Wales rides a coal renaissance

By Buffalo News


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Deep under a pine-covered mountain, men clamber into red overalls and heavy boots, strap on lamps and attach sensors that check gas levels.

They walk with bent knees into the gloom, down a rocky, uneven slope to the coal face 1,200 feet below the surface, and chatter happily about their good luck to be underground - again.

Not 10 years ago, mining was a doomed calling, and the Unity Mine was just another jagged scar slashed into a South Wales hillside, a mine that was abandoned as coal prices fell. But that picture looks different now that oil is close to $100 a barrel. Coal is making a comeback in Britain, bringing jobs - and misgivings - that seemed gone for good.

"I couldn't believe it when I heard there were jobs down the pit again," said Gary Williams, an 18-year-old apprentice at the Unity mine. "My dad was a miner. His old man was a miner, everyone we knew was a miner, but he told me not to think of going down the mines. He said it would never happen."

Most British output is sold to the 18 coal-fired power stations that generate a third of the country's electricity, but rising oil prices and demand from India and China have helped to triple the price of coal from $28.80 a ton in 1999 to $86.60 last year, according to the BP Statistical Review of World Energy.

Coal's comeback angers some Welsh residents and environmentalists, however. They say their landscape and quality of life are being sacrificed for cash and that turning to coal will hasten global warming.

The British government says it is following the European Union's "clean coal" policy, which encourages energy companies to develop technologies for nonpolluting power stations.

Coal remains the dirtiest form of energy: coal-fired power stations still emit as much carbon dioxide as gas-fired ones, as well as sulfur dioxide that falls back to the earth as acid rain.

Terry Evans, a 61-year-old retired accountant, feels the effects when the coal dust settles on his windowsills and creeps into his house, just 100 feet away from Ffos-y-Fran, a new open-pit mine in South Wales.

"We are always thankful when it rains because the dust is not so bad then," he said. "What I really worry about is the dust we can't see, and what harm it will do us over the years."

Like Scotland and northern England, this New Jersey-sized piece of the United Kingdom has a long, turbulent history with coal. Britain's Industrial Revolution drew energy and backbone from under its undulating hills - iron ore, coal, limestone and water - all the things needed for iron production. In the 18th century, industrialists came to the valley to dig mines, build factories and smelt iron.

The industry has long been associated with backbreaking labor and devastating health problems, immortalized by Richard Llewellyn's novel "How Green Was My Valley," whose film version won the 1941 Oscar. Cardiff, Wales' main port city, once led the world in coal exports.

In a 1966 disaster that shocked the world, an avalanche of coal sludge buried a school in the village of Aberfan, killing 116 children and 28 adults. Men working at nearby mines ran to dig out their own children.

By then British coal was already in decline, from a peak of 300 million tons in 1913 to around 16 million tons a year today. The Depression, the decline of Britain's manufacturing base, and the discovery of North Sea oil and gas off the coast of Scotland, fatally weakened coal-mining.

In the 1980s, Britain's Conservative government under Margaret Thatcher closed down most mines after an epic yearlong battle with the left-led miners' union that became a defining feature of her capitalist ideology. In 1984, the year of the strike, there were 196,000 miners working in Britain; by 2006, there were 5,600.

Britain wasn't alone. Throughout Europe, mines closed and power stations imported their coal needs, while increasing their reliance on oil, natural gas and nuclear power. Even now, the new coal drive in Wales is nowhere close to the 44 million tons Britain imports annually, mainly from Russia, South Africa, Columbia and Australia.

But Europe's energy goals are changing. It is growing nervous about being so dependent on Russian energy. Nuclear power remains a hard sell, and many of Britain's 10 nuclear power stations are nearing the end of their natural life.

Enter coal - cheap, plentiful and easily stored. Europe holds a third of the world's reserves, and to many, coal-fired power stations seem a good idea again. Britain plans to open seven new coal-fired electricity plants. One application has been formally submitted, and if successful, will lead to Britain's first new coal-fired power station in 24 years.

The fortunes of the Unity mine at Cwmgrach are indicative of coal's new appeal. It was abandoned 12 years ago when the falling price made it unviable. Two years ago Gerwyn Williams, a former miner, got some investors to reopen the mine as prices rose. The mine now employs 60 men - most of them former miners who had retrained in other areas but were happy to return to their old profession.

But the shift back to coal-fired power stations has provoked environmental protests. The industry advocates carbon-capture technology, which seizes the carbon dioxide from burned coal and stores it underground. But the technology is untested and will not be commercially viable for another decade.

Half of Britain's coal comes from underground mines like the one at Cwmgrach, but the rest comes from open-pit mines, which are blamed for destroying wildlife and the landscape. Their neighbors hate them and complain of dust and noise.

A few miles from Aberfan, where tragedy struck in 1966, on the edge of the town of Merthyr Tydfilis, is the open-pit Ffos-y-Fran site. The mining company Miller Argent won the right to dig here last year after a long legal fight with local opponents including Evans, the retired accountant.

But the environmental campaigners haven't given up. In April they showed their opposition by invading the Ffos-y-Fran site. The local community itself is torn. South Wales has some of the highest unemployment rates in the country, and the jobs being created are needed.

Rossville Jones, a 60-year-old lifelong miner, is happy to have a job at Ffos-y-Fran, close to home, instead of commuting long distances to work.

"Aye, there's a bit of dust from the mines, but there's also a job right on my doorstep," he said, steering a dump truck filled with coal to a sorting station. "Complaining about the mines when there's nothing else here? That's just daft."

But Terry Evans wishes other kinds of jobs were being created in South Wales.

"The mine has stopped other people investing in this area," he said. "Who'd want to open a hotel or a golf course, or even a company headquarters, when this mine is here?"

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FPL stages massive response to Irma but power may not be back for days or weeks

FPL Power Restoration mobilizes Florida linemen and mutual-aid utility crews to repair the grid, track outages with smart meters, prioritize hospitals and essential services, and accelerate hurricane recovery across the state.

 

Key Points

FPL Power Restoration is the utility's hurricane effort to rebuild the grid and quickly restore service across Florida.

✅ 18,000 mutual-aid utility workers deployed from 28 states

✅ Smart meters pinpoint outages and accelerate repairs

✅ Critical facilities prioritized before neighborhood restorations

 

Teams of Florida Power & Light linemen, assisted by thousands of out-of-state utility workers and 200 Ontario workers who joined the effort, scrambled across Florida Monday to tackle the Herculean task of turning the lights back on in the Sunshine State.

The job is quite simply mind-boggling as Irma caused extensive damages to the power grid and the outages have broken previous records, and in other storms Louisiana's grid needed a complete rebuild after Hurricane Laura to restore service.

By 3 p.m. Monday, some 3.47 million of the company's 4.9 million customers in Florida were without power. This breaks the record of 3.24 million knocked off the grid during Hurricane Wilma in 2005, according to FPL spokesman Bill Orlove.

Prepared to face massive outages, FPL brought some 18,000 utility workers from 28 states here to join FPL crews, including Canadian power crews arriving to help restore service, to enable them to act more quickly.

“That’s the thing about the utility industry,” said  Alys Daly, an FPL spokeswoman. “It’s truly a family.”

Even with what is believed to be the largest assembly of utility workers ever assembled for a single storm in the United States, power restoration is expected to take weeks, not days in some areas.

FPL vowed to work as quickly as possible as they assess the damage and send out crews to restore power.

"We understand that people need to have power right away to get their lives back to normal," Daly said.

The priority, she said, were medical and emergency management facilities and then essential service providers like gas stations and grocery stores.

After that, FPL will endeavor to repair the problems that will restore power to the maximum number of people possible. Then it's individual neighborhoods.

As of 3 p.m. Monday, 219,040 of FPL's 307,600 customers on the Space Coast had no power. That's an improvement over the 260,600 earlier in the day.

Daly was unable to say Monday how many crews FPL had working in Brevard County. In some areas, power came back relatively swiftly, much quicker than expected.

" I was definitely surprised at how quickly they got our power back on here in NE Palm Bay," said Kelli Coats. "We lost power last night around 9 p.m Sunday and regained power around 8:30 a.m. today."

Others, many of them beachside, were looking at a full 24 hours without power and it's possible it could extend into Tuesday or longer.

One reason for improved response times since 2005, Daly said, is the installation of nearly 5 million "Smart Meters" at residences. These new devices, which replaced older analog models, allows FPL crews to track a neighborhood's power status via handheld computers, pinpointing the cause of an outage so it can be repaired.

Quick restoration is key as stores and restaurants struggle to re-open, and Gulf Power crews restored power in the early push. Without electricity many of them just can't re-start operations and get goods and services to consumers.

At the Atlanta-based Waffle House, which Federal Emergency Management Administration use to gauge the severity of damage and service to an area, restaurant executives are reviewing its operations in Florida and should have a better handle Monday afternoon how quickly restaurants will re-open.

"Right now, we're in an assessment phase," said Pat Warner, spokesman for Waffle House. "We're looking at which stores have power and which ones have damage."

FEMA's color-coded Waffle House Index started after the hurricanes in the early 2000s. It works like this: When an official phones a Waffle House to see if it is open,  the next stop is to assess it's level of service. If it's open and serving a full menu, the index is green. When the restaurant is open but serving a limited menu, it's yellow. When it's closed, it's red.

 

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Mercury in $3 billion takeover bid for Tilt Renewables

Mercury Energy Tilt Renewables acquisition signals a trans-Tasman energy push as PowAR and Mercury split assets via a scheme of arrangement, offering $7.80 per share and a $2.96b valuation across Australia and New Zealand.

 

Key Points

A PowAR-Mercury deal to buy Tilt Renewables, splitting Australian and New Zealand assets via a court-approved scheme.

✅ $7.80 per share, valuing Tilt at $2.96b

✅ PowAR takes AU assets; Mercury gets NZ business

✅ Infratil and Mercury to vote for the scheme

 

Mercury Energy and an Australian partner appear to have won the race to buy Tilt Renewables, an Australasian wind farm developer which was spun out of TrustPower, bidding almost $3 billion, amid wider utility consolidation such as the Peterborough Distribution sale to Hydro One.

Yesterday Tilt Renewables announced that it had entered a scheme implementation agreement under which it was proposed that PowAR would acquire its Australian business and Mercury would acquire the New Zealand business, mirroring cross-border approvals where U.S. antitrust clearance shaped Hydro One's bid for Avista.

Conducted through a scheme of arrangement, Tilt shareholders will be offered $7.80 a share, valuing Tilt at $2.96b.

Yesterday morning shares in Tilt opened about 18 per cent up at $7.65, though regulatory outcomes can swing valuations as seen when Hydro One-Avista reconsideration of a U.S. order came into play.

In early December Infratil, which owns around two thirds of Tilt's shares, announced it was undertaking a review of its investment after receiving approaches, with investor sentiment sensitive to governance shifts as when Hydro One shares fell after leadership changes in Ontario.

According to a report in the Australian Financial Review, the transtasman bid beat out other parties including ASX-listed APA Group, Canadian pension fund CDPQ and Australian fund manager Infrastructure Capital Group, as Canadian investors like Ontario Teachers' Plan pursue similar infrastructure deals.

“This compelling acquisition proposal is a result of Tilt Renewables’ constant focus on delivering long-term value for shareholders and the board is pleased that, with these new owners, the transition to renewables in Australia and New Zealand will continue to accelerate,” Tilt’s chairman Bruce Harker said.

Comparable community-led clean energy partnerships, such as initiatives with British Columbia First Nations highlighted in clean-energy generation, underscore the broader momentum.

Just prior to the announcement, Tilt shares had been trading for less than $4. Such repricing reflects how utilities can face perceived uncertainties, as one investor argued too many unknowns at the time.

Mercury is already Tilt’s second largest shareholder, at just under 20 per cent. Both Infratil and Mercury have agreed to vote in favour of the scheme. The deal values Tilt’s New Zealand business at $770m, however the value of Mercury’s existing shareholding is around $585m, meaning the company will increase debt by around $185m.

 

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Canada's First Commercial Electric Flight

Canada's First Commercial Electric Flight accelerates sustainable aviation, showcasing electric aircraft, pilot training, battery propulsion, and noise reduction, aligning with net-zero goals and e-aviation innovation across commercial, regional, and training operations.

 

Key Points

Canada's electric flight advances sustainable aviation, proving e-aircraft viability and pilot training readiness.

✅ Battery-electric propulsion cuts emissions and noise

✅ New curricula prepare pilots for electric systems and procedures

✅ Supports net-zero goals through green aviation infrastructure

 

Canada, renowned for its vast landscapes and pioneering spirit, has achieved a significant milestone in aviation history with its first commercial electric flight. This groundbreaking achievement marks a pivotal moment in the transition towards sustainable aviation and an aviation revolution for the sector, highlighting Canada's commitment to reducing carbon emissions and embracing innovative technologies.

The inaugural commercial electric flight in Canada not only showcases the capabilities of electric aircraft, with examples like Harbour Air's prototype flight demonstrating feasibility, but also underscores the importance of pilot training in advancing e-aviation. As the aviation industry explores cleaner and greener alternatives to traditional fossil fuel-powered aircraft, pilot training plays a crucial role in preparing aviation professionals for the future of sustainable flight.

Electric aircraft, powered by batteries instead of conventional jet fuel, offer numerous environmental benefits, including lower greenhouse gas emissions and reduced noise pollution, though Canada's 2019 electricity mix still included some fossil generation that can affect lifecycle impacts. These advantages align with Canada's ambitious climate goals and commitment to achieving net-zero emissions by 2050. By investing in e-aviation, Canada aims to lead by example in the global effort to decarbonize the aviation sector and mitigate the impacts of climate change.

The success of Canada's first commercial electric flight is a testament to collaborative efforts between industry stakeholders, government support, and technological innovation. Electric aircraft manufacturers have made significant strides in developing reliable and efficient electric propulsion systems, with research investment helping advance prototypes and certification, paving the way for broader adoption of e-aviation across commercial and private sectors.

Pilot training programs tailored for electric aircraft are crucial in ensuring the safe and effective operation of these advanced technologies, as operators target first electric passenger flights across regional routes. Canadian aviation schools and training institutions are at the forefront of integrating e-aviation into their curriculum, equipping future pilots with the skills and knowledge needed to navigate electric aircraft systems and procedures.

Moreover, the introduction of commercial electric flights in Canada opens new opportunities for aviation enthusiasts, environmental advocates, and stakeholders interested in sustainable transportation solutions. The shift towards e-aviation represents a paradigm shift in how air travel is perceived and executed, emphasizing efficiency, environmental stewardship, and technological innovation.

Looking ahead, Canada's role in advancing e-aviation extends beyond pilot training to include research and development, infrastructure investment, and policy support. Collaborative initiatives with industry partners and international counterparts, including Canada-U.S. collaboration on electrification, will be essential in accelerating the adoption of electric aircraft and establishing a robust framework for sustainable aviation practices.

In conclusion, Canada's first commercial electric flight marks a significant milestone in the journey towards sustainable aviation. By pioneering e-aviation through pilot training and technological innovation, Canada sets a precedent for global leadership in reducing carbon emissions and shaping the future of air transportation. As electric aircraft become more prevalent in the skies, Canada's commitment to sustainability and ambitious EV goals at the national level will continue to drive progress towards a cleaner, greener future for aviation worldwide.

 

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British carbon tax leads to 93% drop in coal-fired electricity

Carbon Price Support, the UK carbon tax on power, slashed coal generation, cut CO2 emissions, boosted gas and imports via interconnectors, and signaled effective electricity market decarbonization across Great Britain and the EU.

 

Key Points

A UK power-sector carbon tax that drove coal off the grid, cut emissions, and shifted generation toward gas and imports.

✅ Coal generation fell from 40% to 3% in six years

✅ Rate rose to £18/tCO2 in 2015, boosting the coal-to-gas switch

✅ Added ~£39 to 2018 bills; imports via interconnectors eased prices

 

A tax on carbon dioxide emissions in Great Britain, introduced in 2013, has led to the proportion of electricity generated from coal falling from 40% to 3% over six years, a trend mirrored by global coal decline in power generation, according to research led by UCL.

British electricity generated from coal fell from 13.1 TWh (terawatt hours) in 2013 to 0.97 TWh in September 2019, and was replaced by other less emission-heavy forms of generation such as gas, as producers move away from coal in many markets. The decline in coal generation accelerated substantially after the tax was increased in 2015.

In the report, 'The Value of International Electricity Trading', researchers from UCL and the University of Cambridge also showed that the tax—called Carbon Price Support—added on average £39 to British household electricity bills, within the broader context of UK net zero policies shaping the energy transition, collecting around £740m for the Treasury, in 2018.

Academics researched how the tax affected electricity flows to connected countries and interconnector (the large cables connecting the countries) revenue between 2015—when the tax was increased to £18 per tonne of carbon dioxide—and 2018. Following this increase, the share of coal-fired electricity generation fell from 28% in 2015 to 5% in 2018, reaching 3% by September 2019. Increased electricity imports from the continent, alongside the EU electricity demand outlook across member states, reduced the price impact in the UK, and meant that some of the cost was paid through a slight increase in continental electricity prices (mainly in France and the Netherlands).

Project lead Dr. Giorgio Castagneto Gissey (Bartlett Institute for Sustainable Resources, UCL) said: "Should EU countries also adopt a high carbon tax we would likely see huge carbon emission reductions throughout the Continent, as we've seen in Great Britain over the last few years."

Lead author, Professor David Newbery (University of Cambridge), said: "The Carbon Price Support provides a clear signal to our neighbours of its efficacy at reducing CO2 emissions."

The Carbon Price Support was introduced in England, Scotland and Wales at a rate of £4.94 per tonne of carbon dioxide-equivalent and is now capped at £18 until 2021.The tax is one part of the Total Carbon Price, which also includes the price of EU Emissions Trading System permits and reflects global CO2 emissions trends shaping policy design.

Report co-author Bowei Guo (University of Cambridge) said: "The Carbon Price Support has been instrumental in driving coal off the grid, but we show how it also creates distortions to cross-border trade, making a case for EU-wide adoption."

Professor Michael Grubb (Bartlett Institute for Sustainable Resources, UCL) said: "Great Britain's electricity transition is a monumental achievement of global interest, and has also demonstrated the power of an effective carbon price in lowering dependence on electricity generated from coal."

The overall report on electricity trading also covers the value of EU interconnectors to Great Britain, measures the efficiency of cross-border electricity trading and considers the value of post-Brexit decoupling from EU electricity markets, setting these findings against the global energy transition underway.

Published today, the report annex focusing on the Carbon Price Support was produced by UCL to focus on the impact of the tax on British energy bills, with comparisons to Canadian climate policy debates informing grid impacts.

 

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KHNP is being considered for Bulgarian Nuclear Power Plant Project

KHNP Shortlisted for Belene Nuclear Power Plant, named by the Bulgarian Energy Ministry alongside Rosatom and CNNC; highlights APR1400 reactor expertise, EPC credentials, and expansion into the European nuclear energy market.

 

Key Points

KHNP is a strategic investor candidate for Bulgaria's Belene NPP, leveraging APR1400 and European market entry.

✅ Selected with Rosatom and CNNC by Bulgarian Energy Ministry

✅ Builds on APR1400 reactor design and EPC track record

✅ Positions KHNP for EU nuclear projects and O&M services

 

Korea Hydro & Nuclear Power (KHNP) has been selected as one of the three strategic investor candidates for a Bulgarian nuclear power plant project amid global nuclear project milestones worldwide.

The Bulgarian Energy Ministry selected KHNP of Korea, RosAtom of Russia and CNNC of China as strategic investor candidates for the construction of the Belene Nuclear Power Plant, KHNP said on Dec. 20. The Belene Nuclear Power Plant is the second nuclear power plant that Bulgaria plans to build following the 2,000-megawatt Kozloduy Nuclear Power Plant built in 1991 during the Soviet Union era. The project budget is estimated at 10 billion euros.

By being included in the shortlist for the Bulgarian project, KHNP has boosted the possibility of making a foray into the European nuclear power plant market, as India takes steps to get nuclear back on track worldwide. KHNP began to export nuclear power plants in 2009 by winning the UAE Barakah Nuclear Power Plant Project, with Barakah Unit 1 reaching 100% power as it moves toward commercial operations. The UAE plant will be based on the APR1400, a next-generation Korean nuclear reactor that is used in Shin Kori Units 3 and 4 in Korea.

The ARP1400 is a Korean nuclear reactor developed by KHNP with investment of about 230 billion won for 10 years from 1992. The nuclear reactor became the first non-U.S. type reactor to receive a design certificate (DC) from the U.S. Nuclear Regulatory Commission (NRC), as China's nuclear energy program continues on a steady development track globally. By receiving the DC, its safety was internationally recognized. In June, the company also won the maintenance project for the Barakah Nuclear Power Plant, completing the entire cycle from the construction of the nuclear power plant to its design, operation and maintenance. However, U.S. and U.K. companies took part of the maintenance project for the nuclear power plant.

In July, KHNP officials visited Turkey and contacted local energy officials to prepare for nuclear power plant projects to be launched in that country, as Bangladesh develops nuclear power with IAEA assistance in the region. Earlier in May, the company also submitted a proposal to participate in the construction of a new nuclear power plant in Kazakhstan, while Kenya moves forward with plans for a $5 billion plant.

 

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Carbon emissions fall as electricity producers move away from coal

Global Electricity Emissions Decline highlights a 2% drop as coal power falls, while wind and solar surge. EU and US decarbonize faster; China expands coal and gas, challenging Paris Agreement climate targets.

 

Key Points

A 2% annual fall in power-sector CO2, led by less coal and rising wind and solar in the EU and US.

✅ Coal generation fell 3% globally despite China growth

✅ EU and US cut coal; wind and solar up 15% worldwide

✅ Gas gains in US; rapid renewables rollout needed for targets

 

Carbon emissions from the global electricity system fell by 2% last year, the biggest drop in almost 30 years, as countries began to turn their backs on coal-fired power plants.

A new report on the world’s electricity generation revealed the steepest cut in carbon emissions since 1990, with IEA data indicating global totals flatlined in 2019 as the US and the EU turned to cleaner energy sources.

Overall, power from coal plants fell by 3% last year, even as China’s reliance on coal plants climbed for another year to make up half the world’s coal generation for the first time.

Coal generation in the US and Europe has halved since 2007, and last year collapsed by almost a quarter in the EU and by 16% in the US.

The report from climate thinktank Ember, formerly Sandbag, warned that the dent in the world’s coal-fired electricity generation relied on many one-off factors, including milder winters across many countries.

“Progress is being made on reducing coal generation, but nothing like with the urgency needed to limit climate change,” the report said.

Dave Jones, the lead author of the report, said governments must dramatically accelerate the global energy transition so that global coal generation collapses throughout the 2020s.

“To switch from coal into gas is just swapping one fossil fuel for another. The cheapest and quickest way to end coal generation is through a rapid rollout of carbon-free electricity such as wind and solar,” he said.

“But without concerted policymaker efforts to boost wind and solar, we will fail to meet climate targets. China’s growth in coal, and to some extent gas, is alarming but the answers are all there.”

The EU has made the fastest progress towards replacing coal with wind and solar power, while the US has increased its reliance on gas as Wall Street’s energy strategy shifted following its shale boom in recent years.

The report revealed that renewable wind and solar power rose by 15% in 2019 to make up 8% of the world’s electricity.

In the EU, wind and solar power made up almost a fifth of the electricity generated last year, and Europe’s oil majors are turning electric as the bloc stayed ahead of the US which relied on these renewable sources for 11% of its electricity. In China and India, renewable energy made up 8% and 9% of the electricity system, respectively.

To meet the Paris climate goals, the world needs to record a compound growth rate of 15% for wind and solar generation every year – which will require “a colossal effort”, the report warned.

The electricity generation report was published as a separate piece of research claimed that 38 out of 75 of the world’s largest asset managers are stalling on taking action on environmental, social and governance (ESG) issues, and amid investor pressure on utilities to release climate reports.

The latest ranking by Asset Owners Disclosure Project, a scheme managed by the investment campaign group ShareAction, found that the 38 asset managers have weak or nonexistent policy commitments and fail to account for their real-world impacts across their mainstream assets.

The survey also claimed that the investment managers often lack appropriate engagement and escalation processes on climate change, human rights and biodiversity.

Scores were based on a survey of activities in responsible investment governance, climate change, human rights, and biodiversity and ranged between AAA to E. Not a single asset manager was granted an AAA or AA rating, the top two scores available.

Felix Nagrawala, ShareAction analyst, said: “While many in the industry are eager to promote their ESG credentials, our analysis clearly indicates that few of the world’s largest asset managers can lay claim to having a truly sustainable approach across all their investments.”

ShareAction said the world’s six largest asset managers – including BlackRock (rated D), State Street (D) and Vanguard (E) – were among the worst performers.

Vanguard said it was committed to companies making “appropriate disclosures on governance, strategy and performance on relevant ESG risks”. BlackRock and State Street did not respond to a request for comment.

 

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