China-ASEAN Power Cooperation & Development Forum 2007
Chinese Hydropower Industry Investment in the Mekong Region – Impacts and
Opportunities for Cooperation: Perspectives from Civil Society
12Zao Noam and Piaporn Deetes
Abstract
China has been a major impetus for economic development in ASEAN countries, especially
for the Mekong region – Burma/Myanmar, Laos, Thailand, Cambodia and Vietnam. China is now globally recognized for its rapid economic development and industrialization, which is
also filtering to its downstream neighbors. Despite social and ecological impacts being
recorded in downstream countries, China can use its increasing linkages with ASEAN as an
opportunity to demonstrate its central promotion of harmonious co-existence with its
neighbors and encourage sustainable development with its Mekong neighbors.
A number of Chinese companies have solidified plans to invest in hydropower projects in
Mekong countries. Most of the power from these hydropower projects is planned for export
to neighboring countries—Thailand and Vietnam—and the rest to yet unidentified markets.
Unmet energy demand in the region is questionable, with Power Development Plans (PDPs)
often over-estimating the actual domestic energy demand. This is often a reflection of
unsound economic non-transparent decision-making, which accrues profit for energy utility
enterprises at the expense of consumers.
Social and environmental impacts from hydropower development in the Mekong countries
must be seriously addressed in order to mitigate damaging impacts to regional economies,
food security and rural livelihoods. Without comprehensive and careful consideration of
hydropower‘s multi-faceted impacts, millions of small farmers and fisher folk whose
livelihoods depend on the richness of the Mekong ecosystems will bear most of the costs.
Civil society in the Mekong region urges the Chinese corporate sector to conduct hydropower
development in the region according to international standards which minimizes socio-
economic and ecological harm. In this way, Chinese hydropower investment will
significantly contribute to sustainable development in the Mekong region.
Introduction
3China is reshaping the river basins that flow through the Greater Mekong Sub-region (GMS),
not just by dams in Yunnan, but also through Chinese large-scale dam investments in
downstream countries, collectively referred to as the ‗Mekong‘ region or mainland Southeast
1 Non-indigenous independent environmental researcher and writer based in the region for nearly ten years.
Contact: zaonoam@yahoo.com 2 Research coordinator for Living River Siam, a local NGO based in Chiang Mai, Thailand; conference
participant. 3 The GMS includes Burma/Myanmar, Cambodia, Laos, Thailand, Vietnam and Yunnan, China.
1
China-ASEAN Power Cooperation & Development Forum 2007
Asia (MSEA). While these considerable engineering and financing feats are aiding increasing energy connectivity of the GMS to the benefit of regional economic development, other factors must also be considered. Firstly, there must be deeper analysis on energy markets in GMS on whether further hydropower investments follow sound economic policies. Governments often exaggerate domestic energy demand (e.g., Thailand), and regional / domestic energy security should be more carefully considered when building dams in politically unstable environments (e.g., Burma/Myanmar). Secondly, the multifaceted impacts from dams dramatically affect millions of people still heavily reliant on river basins to meet their daily needs, which in Southeast Asia is the majority of rural villagers. This includes not only downstream impacts (e.g., dams on the Lancang River in Yunnan, China), but also communities located in and near future flooded reservoirs. Socio-economic and ecological impacts, with specific attention to local livelihoods, needs to be more thoroughly and holistically addressed by the hydropower industry in order to ensure better regional and local acceptance. Third includes domestic, regional and international laws and policies governing good water management practices, such as environmental and social impact assessments (E/SIAs), local participation in the decision-making process, and information and revenue transparency. The Chinese hydropower industry has already begun to adopt international best practices for hydropower development into their domestic projects, supported by central Chinese government laws; in this light these recent welcoming steps should continue to be pushed to include legally-binding policies governing Chinese hydropower investment abroad as well.
Cooperation should continue to be fostered between China and the riparian Mekong nations on regional water management. Southeast Asia civil society could offer lessons learned on local livelihood impacts from dams, how to encourage local communities to actively participate in local watershed governance (including E/SIAs), and creative solutions to address socio-economic and ecological impacts from dams. China, on the other hand, has great technological expertise and experience with dam construction and maintenance, conducting EIAs, and mitigation and compensation measures, which ASEAN could likewise benefit. Communication channels among governments and institutions should be further strengthened to encourage better information sharing on dam plans and operations, such as when flood gates are opened / closed. This enhanced cooperation could help China further carry out their central government tenant of ‗peaceful and harmonious coexistence‘ with their
neighbors. With further engagement on this issue we can help to mitigate unnecessary harmful dam impacts to both local communities and their environment.
Chinese Domestic and Regional Hydropower Investment
National and provincial Chinese policies have been established so to develop the Chinese state periphery. China‘s grandest national campaign, the ―Great Opening of the West‖, or
―Great Western Development Program‖, strives to develop the marginalized regions of China,
which includes SW China, and specifically Yunnan province. This has led to the
2
China-ASEAN Power Cooperation & Development Forum 2007
strengthening of China relations with their Southeast Asian neighbors, showcased by
Yunnan‘s official inclusion in ADB‘s GMS block, as well as ASEAN-China. For instance in
1994 China established the office of Lancang-Mekong River Development Prophase
Research and Coordination, with representatives from 19 departments of the central ndgovernment. A decade later in July 2005, Mekong government heads at the 2 GMS Summit
in Kunming, China signed a MoU for the Regional Power Trade Operating Agreement
(RPTOA) to promote a region-wide transmission network spanning MSEA. The Chinese
government promotion for enhancing government linkages between China and ASEAN has
subsequently paved the path for Chinese enterprises to follow suit.
For example, Yunnan Power Grid Corporation, under the Yunnan provincial government and
a regional subsidiary of China Southern Power Grid Co., has pushed beyond Yunnan to
invest in furthering development of the electricity grid and energy resources of the Mekong
region, becoming one of China‘s main participants in the development of the GMS Power
Grid. As China Southern Power Grid Co. covers the five most southern Chinese provinces, it
is China‘s main player in the import and export of Southeast Asian electricity.
World-famous for its gigantic dams, China has reached its domestic hydropower potential.
Economically feasible undammed rivers remain a scarce commodity in China, with official
and non-government discussions over the looming social, environmental and true economic
costs associated with large-scale dams. But hundreds of state-owned, partially state-owned,
and private Chinese hydropower companies, and thousands of associated engineering and
design firms, built up an armor of investment institutions and banks to continue to push
hydropower development schemes. But with the realization that hydropower potential nears
capping in China, Chinese hydropower corporations – from design to construction – have
begun to move out into the global energy market.
This decade has witnessed a trend of Chinese hydropower corporations to invest abroad as
China continues to overdevelop its own hydropower potential and environmental protection
takes greater priorities within the country. For example, Sinohydro Corp. agreed to finance
the Hutgyi dam on the Salween/Nu River, Burma/Myanmar, and China Power Investment
Corporation (CPI) signed MoU‘s for the N‘Mai Hka and Mali Hka dam cascade in Kachin State, Burma/Myanmar just west of the Nu valley; meanwhile the Chinese central
government postponed building the Nu River dam cascade in Yunnan for environmental
reasons.
As illustrated in Table 1, almost 50 different dams have been built, are undergoing
construction, or are being surveyed by a team of a total of 21 different Chinese hydropower
companies in mainland Southeast Asia (MSEA) (in this case, Burma/Myanmar, Cambodia,
Laos and Vietnam). This list invariably is incomplete as this represents only these authors‘
initial survey. Thailand is not included as almost no dam construction currently takes place
due to the strong Thai civil society movement against large-scale dams. And this does not
include dams not financed and/or built by Chinese corporations.
3
China-ASEAN Power Cooperation & Development Forum 2007
As China‘s economy continues to outpace their own domestic supply of natural resource capital, Chinese businessmen are increasingly looking towards Southeast Asia as a nearby
source. China looking to Southeast Asia as a cheap source of natural resources to feed
Chinese domestic and international consumer markets, and concomitantly continue to
generate profits for Chinese businesses, has resulted in a shift from Chinese foreign policy to
―resource diplomacy‖. This underscores the economic-social-environmental tension currently re-defining China‘s relationship with ASEAN. Chinese businessmen, and the markets they serve, increasingly must tap into natural resources – in this case hydropower – from other
countries in order to help build modern China while Chinese businessmen can still make huge
profits in the process.
However, the authors of this paper would like to highlight two main factors which weaken
the force of this disconcerting energy development strategy. The first factor covered in this
paper is based on energy market analysis. National government agencies often exaggerate
predicted future domestic energy demand in their Power Development Plans (PDPs),
meaning that an eagerness in hydropower development in the region could provide an over-
supply of hydro-electrical power on the market. In addition, many ASEAN countries, notably
Burma/Myanmar, remain stuck in political turmoil, creating a politically unstable climate
rendering high-risk investments which could later be dishonored. The second factor revolves
around local livelihood impacts, both those affected by downstream impacts from dams in
China, as well as impacts by the community living in the vicinity of the dam.
This paper invites discussion of the positive and negative impacts, direct and unintentional, of
large-scale dams in GMS. It is our hope that highlighting these two factors, together with
sound recommendations for improvements in the hydropower industry, will be genuinely
reflected upon and adopted by the hydropower industry.
Energy Market Mechanisms
Energy Demand and State Energy Utilities
Most of the power from Chinese hydropower investment projects in MSEA is planned for
export to neighboring more developed countries—Thailand and Vietnam—and the rest to yet
unidentified markets.
For the case of Thailand as a major potential energy market in the region, actual energy
demand is debated among state-controlled electricity enterprises and civil society consumer
groups. Over the past almost decade and a half, energy forecasts have repeatedly over-
4estimated the actual demand, sometimes as much as 48 percent. Since 1993, 12 out of 13
4 Greacen, C. and A. Palettu. 2007. ―Electricity sector planning and hydropower in the Mekong Region‖,
Chapter 5 in Democratizing Water Governance in the Mekong Region, Lebel, L., J. Dore, R. Daniel and Y. S.
Koma (Eds.). Mekong Press.
4
China-ASEAN Power Cooperation & Development Forum 2007
5forecasts that predicted energy demand for Thailand was in reality never reached. The
6January 2004 forecast for Thailand overestimated the 2006 peak demand by 1,674 MW.
And an April 2006 forecast overestimated actual 2006 peak demand by 899 MW. The 2006
load forecast was based on a projected average economic growth of 5.38% per year for the
next 15 years; in reality the actual average annual GDP growth rates over the past 10 and 15
7years were only 2.8% and 4.7% respectively.
In order to understand this repeating trend of over-estimating domestic energy demand, it is
necessary to explain the process of how these figures are generated for the case of Thailand.
The Thai Load Forecast Committee is the responsible party for predicting energy demand
forecasts, which in turn bases their decision primarily on economic growth forecasts from a
research institute that is funded by the state‘s three electric utilities. According to Palang Thai,
a Thai alternative energy NGO, one reason for the over-investment in energy generation is
8that the utilities hold a perverse incentive to overestimate power demand. Their profits are set according to a ―cost plus‖ structure, which provides an incentive for heavy investment in electricity infrastructure. In this way, state-controlled energy utility enterprises (for Thailand,
Energy Generating Authority of Thailand, EGAT) controls the decision-making process on
which power plants to pursue, but with all costs transferred to consumers through tariffs.
Furthermore, the cost-plus incentive scheme undermines any sincere promotion of energy
efficiency because quite simply EGAT earns less profit when customers use less energy. In
2003, the then Prime Minister Thaksin Shinawatra estimated that accumulated unnecessary
9investment in the power sector totaled 400 billion baht (US$10 billion). Another contentious issue for Thailand‘s energy sector is that EGAT, the utility responsible
for constructing power plants, is also responsible for developing Thailand‘s non-transparent Power Development Plan (PDP). EGAT controlled 47% of the electricity generation market
share in 2006 as well as owning and operating Thailand‘s electricity transmission network
10and acting as the single buyer of electricity in Thailand. This conflict of interest has led to exaggerated demand forecasts with PDPs that focus on large-scale, EGAT-owned
hydropower plants and large hydropower energy imports from Burma, Yunnan and Laos.
This translates into hydropower development schemes not being grounded in market
competition following sound economic policy. For the case of Thailand, the embedded
system instead follows ―demand forecasting that tends to overestimate actual energy demand,
5 Ibid. 6 Ibid. 7 Bank of Thailand. 2006. "Key Economic Indicators." http://www.bot.or.th/bothomepage/databank/EconData/
Thai_Key/Thai_KeyE.asp.
8 Greacen, C. and S. Bijoor. 2007. ―Decentralized Energy in Thailand: An Emerging Light,‖ World Rivers Review. June. 9 The Nation 2003. "PM Pressing for Egat IPO this year." March 14. 10 Greacen, C. and A. Palettu. 2007.
5
China-ASEAN Power Cooperation & Development Forum 2007
power development planning that favors capital-intensive supply-side solutions, and tariffs
11that pass costs on to consumers.‖
Energy Market Regulations and Recommendations
Civil society calls for a fair and independent energy regulator that would oversee the national and regional energy development process instead of the current practice of self-regulating abusive energy utilities.
An independent regulatory body would help in keeping hydropower projects from simply political and money-making deals, and more focused on basing decisions on actual energy demand, cost-efficiency and energy conservation. In addition, other costs need to be considered in the PDP other than just capital and operating costs, such as social and environmental costs. These external costs must be internalized in order for the true costs of energy generation, and thus more conservation-orienting solutions, to be realized. In addition to internalizing hidden costs, energy utility companies must work in the best interest of society, not just on profit maximization for utility companies that only make money if they build power plants. In other words, energy efficiency is not often adopted by ASEAN energy utility companies because their revenues are based on selling energy, not saving it. There has been some progress in Thailand in terms of improving energy efficiency; as of March 2006, Thailand‘s Demand Side Management (DSM) program had reduced peak
12electricity demand by just over 1,300 MW. Energy efficiency should be the ASEAN
strategy for meeting regional energy demand, which would cost only a fraction of the cost of a new power plant. But EGAT has little incentive to invest in energy efficiency because its revenues are based on the amount of electricity sold, in contrast to energy efficiency which leads to lower electricity sales. China-ASEAN should follow best international practices such as employing an integrated resource planning (IRP) least-cost model. This includes utility companies making decisions based on sound economic policy, employing cost-benefit analysis, and weighing other options such as energy conservation and political-economic risk, with the final decision bearing the least overall cost to society, not just the lowest cost to investors. And in order for this process to work, the decision-making process must involve prior and informed consent and full and meaningful participation from affected stakeholders.
Fisheries Livelihoods: Social and Environmental Costs
While large-scale dams can play a positive role in energy generation, flood control and irrigation, many adverse impacts result which in some cases may outweigh the benefits. This
11 Ibid. 12 Ibid.
6
China-ASEAN Power Cooperation & Development Forum 2007
includes fish populations drastically changed affecting local fishing livelihoods, forced
relocations of communities inundated by the reservoirs, inadequate compensation packages, 13corruption, logging, and changes in siltation and flood regimes, among many others.
Considering social and environmental impacts from hydropower development in the Mekong
region raises concerns about conflicts between local fishery livelihoods and the hydropower
industry.
An outstanding example is the Mekong River Basin, in which there are over 1,300 fish
species recorded so far. The World Fish Center states that the Lower Mekong Basin hosts the
most productive freshwater fishery in the world, contributing substantially to regional
14economies, food security, and rural livelihoods. Particularly for millions of self-reliant inhabitants in communities along the Lower Mekong and its tributaries, fisheries resources
are extremely important to their livelihoods. The Mekong River Commission (MRC)
estimates the total value of annual catch at US$ 2 billion, which is approximately 2% of the
15total world marine and freshwater fishery capture.
16Boonkong Boonwat, the village headman of Baan Pak Ing Tai, a Mekong riverside
community in northern Thailand, who presides over the village with more than 100 fisher
folk, explained that all men of working age were engaged in using traditional fishing gear to
catch fish in the area where the Ing River meets the Mekong. Each day they would catch a
variety of fish, enough for their household consumption and income.
Villagers and fisheries in the Mekong and its tributaries are closely-connected, as the village
headman further explains, ―The fisher folk here fish in both the Ing and Mekong Rivers. They go to the tributary during the rainy season when the fish from the Mekong spawn in the Ing
River. Most of the fish caught in the Ing River during this time migrate from the Mekong.
When the water in the Mekong River starts to recede during the dry season there are lots of
fish in the Ing River then, as the fish swim down from the Ing to the Mekong.‖
Not only are the fisheries immensely important for villages, but also the Mekong‘s rich
complex ecosystems. The Thai word that local communities living along the Mekong use to
17describe the islets, rapids and riverine forest translates to ―market‖. So the rivers are not
only an essential source of food, but also a livelihood survival strategy for many in the
Mekong communities. Countless villages, like those in north and northeast Thailand, with
limited agricultural land for growing food, depend on the income they receive from selling
fish to buy rice and other essential commodities. The deterioration of the riverine ecosystem
13 World Commission on Dams. 2000b. Chapter 2: Technical, Financial and Economic Performance. The Report
of the World Commission on Dams. London, Earthscan Publications Ltd.
http://www.dams.org/report/contents.htm;
WWF. 2004. "Rivers at Risk: Dams and the future of freshwater ecosystems."
http://www.panda.org/downloads/freshwater/riversatriskfullreport.pdf 14 Baran, E and B. Ratner. 2007. The Don Sahong Dam and Mekong Fisheries, World Fish Center. 15 Mekong River Commission (MRC). 2007. http://www.mrcmekong.org/programmes/fisheries.htm 16 Living River Siam. 2006. Testimony of Downstream People. 17 Ibid.
7
China-ASEAN Power Cooperation & Development Forum 2007
means a decrease in food security for local people, as well as disrupted economic and social
structures, which are tightly linked to a healthy natural ecosystem.
Similar to the Mekong Basin, many other river basins in the GMS where Chinese companies
are investing in hydropower development projects, such as along the Salween (Nu) and
Irrawaddy (Dulong), are also vital sources of livelihoods for millions of rural poor villagers.
The large number of hydropower development projects being implemented by Chinese
companies in MSEA could potentially create massive impacts on ecosystems and fisheries.
This has even been officially recognized by Chinese hydropower officials recently at a forum
regarding the Three Gorges Dam. "There exist many ecological and environmental problems
concerning the Three Gorges Dam. If no preventive measures are taken, the project could
lead to catastrophe." Wang Xiaofeng, director of the administrative office in charge of
building the dam, further warns, "We absolutely cannot relax our guard against ecological
and environmental security problems…we cannot win passing economic prosperity at the 18cost of the environment."
Dams, on the mainstream and tributaries, can obstruct the migratory route of fish, cutting fish
off from their habitats and more importantly their special and specific spawning grounds. The
decline of river health and fish catch due to hydropower development will thus inevitably
create accumulative impacts on rural livelihoods in the region. Of course ecology is without
political borders with fish migratory patterns not following national boundaries, giving
precedence to mounting and yet mostly unresolved transboundary impacts from dams.
A concrete example of transboundary hydropower development impacts is on the Lancang-
Mekong River, where the first two hydroelectric dam have already been built in Yunnan
Province, while six more are awaiting construction. During the past decade, communities
living along the Mekong River along Thai-Lao border have witnessed many changes in the
river, citing Lancang dams in Yunnan as the cause. The villagers claim that one of the most
adverse impacts is the unusual and unpredictable water fluctuation and the decreased
minimum discharge. According to one study, after the construction of the Manwan dam the
19mean minimum discharge of the Mekong River on Thai-Lao border declined by 25 percent.
20According to in-depth research by Southeast Asia Rivers Network (SEARIN), fisher folk
along the Mekong on the Thai-Lao border in Chiang Rai province complained they could not
fish in conditions where the river rose and then lowered swiftly in a day or two as in the past
few dry seasons. As most fish in the Upper Mekong are migratory species that migrate
upstream for reproduction, fish depend on the annual river flow for their life cycle. Thus, the
water fluctuation inevitably greatly impacts fish migration, and thus abundance of fish.
18 Reuters. 2007. ―China warns of catastrophe from Three Gorges Dam.‖ 26 September. 19 Department of Water Resources. 2004. Report on Water Flow of the Mekong River. 20 Southeast Asia Rivers Network (SEARIN). 2004. Downstream Impacts of Hydropower and Development of
an International River: A Case Study of Lancang-Mekong.
8
China-ASEAN Power Cooperation & Development Forum 2007
SEARIN has developed a fisheries impact model known as Thai Baan Research, where
villagers‘ conduct their own research on their local knowledge of local fisheries (similar to an
EIA done by local residents). One such published report conducted by fishing communities
along the Mekong in Chiang Rai province, Thailand, found that during 2002-2004, fish catch
21has been reduced by 50 percent.
More scientific research needs to be conducted examining the downstream impacts of dams.
These scientific studies could then compliment villager-led studies to better understand the
cost-benefit of dams. For any EIA‘s conducted for upstream dams, the potential downstream
environmental and social impacts should also be taken into account. In order to responsibly
invest in hydropower development in MSEA, civil society encourages Chinese companies to
comprehensively assess the potential environmental and social impacts, and to recognize
local livelihoods which depend on abundant riverine resources.
Promoting Domestic Policies Abroad, International Standards
There are many international standards applicable to the construction, operation and
financing of hydroelectric projects. The World Commission on Dams‘ (WCD) guidelines is
the most comprehensive, requiring EIAs as well as public participation and disclosure. The
need for EIAs and consideration of the rights of indigenous peoples are widely recognized in
international law. The international community has increasingly recognized the need for
corporate responsibility, as laid out in the draft UN Norms on the Responsibility of Transnational Corporations, the UN Global Compact, and the OECD Guidelines for Multinational Enterprises.
In recent years, China has included environmental assessment, public participation,
environmental reporting, and resettlement benefits in its own laws and policies. Since 2003,
the Environmental Impact Assessment Law has required EIAs for all major development
projects in China; the process also includes public participation and the release of the EIA.
The State Environmental Protection Agency (SEPA) issued a Bulletin on Information Disclosure for Corporate Environmental Performance in 2003 which recognizes the need for corporations to report on the environmental impacts of their projects and release them to the
public. Furthermore, in 2006 the State Council implemented Order No. 471 Regulations on
Land Requisition Compensation and Residents Resettlement in Construction of Large and
Medium-sized Water Conservancy and Hydroelectric Projects. In addition, some Chinese hydropower corporations are adopting social and environmental accountability standards
within their operations, following suit with international standards in the hydropower private
sector. For example, China Southern Power Grid Co. has publicized its Safety &
Environmental Protection Regulations.
21 Southeast Asia Rivers Network (SEARIN). 2004. Thai Baan (Villagers’) Research at Chiang Khong.
9
China-ASEAN Power Cooperation & Development Forum 2007
While it is understood that these laws and regulations govern Chinese businesses within China, they present an opportunity for China to extend its same commendable domestic standards to its projects in other countries, such as in ASEAN. Also, these laws could be adapted to include transboundary downstream impacts in other countries from dams built in China. This is of considerable concern for dams built on the Lancang River and possible future dams on the Nu River, as millions of downstream villagers rely upon these rivers‘ delicate ecology for their immediate livelihood needs.
Chinese hydropower investment corporations should follow best practices enshrined in domestic laws of the country they are operating in. For example, in Laos, where many Chinese corporations are actively involved in hydropower investment projects, many such laws governing hydropower development projects are in place. The Government of Laos has enforced a Law on Environment Protection (EPL), a Law on Water and Water Resources and a Law on Electricity, an implementation decree for the EPL and EIA regulations. In 2005 it issued the National Policy on Environmental and Social Sustainability of the Hydropower Sector in Lao PDR. The government also issued a decree in 2005 on its national policy on involuntary resettlement and compensation for major projects, with implementing regulations, consistent with best practices. General regulations exist regarding the assessment of the social and environment impact of development projects in Laos. The Ministry of Energy and Mines has also issued special regulations regarding environment and resettlement for power development projects. And in cases where little to no legal standards already exist in the country for hydropower projects, such as in Burma/Myanmar, Chinese companies should still insist on following Chinese domestic and international best practices for large-scale development projects.
Concluding Recommendations
We commend the Chinese government‘s ‗peaceful development‘ and ‗harmonious co-
existence‘ policy guiding foreign relations. However, this official admirable position is being
undermined by numerous Chinese company investments in natural resource extraction in neighboring countries, including but not limited to tapping hydroelectric power. In order to promote regional and international good will and peaceful co-existence, Chinese corporations constructing, operating, and/or financing hydroelectric projects must conduct environmental, social and economic impact assessments, receive prior and informed consent from affected communities through multi-stakeholder consultations, ensure the full and meaningful participation of affected people, and make all dam and resettlement plans and financing transparent. The Chinese government should promote Chinese corporations operating abroad to strictly follow these international best practices for development projects. Despite recent commendable advances in the Chinese government to increasingly regulate companies domestically, this has had an adverse impact on neighboring countries with Chinese corporations rushing to relocate to countries where there are much lower standards and/or less enforcement of existing regulations.
10