Letter to the Editor

Southern Company, named as one of the 10 worst corporations of 2001 in last December’s issue of Multinational Monitor, replied to the article in a letter to the corporate responsibility representatives at The Sisters of Charity of Saint Elizabeth, Sisters of St. Dominic of Caldwell, New Jersey, and Sisters of Charity of the Incarnate World. The text of the letter follows below.

Sister Patricia last month faxed me an excerpt from an article entitled “Corporations Behaving Badly: The Ten Worst Corporations of 2001” that had appeared in the December 2001 issue of Multinational Monitor. The excerpt was a section dealing with Southern Company. Unfortunately, the section not only presents a highly biased view of our company but also is inaccurate.

For example, it begins by talking about a non-existent “grandfather clause” in the Clean Air Act. It says: “This provision exempts power plants built before 1970 from Clean Air Act standards.” All Southern Company power plants, regardless of age, are subject to various standards established in or under the authority of the Clean Air Act. This includes National Ambient Air Quality Standards (NAAQS) and Title IV (acid rain) standards. Under the NAAQS provisions, states establish —and revise as necessary — specific emission limits for power plants and other major sources that are designed to ensure that the NAAQS are met and the public is protected from unhealthful air. In 1990, Congress added the Title IV acid rain program to address further concerns about power plant emissions. Both the NAAQS and acid rain programs have resulted in substantial emissions reductions from existing power plants. These plants are not — by any stretch — “grandfathered.” There are, over and above these health- and welfare-based requirements that apply to all plants, some more stringent “new source” standards that apply only to new plants, reflecting the fact that additional controls may be cost-effectively incorporated when a plant is being initially designed.

Another inaccuracy is the characterization of Southern Company’s emissions, most notably the discussion of our emission rates (emissions per kWh). The article says: “It pollutes at higher rate [sic] than other utilities, citing sources that we have not been able to verify. However it is useful to compare us to other utilities using information published by the Natural Resources Defense Council, one of the more prominent environmental organizations. Attached are figures showing a comparison of Southern Company’s SO2, NOx, and CO2 emission rates from fossil-fired power plants to those of other utilities based on the NRDC data. The figures show that Southern Company's emission rates are typical of fossil-fired units and certainly not the extreme rates indicated in the article.

The last point I’d like to make concerns the sinister portrayal of Southern Company’s participation in the political process. We believe that we have an obligation to our shareholders, customers and employees to speak out on public policy issues affecting our business and to actively participate in the political process. In doing this, we comply with all applicable laws, including those dealing with public disclosure. With respect to environmental issues, we have strongly supported establishing requirements based on the best scientific information available as well as a broad view of societal benefits. We believe this is the responsible position to take.

We appreciate you providing a copy of this information dealing with Southern Company and giving us an opportunity to comment. I hope this will be helpful in better understanding our company, and I would be happy to discuss this with you further.

- Charles Goodman
Senior Vice President
Research and Environmental Affairs
Southern Company
Birmingham, Alabama

Editorial clarification: Regarding the “characterization of Southern Company’s emissions,” the Ten Worst Corporations of 2001 article cited U.S PIRG, as well as Southern itself. The following statement is from the company’s website: “In fact, according to 1997 data release by EPA and the U.S. Department of Energy, though Southern Company generated more electricity than any utility in America, we ranked 7th among utilities in SO2 emissions per megawatt-hour.” We acknowledge the typographical error caught by Mr. Goodman.