煤炭地下气化(UCG)是我国能源发展的必然选择和高效煤炭能源结构发展的战略所驱，产业化进程亟待各方协同推进，产业政策建设首当其冲。立足这一背景，广泛调研国内外相关情况，从UCG产业化战略价值、相关国家UCG项目市场准入及法制现状、我国UCG项目备案审批办法、UCG产业政策建设思考4个方面，分析论证了煤炭地下气化产业政策建设面临的困境，提出了破解困局的对策建议。分析表明，UCG项目在矿产资源管理方面涉及煤炭、石油和天然气3个领域，从环境保护管理来看涉及地下水、土壤及地表生态、大气等诸多方面，管理职责隶属于政府多个部门，申报和审批过程十分复杂。相关国家尽管在UCG产业政策建设方面做过较多尝试，但尚无任何一部现行且可持续的UCG产业激励政策，成为UCG产业化推进的“短板”。国外专家曾向本国政府建议，通过政策和监管框架尽早推出UCG技术，同时消除社会对UCG环境安全的担忧。我国长期以来对UCG项目的备案审批采用“一事一议”办法，部分UCG项目落地审批难的现象客观存在，极大制约了UCG产业化进程。基于上述困境，建议国家研究并制订出台具有可操作性的UCG产业政策体系，重点在于5个方向，一是建立UCG项目市场准入与审批制度，二是明确UCG项目矿产资源使用与财税优惠政策，三是将UCG科技创新纳入国家科技重大计划，四是建设UCG科技创新平台体系，五是创建UCG高素质专业人才培养基地，目的是为加大力度推进我国UCG产业化进程提供法制保障。

Underground coal gasification (UCG) is the inevitable choice for China’s energy development and driven by the strategy of the development of efficient coal energy structure. The industrialization process needs to be promoted by all parties in coordination, and the making of industrial policy is the first to bear the brunt. Based on the background and extensive investigation on relevant situations at home and abroad, the difficulties faced by the making of industrial policies for UCG are analyzed and demonstrated, and the countermeasures and suggestions to solve the difficulties are put forward from four aspects, including the strategic value of UCG industrialization, market access and legal status of UCG projects in relevant countries, method of filing and approval of UCG projects in China, and the thinking on the making of UCG industrial policies. It is shown that the UCG project involves coal, oil and natural gas in the management of mineral resources. From the perspective of environmental protection management, it involves groundwater, soil and surface ecology, atmosphere and many other aspects. The management responsibility belongs to multiple government departments, and the application and approval process is very complex. Although relevant countries have made many attempts in the making of UCG industrial policies, there is no current and sustainable policy for improving UCG industry, which has become a “short board” for the promotion of UCG industrialization. Foreign experts have suggested to their own governments to launch the UCG technology as soon as possible through the policy and regulatory framework, and to eliminate social concerns about the environmental safety of UCG. For a long time, China has adopted the “one case, one discussion” method for the filing and approval of UCG projects. It is difficult for some UCG projects to be approved, which has greatly restricted the industrialization process of UCG. Based on the above difficulties, it is suggested that the government should formulate and issue an operable UCG industrial policy system, focusing on five directions: establishing a UCG project market access and approval system, clarifying the use of mineral resources and fiscal and tax preferential policies for UCG projects, bringing UCG scientific and technological innovation into the national major science and technology plan, building a UCG scientific and technological innovation platform system, and creating a high-quality professional talent training base of UCG. The purpose is to provide legal guarantee for promoting the industrialization of UCG in China.