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Ameren’s ash storage practices expose the company to significant financial and regulatory risks.
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Ameren’s public disclosure on this issue is insufficient. While the Company produced a Corporate Social Responsibility Report in December 2016 (2016CSR) and posted on its website limited information required by EPA’s coal ash regulations, it has not provided the information requested in the proposal:
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The company claims “We have decades of experience managing coal ash in a safe and environmentally responsible way.” In fact, Ameren has decades of experience disposing of coal ash in leaking, unlined ash ponds, alongside the Missouri and Mississippi rivers, and failing to conduct groundwater monitoring. The CSR2016 fails to note these facts. The page in the 2016 CSR devoted to “Protecting Water” provides similar generalizations and links to government data with no specific information regarding Ameren’s plants’ water impacts. (#1 below)
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The 2016CSR claims as a “success” for water conservation and quality “developing an effective plan of action in response to the EPA’S revised effluent guidelines for the steam electric power sector.” In fact, as the Company fails to note, Ameren’s “effective plan” is suing the EPA to seek a rollback of these regulations limiting its power plants’ discharge of coal waste pollution. (UE Company (d/b/a Ameren MO) and Utility Water Act Group v EPA, No. 15-3658, November 19, 2015 8th Circuit, and No. 15-60821, 5th Circuit)
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Substantive inadequacies in Ameren’s CDP WATER 2016: (NUMBER REFERENCES are FROM CDP WATER 2016 AMEREN):
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2.3, 2.6. Ameren belongs to the Missouri River Recovery Implementation Committee Advisory Group, but does not disclose its specific role or how it has influenced progress in abating Missouri River pollution and aid for endangered species.
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8.1b There are no goals listed for improving water quality, reducing the pollution or minimizing the release of hazardous chemicals and materials (CCR).
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There is lack of recognition of the water stress in its supply chain as required by CDP. In December 2014, CDP Water Reported: “Ameren should look at requiring key suppliers to report on water use, risks and management, and factor such suppliers into water risk assessments.” (Power Generation Utilities: Navigating Global Water Risk, CDP and Morgan Stanley, p 35)
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2.6, 3.2 The Company continues to list only the Powder River Basin, a water-scarce area, as its major supplier of coal; coal mining in itself consumes 1% of all global fresh water as of 2014. Natural gas is also a supplier which carries water contamination risks but natural gas is ignored in the CDPWATER2016. (Coal is 70.1% of Ameren’s energy supply and natural gas 29.2% according to Bloomberg Intelligence ESG Industry Primer, 2017).
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1.3a Two of Its peer companies who received A Ratings from CDP Water reported 40 environmental criteria for supply chain, including natural gas; one company was also specific in listing Tier One and Tier Two suppliers.
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1.3a Ameren does not recognize other supply chain items such as poles, wires, steel, metals, IT equipment and how these items are also dependent on global water quantity and quality. All companies belong to the Electric Utility Sustainability Supply Chain Alliance, A companies report further efforts beyond the capacity of this Alliance.
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6.3a Ameren’s Water Policy, instituted in 2013, is as follows: “Ameren is committed to protecting all natural resources, including water. Though our facilities are geographically situated in an area of ample water supply, all divisions with Ameren Corporation will take in to consideration the impact of our operations on both water quality and use.” There is no data or information on HOW this Policy will actually affect their ‘consideration,’ decisions or their impacts on quality of water. While the company emphasizes the abundance of water and how water beneficially impacts the Company, it provides nothing on how the Company impacts the waters of the Great Mississippi Basin.
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Ameren is indeed located in an area of ample water supply but has not produced evidence it is planning for floods/droughts that will intensify with climate change. Ameren did not provide scenarios to CDP WATER2016 on impacts of flooding/droughts although it consistently lists these risks in its “Forward Looking Statements.” (10k 2015, 2016,February 2017) In December 2015, Ameren might have had to close its Meramec plant, due to unusual winter flooding. (Impact News, Mehlville, MO 01/06/16) This is not mentioned in its CDP Water2016 report.
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Comparison/Contrasts with Ameren’s A-rated CDPWATER Peers; two utility corporations which were rated A are listed first, Ameren second:
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2.5 A companies evaluate water risks through local groups, Electric Power Research Institute and many others, in addition to only two sources listed by Ameren, WBCSD/WRI.
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2.6c A companies disclose Stakeholder conflicts, compliance issues, verification, transparent scenario analyses; Ameren lists only compliance issues, no conflicts (despite 5 years of conflicts regarding Labadie Land Fill) and no scenario analyses.
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6.2a How has water positively impacted business strategy?: A Companies report active flood/drought task forces, working with DOE task force, a climate resilience task force, and $ spend. Ameren reports money spent on developing and implementing energy efficiency programs which reduced generation and associated water use. It also reports that beneficial use of 208,000 tons of fly ash in 2015 resulted in substantial savings of water used to convey ash to ponds.
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2.6 – 2.7, 3.2.c Peer corporations listed specific Estimates and Scenarios of future water risks. Ameren provides no Scenarios; but elsewhere admits that if facilities would need to close due to lack of water availability, “the financial impact could be medium-high.” (10k)
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A companies reported substantial change in Business due to Water and climate change: Environmental Impact, reliance on barge delivery, water reserves; Ameren listed NPDES, EPA and CWA regulations, and capital expenditures that may be required for new regulations.
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3.2f A companies agreed there are risks in their Supply Chain; Ameren repeated there is no risk in the Powder River Basin despite reports by WRI, World Business Council of Sustainable Development, and Global Water Tool to the contrary.
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6.2a A companies listed specifics on the Influence of water on business strategy. A companies listed 47 studies in re-licensing beyond compliance, coding 7% of supplier evaluation on water use; A companies disclosed spending on water.
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7.1 List penalties, fines, enforcement orders for breaches of abstraction licenses, discharge consents, or other water and wastewater related regulations.
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8.1b Describe qualitative goals and your progress in reaching these. A companies listed data such as a subsidiary that sells solar with free offers of water-saving devices, specific donations of rehabilitating grasses, etc; Ameren presented “no coherent measure of success, completion, or when Goal is expected to be achieved.” (CDPWater Interview, MCRI/ICCR, October 2016 )
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9.1a Describe the linkages or trade-offs and the related management policy or action. A companies disclosed several linkages and trade-offs to Environmental Issues such as increased expense of water permit conditions related to closed-cycle cooling towers, increased energy required at coal/gas/oil power production facilities (except nuclear) to comply with CCR proposed Effluent Limitations Guidelines (ELG). Ameren listed two trade-offs, its 2015 5.7MW Solar Park and ELG compliance costs.
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MSCI Data Metrics Report February 2016, lists Ameren 3/10 Performance of Water Intensity Relative to Peers, (0-10 Score, 0=worst, 10=best). Scores a 0 for Implementation of Water Efficient Production Processes (0-10 Score, 0=Worst, 10=best). It seems that MSCI agrees Ameren could do more in its Water Disclosure and Management practices.
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- Labadie Historic Leakage (from 1992 through at least 2011): MO State Opening Permit MO 0004812 (effective August 1, 2015, modified Nov. 24, 2015) available at https://dnr.mo.gov/env/wpp/permits/issued/docs/004812.pdf
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