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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

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


Note: Eskom's response also addresses this item

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

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All components of this story

Company response
30 April 2015

Eskom response to subcritical coal report

...Preparation for an extensive emission reduction programme is underway at Eskom to reduce emissions through actions including installing filters at existing power stations. The programme will cost about R72 billion in nominal terms and requires substantial staff allocation and generation plant downtime over the next 12 years or so. The programme focuses on the highest-emitting and largest power stations...

Download the full document here

Company response
6 April 2015

RWE response to subcritical coal report

With regard to our CO2-emissions and the respective exposure of our power plants we report annually in our Corporate Responsibility reports.  Emissions data as well as our strategy, indicators, and steps taken with regard to reduce CO2-emissions can be found there.

Please find the link to the latest report for the year 2014 (http://www.rwe.com/web/cms/en/179662/rwe/responsibility). At the same place our previous reports can be downloaded (http://www.rwe.com/web/cms/en/1510216/rwe/responsibility/reporting/cr-reports).

Download the full document here

Company response
30 March 2015

American Electric Power response to subcritical coal report

Thank you for giving us the opportunity to respond to this report.  Without the complete set of data used to compile the rankings, it is a little bit difficult to confirm the data.  The ranking is presumably based on our 2012 generation statistics. The table lists 87.6 MM mWh which would be much higher than the mWh generated from our subcritical coal units that year – actually more than double the amount of electricity generated from those units. So, it appears that the data may be flawed.

Irrespective of that, in less than a year, we will have far less subcritical capacity due to planned retirements of coal-fueled generating units in 2015 and 2016...

Download the full document here

Company response
27 March 2015

AGL response to subcritical coal report

Climate change and greenhouse gas GHG emission reductions are a long term challenge requiring long term and lasting solutions.  Currently, Australians depend on coal for reliable and affordable energy but there is increasing uptake of new technologies such as solar PV and other renewables. AGL Energy Limited (AGL) recognises that as a large emitter we have a key role to play in seeking to reduce our emissions over time...

Download the full document here

13 March 2015

US and Chinese companies dominate list of most-polluting coal plants

Author: Damian Carrington, Guardian (UK)

The 100 global power companies most at risk from growing pressure to shut highly polluting coal plants have been revealed in a new report from Oxford University.

Chinese companies dominate the top of the ranking but US companies, including Warren Buffett’s Berkshire Hathaway, occupy 10 of the top 25 places.

The analysis, produced to help investors assess the risk of major financial losses, also found French energy giant GDF Suez was third in the list of most polluting coal station fleets in the world.

Coal currently provides 40% of the world’s electricity and three-quarters of this is produced by the most-polluting, least-efficient and oldest “sub-critical” coal-fired power stations...

The new analysis ranked the companies by how much electricity they produced from sub-critical plants. [Note: Business & Human Rights Resource Centre invited the top 20 companies by energy generation from sub-critical coal to respond]

Read the full post here