How we manage impacts and performance

In 2024, the EDD process was updated to incorporate more nature-related elements, which included the adoption of IBAT (Integrated Biodiversity Assessment Tool) for identifying biodiversity sensitive areas. IBAT contains a database of global biodiversity-sensitive areas and threatened species, and is used during the pre-investment stage to avoid biodiversity risks. This tool enables CLP to identify potential biodiversity risks early, allowing for due diligence and early evaluation of operational and business risks. Further analysis and stakeholder engagement exercises follow to mitigate these risks if appropriate.

The CLP Biodiversity Impact Assessment Guideline applies to power generation, transmission and distribution, mines and other power-related projects. It provides a framework for systematically assessing biodiversity impacts and managing biodiversity risks. For example, the Guideline helps CLP flag new operations that could affect the IUCN Red List of Threatened Species and the relevant country’s national conservation list of threatened species well ahead of any investment decision. The Guideline is currently being updated to include considerations from sectoral guidelines issued by the TNFD.

The biodiversity impact assessment also observes local legislative requirements and references the International Finance Corporation Sustainability Framework. It involves describing the baseline conditions, evaluating the magnitude and significance of project impacts and investigating options for mitigation. The assessment only contemplates offsets after considering options for avoidance, minimisation and restoration or rehabilitation.

Mitigation measures will be developed based on the findings and on recommendations from the EDD and Environmental Impact Assessment (EIA) exercises, to address adverse impacts related to nature, biodiversity and ecosystems.

At the project operation stage, all identified adverse impacts will be monitored and controlled under the EMS. The EMS is also continuously reviewed to incorporate emerging environmental matters, such as nature, into existing management processes. In 2024, CLP Power’s Generation Business Unit updated its significant environmental aspect registers for operation and maintenance activities to include nature-related impact drivers and dependences, along with associated mitigation measures.

Biodiversity and nature-related enhancement programmes in 2024 included:

• Aquaculture and fisheries conservation
  CLP Power supports marine conservation and fisheries enhancement projects through the Marine Conservation Enhancement Fund (MCEF) and the Fisheries Enhancement Fund (FEF) set up by the Hong Kong Offshore LNG Terminal Project in Hong Kong in 2020. By 2024, total funding of HK$100 million had been allocated to support 44 projects under the MCEF and 28 projects under the FEF. Projects funded by the MCEF focus on marine conservation, habitat restoration, rehabilitation, education and ecotourism, while the initiatives supported by the FEF include fisheries education and tourism, enhancement of fisheries resources and sustainable fishery development. A series of project highlights will be published on CLP’s social media channel to showcase the achievements of these funded projects, with the aim of raising public awareness and knowledge of marine and fisheries conservation-related issues.
• Nature-based solution at the Yuen Long Industrial Estate Substation in Hong Kong
  In Hong Kong, the new Yuen Long Industrial Estate Substation features urban greenery as a nature-based solution to help address climate change. Over 20% of the building area is covered by greenery, with plant species such as Sapium discolor and Millettia pinnata specifically selected for their climate resilience and aesthetic appeal. Situated between the renowned wetland area of Nam Sang Wai and Yuen Long Industrial Estate, the substation was designed with Building Information Modelling (BIM) technologies to provide better integration with the natural landscape. This project was awarded a Provisional Platinum Rating in BEAM Plus New Buildings Version 2.0 certification, and was a winner at the Autodesk Hong Kong BIM Awards 2024.
• Local vegetation management in Hong Kong
  CLP Power continues to monitor the growth and condition of trees and other vegetation that may affect overhead line operations using the Predictive Vegetation Management System (PVMS) developed in 2022. At around 210 locations, the PVMS and CLP Power’s existing tree inventory have helped CLP Power identify tall trees near its transmission and distribution overhead lines for replacement with native short trees as part of its Tree Replacement Programme. This approach aligns with the Hong Kong Government's 'Right Tree & Right Place' Policy and its Nature Conservation Policy. In 2024, about 85 tonnes of timber logs were delivered to Hong Kong Y-Park for recycling under the Tree Replacement Programme.
• Habitat restoration programme in Australia
  EnergyAustralia is committed to nature preservation and habitat restoration in its operation. All its large-scale projects will include a Flora and Fauna Management Plan to maintain local species populations and enhance biodiversity. The Tallawarra B gas-fired Power Station, which began commercial operations in June, developed a detailed Fauna and Flora Management Plan with local ecologists and indigenous community groups. This plan includes an offset programme for minor clearing, serving as an example of no net loss of biodiversity. In preparation for the retirement of Yallourn Power Station and its coal mine, a transformation project was initiated involving rehabilitation and remediation. In 2024, the focus was on assessing potential remediation sites within the boundary to identify associated nature-related risks and opportunities.
• Biodiversity conservation in the Jiangbian Hydro Power Station
  At the Jiangbian Hydro Power Station, various fish species are released annually to maintain the ecological balance of the river. The fish release activity for 2024 was completed in November. Furthermore, CLP China restricts ecological discharges at its hydro power stations during both construction and operation phases, adhering to local environmental protection authority requirements and the mitigation measures stipulated in the EIA report. This practice supports the healthy growth and reproduction of aquatic organisms downstream of the dams.
• Promotion of awareness of nature and biodiversity
  CLP is dedicated to promoting environmental protection and nature conservation across its locations of operation. CLP China engages with communities and local governments in different regions during World Environment Day and other national environmental events. In 2024, a series of planting activities were organised across different CLP China sub-regions, in which thousands of diversified trees and flowering plants, such as fruit trees, willows and bamboos, were planted. Planting within the power stations is also encouraged.
  
  In Hong Kong, eco-tours are arranged annually to enhance the awareness of nature and biodiversity conservation of local staff. For example, a guided tour of the Fung Yuen Butterfly Reserve is held each year to increase staff’s understanding of butterfly ecology and the related conservation efforts in Hong Kong. CLP also sponsors a forest restoration programme conducted by Kadoorie Farm and Botanic Garden (KFBG), and supported staff to participate in the KFBG "Nature Walk & Treasure Hunt" 2024 event, where they learned about nature and biodiversity conservation.
  
  In Australia, EnergyAustralia created a video on the natural aspects of the Lake Lyell project, including the protection of the platypus and its habitat, to raise awareness of nature conservation.

According to the CLP Group HSEMS, the coal-fired and gas-fired power plants under CLP's operational control must adhere to CLP’s prescribed limits on SO₂, NO_x and total PM, or they must fully comply with local regulations, whichever is more stringent. These emissions are monitored by continuous emissions monitoring systems. Aware of the increasing focus on mercury emissions from coal-fired power plants, CLP has also been monitoring and reporting mercury quantities from its coal-fired power plants since 2021.

In addition to incorporating state-of-the-art air emissions control technologies and mitigation measures into its plant management, CLP has also designed new gas-fired power stations with advanced generation technologies. These new technologies enhance electricity generation efficiency, and are contributing to the further reduction in air pollutants and greenhouse gas emissions.

Coal-fired power plants, such as Yallourn, Mount Piper and Castle Peak Power Stations, are the main contributors to the Group's air emissions and the emissions metrics are largely influenced by these plants’ performance. CLP uses a combination of a managed fuel mix and advanced technologies to limit its air emissions.

CLP had set Group-wide medium- and long-term emissions targets for the years 2025 and 2030 to guide further improvements in reducing air emissions of NO_x, SO₂ and PM. The emission targets scope covers all power plants under its operational control.

The 2024 results related to the emission targets and progress are presented in the following table:

In 2024, CLP cut emissions of NO_x, SO₂ and PM by 26%, 18% and 16% respectively compared with the baseline year of 2021, in line with its emission targets and is slightly ahead of the PM emissions target set for 2025. 

Following the divestment of a majority stake in the Fangchenggeng coal-fired Power Station in Mainland China, and excluding assets in India, particularly the coal-fired Jhajjar Power Station, overall emissions were significantly reduced. By implementing a strategy of fuel diversification and consistently maintaining the effectiveness of emission control facilities, emissions can be further reduced.

Key initiatives and programmes in 2024 included:

• Advanced air emission control systems
  In Hong Kong, the new 600MW Unit D2 combined-cycle gas turbine generation unit went into service at Black Point Power Station in April, further lowering air emissions and providing a lower-carbon electricity supply. This follows the retirement of three of the four coal-fired units at Castle Peak A Power Station, which had a combined capacity of 1,050MW, in 2024.
  
  In Australia, the new 320MW Tallawarra B gas turbine generation unit went into service at Tallawarra Power Station in June. This plant is designed to run on a mixture of natural gas and hydrogen, thereby lowering emissions and providing a lower-carbon electricity supply. It is also a fast-start peaking generator that provides dispatchable capacity and can respond quickly to changes in power demand, bolstering supply reliability as more renewable energy enters the grid.

• Upgrade of emissions monitoring systems
  EnergyAustralia has installed an ambient air monitoring network consisting of three real-time dust monitors placed near the sensitive receivers around the Yallourn Power Station and its mine. The data provided by these monitors enables early detection and proactive management of the point source ambient emissions from both the power station and the mine, thereby improving overall air quality. Besides, installation of the Particulate Matter Continuous Emissions Monitoring System (PM-CEMS) at Mount Piper Power Station is delivering accurate real-time data for better management of the filter bag-house and a reduction in stack dust emissions.
• Optimisation of Castle Peak Power Station’s Selective Catalytic Reduction (SCR) and minimisation of unreacted ammonia slip
  In 2024, CLP Power conducted a review of Selective Catalytic Reduction (SCR) optimisation at Castle Peak B Station. Based on the review and NO_x removal efficiency test results, ammonia injection was optimised to maximise NO_x reduction efficiency. Following this review, SCR operations were further optimised to maximise NO_x reduction while minimising unreacted ammonia slip. The optimised usage of the SCR catalyst is extending its life and reducing the chemical usage of urea, as well as the generation and disposal of chemical waste.

• Educating and empowering operators on emissions monitoring and control
  In 2024, EnergyAustralia introduced a new mandatory environmental awareness training programme for all its employees and major contractors. Customised for each EnergyAustralia site, the training highlights key environmental risks and control measures for staff and contractors. Given air emissions is a key matter for EnergyAustralia’s operations, the training aims to enhance the awareness and capabilities of staff and relevant contractors in emissions control, prevent emission exceedances and improve ambient air quality.

• Control of fugitive GHG emissions from electrical equipment
  CLP is striving to reduce its SF₆ emissions from high voltage equipment by enhancing operational efficiency, performing maintenance on SF₆ equipment and taking immediate corrective actions against SF₆ leakage due to equipment defects. Following a trial of non-SF₆ gas switchgears at the distribution level in 2023, the first non-SF₆ 132kV transmission transformer with bio-degradable insulation fluid was commissioned at a Hong Kong substation in October 2024. The performance of non-SF₆ gas switchgears at both distribution and transmission levels will be reviewed, and CLP will continue to explore measures to reduce SF₆ emissions from electrical equipment and introduce sustainable alternatives.

Through the EDD and EIA during the project design and construction stage and the EMS during the operation stage, all hazardous and non-hazardous waste is managed appropriately and in accordance with local regulations. Following the waste reduction hierarchy, CLP prioritises waste reduction and then reuse and recycling rather than disposal. CLP also encourages the adoption of CE principles throughout the project cycle, from design to end-of-life. If hazardous waste has to be collected for recycling or disposal, it is handled by licensed contractors in accordance with local regulatory requirements.

The main operational by-products of CLP’s coal-fired power stations are coal ash from coal combustion and gypsum from the flue gas desulphurisation process. CLP actively manages these by-products according to the waste management processes and procedures outlined in the EMS. Rather than disposing of them, CLP endeavours to reuse them for construction and other applications in line with circular economy principles and in accordance with local regulations and practices.

While CLP’s regular operations produce relatively small amounts of solid and liquid waste, projects involving demolition and construction usually increase the generation of non-hazardous solid waste. These waste streams are addressed and monitored under the EMS, and incorporate CE concepts to minimise waste and pollution. CLP also collaborates with its suppliers in identifying recovery and recycling opportunities, and works to drive behavioural changes among its own employees. This includes setting up recycling facilities at power stations and office premises, and providing e-learning courses on circular economy principles and waste management.

CLP monitors waste generation on a monthly basis by tracking the solid and liquid forms of hazardous and non-hazardous waste produced and recycled at its facilities.

Reviews of all the ash impoundments at CLP-owned plants (i.e. the various ash lagoons at Castle Peak Power Station in Hong Kong and Yallourn Power Station in Australia) have identified them as having low hazard potential and satisfactory structural integrity.

CLP has implemented various measures and initiatives to reduce waste and increase reuse and recycling during electricity generation and other operations.

It recycles its hazardous and non-hazardous solid and liquid waste where feasible and sells by-products such as ash and gypsum for reuse in other industries.

Different assets generate varying types of waste. Fossil fuel plants are the main contributors of waste generated. The amount of waste produced and recycled is not directly related to the amount of electricity sent out, but can be affected by maintenance and construction activities as well as local waste facilities and treatment practices.

CLP set Group-wide medium- and long-term waste targets for the years 2025 and 2030 in terms of a percentage reduction of total waste produced, including by-products produced by the coal-fired power plants, against the base year of 2021. In addition, waste targets for the year 2025 of 100% were set for the recycling of Waste Electrical & Electronic Equipment (WEEE), scrap rechargeable batteries, scrap metals and inert construction waste and for the removal of single-use plastics in catering facilities.

In 2024, total waste products from the Group’s operations were reduced by 68% compared with the target-setting baseline year of 2021, slightly ahead of the waste target set for 2025.

The decrease was mainly contributed by the divestment of a majority stake in Fangchenggeng coal-fired power station in Mainland China, the exclusion of India's assets, particularly the coal-fired Jhajjar Power Station, and various waste management initiatives at certain assets.

Coal ash from coal combustion and gypsum from the flue gas desulphurisation process remain CLP's main waste products. 

All Waste Electrical and Electronic Equipment (WEEE), scrap rechargeable batteries, scrap metal and inert construction waste were fully recycled in 2024 and single-use plastics in catering facilities were also removed in 2024, based on local regulatory policies and infrastructure available for recycling. Looking ahead, CLP will continue to refine the waste management process and promote the implementation of CE principles as well as explore CE improvement opportunities throughout the project cycle. 

The waste target scope covers all operating assets under CLP’s operational control. The 2024 results relating to the waste targets and their progress are shown in the following table:

Key programmes and initiatives in 2024 included:

• Circular use of bottom ash from Mount Piper Power Station
  Ash is typically the largest waste stream from coal-fired power stations. EnergyAustralia's Mount Piper Power Station is collaborating with an Australian building products company by utilising its bottom ashes to make bricks.
• Extending the useful life of equipment in solar and wind farms in Mainland China
  CLP China is embracing circular economy principles in several initiatives aimed at prolonging the lifespan of assets at its solar and wind farms. At Lingyuan and Xicun Solar Farms, spent photovoltaic modules are repurposed for second-life applications, such as power supplies for lighting. At Sihong and Huai'an Solar Farms, enhanced repair approaches are used to maintain existing equipment for extended use, including replacing quick plugs and sockets for solar plant equipment repairs. At Laiwu Wind Farm, information supplied by the Original Equipment Manufacturer (OEM) is being used to identify repairable waste components, such as heaters, pitch electromagnetic brakes and relays, that can extend the equipment’s useful life.
• Providing new uses for end-of-life assets in Mainland China’s solar and wind farms
  CLP China is using circular economy concepts in the recycling of solar panel waste. In 2024, Jinchang, Sihong and Huai'an Solar Farms recycled over 2,500 solar panels. For wind farms, CLP China is collaborating with a leading wind turbine manufacturer and a certified materials company to recover and repurpose retired wind turbine blades in Shandong Region. The resulting fragments are being recycled into new products, including water pipes, manhole covers, park benches, railings, signage and other construction materials, as well as household items.

• Enhancement of waste management in offices
  In Hong Kong, a series of awareness campaigns, including promotion booths, green tours, DIY workshops, quizzes and seminars, were held throughout the year to educate staff about circular economy concepts and the importance of source reduction and recycling in Hong Kong. CLP Power also increased the recycling facilities at its offices and rolled out a web-based platform of recycling information for staff. In Australia, a training programme for all corporate office users was run to facilitate better waste management in corporate offices.
• Local recycling of Waste Lead-Acid Battery (WLAB) in Hong Kong
  The implementation of circular economy concepts for local Waste Lead-Acid Battery (WLAB) recycling marks a significant environmental advance for CLP Power. Lead-acid batteries are used extensively in vehicles and backup power systems. Previously, these batteries were exported overseas for recycling, generating substantial carbon emissions per tonne of shipped batteries. Collaboration with a local WLAB recycling supplier enabled local recycling in 2024, significantly reducing the related carbon footprint.
• Adoption of sustainable development principles with circular economy concepts for substation projects
  CLP Power is adopting circular economy concepts for the construction of transmission substations, to minimise materials use and waste disposal. During the substation construction period, several initiatives are implemented to eliminate, minimise, or reduce waste arising from construction activities. For example, used water is collected and treated for site cleaning, and waste generated at the construction site is sorted for recycling as far as practicable. The steel beams used for excavation and lateral support are also reused or recycled.

CLP is working to reduce the amount of fresh water it uses for its operations, and to minimise the impact of new energy projects on water systems. CLP’s power stations carry out a range of water conservation initiatives depending on their site conditions, operational situation and age. The amount of water which can be recycled also depends on factors such as location, power station design and local regulatory requirements.

There are two major water concerns that affect CLP. One is that water use in its power plants may impact local water quality and contribute to local water scarcity. To address this, EIAs are carried out at the planning stage of new projects, in accordance with local requirements, to ensure that any water use impacts associated with project construction and plant operation are managed and mitigated to an acceptable level.

The second concern is water security at CLP’s fossil fuel and hydropower generation assets. Four of CLP's six fossil fuel plants under operational control use seawater for cooling. Where seawater cooling is not feasible, CLP strives to minimise its use of freshwater and instead adopt water recirculation processes. Solar farms also use water for the cleaning of solar panels, but the amount required is comparatively small. These measures help limit the risks caused by water security issues.

CLP assesses water risks associated with its new projects through systematic environmental due diligence and using globally recognised tools such as WRI Aqueduct. Its assessments cover parameters such as water availability, water sensitivity, water stress mapping, potential competing use with other stakeholders and the management strategies in each region. Where a water supply risk is identified, the Company engages with local stakeholders to understand their needs and with local water suppliers to mitigate or resolve the issue. The latest assessments across the Group indicate that its current water supply regimes are stable and the overall risk of substantial impact is minimal.

The quality of CLP’s water discharges must also meet licensing and regulatory standards. Under CLP’s EMS, the adverse impacts of water discharges are identified, monitored and controlled under programmes which are reviewed on a regular basis. Specific emergency response plans have also been developed to prevent and address the spillage or leakage of pollutants. As a result of the wastewater treatment processes put in place, none of CLP's operations had any material impact on the water bodies associated with them.

To monitor its water-use efficiency, CLP tracks its freshwater withdrawal, discharge and intensity (based on electricity sent out). Internal targets are set each year to encourage continuous improvement in water management practices. CLP also participates in the CDP water security questionnaire. By sharing water resource management data through the survey, CLP is able to benchmark its practices against industry peers.

In 2023, CLP reviewed its environmental target-setting process and refined its water targets to reflect the upcoming retirement of CLP’s fossil fuel plants. CLP has set Group-wide medium- and long-term freshwater consumption targets for the years 2025 and 2030 in terms of a percentage reduction of freshwater consumption quantities against the base year of 2021. It has set an ambitious freshwater consumption target comprising an absolute reduction of 45% to 55% by 2025, and a reduction of 85% by 2030, using 2021 as the baseline. The freshwater consumption target covers all CLP’s operationally controlled assets.

The 2024 results against the Group-wide medium- and long-term freshwater consumption targets are shown in the following table:

Against the group-wide targets in compared with the baseline year of 2021, CLP reduced the freshwater consumption by 51% in 2024 which was in line with the freshwater consumption target. 

The decrease was mainly contributed by the divestment of a majority stake in Fangchenggeng coal-fired Power Station in Mainland China, the exclusion of India’s assets, particularly the coal-fired Jhajjar Power Station and various water conservation initiatives at certain assets.

CLP will continue to track the volume of water recycling in its power stations for continual improvement and share good practices across the Group to maximise the benefit of individual power stations' efforts.

Examples of CLP’s water management are summarised below:

• Enhanced monitoring of process water discharge utilising innovative technology at Castle Peak Power Station
  Castle Peak Power Station is a coal-fired power plant using once-through seawater cooling. During the cooling process, seawater is returned to the sea, often resulting in floating scum at the cooling water outfall. To control scum formation, the station doses anti-foaming agents, as required by regulation. To effectively monitor the cooling water outfall conditions, an Artificial Intelligence (AI) camera monitoring system has been installed at the station. This system delivers real-time monitoring with video analytics of environmental issues such as scum and floating and sends alerts to operators. This enables timely mitigation measures to be taken, ensuring regulatory compliance, and reduces nuisance for nearby residents.
• Initiatives for minimising freshwater consumption in CLP's Mainland China renewable energy assets
  To reduce freshwater use, CLP China has implemented robotic systems in its solar farms for the automatic cleaning of photovoltaic panels. In addition, robotic cleaning systems are also deployed for some wind farms for cleaning of wind turbine towers and blades. The freshwater at the solar and wind power stations is mainly for domestic use and in minimal quantities. Sewage treatment facilities have been set up at the sites, and the treated sewage used for irrigation or gardening. Additionally, water-saving awareness training has been conducted for site staff.
• Reduction of freshwater consumption at Mount Piper Power Station
  To avoid the flooding of the coal mine during heavy rains, Mount Piper Power Station receives significant volumes of mine water from the Springvale Mine for treatment. Besides managing the challenges posed by the increased intake of mine water, the Springvale Water Treatment Plant meets about 80% of the station's daily water needs, significantly reducing the need for freshwater intake.

Freshwater balance