The Environment and Climate Change Law Review: South Korea
The year 2021 was a significant milestone for Korea's climate policy. At the United Nations Framework Convention on Climate (UNFCCC) Conference of the Parties (COP) 26 held in Glasgow, Korea submitted the Intended Nationally Determined Contribution (INCD) to achieve a 40 per cent domestic reduction in greenhouse gas emissions by 2030, a significant increase from the 2018 levels of 26.4 per cent. This is the result of an ongoing effort driven by the carbon neutrality legislation and policies that continued throughout 2021, since Korea announced a vow to 'achieve carbon neutrality by 2050' in October 2020. The Presidential 2050 Carbon Neutrality Committee was established, in which the government and private members participated together, and the committee presented specific 2050 carbon-neutral plans (carbon neutral scenario) twice. Eventually, two plans – different in content but with the same aim for a coal-free society – were officially adopted as government proposals. In addition, the Korean National Assembly enacted a 2050 carbon neutrality framework, and Korea became the 14th country in the world to legislate a carbon neutrality act. With the legislation, Korea expressed its strong will to reduce greenhouse gas emissions by at least 35 per cent from the 2018 levels. In November, the Hydrogen Economy Roadmap 2.0, a follow-up to the initial Hydrogen Economy Roadmap announced in January 2019, was released, and the revised hydrogen law is expected to be passed in the next year, making Korea the world's first country to implement the CHPS, a mandatory renewable energy supply system using clean hydrogen.
Korea's efforts to create a better environment are not limited to climate-related matters, as various laws and regulations are constantly introduced and amended to protect and improve the environment.
Article 35 of the Constitution of Korea provides the environmental rights of citizens and the obligations of the state as well as the basis for the Framework Act on Environmental Policy. The Framework Act on Environmental Policy sets forth the purpose of environmental policy and the basic principles in environmental law, and serves as the cornerstone of Korean environmental law. In addition, other specialised environmental statutes have been enacted and implemented to deal with other specific environmental matters.
Korea's overall environmental law and related regulations are as follows:
- the Framework Act on Environmental Policy;
- the Environmental Impact Assessment Act;
- the Act on the Integrated Control of Pollutant-Discharging Facilities;
- the Act on the Control and Aggravated Punishment of Environmental Offences, among others;
- the Environment Dispute Mediation Act, the Act on Liability for Environmental Damage and Relief Thereof;
- the Sustainable Development Act; and
- the Framework Act on Carbon Neutrality and Green Growth to Respond to the Climate Crisis (effective from March 2022).
Article 6 of the Constitution of the Republic of Korea provides that the treaties duly concluded and promulgated under the Constitution shall have the same effect as the domestic laws of Korea. As such, Korea carries out its obligations under international agreements through the enactment of domestic laws, regulations and policies.
Some representative international environmental agreements to which Korea is party are as follows:
- the United Nations Convention on the Law of the Sea;
- the International Convention for the Prevention of Pollution of the Sea by Oil;
- the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal;
- the Convention on International Trade in Endangered Species of Wild Fauna and Flora; and
- the Convention on Biological Diversity.
Korea is a contracting state to the following international agreements or regulations on climate matters:
- the United Nations Framework Convention on Climate Change (UNFCCC);
- the Kyoto Protocol to the United Nations Framework Convention on Climate Change;
- the Vienna Convention for the Protection of the Ozone Layer;
- the Montreal Protocol on Substances that Deplete the Ozone Layer;
- the London Amendment to the Montreal Protocol;
- the Copenhagen Amendment to the Montreal Protocol;
- the Montreal Amendment to the Montreal Protocol;
- the Beijing Amendment to the Montreal Protocol;
- the Marrakesh Accords; and
- the Paris Agreement.
The Ministry of Environment (MOE) is the leading authority responsible for the administration and enforcement of Korea's environmental policy.
The competent authorities (including the MOE) have the authority to impose sanctions, such as suspension of work, licence revocation, administrative fines, and the granting of permits or subsidies as prescribed in the individual laws.
Although variations exist depending on the applicable laws and regulations, the MOE, its affiliates and local governments may either routinely conduct inspections of regulated facilities or irregularly conduct investigations in the case of an incident.
The regulators decide on the extent of sanctions for each violation with reference to detailed disposition standards prescribed under relevant regulations. Possible sanctions include requiring the installation of pollution prevention equipment, the cessation of the infringing activity, suspension of work, the shutdown of a facility, revocation of the permit and the imposition of administrative fines. Injunctive reliefs may also be pursued to require the abatement of the violation or environmental harm.
Such administrative sanctions can be challenged through administrative litigation. The judicial authority in Korea is exercised by courts on three levels: District Court (or Administrative Court), High Court and the Supreme Court. If an interested party wishes to contest an administrative disposition by a competent authority (such as the MOE), he or she could file an administrative litigation before the Administrative Court. The judgment made in the Administrative Court can be appealed to a High Court, which can then be appealed to the Supreme Court.
Environmental laws and regulations authorise or otherwise provide statutory grounds for a wide range of civil liabilities and criminal penalties.
The Act on Liability for Environmental Damage and Relief Thereof, enacted in 2014, defines the term 'environmental damage' as damage (including a series of damages with the same cause) inflicted on the life, body (including mental harm) or property of any third person by air pollution, water pollution, soil pollution, marine pollution, noise, vibration or other causes that occur from installing and operating a facility, except the damage inflicted on a business owner and the damage suffered by employees during the course of business.
To provide prompt and adequate relief to the victims, the Act on Liability for Environmental Damage and Relief Thereof introduced strict liability, an obligation for business owners to have environmental liability insurance, presumption of causal relationship, the right to request information and payment of relief money to the victims of environmental damage. However, the Act on Liability for Environmental Damage and Relief Thereof also stipulated a liability cap for compensation, as it may impose too much of a burden on business owners with strict liability, among others, with exceptions for the presumption of a causal relationship.
Other than relief provided under the Act on Liability for Environmental Damage and Relief Thereof, relief from environmental pollution among private parties is mainly based on civil claims under the Civil Act, including (but not limited to):
- the owner's or possessor's demands for cessation of the disturbances and compensation of damages;
- claims for compensation of damages based on torts;
- the seller's liability for warranty against defects existing in the subject-matter of the sale; and
- product liability and non-performance of contractual obligations that are among the potential civil claims under the Korean Civil Code.
Violations of environmental laws and regulations may be subject to criminal liabilities, and certain serious environmental offences that have, or may have, caused damage to the environment or human health are subject to aggravated punishment in accordance with the Act on the Control and Aggravated Punishment of Environmental Offences.
If the violation is perpetrated by a corporate entity rather than an individual, then the corporate entity's directors or officers may be subject to criminal liabilities. Most individual environmental regulations have joint penalty provisions, which typically take the following form:
If a representative of a corporation, or an agent, employee, or any other servant of a corporation or an individual commits an offence described in the Act in connection with the duties of such corporation or individual, not only shall the offender be punished accordingly, but such corporation or individual also shall be punished by the fine provided in the relevant Article: provided that this shall not apply where the corporation or individual has not been negligent in giving due attention and supervision concerning the relevant duties to prevent such offence.2
These joint penalty provisions provide the legal basis for the criminal prosecution of directors and officers for their management supervision negligence. In addition, the Act on the Control and Aggravated Punishment of Environmental Offences has been recently amended to increase penalties imposed on the business entities that have illegally discharged 'specific pollutants', which are likely to harm human health, property or the growth of animals and plants. Regardless of the proceeds (usually the cost of discharge treatment) from the illegal discharge, penalties are now calculated as the sum of the amount not exceeding 5 per cent of the sales and the remediation costs.
The typical defences asserted include lack of intent (in the case of criminal liability) and the failure to establish the necessary elements for civil or criminal liability. For civil claims, the burden of proof and statutes of limitation are among some of the essential issues commonly asserted by the defendants in environmental cases.
Reporting and disclosure
Under environmental laws and regulations, most of the pollutant discharging facilities must submit periodic reports to the relevant competent authorities. For example, the Water Environment Conservation Act provides that anyone who transports or stores petroleum, toxic substances, pesticides or other designated water pollutants must report to the regulators if such substances pollute water. The Soil Environment Conservation Act provides that anyone who produces, transports, stores, handles, treats or processes soil pollutants must report to the regulators if soil pollutants were leaked or drained during the process. Furthermore, anyone who owns, occupies or operates soil-contaminating facilities must report to the relevant regulators if any soil contamination is found in the facilities.
Compliance with environmental regulations may have a substantial impact on the valuation of a business to be transferred in an M&A transaction. In most cases, buyers carry out extensive legal due diligence. Prior to acquiring a business that operates installations that require environmental permits, the buyer must check the existence, validity and duration of all required permits for every installation. The buyer must also be aware of all regulations applicable to the activities that are proposed to be carried out. Furthermore, non-compliance committed by the previous owner may give rise to potential risks for the buyer.
For real-estate transactions of (former) places of businesses, the existence of contaminants and the liability for their removal are the main environmental aspects to consider. According to the Soil Environment Conservation Act, the buyer of land becomes jointly liable with the previous owner and the polluter.
Violations of environmental laws may jeopardise continuation of business activities as they may result in the suspension of business or cancellation of business permits. In addition, liability for damages caused by environmental pollution may remain as a contingent liability. Consequently, in some cases, environmental aspects are treated as serious legal obstacles for financing, corporate listing or invitation of investments.
In relation to climatic change, the emission trading scheme under the Act on the Allocation and Trading of Greenhouse-gas Emission Permits provides mandatory requirements applicable to the business entities eligible for allocation. Such business entities have to submit annual reports on the amount of greenhouse gas emissions, as well as emission permits to the relevant competent authorities. The mandatory reporting mentioned above is not yet aligned with the Task Force on Climate-related Financial Disclosures recommendations.
The Protection of Public Interests Reporters Act provides the legal basis for the protection offered for whistle-blowers. Any whistle-blower who discloses acts detrimental to the public interest (e.g., acts detrimental to the health and safety of people, the environment, the interests of consumers or fair competition) shall be protected by the Anti-Corruption and Civil Rights Commission. The protection provided by the Anti-Corruption and Civil Rights Commission includes confidentiality, exemption from responsibility, prohibition of disadvantageous measures, preferential treatment and other relevant measures.
Korea has enacted and implemented multiple specialised environmental statutes to deal specifically with individual sources of pollutants. However, in 2017, the Act on the Integrated Control of Pollutant-Discharging Facilities was promulgated and introduced a new legal regime, the integrated environmental management system (IEMS), which is applicable to large-scale business sites having great impact on the environment.
The IEMS integrated previous regulations into a single integrated management permit per business unit, thereby simplifying the process. Before the IEMS was introduced, businesses had been regulated by seven different environmental regulations requiring them to obtain up to 10 different types of permits for each source of pollutants. The IEMS permits, once issued, are valid for five years and can be extended for up to three additional years. If the discharging facilities are transferred, the transferee shall succeed the rights and obligations of the preceding transferor's permits, revised permits or file of reporting.
In the event a business site falls outside of the scope of the IEMS, then a separate regulatory regime is applicable, depending on the type of pollutant.
i Air quality
Air emissions are regulated by the Clean Air Conservation Act. This adopts different sets of regulations for the emissions by categorising the sources of air pollutants into places of business, living environments and motor vehicles or ships. Korea's regulation of air emissions is mainly focused on regulating places of business. Any person who intends to install emission facilities shall obtain a permit from the relevant mayor or governor or file a report thereon and install air pollution prevention facilities in accordance with the 'polluter pays' principle. A prevention facility should also be installed and an operation commencement report submitted to the MOE before the facility starts operating.
The Clean Air Conservation Act sets permissible emission levels of air pollutants emitted from air pollutant-emitting facilities, thereby adopting a concentration-based regulation instead of an overall quantity-based regulation. However, certain areas designated as air pollution control areas are subject to overall quantity-based regulation under the Special Act on the Improvement of Air Quality in Air Pollution Control Areas (the Special Act). The Special Act designates regions deemed to be seriously affected by air pollution and comparable regions as 'air control zones' and sets emission limits, defined as 'total emission allowances' for each zone.
Within the air control zone, establishing a place of business requires permission from the MOE provided that its annual emission of NOx, SOx or TSP exceeds 4.0t, 2.0t or 0.2t, respectively, more than once for the last two years. These permits are based on an annual allocation of total emission allowances for five years.
The MOE is entitled to collect penalty surcharges for excess emissions and may even revoke permissions of businesses entity that are in violation of the law. At the same time, the MOE may order a shutdown of a place of a business where the permission has been granted based on information that is fraudulent or through other improper means.
ii Water quality
The main legislation addressing the protection of fresh water is the Water Environment Conservation Act, which is the framework act for the prevention of water pollution. The act categorises water quality pollutants into point source, non-point source and miscellaneous sources. Under the Water Environment Conservation Act, the point source pollutants are subject to similar regulations imposed on places of business under the Clean Air Conservation Act.
Anyone intending to install a wastewater-discharging facility must obtain a permit from or file a report with the MOE. Once the MOE receives the application, the MOE can consult the local authority and restrict the installation of the facility if the MOE determines the facility's proximity to any reservoir protection zone or special protection zone to be harmful. The operator of the facility must also install a prevention facility to ensure that the amount of pollutants discharged does not exceed the permissible thresholds. An operation commencement report must be filed with the MOE before the operation of the facility.
Under the Water Environment Conservation Act, the MOE can order a facility to lower the amount of water pollutants discharged within a designated period if the facility is determined to be discharging water pollutants in excess. The facility must promptly report to the MOE once it completes the order. If the facility fails to comply, the MOE can suspend the facility's operation in whole or in part.
The MOE can also order a facility to stop discharging pollutants or other special measures if it determines that water quality will not satisfy the existing standards due to reservoir pollution, and may seriously harm public health.
Hazardous products and substances are mainly regulated by the following laws and regulations:
- the Act on Registration, Evaluation, etc. of Chemicals (K-REACH);
- the Chemicals Control Act; and
- the Act on Safety Management of Consumer Chemical Products and Biocides (K-BPR).
K-REACH, the Chemicals Control Act, K-BPR and respective regulations thereunder protect human health and the environment against risks caused by hazardous products and substances.
K-REACH is similar to the EU REACH as it is a statute that regulates the market entry of a chemical substance. Under K-REACH, any person who manufactures or imports no less than 100 kilograms of non-phase-in substance or any person who manufactures or imports no less than 1 tonne of phase-in substance must register the uses and quantity, among others, of the chemical substance in advance to the MOE. Non-compliance with the registering requirement could be subject to criminal penalties and a suspension order for the manufacture, import, use or sale of the chemical substances.
Conversely, the Chemicals Control Act regulates the usage of such chemical substances once they have been introduced to the domestic market. Specifically, the manufacture, keeping, storage, transport and use of chemical substances (collectively, handling) require a business permit and handling facility in accordance with the specifications set forth in the Chemicals Control Act.
Lastly, K-BPR was promulgated in 2018 and came into effect in 2019. K-BPR, which is substantially similar to the EU Biocidal Products Regulation, imposes safety and labelling standards for certain consumer chemical products and requires manufacturers and importers of biocidal products to obtain prior approval for the biocides from the MOE.
iv Solid and hazardous waste
Under the Waste Control Act, the term 'waste' is defined as 'materials such as garbage, burnt refuse, sludge, waste oil, waste acid, waste alkali and carcasses of animals, which have become no longer useful for human life or business activities'. The Water Control Act categorises waste into two main categories and provides a differentiated management system for each category: industrial waste and household waste.
Any business operator that discharges (i.e., generates) industrial waste must report the type and amount of the waste it discharges to the relevant local authority. The operator must treat the waste directly or have it treated by someone with a licence to manage a waste treatment business or operate a waste treatment facility. It is illegal to conduct waste treatment business without the requisite permit from the MOE or the relevant local authority. It is also illegal to dispose of waste in an area that is not prepared for waste collection by the local authority and to fill or incinerate waste in a waste treatment facility not licensed or registered. Such unlawful dumping of industrial wastes is subject to criminal penalties. Local authorities are in charge of household waste, and unlawful dumping of household waste is subject to administrative fines.
The Framework Act on Resource Circulation, enacted in 2018, regulates recycling of waste. The Framework Act on Resource Circulation introduced the new concept of 'resource circulation' and provides general principles to promote recycling. The Construction Waste Recycling Promotion Act and the Act on Resource Circulation of Electrical and Electronic Equipment and Vehicles regulate the recycling of certain special types of waste.
v Contaminated land
The Soil Environment Conservation Act regulates matters relating to soil pollution in Korea and prohibits the following:
- the disposal of soil pollutants or reclamation using soil pollutants;
- the leakage of soil pollutants during storage, transportation or remediation;
- the installation of an unreported facility (installation of a soil-contaminating facility requires the installation of a soil-contamination prevention facility as well as its maintenance) that could severely contaminate soil;
- the failure to report leakage of soil pollutants to the competent authority during manufacture, transportation, storage or treatment; and
- the failure to report contamination of an installed soil pollution management facility.
Regarding soil contamination, Soil Environment Conservation Act imposes two types of liabilities: payment of damages or contamination remediation obligations. While the former is a type of strict liability borne by the persons responsible for the soil contamination, the latter is a liability borne by the following persons designated by the law:
- any person who causes soil contamination by discharging, leaking, dumping or neglecting soil contaminants or committing other acts;
- the proprietor, occupant or operator of a facility subject to the control of soil contamination constituting a cause for soil contamination at the time soil contamination occurs;
- any person who has comprehensively succeeded to the rights and liabilities of either (a) or (b) on account of merger, inheritance or other reasons; and
- any person who previously owned or presently owns or occupies land on which soil contamination has occurred.
Clean-up of soil contamination first starts with the detection of contaminated soil through an inspection. If the inspection reveals that the soil contamination of the area exceeds 'the Worrisome Levels', then measures such as the installation of a pollution prevention facility, improvement of an existing pollution prevention facility or restrictions imposed on the use of soil pollutants shall be implemented. If the soil pollution is severe and exceeds the Countermeasure Standards, the person designated by the law shall be ordered to implement a project to remediate the soil contamination, or the competent authority may execute such a project at the expense of the person designated by the law. The Countermeasure Standards are defined as the levels of soil contamination that are likely to damage human health and properties or rearing of animals and plants. The Worrisome Levels are about 40 per cent less severe than the Countermeasure Standards.
In an asset sale, the buyer generally inherits pre-acquisition environmental liability, with a few exceptions (e.g., the buyer was in good faith and not negligent).
The buyer shall be deemed to be in good faith and not negligent in preventing the relevant soil contamination if the buyer:
- carried out the Assessment of Soil Environment, as described in the Soil Environment Conservation Act, and
- confirmed that the contamination level was below the Worrisome Levels at the time of acquisition.
Korea is an active participant in the international community's collective efforts against climate change, having joined the UNFCCC in 1993, ratified the Kyoto Protocol in 2002 and ratified the Paris Agreement on 3 November 2016. In 2015, the government submitted its Intended Nationally Determined Contribution (INDC). The INDC was a proposal to designate an economy-wide target to reduce greenhouse gas emissions by 37 per cent below its business-as-usual emissions level by 2030. In 2020, the government announced its commitment to achieve net-zero emissions and be carbon-neutral by 2050.
In 2021, the Framework Act on Low Carbon Green Growth, a key legal basis for Korea's domestic implementation of the INDC, is to be abolished. Instead, the Framework Act on Carbon Neutrality and Green Growth (or the Carbon Neutrality Act) will enter into force on 25 March 2022. It requires the government to cut its greenhouse gas emissions in 2030 by 35 per cent or more from the 2018 levels to achieve carbon neutrality by 2050, with the 2050 Carbon-Neutral Green Growth Committee established. The Carbon Neutrality Act also includes the provision of a fund (the Climate Response Fund) to support the classes, regions and industries vulnerable to climate crisis, based on the concept of 'climate justice'.
The government has implemented various policy measures in response to climate change. The two most notable schemes are the Renewable Portfolio Standard (RPS) scheme under the Act on the Promotion of the Development, Use and Diffusion of New and Renewable Energy in 2012, and a greenhouse gas emissions allocation system and national cap-and-trade system, commonly known as the KETS under the Act on the Allocation of and Trading of Greenhouse-Gas Emission Permits in 2015.
However, as the price of new and renewable energy continued to decrease, it was pointed out that the RPS scheme had reached its limit of supply of new and renewable energy; thus, the Clean Hydrogen Portfolio Standard (CHPS), a newly designed scheme only targeting clean hydrogen energy, was devised in Korean in 2021. A basis law for the CHPS is the world's first Hydrogen Economy Fostering and Hydrogen Safety Management Act (the Hydrogen Act), which was enacted in 2020 and entered into force in 2021. The Hydrogen Act was enacted to promote the implementation of the hydrogen economy and to manage hydrogen safety, and it will be amended to include matters regarding the CHPS in 2022.
i The RPS Scheme
In 2012, the government replaced the previous feed-in-tariffs regime and implemented the RPS in accordance with the Act on the Promotion of the Development, Use and Diffusion of New and Renewable Energy. The RPS relies on renewable energy certificates (REC), which are certificates authenticating the fact of supply by using renewable energy facilities, based on each megawatt-hour of electricity generated from a renewable energy resource. RECs can be traded once issued.
The government has obliged companies with a generation capacity of 500 MW or more to generate a certain minimum percentage of gross power from renewable energy sources. Currently, 22 large power companies in Korea are subject to this obligation. Failure to meet the required generation quota may result in administrative fines of 1.5 times the average trading price of a REC. As of October 2021, the average trading price of REC is approximately 35,000 Korean won.
In 2021, the REC weight of the RPS system was adjusted to raise the weight of offshore wind power generation from 2.0 to 2.5, to lower from 0.7 to 0.5 in the case of mountain solar power, and to exclude RECs from the RPS in the case of coal IGCC. In addition, fuel cell power generation will also be excluded from the RPS from 2022 due to the implementation of the CHPS, which is to be further explained below.
ii The Korea Emissions Trading Scheme
In 2015, Korea established a national greenhouse gas emissions trading scheme, commonly known as the KETS. In 2020, the emissions rights for the Phase 3 allocation plan (2021-2025) were allocated to 685 companies and public entities whose total annual emissions were not less than 125,000 tCO2, or to places of businesses with annual emissions not less than 25,000 tCO2, which represents a drastic increase from 589 companies in the Phase 2 allocation plan (2018–2020). If greenhouse gas emissions of a company or public entity exceeded the allocated emissions, then the company or public entity either had to pay administrative fines, purchase emissions rights from the emissions trading market or offset excessive emissions with offset credits.
With the revision of the subregulation on the KETS in 2021, by purchasing RECs, an organisation receives credit for carbon emissions in the amount equivalent to the purchase amount (indirect emissions from electricity use). This is to encourage companies to participate in the RE 100 (production of products using only renewable energy), representing the partial integration of the RPS market and the KETS market.
Korea has not yet participated in an international greenhouse gas emissions trading scheme. With the recent proposal of the EU CBAM, EU-ETS is expected to have an impact on the various industrial sectors around the world, starting with target industries such as steel and aluminium. In light of the circumstances, it is likely that the relevant change in the KETS will be made and ultimately, at least, the discussions on the ETS integration centred on East Asia may take place.
iii The Hydrogen Act and CHPS Scheme
In February 2020, Korea enacted the world's first Hydrogen Act and it was entered into force in February 2021. The Hydrogen Act is a law to implement the 'Hydrogen Economy Roadmap', which was initially announced in 2019 and supplemented with the 2.0 version, and to promote the safety of hydrogen supplies and facilities using hydrogen fuel. With the amendment bill expected to be passed in December 2021, the current hydrogen power generation sector will also include hydrogen turbine power generation and ammonia mixed power generation, in addition to the existing fuel cell power generation. In addition, it will also newly define the concept of 'clean hydrogen' produced by using renewable energy instead of using fossil fuels, and it will include matters describing how to promote the use of clean hydrogen. The Hydrogen Act will also define the CHPS system that will require electricity providers to supply electricity produced with clean hydrogen, similar to the RPS. Such change will transfer the fuel cell power generation currently included in the RPS to the CHPS system.
Outlook and conclusions
The full-fledged implementation of the plan for the 2050 carbon neutrality that focuses on hydrogen will commence in 2022. Representatively, with the implementation of the CHPS, hydrogen will be separated from the RPS market, and the integration of the RPS market and the ETS market, which started in 2021, will also be affected, which therefore would bring about a considerable change in the renewable energy supply policies. On top of that, the CBAM proposed by the European Union will also have an impact on the KETS policy. In terms of regulation, most large-scale emission facilities should have obtained an integrated permit by the end of 2021 under the integrated environmental permit system implemented in 2019. Next year, the relevant regulation will take place and attention will be paid to how the regulation will work on the emission facilities that have obtained the integrated permit and companies that have not obtained the integrated permit.
1 Tong Keun Seol is a partner, and Yun Sung Kim and Seulbin Park are associates at Lee & Ko.
2 Article 31 of the Soil Environment Conservation Act, Article 81 of the Water Environment Conservation Act, Article 95 of the Clean Air Conservation Act and other environment-related statutes also have similar provisions.