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6 Apr 2015

Subcritical coal top 20: Engaging energy companies on climate & human rights impacts

In March 2015, researchers at the Smith School of Enterprise and the Environment at Oxford University published "Stranded Assets and Subcritical Coal: The Risk to Companies and Investors".  The report describes sub-critical coal as: "the least efficient and most polluting form of coal-fired generation."  This form of energy production contributes significantly to climate change, localized air pollution, and stress on water supplies.

Climate change has major impacts on human rights, including the rights to life, health, housing and food.  Business & Human Rights Resource Centre invited the 20 companies ranked in the report as having the highest energy generation from sub-critical coal to respond.  Here we indicate which of the top 20 have responded.  See below for the specific questions asked, and media coverage of the report.

We are continuing to follow up with the companies and will add any new responses to this page.

Top 20 - responses and non-responses

1China Huaneng (China)Not yet responded
2Huadian Group (China)Not yet responded
3China Guodian Group (China)Not yet responded
4China Datang Group (China)Not yet responded
5NTPC (India)Not yet responded
6Eskom (South Africa)


Note: Eskom's response also addresses this item

7Shenhua Group (China)Not yet responded
8China Power Investment Corp (China)Not yet responded
9AES Corporation (USA)Not yet responded
10China Resources Power Holdings (China)Not yet responded
11Southern Company (USA)Not yet responded
12Duke Energy (USA)Not yet responded
13NRG Energy (USA)Not yet responded
14American Electric Power (USA)Response
15RWE (Germany)Response
16North China Grid Co Ltd (China)Not yet responded
17E.ONNot yet responded
18Berkshire Hathaway Energy (USA)Not yet responded
19AGL Energy (Australia)Response
20State Grid Power Corp (China)Not yet responded

 What we asked the companies

We approached the 20 companies above, pointing them in particular to two tables in the report: one ranking them (as above) by total power generation from sub-critical plants, and one that compares their carbon intensity, air pollution and water stress.

Both tables are available here

We asked the companies:

  • What steps is your company taking to avoid harm to human rights (such as impacts on health, access to water and climate change) from operation of its sub-critical power stations?
  • Does your company have a plan to reduce or eliminate emissions from sub-critical coal plants?

We also said that the companies were welcome to include their response answers to some or all of the four questions that are posed by the authors of the report, in the introduction on page 11.  The report says companies should be encouraged to:

i)    publicly confirm their exposure and the proportion of their total generation portfolio that is subcritical [see table 13]
ii)    disclose what proportion of this is most at risk, for example, the bottom quartile in terms of carbon intensity, air pollution, and water stress [see table 14]
iii)    disclose how much of their capex pipeline is subcritical and how this might change portfolio risk exposure, and
iv)    describe the strategies employed at an asset-level and across a portfolio to minimise carbon intensity and manage deleterious contributions to local air pollution and water stress.

Company Responses

American Electric Power View Response