Management Approach

Managing Natural Capital

We use natural capital efficiently and conservatively and aim to continuously improve our environmental performance in line with technological advances and evolving stakeholder expectations.

Group-wide management approach

Our Value Framework includes an overarching Group-wide Environmental Policy. It is supported by a suite of standards and guidelines to mandate good practices and align Group-wide practices. The material environmental issues covered include:

  • environmental impact assessment
  • environmental monitoring
  • environmental management system development
  • environmental due diligence 
  • data management systems
Strategies and procedures

Environmental Management System Standard – We require power generation facilities over which we have operational control to achieve third-party certified ISO14001 environmental management systems within two years from commencement of operation or acquisition.

We are pleased to report that in 2017, all generation assets over which we have operational control achieved ISO14001 certification on time, with our Xicun solar plant and Xundian wind farm in Mainland China achieving ISO14001 certification in 2017.

Download the environmental management systems and measures in our assets


Monitoring and follow-up

Environmental information is managed using the Group Operations Information System (GOIS), a customised system launched in 2014 which is also used to collect and manage data in relation to asset management, safety and community initiatives. GOIS is the first cloud-based Group-wide reporting system for CLP, and provides a user-friendly environment with a built-in internal data approval sequence and automated presentation and reporting functions.

Environmental Regulatory Non-Compliances

We voluntarily follow other internal standards that go beyond legal requirements. On the business development side, we assess our potential environmental liability before we commit to projects. CLP’s Pre-Investment Environmental Risk Assessment process ensures that environmental liabilities are fully considered for every project as part of the approval process by the Investment Committee. We have recently strengthened our environmental due diligence process as part of the pre-investment risk assessment process.

As we enter into operation stage, for all assets under our operational control, when an incident occurs, a record is compiled and each incident is classified and recorded according to notifications from local authorities and based on prevailing regulatory or legal definitions. Each incident is classified and recorded at the time of notification of the fine or prosecution. Instances of Environmental licence limit exceedances and other non-compliances and Environmental regulatory non-compliances resulting in fines or prosecutions, are mutually exclusive.

Material Topic : Materials
Most Material Topic : Emissions
Most Material Topic : Energy

Energy and greenhouse gas emissions

Our stakeholders expect us to use energy more efficiently and opt for renewable energy sources where practicable. As the world is moving towards a low carbon future, it is in our business interest to decarbonise our generation portfolio. 

In our Value Framework, our Environmental Policy Statement commits us to use all resources, including fuel, water and other natural resources efficiently and conservatively. We are also committed to develop and implement strategies to address renewable resources and global climate change as key issues for the energy sector.

Goals and targets 

Refer to our Climate Vision 2050 for our goals and roadmap on carbon reduction.

Monitoring and follow-up 

Fuel Consumption for Power Generation - Fuel consumption calculations for facilities under CLP’s operational control depend on the type of fuel. For coal consumption, fuel consumed is calculated based on invoices and receipts for coal deliveries as well as recorded actual coal used in the combustion process. Gas consumed for electricity generation is based on calculations from meter readings recorded at the respective facility. Oil consumption for electricity generation is calculated based on measurement of changes in the volume of oil storage tanks adjusted for destiny and calorific value. Fuel consumption for power generation is reported in Terajoules (TJ).

Carbon Emissions Intensity – This is an important indicator to track progress against our “Climate Vision 2050”. Data is collected directly from most of our facilities but for a few minority-owned facilities where we have difficulty in directly obtaining the data; best conservative estimates are made based upon historical performance data or benchmarking with similar facilities.

Our carbon emissions are tracked at both facility and Group levels under the categories of Scope 1: Direct GHG Emissions and Scope 2: Indirect GHG Emissions as defined by the GHG Protocol. Due to data availability constraints, we include Scope 1 and Scope 2 emissions for those facilities which fall within our Environmental Scope, and Scope 1 emissions only for those facilities which fall outside our Environmental Scope. The Group’s carbon intensity calculation is based upon net electricity sent-out from all operating facilities across our portfolio.

Air emissions


Air emissions remain as one of the most material environmental aspects of our generation portfolio. Although our overall air pollutant emissions intensities have reduced because of our expanding nuclear and renewable energy portfolio, the net emissions from our fossil-fuel power stations is still an issue high on our agenda.

Strategies and procedures 

Our Power Plant Air Emissions Standard stipulates any fossil fuel-based power plant developed after the effective date of our Power Plant Air Emissions Standard is required to operate within CLP’s prescribed limits on sulphur dioxide (SO2), nitrogen oxides (NOX) and particulates emissions, or to comply with local regulations, whichever is more stringent. This means if there is a lack of local emissions regulations or the levels are not as stringent as our internal standard, we are committed to go beyond the local requirements.

We take great care in conducting our environmental impact assessments (EIA), and are fully committed to fulfilling the requirements and recommendations stipulated in the EIA reports and local regulations. We also go beyond compliance in less developed countries where regulations are not as mature.

Apart from incorporating state of the art air emissions mitigation measures in our power stations, we also design our new power stations with advanced power generation technologies to generate electricity as efficiently as technology allows, thus lowering the amount of emissions.

Monitoring and follow-up 

We continuously monitor air emissions (SO2 / NOx / Total PM) for facilities under CLP’s operational control through real-time systems installed on site. We supplement this approach with stack sampling and mass-balance calculation methodologies, amongst others, accepted by local regulations if and when it is required by regulators or we deem it necessary.

Material Topic : Effluents and Waste
Material Topic : Water



Our power generation portfolio uses water in a variety of ways. At fossil-fuelled power stations, it is used as process water and for cooling. The majority of this water is discharged back to source after appropriate treatment to minimise the environmental impact. Water is also the main element for power generation in hydro power stations. At other renewable energy power stations, such as wind and solar, the use of water is on a much smaller scale, but still essential for some processes, e.g. routine cleaning.

Strategies and procedures  

Our operational-controlled facilities monitor their total water withdrawal and discharge. We manage our water resource risks through a number of means. We assess the water availability in the planning stage of projects including the likelihood of water scarcity in the future. During operations, we ensure that all requirements and necessary engagements with local stakeholders are in place to maintain our licence to operate.

Monitoring and follow-up 

We conducted an in-depth assessment on water risk throughout our portfolio in 2017. The assessment covered parameters such as water availability, water sensitivity, water stress mapping, potential competing use with other stakeholders, and the management strategies in place in each of our regions. The results of the assessment indicated that we have a sufficiently robust management regime in managing our water risks. We will continue to monitor our water use, and manage this precious resource efficiently.

Our power stations, in particular our fossil-fuel fleet which uses more water, carry out a range of water conservation initiatives depending on site-specific conditions, operational situations and age. We also place high emphasis on sharing initiatives across CLP Group to maximise the benefit of an individual power station’s efforts.

Material Topic : Effluents and Waste



The nature of our power stations, as well as the different stages of our power generation process, produces different types and volumes of waste. We endeavour to reduce the waste we produce and work with qualified parties and partners to reuse or recycle our waste as much as we can. Broadly speaking, the volume of solid and liquid waste we generate is relatively small, and the volumes correlate with our level of activities. Projects that involve demolition and construction will produce more inert waste.

Strategies and procedures  

We avoid the use of hazardous materials and use alternatives where possible. We find ways to reduce the volume of waste and recycle and reuse as much as possible. At our coal-fired power stations, the most significant amount of waste generated is coal ash from coal combustion and gypsum from the flue gas desulphurisation process.

Monitoring and follow-up 

We monitor our waste generation by tracking the amount of both solid and liquid forms of hazardous and non-hazardous waste produced and recycled by our facilities on a monthly basis.

Nuclear waste in the Guangdong Daya Bay Nuclear Power Station

In accordance with national policy and international practices, Guangdong Daya Bay Nuclear Power Station (GNPS) stores its spent nuclear fuel onsite in a dedicated storage pool for each reactor for a number of years before passing it to a service provider licensed by the Mainland Chinese Government for reprocessing. The operation of the service provider is supervised by the National Nuclear Safety Administration (NNSA) and its environmental impact is monitored by the Ministry of Environmental Protection (MEP). The policy in Mainland China on reprocessing spent nuclear fuel is similar to that of a number of European countries.

Intermediate to low-level solid radioactive waste arises from operational processes and technical maintenance of the systems and equipment at GNPS. The waste is packed and stored in a dedicated facility onsite on an interim basis, and is provided with security to prevent unauthorised access. The waste will be transferred to a final repository operated by a separate service provider away from GNPS, using the shallow burial method, which is commonly adopted in the United States, France and the United Kingdom. The operation of the repository is expected to come under the supervision of the national nuclear regulator according to the relevant nuclear safety regulations.

As a minority shareholder of GNPS, CLP is not in the position to report the mass or inventory of high level radioactive waste (HLW) from reprocessing of the spent fuel from the plant, as this is the responsibility of the licensed service provider. The licensed service provider is obliged to dispose of HLW safely as required by the Chinese authorities.

Material Topic : Biodiversity


Operational responsibilities 

We manage our biodiversity impacts on a site-specific basis since our operations have different levels of interaction with the local ecosystems, depending on factors such as location, the level of development in the vicinity and the surrounding environment.

Strategies and procedures 

The regions we operate in face different levels of regulatory controls on biodiversity, from assessment requirements to ecological compensation. In our projects in Mainland China, we have been facing increased attention on biodiversity conservation. We welcome a stronger regulatory regime, as it provides a level playing field for companies such as ourselves who have always tried to move beyond compliance. This is because the additional effort often comes at a higher cost for us. A clearer regime helps reduce regulatory risk especially in a subject such as biodiversity which is often less well understood by the public.

In addition to implementing an internal Environmental Impact Assessment standard that mandates an environmental assessment for all new projects, a Biodiversity Impact Assessment Guideline has been implemented. We believe that to properly address our biodiversity impacts, we need to conduct biodiversity impact assessments in a more systematic and accurate manner. Any new operations that could affect IUCN Red List species and national conservation list species would be flagged well before any investment decision is made.