordinating multiple simultaneous campaigns demanded substantial administrative resources to ensure continuous support and oversight – a requirement that proved difficult to sustain due to budgetary constraints (Biber, 2013; Brombal, 2017). This tension between limited administrative resources and the need for robust regulation became a central issue that needed to be addressed in the third period of CSG's evolution.

While the restrictions of the campaign package contributed to the standardization of CSG, its high resource demands drove the Central Government to seek more sustainable solutions through technological innovations. One of the most significant technological improvements was the auto-monitoring system. To understand how this system supports CSG standardization, it is necessary to examine it in the context of China's environmental vertical management reform of 2016. This reform divided monitoring into two categories: water quality status monitoring and compliance monitoring. Water quality status monitoring aims to obtain an overall view of water quality in a specific area, helping to determine potential pollution and inform the formulation of long-term water quality policies and standards. Compliance monitoring aims to detect violations such as illegal emissions, serving as a preparatory step for law enforcement (Xu, 2022). Both types of monitoring can be conducted manually or through automated processes using auto-monitoring technology.

The auto-monitoring system significantly improved water quality status monitoring. Since 2015, the MEE has promoted the construction of auto-monitoring networks to enhance state performance (MEE, 2015, 2016, 2018c). A more comprehensive water quality monitoring network is expected to be completed by 2025 (Li, 2021). Unlike traditional manually operated monitoring methods, the auto-monitoring sensor automatically takes samples, collecting data every 4 h, and transmitting these data back to the monitoring station for analysis (MEE, 2017). This process provides environmental authorities with more accurate and independent information to support daily supervision. Additionally, the monitoring data for key river basins is made publicly available on an official platform, increasing transparency and allowing the public to participate more actively in water quality management (Brombal, 2017). Beyond supervision, these data are crucial for planning under CSG, enabling policymakers to track trends, set priorities, and efficiently allocate resources to key areas.

Compliance monitoring has developed differently since the deployment of the auto-monitoring system. While auto-monitoring sensors are mandatory for designated key pollutant-discharging enterprises at their emission sites, other companies face no such requirements (MEE, 2018b). This partial automation means that, unlike water quality status monitoring, which now operates primarily through off-site auto-monitoring-based surveillance, compliance monitoring still depends heavily on manual verification and on-site surveillance conducted by environmental agency personnel (MEE, 2018a). To enhance compliance monitoring in the Huai, a three-tiered monitoring framework has been developed, as noted by interviewees no. 6-202105, no. 7-202105, and no. 9-202106. Each tier serves a distinct purpose while complementing the others: Level I monitoring provides broad surveillance through unmanned aerial vehicles (UAVs). These UAVs, equipped with automatic water intake devices and sensors, enable rapid coverage of large areas. Level II focuses on specific areas of concern, using personal digital assistants (PDAs) connected to monitoring centers. This connection allows for immediate data analysis and reporting, helping authorities respond quickly to emerging issues. Level III delivers a detailed analysis of targeted locations. Expert teams conduct thorough investigations of complex environmental issues, providing the most precise and comprehensive assessments. Together, this three-tiered monitoring framework not only enhances the capacity of environmental authorities to detect and address violations effectively but also optimizes the allocation of administrative resources by matching monitoring intensity to specific needs.

Another important innovation was the Smart Administrative Decision-Making Assistant System (SADAS) for environmental enforcement. According to interviewee no. 09-202106, SADAS transformed traditionally discretionary administrative processes into a structured, evidence-based framework through four interconnected modules, each supported by its own database. The first module, the Administrative Discretionary Module, classifies the seriousness of individual violations and their corresponding effects into five levels (minor, normal, relatively serious, serious, and very serious) based on legal requirements. This assessment provides the initial input for making an administrative decision. The second and third modules, the Registration, Record, and Resource Module and the Judicial Cases Module provide benchmarks for other relevant factors in making decisions, such as regional differences and individual criminal records. The fourth module, the Administrative Enforcement Workflow Module, directs the operational processes of SADAS in accordance with the Guiding Opinions on Further Regulating the Exercise of Discretionary Powers in Environmental Administrative Penalties (MEE, 2019).

SADAS advances CSG standardization in two key aspects. First, it helps address one of CSG's fundamental challenges discussed earlier: the board's administrative discretion that authorities often exercise in CSG. While China's Administrative Penalty Law embeds the principle of proportionality, requiring that ‘the setting and enforcement of administrative penalties must be based on facts and be equivalent to the circumstances and severeness’ (CPC, 2021), in practice, the distinction between severe and ordinary pollution remains ambiguous due to the lack of a clear and uniform standard. This ambiguity has historically allowed environmental officers considerable discretion in imposing administrative penalties (Trevaskes, 2010). Under CSG, the problem is further exacerbated, as authorities are granted additional flexibility to bypass institutional constraints, expanding their discretionary power in law enforcement. SADAS mitigates this issue by quantifying enforcement criteria and providing detailed guidelines, enabling more targeted decisions through consideration of aggravating and mitigating circumstances (Marquis et al., 2011; Zhuang & Hu, 2021). Additionally, by making enforcement criteria, processes, and guidelines publicly accessible, SADAS improves transparency. This transparency enables both supervising authorities and the public to more effectively supervise how environmental agencies exercise their expanded powers under CSG.

As our analysis demonstrates, CSG has undergone a significant standardization process in China's environmental management, particularly evident in the Cleanup Project in Huai. Traditionally, CSG operated through ad hoc arrangements, including temporary resource mobilization and delegated powers. However, following two major revisions, we argue that the formalized procedures and guidelines, created through the standardization process, have evolved into structured operational frameworks in CSG. These frameworks have gradually changed what were once temporary and ad hoc measures in CSG into more stable and enduring elements of broader institutional arrangements. As shown in Table 1, these changes are reflected in three key areas:

• (1) The introduction of comprehensive monitoring systems (including auto-monitoring and the three-tiered monitoring framework) has made resource redistribution in CSG more organized and fairer (mainly based on the second revision).

• (2) The gradual establishment of clear guidelines and procedures has made the distribution and exercise of delegated powers in CSG more predictable, accountable, and rule-based (based on the first and second revisions).

• (3) The gradual emergence of structured operational frameworks has shifted the application of CSG from isolated, case-by-case interventions that were difficult to predict to a more standardized and predictable form of governance practice (mainly becoming evident after the second revision).

At the planning stage, the comprehensive monitoring systems brought major improvements by enabling continuous, standardized data collection across the basin's key monitoring points. This significantly reduced information asymmetry between central and local levels. With real-time and verified data on the condition of water quality, the Central Government can develop clearer criteria for determining where and when to apply CSG in the basin, formulate strategies tailored to specific regional pollution challenges, and address the long-standing problems of local protectionism and collusion that previously hindered effective resource allocation (Beyer, 2006; Beeson, 2010; Zhou, 2012a).

For implementation, although campaign package restrictions offered some improvements, the utilization of the comprehensive monitoring systems and SADAS has fundamentally transformed how authorities utilize their reallocated resources and powers under CSG. The real-time data provided by these comprehensive monitoring systems enables authorities to establish clear priorities for regulatory actions and determine appropriate enforcement intensities. Additionally, with SADAS providing structured frameworks for administrative decision-making, authorities can now justify their enforcement actions with clear operational guidelines, rather than resorting to overly harsh measures for quick compliance (Kolieb, 2015).

In the supervision stage, the campaign package restrictions enhanced the Central Government's supervisory capacity but proved less sustainable due to administrative resource and budget constraints. This limitation was overcome after CSG's second revision, where the introduction of SADAS and comprehensive monitoring systems provided a more sustainable and effective framework for supervising the exercise of expanded powers and resources. Specifically, SADAS establishes a structured supervision process by requiring administrative agencies to document and justify their decisions at the enforcement stage. This documentation requirement, combined with continuous data from the comprehensive monitoring systems, enables the Central Government to detect and prevent the misuse of delegated powers for short-term gains or personal promotion (Van Rooij et al., 2018). From the public perspective, SADAS's requirement for authorities to provide reasoned explanations for their enforcement decisions has significantly enhanced transparency and accountability. When authorities now exercise their delegated powers, the public can verify through SADAS that these measures are proportionate and necessary for achieving environmental goals. This enhanced transparency helps mitigate public concerns about excessive enforcement while demonstrating CSG's growing alignment with good governance principles (Sweet & Mathews, 2008).

While significant progress has been made, these developments have intensified tension in CSG's standardization. Since 2016, as structural operational frameworks have become increasingly evident within CSG's project-based temporary arrangements, these standardization efforts have triggered institutional changes in this non-conventional governance approach. The Huai case provides compelling evidence that these efforts go far beyond simply making the application of CSG more predictable – they have reshaped how the distinctive capacity of CSG to break through institutional constraints is exercised. While this capacity remains central to CSG's original position as a non-conventional governance approach designed to address urgent environmental challenges, it is now applied within more structured parameters. For instance, authorities' decisions to mobilize additional resources must be supported by comprehensive monitoring data, their expanded enforcement powers must follow documented procedures, and their actions are subject to continuous supervision. This evolution demonstrates how standardization has gradually initiated an institutionalization process for CSG, transforming it from an approach primarily characterized by flexible responses and extraordinary measures into one that combines the predictability and consistency of conventional governance approaches with the rapid response capability of non-conventional governance approaches. Such transformation suggests that CSG is developing into a more sophisticated governance approach that balances institutional stability with adaptive capacity.

Given this fundamental change, we argue that post-2016 CSG can no longer be accurately described as ‘campaign-style’. We also contend that it is inappropriate to label it as ‘CSG 2.0’, as this term suggests merely an upgraded version of the original model, but our analysis reveals a more profound transformation. Instead, we suggest that the twice-revised CSG represents a hybrid model of governance approach that combines the conventional governance approach's emphasis on predictable procedures with the non-conventional governance approach's capacity for flexible response. Furthermore, understanding CSG as a hybrid model requires us to move beyond analyzing it solely through the conventional versus non-conventional governance dichotomy. While this analytical framework helps identify whether CSG operates in ways that align with existing institutional arrangements, it fails to capture how the practices and lessons learned from CSG applications gradually change existing institutional arrangements and how these changes in return influence CSG's institutionalization.

To better understand the institutionalization that CSG's standardization has triggered, we need a more fine-grained analytical framework. Lawrence et al.'s framework offers particularly valuable insights as it examines institutionalization by scrutinizing how power is actually exercised in this process. Compared to merely examining how different governance approaches are applied, this framework provides a more detailed analysis by revealing how key mediating factors (such as power) function to drive institutional changes during the application of a particular governance approach. In their framework, they argue that power can be exercised in two distinct modes: episodic and systemic power. Episodic power refers to power exercised through discrete and targeted actions. Its exercise depends on direct interventions and ad hoc mobilizations, typically triggered by specific events or personal influence. This mode of power is primarily used to address urgent issues and changing circumstances. While it enables rapid responses, it often leads to unpredictable outcomes and may undermine stakeholders' confidence because its use is not consistent over time. In contrast, systemic power refers to power exercised through routinized practices. Its exercise relies on established organizational procedures and formal rules, mainly employed to maintain stable and predictable institutional arrangements. Although this mode of power ensures predictability and enhances stakeholders' trust, it may lack the flexibility needed for immediate problem-solving (Lawrence et al., 2001).

When a governance approach is applied, governing bodies may simultaneously employ both modes of power to accomplish their governance goals, with both their emphasis on and conditions for exercising each mode shifting dynamically according to different contexts. This dynamic combination of episodic and systemic power significantly shapes the approach's institutionalization, determining its' pace (how quickly it shifts from relying on episodic power to predominantly using systemic power), stability (how well-structured operational frameworks developed through standardizing this approach can sustain the exercise of systemic power across contexts while creating more stringent conditions for episodic power use), and legitimacy (to what extent the public could accept this approach's balance between episodic and systemic power as appropriate for good governance) (Lawrence et al., 2005; Lawrence, 2008).

The evolution of CSG in the Huai case precisely exemplifies this dynamic interplay between episodic and systemic power. Initially, CSG operated primarily through episodic power, with authorities exercising broad discretion for immediate interventions. Through its standardization process, particularly the introduction of auto-monitoring systems and SADAS in 2016, CSG has gradually incorporated more systemic power while retaining its capacity for initiating episodic intervention, making its application more predictable and consistent. As discussed in the introduction and Section 2, these standardization efforts by the Central Government primarily aim to enhance the predictability and consistency of CSG, as such qualities are considered essential for gaining public acceptance of CSG as a legitimate governance approach meeting the standards of good governance. Nevertheless, as the standardization of CSG triggers its institutionalization process, gaining public acceptance now requires meeting a more complex expectation: While the public values CSG's increased predictability through standardization, they simultaneously expect it to maintain its flexibility in quickly addressing urgent environmental problems. Consequently, as CSG continues to evolve, how the Central Government coordinates episodic and systemic power to simultaneously maintain CSG's predictability while ensuring its effectiveness in environmental problem-solving, and whether such balance can be considered consistent with good governance requirements, will become key focuses for future observation and analysis. One could imagine that different perspectives on this coordination will likely be provided. For instance, those who emphasize the importance of constraining administrative discretion may suggest that systemic power should always dominate CSG applications, with episodic power strictly limited to emergencies where pollution levels exceed critical thresholds. Some may suggest that regions with strong environmental governance capacity might rely primarily on systemic power, while areas with weaker institutions might need to exercise episodic power more frequently. Others may propose technical solutions and suggest that authorities should determine when to switch between systemic and episodic power based on real-time environmental data.

While these diverse viewpoints enrich our knowledge of how to coordinate systemic and episodic power in CSG's application, they can also generate competing suggestions for its actual application and create disagreements and disputes among affected parties. Given that modern states have traditionally developed their legal systems to regulate and construct normative requirements for the exercise of power (Habermas, 1996; Luhmann, 2004), resolving these disagreements and disputes may ultimately require legal solutions that establish clear frameworks for balancing systemic and episodic power in CSG. Yet the task of transforming diverse perspectives and positions into consistent legal frameworks is highly challenging in practice. First, different stakeholders, coming from various disciplinary backgrounds or holding different positions, bring distinct methodologies and standards that are difficult to reconcile within a unified legal framework. Second, the dynamic nature of environmental problems requires legal frameworks that are both specific enough to guide current actions and flexible enough to accommodate emerging challenges. These practical challenges in developing effective legal frameworks to guide power exercise in ways that balance predictability and flexibility have already attracted scholarly attention (Farber, 1999; Qian, 2018). This paper contributes to this ongoing discussion and calls for more attention and dialogue on this issue, particularly in the context of the application of CSG in China, as China's continuous efforts to standardize CSG have led it into a new phase, where emerging challenges and experiences provide rich materials and insights for analyzing this issue both in theory and in practice.

Since the initial application of CSG in Huai, China has undergone significant efforts to standardize CSG by developing structured operational frameworks throughout its governance process. Through our analysis of CSG's evolution in the Huai case, we identified two major revisions by the Central Government that aimed to make the application of CSG more predictable and consistent. We argue that this standardization has transformed CSG into a hybrid model that combines the characteristics of conventional governance approaches in following established institutional arrangements with the distinctive capacity of non-conventional governance approaches to break through institutional constraints when addressing specific challenges. For future research, we propose conducting a more fine-grained analysis to examine how power is exercised when applying this hybrid model. Additionally, we call for greater attention to developing practical strategies for guiding CSG applications, with the aim of achieving an appropriate balance between public expectations for predictability and flexibility. Such a balance is essential for CSG to gain broader recognition as a governance approach that meets the requirements of good governance.

All relevant data are included in the paper or its Supplementary Information.

The authors declare there is no conflict.