In the first year of China's 11 th five-year plan,both energy conservation target and pollutant emission con- trol target failed to be realized.This paper probes into the target-making process and target-implementing process to see what the formal rules are and how they operate informally.It is demonstrated that,on one side,local governments have little opportunity to present their willingness in the target-making process though formal rules do give them enough space,and on the other side,target-based responsibility system the legal effectiveness of which is in vagueness can not give local governments proper expectation.Based on the analysis above,corresponding countermeasures are put forward.