Sarawak Hydropower: Sustainability & China
Sarawak Hydropower: Sustainability & China
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The Bakun Hydroelectric Dam in Sarawak. Picture: IEEE Curtin Malaysia Student Branch,
https://www.facebook.com/IEEE.CurtinMalaysia/photos/a.558865270846311/5054565917942868
/.
* Tham Siew Yean is Visiting Senior Fellow at ISEAS – Yusof Ishak Institute and Emeritus
Professor, Universiti Kebangsaan Malaysia. She thanks Siwage D. Negara, Lee Poh Onn
and Winston Peng (of The Society of Certified Risk Professionals), for useful comments.
The usual caveat remains.
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EXECUTIVE SUMMARY
• China has become the most significant foreign partner in Sarawak’s hydropower
development, as its extensive knowledge and experience in this domain dovetails
with Sarawak’s ambitious programme to develop hydropower for its own needs and
for export to the region.
• The construction of large dams has inevitably attracted controversy and protests over
its negative impact, particularly in the dislocation of local communities and
endangerment of wildlife and the natural environment. China’s track record in this
field and Sarawak’s earlier dam construction projects had raised questions over their
commitment to address such sensitivities and meet mandatory requirements for
ecological sustainability. In this context, both Sarawak and China have stepped up
their game to alleviate these concerns.
• Sarawak Energy, the key stakeholder in Sarawak’s dam projects, has committed to
attaining the international Hydropower Sustainability Council (HSC)’s performance
standards and certification. Providing a roadmap towards achieving this goal and
increasing the disclosure of performance metrics will help to enhance the
sustainability claims of the company to regulators, investors and consumers in
Malaysia and the region.
• Likewise, China has declared ambitious goals and enunciated policies towards
improving sustainability performance. However, this must be followed through with
rigorous implementation and regulatory enforcement on the reporting of
environmental sustainability measures and metrics, in order to reverse the image of
China as a sustainability laggard, especially in its investments and construction of
dams outside the country.
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INTRODUCTION
In 2008, Malaysia launched five corridors of development, including the Sarawak Corridor
of Renewable Energy (SCORE). SCORE differs fundamentally from the other Malaysian
economic corridor projects in its predominant emphasis on hydropower, aiming as it does
to use the state’s vast network of rivers as a source of energy. Sarawak, unlike Peninsular
Malaysia, also has topographic features and rainfall that enhance its hydropower resources.
Hydropower is also chosen because it is a renewable form of energy, with low emissions.
China is the largest hydroelectric power-generating country in the world. It also has the
largest dam in the world, namely the Three Gorges dam, and half of all the large dams
worldwide. Chinese leaders and hydropower State Owned Enterprises (SOEs) continue to
uphold and promote hydropower as a source of clean energy for China and the world.3
Negative concerns are deemed as technical issues that can be solved by the state.
Given the saturation in China’s home market, external markets for hydropower and dam
construction have become crucial, making hydropower projects an important component of
China’s Belt and Road Initiatives (BRI).4 In fact, the energy sector constitutes the largest
sector in Chinese BRI engagement in 2013-2021.5 In particular, China’s engagement in
green energy and hydropower amounted to USD10 billion in 2021. The trend also shows a
decrease in investment and an increase in construction projects.
Chinese investors have already invested in a majority of the hydropower projects in Laos,
Cambodia and Myanmar.6 Between 2006 and 2011, China was responsible for more than
USD6.1 billion to finance the addition of 2729 MW of hydro capacity in the three countries.
There are currently three large hydropower dams operating in Sarawak, and a fourth is being
built. As much as 67.9% of the total installed capacity in the state’s electricity supply was
sourced from hydropower in 2018 (latest year available).7 Sarawak’s hydropower ambitions
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also make the state a natural attraction for China to be involved in dam development there,
be it in terms of investments or construction.
Twelve hydropower projects were planned for the period 2008-2020 to meet the power
demand for SCORE, as well as Sabah and Peninsular Malaysia.8 Out of these, three are up
and running while a fourth is being constructed.
Japan was engaged in the construction of the first dam, the Batang Ai dam which was
commissioned in 1984 (Table 1). China is involved in the three subsequent dams, including
Baleh dam that is currently being constructed. The Chinese SOEs involved are Sinohydro,
Three Gorges, Gezhouba and Yellow River Engineering Consulting.
Bakun dam, the first project with China’s involvement predates the launch of the BRI
initiative in 2013, and offers interesting insights on mega dam construction in Sarawak. It
is, by far, the most controversial as its completion spanned over five decades.9 Although it
was first mooted in the 1960s, numerous challenges dogged the construction of this dam,
from technical, economic, political, legal and regulatory, to social issues. It should also be
noted that the Bakun project, as a federal project, initially aimed to supply electricity to
Peninsular Malaysia by undersea cables across the South China Sea, but this idea was
subsequently abandoned due to the costs involved and the possibility of leakages.10
Although initiated by Australia, pressures from green and human rights groups over the
inevitable relocation of the longhouse communities as well as massive cost over-runs led to
the withdrawal of Australian interests from the project. The Chinese then took over the
project, with Sinohydro which is part of PowerChina, 11 managing to bring it to
completion. 12 Sinohydro was established as a state-owned (SOE) hydropower project
contractor in the 1950s, and has participated in the construction of China’s large and
medium-scale hydropower projects. It established a joint-venture (30% Sinohydro and 70%
Sime) with Sime Engineering Berhad, which is part of Sime Darby, a government-linked
company (GLC), for the Bakun project, building the dam as part of an Engineering
Procurement Construction (EPC) / turnkey contract.13 The project was funded by federal
and state agencies including EXIM bank, China’s official export credit agency that funded
most of China’s overseas dams.14 The official cost is RM7.4 billion. Subsequently, Sarawak
Energy, the state-owned investment holding company of Sarawak that generates, transmits,
distributes and sells electricity acquired Sarawak Hidro, the owner and operator of Bakun
Hydroelectric Plant from the federal government at RM2.5 billion, in 2017.15 RM2.5 billion
is reportedly the original cost of the dam.16
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Work on a second dam, the smaller Murum Dam, was started in 2008, and its first generator
was commissioned in December 2014. The Murum dam is the second hydroelectric project
(HEP) to be developed by Sarawak Energy (SE) after the Batang Ai HEP in the 1980s. The
main EPC (Engineer, Procure, Construct) contractor is Three Gorges Development
Company (M) Sdn. Bhd. and Yangtze Three Gorges Technology & Economy Development
Co. Ltd.17 Three Gorges built China’s largest hydro dam – the 22,500MW Three Gorges
dam, and has extensive dam-building experience. SE apparently issued RM3 billion Islamic
bonds to fund the dam.18
Two dams were subsequently slated for development, namely the Baram and Baleh dams.
Baram dam was however called off by the former Chief Minister of Sarawak, the late Datuk
Patinggi Tan Sri Datuk Amar Adenan Satem, in March 2016, following massive protests by
affected communities.
Baleh dam, like the Murum dam is being developed under SE, and it is slated for
commissioning in 2026. SE is moving towards exporting electricity, first to Sabah, and then
to the regional market. It is reportedly funding Baleh dam through its own internal funds
while RM5.5 billion is obtained from sukuk financing.19 The main civil works contract has
been awarded to a joint venture formed by China Gezhouba Group Company Ltd and local
firm Untang Jaya Sdn Bhd.20 The former is a large state-owned development company
which has built and financed dams in over 30 countries in Asia and Africa.21 Yellow River
Engineering Consulting Ltd, has provided designs for more than 10 concrete-face rock-
filled dams worldwide. Untang Jaya, is a local Dayak Iban contractor from the Baleh/Kapit
area, that was established in 2000, and holds 30% of the joint venture.22
Table 1. Large Hydropower Dams in Sarawak
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and loans from
EXIM bank
Sources: *: https://www.power-technology.com/marketdata/batang-ai-malaysia,
https://www.adb.org/sites/default/files/evaluation-document/35473/files/ss-36.pdf, page 28 converted at
exchange rate then from https://data.worldbank.org/indicator/PA.NUS.FCRF?locations=MY /;
**: https://www.jstage.jst.go.jp/article/seas/5/3/5_373/_pdf/-char/en, and
https://www.malaymail.com/news/malaysia/2013/10/02/a-g-report-mismanagement-cost-bakun-dam-
operator-extra-rm1.3b/535411 ; ***: https://www.sarawakenergy.com/what-we-do/power-generation,
https://www.malaymail.com/news/malaysia/2016/05/18/murum-dam-cost-rose-by-rm530m-federal-audit-
shows/1122545 ;
****: https://www.nsenergybusiness.com/projects/baleh-hydroelectric-power-project/ ;
https://www.malaymail.com/news/malaysia/2021/10/05/nothing-to-worry-about-baleh-dams-cofferdams-
seepage-says-sarawak-
energy/2011037#:~:text=The%201%2C285%2Dmegawatt%20Baleh%20dam,renewable%20energy%20for
%20the%20state.
GOVERNANCE
Environmental and social issues are the most common problems encountered in the
development of hydropower, especially by large dams. Environmental Impact Assessment
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(EIA) is a common project-specific tool used to assess the positive and negative
environmental, economic and social impacts of a project. When properly conducted, an EIA
can help minimise adverse environmental effects by identifying the risks, and reducing
conflicts through community participation. It is therefore used to help decision makers make
informed decisions.
There has however been an improvement in terms of adherence to the mandatory EIA
requirements after the Murum dam. The Social and Economic Impact Assessment (SEIA)
for Baleh dam was conducted and submitted to the Natural Resources and Environment
Board (NERB) for approval before construction work started. It was reported in December
2015 that the SEIA report was made available for public viewing at various district and
government offices in Sarawak. It was also made available for external review by
stakeholders such as government agencies and NGOs, as part of the stakeholder review
process, around Sept 2014. Public viewing is reportedly possible at NERB’s office, if
permission is granted. But the report has not been uploaded at either NERB nor Sarawak
Energy’s web-site, nor at Malaysian Administrative Modernisation and Management
Planning Unit (MAMPU)’s open data portal.
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l EIA report is not available for
public viewing
Bakun dam has become an example of poor governance in large dam building, or the case
study in numerous studies documenting that phenomenon. These studies typically lay the
blame for the adverse effects on the environment and the displacement of indigenous
communities and wild life on the Chinese company (Sinohydro), while neglecting the fact
that the Malaysian partner holds 70% of the equity and local governance and local
stakeholders have a role to play in the governance of the project.
Governance of any project, especially large-scale and expensive projects, requires both
source countries of investors and builders as well as host countries to play complementary
roles. Host economies need to have political willingness and capacity to maintain,
implement and enforce stringent environmental laws and regulations. 27 Regardless of
whether it is an FDI or a construction project, weak local requirements open the door for
minimal safeguards from dam builders. This is especially the case where short-term
contracts are concerned, such as engineering, procurement and construction (EPC) contracts
which do not incentivise contractors to deal with long-term social and environmental
problems.28
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SE became a member of the International Hydropower Association (IHA) in 2010. It is also
one of the early adopters of the guidelines in IHA’s Hydropower Sustainability Assessment
Protocol (HSAP). According to SE, it is currently adopting the HSAP for the ongoing
1,285MW Baleh Hydroelectric Project. This is a significant shift as it seeks to embed
sustainability best practices into the project’s development and operation.
Given SE’s commitment to the HSAP, targeting the HSC’s ESG performance standard and
certificate is a natural progression on its sustainability journey. Going forward, a roadmap
towards the attainment of this certificate will further enhance the ESG standing of the
company. In particular, such a roadmap should include clear targets for the scores of each
dimension in this instrument, as well as an implementation programme. Second, in view of
the increasing demand for disclosures, it is important that the targets, progress and
milestones achieved, including short falls in outstanding metrics and plans to overcome
these shortfalls, need to be enumerated in the sustainability reports in order to align
commitments with disclosures. This, in turn, will enhance the sustainability claims the
company makes to regulators, investors, and consumers in Malaysia and to the region as
well, in view of its regional ambitions to be an energy exporter.32 Many international leading
companies have in fact improved public disclosure in line with their commitments to
transparency and accountability.
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China as a source of hydropower investors and contractors
The environmental risks associated with large-scale BRI infrastructure projects, including
the construction of large dams, gave rise to many negative reports on such projects. China’s
“Green Investment Principles for the Belt and Road” (GIP), launched in November 2018,
is an attempt to address sustainability issues in BRI projects. As of June 2021, the GIP
expanded its membership to 39 signatories and 11 supporters from 14 countries and regions
around the world.33 The signatories have jointly agreed to ensure that BRI’s investment and
operations are environmentally friendly, climate resilient and socially inclusive. As finance
plays a key role in BRI projects, the green principles agreed upon by major bankers are
meant to incentivise the use of sustainable principles in investment decision-making as well
as in daily operational procedures. The seven principles included in the GIP are: (i)
embedding sustainability into corporate governance, (ii) understanding ESG risks, (iii)
disclosing environmental information, (iv) enhancing communication with stakeholders, (v)
utilising green financial instruments, (vi) adopting green supply chain management, and
(vii) building capacity through collective action.
China continues to press on with new and updated guidelines. For example, in September
2021, Beijing issued the “Green Development Guidelines for Overseas Investment and
Cooperation”.34 Significantly, companies are encouraged to adhere to international norms
when local standards are inadequate, to engage with host country environmental protection
organisations, and to focus on non-fossil energy technologies. Environmental impact
assessments and due diligence based on international standards are other promoted
measures.
But since all these policy statements are merely guidelines, they are toothless without
enforced implementation by China’s own regulatory bodies. Effectiveness still depends on
the commitment from the joint stakeholders, namely the host economies and China, to
adhere to these guidelines in the negotiation and implementation phases of BRI-related
projects. Thus, it is not surprising that China is deemed as a sustainability laggard. Certainly,
this image is supported by the MSCI median ESG score35 that aims to ascertain the ESG
performance of countries. In 2021, China was ranked 47 out of 50 countries measured. The
UK was ranked first, followed by Australia, Japan and the US.36
At the firm level, regulatory requirements are needed to push companies towards
sustainability reporting. For example, China’s first mandatory ESG information reporting
scheme was proposed by the Ministry of Ecology and Environment (MEE) in October
2021. 37 The proposed measures require relevant companies to disclose a variety of
environment-related information. When implemented, this would shift China towards
establishing a nationwide mandatory environmental disclosure system by 2025. Global
trends further indicates that ESG reporting is shifting beyond mere narratives towards
common ESG metrics for reporting purposes.38
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CONCLUSION
China’s involvement in hydropower development is driven by push and pull factors. Push
factors include China’s belief that hydropower is a source of clean energy that can be
harnessed for development and for the export of the country’s capacity and knowledge in
dam building. Sarawak’s green energy ambitions focussing on hydropower production for
itself and for export, dovetails nicely with China’s outward strategies.
Although the construction of large dams is littered with environmental sustainability issues,
there are increasing signs of improvements with greater adherence towards regulatory
compliance in the current construction of the Baleh dam. This is also boosted by Sarawak
Energy, the key stakeholder in the green energy ambitions of Sarawak, and its adoption of
IHA’s Hydropower Sustainability Assessment Protocol (HSAP) for the development of
Baleh dam.
While China has been heavily criticised for the negative environmental impact of its large
dam constructions, these projects really do require both the host and source countries to
work together.
For Sarawak Energy as a key stakeholder in dam development, targeting the HSC’s ESG
performance standard and certificate is a natural progression along its sustainability journey.
Providing a roadmap towards the achievement of this standard as well as improving
transparency through increasing disclosures of the metrics on this roadmap will enhance the
sustainability claims made by the company to regulators, investors and consumers in
Malaysia and ultimately in the region as well. This is very important in view of Sarawak’s
ambitions to be an energy exporter.
Likewise, China has put forth many policies and ambitious goals towards improving
sustainability performance. Implementation is key and regulatory enforcement on enhanced
disclosures and reporting of environmental sustainability measures and metrics will
definitely reverse the image of China as a sustainability laggard, especially in its
investments and construction of dams outside the country.
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ENDNOTES
1
See definition in https://www.eia.gov/outlooks/ieo/pdf/industrial.pdf
2
Askari Mohammad Bagher, Mirzaei Vahid, Mirhabibi Mohsen, Dehghani Parvin. Hydroelectric
Energy Advantages and Disadvantages. American Journal of Energy Science. Vol. 2, No. 2, 2015,
pp. 17-20
3
Lila Buckley, Hua Wang, Xiaoxi Zhou and Andrew Norton 2022. What drives safeguarding for
China’s hydropower projects in LDCs? International Institute for Environment and Development
(IIED) Working Paper January 2022. https://pubs.iied.org/sites/default/files/pdfs/2022-
01/20721iied.pdf
4
https://www.greenrecruitmentcompany.com/blog/2020/09/is-hydropower-the-secret-winner-of-
the-belt-and-road-initiative
5
Nedopil, Christoph, 2022. “China Belt and Road Initiative (BRI) Investment Report 2021”,
Green Finance & Development Center, FISF Fudan University, Shanghai.
6
Xunpeng Shi, Lixia Yao, 2019. “Prospect of China’s Energy Investment in Southeast Asia under
the Belt and Road Initiative: A Sense of Ownership Perspective”, Energy Strategy Reviews,
Volume 25, Pages 56-64. https://doi.org/10.1016/j.esr.2019.100365.
7
https://meih.st.gov.my/documents/10620/6d3608ca-ec57-4034-b8b6-28809ee7cd67
8
Suhakam 2009. SUHAKAM’S Report on the Murum hydroelectric project and its impact
towards the economic, social and cultural rights of the affected indigenous peoples in Sarawak.
http://www.suhakam.org.my/wp-content/uploads/2013/12/Murum1.pdf
9
Sovacool, Benjamin K. & Bulan, L.C., 2011. “Behind an ambitious megaproject in Asia: The
history and implications of the Bakun hydroelectric dam in Borneo,” Energy Policy, Elsevier, vol.
39(9), pages 4842-4859, September.
10
https://www.theborneopost.com/2017/09/21/electricity-from-bakun-dam-will-not-be-sold-to-
peninsular-malaysia-cm/
11
PowerChina, is a wholly State-owned company administered by the State-owned Assets
Supervision and Administration Commission and part of the heavy and civil engineering
construction industry.
12
Fam, Shun Deng (2017), “China Came, China Built, China Left?: The Sarawakian Experience
with Chinese Dam Building”, Journal of Current Chinese Affairs, 46, 3, 119–158.
13
Schapper, A, Urban, F., 2021. “Large dams, norms and Indigenous Peoples”, Development
Policy Review 2021; 39 (Suppl. 1): O61-O80. https://doi.org/10.1111/dpr.12467.
14
International Rivers 2008. The New Great Walls: A Guide to China’s Overseas Dam Industry.
https://www.china.tu-
berlin.de/fileadmin/fg57/Lehre/0809_Wasserwirtschaft/China_dam_guide.pdf
15
https://www.sarawakenergy.com/media-info/media-releases/2017/sarawak-energy-completes-
acquisition-of-bakun-hep-from-federal-government
16
https://theecologist.org/2014/apr/22/large-dams-are-uneconomic
17
https://www.business-humanrights.org/en/latest-news/sarawak-energy-fact-sheet-murum-dam/
18
https://www.hydroreview.com/world-regions/malaysia-utility-to-issue-bonds-to-fund-900-mw-
murum/#gref
19
https://www.theborneopost.com/2017/08/03/construction-of-baleh-hep-to-cost-rm8-bln-
seb/#:~:text=KUCHING%3A%20The%20total%20construction%20cost,generated%20funding%2
0and%20sukuk%20financing.
20
http://ir.chartnexus.com/source/2/52/market_news/757/Works%20to%20start%20on%20Baleh%2
0hydro%20dam.pdf. Reportedly the work packages are tendered out.
21
Op.cit. International Rivers, 2008.
22
https://www.pressreader.com/malaysia/the-borneo-post/20160919/281938837383284
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23
https://www.adb.org/sites/default/files/evaluation-document/35473/files/ss-36.pdf . According
the ADB 1999, “The Batang Ai Project was approved in 1981 before environmental guidelines
were developed in ADB and the relevant agencies were established in Malaysia. Therefore, its
preparation did not include an environmental mitigation plan.”
24
Ho, Peter, Bin M.S. Nor-Hisham, and Heng Zhao. 2020. “Limits of the Environmental Impact
Assessment (EIA) in Malaysia: Dam Politics, Rent-Seeking, and Conflict”, Sustainability 12, no.
24: 10467. https://doi.org/10.3390/su122410467
25
See Op cit. Suhakam 2009. Page 6.
26
Maisarah Makmor, Hafez Salleh, Nikmatul Adha Nordin 2020. “Ineffective public participation
for EIA: The cause of environmental issues in Malaysia?”, Journal of Surveying, Construction and
Property (JSCP), 11(1): 83-96.
27
Coenen, Johanna & Bager, Simon & Meyfroidt, Patrick & Newig, Jens & Challies, Edward.
(2020). Environmental Governance of China’s Belt and Road Initiative. Environmental Policy and
Governance. 31. 10.1002/eet.1901.
28
Op cit., Lila Buckley, Hua Wang, Xiaoxi Zhou and Andrew Norton 2022.
29
https://www.sarawakenergy.com/investors/annual-and-sustainability-reports/sustainability-
reports#:~:text=Sarawak%20Energy%20Sustainability%20report%20provides,creating%20value
%20to%20our%20stakeholders.
30
https://www.reuters.com/business/sustainable-business/global-hydropower-industry-launches-
esg-standard-attract-investors-2021-09-
08/#:~:text=LONDON%2C%20Sept%208%20(Reuters),projects%2C%20it%20said%20on%20T
hursday
31
https://blogs.worldbank.org/allaboutfinance/can-esg-disclosure-improve-investment-efficiency
32
https://www.theedgemarkets.com/content/advertise/energising-region-hydropower
33
https://greenfdc.org/green-investment-principle-gip-belt-and-road-initiative/
34
https://chinadialogue.net/en/business/what-chinas-new-guidelines-on-green-development-mean-
for-the-belt-and-road/
35
MSCI Inc. is the world’s largest provider of ESG Indexes. See https://www.msci.com/our-
solutions/indexes/esg-indexes
36
https://www.euromoney.com/article/297g1ykzy4xbli3gtf7cw/esg/chinas-weak-esg-data-
undermines-xis-bold-pledges
37
https://www.fitchratings.com/research/corporate-finance/proposed-rules-may-strengthen-chinas-
esg-disclosure-28-10-2021
38
https://assets.kpmg/content/dam/kpmg/be/pdf/2020/12/The_Time_Has_Come_KPMG_Survey_of
_Sustainability_Reporting_2020.pdf
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