Ameren Corporation: Request for Report on Coal Combustion Residuals
WHEREAS: The World Economic Forum 2015 Global Risk Report ranked water as the top societal risk facing the world in terms of potential economic impact. (1) The Human Right to Water, formally recognized by the United Nations in 2010, clarifies that it is the responsibility of companies to ensure their operations to not infringe upon the right of individuals to sufficient, safe, acceptable and physically accessible and affordable water. This human right is further buttressed by the UN’s Sustainable Development Goal 6, which includes a target for improving water quality by reducing pollution and minimizing the release of hazardous chemicals and materials. (2)
Coal combustion residual (CCR) is a by-product of burning coal and contains arsenic, mercury, lead and other heavy metals and toxins.
In October 2015, the EPA CCR Rule became effective, finalizing regulations to set minimum federal standards for CCR disposal. While Ameren has thus far filed the minimum information required by the CCR Rule, significant questions remain regarding risks posed by its lined and unlined ash ponds along the Mississippi and Missouri Rivers. In 2011, 46.7% of shareholders supported a resolution requesting a report on Ameren’s efforts to identify and reduce environmental and health hazards associated with CCR. Ameren has responded with only general information that does not provide shareholders with adequate information regarding the risks associated with its coal ash disposal practices.
Ameren has not commenced routine groundwater monitoring at any of its ash ponds, many of which are unlined.
Ameren has not committed to removing coal ash from its ash ponds when it closes them, unlike other utilities in Missouri and elsewhere.
Where Ameren already knows of groundwater contamination caused by its ash ponds, there is no indication that it has taken steps to clean up existing contamination or provided meaningful estimates of future cleanup costs.
Ameren has submitted but not received third-party Verification for the CDP Water 2016 report:
Ameren’s primary coal source is the Powder River Basin; Ameren continues to claim that PRB is not a water stressed area despite reports by World Resources Institute, World Business Council of Sustainable Development, and Global Water Tool to the contrary.
Despite its claims that “our facilities are located in an area of ample water supply,” Ameren admits that if facilities would need to close due to lack of water availability, the financial impact would be ‘medium-high.’
BE IT RESOLVED: Shareholders request that the Board prepare a complete report on the company’s efforts, above and beyond current compliance, to identify and reduce environmental and health hazards associated with past, present and future handling of coal combustion residuals, and how those efforts may reduce legal, reputational and financial risks to the company. This report should be available to shareholders within 6 months of the 2017 annual meeting, be prepared at reasonable cost, and omit confidential information such as proprietary data or legal strategy.
As You Sow and School Sisters of Notre Dame Central Pacific Province