Consumers Energy : 2022 Carbon Disclosure Project Water Report

CMS Energy Corporation - Water Security 2022

W0. Introduction

W0.1

(W0.1) Give a general description of and introduction to your organization.

CMS Energy Corporation (CMS Energy) is an energy company operating primarily in Michigan. It is the parent holding company of several subsidiaries, including its principal subsidiary, Consumers Energy Company (Consumers Energy or Company), an electric and natural gas utility and CMS Enterprises Company (CMS Enterprises), primarily a domestic independent power producer and marketer. Consumers Energy's electric utility operations include the generation, purchase, distribution, and sale of electricity, and its gas utility operations include the purchase, transmission, storage, distribution, and sale of natural gas. Consumers Energy serves about 6.8 million of Michigan's 10 million residents. CMS Enterprises, through its subsidiaries and equity investments, is engaged in domestic independent power production, including the development and operation of renewable generation and marketing of independent power production. CMS Energy was also the parent holding company of EnerBank USA® (EnerBank) until October 1, 2021 when EnerBank was acquired by Regions Bank. This report is ONLY for the principal subsidiary of CMS Energy, Consumers Energy.

Consumers Energy acknowledges that the long-term sustainability of our Company depends upon our ability to listen to our stakeholders and conduct business that promotes environmental health, increases societal value, and brings economic success so that we can provide safe, reliable, and affordable energy to our customers. This commitment is advanced by our focus on the triple bottom line: people, planet and prosperity.

In 2018, Consumers Energy committed to a set of Corporate Planet Breakthrough Goal to save 1 billion gallons of water through 2022.

1. This report is made as of the date hereof and contains "forward-looking statements" as defined in Rule 3b-6 of the Securities Exchange Act of 1934, Rule 175 of the Securities Act of 1933, and relevant legal decisions. The forward-looking statements are subject to risks and uncertainties and should be considered in the context of the risk and other factors detailed in CMS Energy's and Consumers Energy's SEC filings. Forward-looking statements should be read in conjunction with "FORWARD-LOOKING STATEMENTS AND INFORMATION" and "RISK FACTORS" sections of CMS Energy's and Consumers Energy's most recent Form 10-K and as updated in reports CMS Energy and Consumers Energy file with the SEC. CMS Energy's and Consumers Energy's "FORWARD-LOOKING STATEMENTS AND INFORMATION" and "RISK FACTORS" sections are incorporated herein by reference and discuss important factors that could cause CMS Energy's and Consumers Energy's results to differ materially from those anticipated in such statements. CMS Energy and Consumers Energy undertake no obligation to update any of the information presented herein to reflect facts, events or circumstances after the date hereof.
2. Nameplate capacity in section W-EU0.1b represents generation capacity during the summer months (planning year 2021 capacity as reported to Midcontinent Independent System Operator, Inc. and limited by interconnection service limits), for wind and solar generation, the amount represents the effective load-carrying capability.

W-EU0.1a

(W-EU0.1a) Which activities in the electric utilities sector does your organization engage in?

Electricity generation

Distribution

W-EU0.1b

(W-EU0.1b) For your electricity generation activities, provide details of your nameplate capacity and the generation for each technology.

	Nameplate capacity (MW)	% of total nameplate capacity	Gross electricity generation (GWh)
Coal - hard	2043	40.9	10861
Lignite	0	0	0
Oil	701	14	0
Gas	2318	46.4	5562
Biomass	0	0	0
Waste (non-biomass)	0	0	0
Nuclear	0	0	0
Fossil-fuel plants fitted with carbon capture and storage	0	0	0
Geothermal	0	0	0
Hydropower	0	0	0
Wind	632	12.6	1570
Solar	4	0.08	6
Marine	0	0	0
Other renewable	0	0	0
Other non-renewable	0	0	0
Total	5698	100	17999

W0.2

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(W0.2) State the start and end date of the year for which you are reporting data.

	Start date	End date
Reporting year	January 1 2021	December 31 2021

W0.3

(W0.3) Select the countries/areas in which you operate.

United States of America

W0.4

(W0.4) Select the currency used for all financial information disclosed throughout your response.

USD

W0.5

(W0.5) Select the option that best describes the reporting boundary for companies, entities, or groups for which water impacts on your business are being reported.

Companies, entities or groups over which financial control is exercised

W0.6

(W0.6) Within this boundary, are there any geographies, facilities, water aspects, or other exclusions from your disclosure?

Yes

W0.6a

(W0.6a) Please report the exclusions.

Exclusion	Please explain
Hydroelectric Operations	This report focuses on Consumers Energy's largest sources of water withdrawals, our steam electric power generating facilities which operate under National Pollutant Discharge
	Elimination System (NPDES) permits and comprise a majority of our water use. Our hydroelectric plants and Ludington Pumped Storage Facility are not included in this report.
Electric Distribution	This report focuses on Consumers Energy's largest sources of water withdrawals, our steam electric power generating facilities which operate under National Pollutant Discharge
Operations	Elimination System permits and comprise a majority of our water use. Therefore, our electric distribution operations are not included in this report.
Gas Distribution,	This report focuses on Consumers Energy's largest sources of water withdrawals, our steam electric power generating facilities which operate under National Pollutant Discharge
Transmission and Storage	Elimination System permits and comprise a majority of our water use. Therefore, our natural gas compressor stations are not included in this report.
Operations
Service Center, Call	This report focuses on Consumers Energy's largest sources of water withdrawals, our steam electric power generating facilities which operate under National Pollutant Discharge
Centers and Office	Elimination System permits and comprise a majority of our water use. Therefore, our service centers, call centers and office buildings are not included in this report.
Buildings
Non-Utility Operations	This report focuses on Consumers Energy's largest sources of water withdrawals, our steam electric power generating facilities which operate under National Pollutant Discharge
	Elimination System permits and comprise a majority of our water use. Therefore, non-utility operations are not included in this report.

W0.7

(W0.7) Does your organization have an ISIN code or another unique identifier (e.g., Ticker, CUSIP, etc.)?

Indicate whether you are able to provide a unique identifier for your organization.	Provide your unique identifier

W1. Current state

W1.1

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(W1.1) Rate the importance (current and future) of water quality and water quantity to the success of your business.

	Direct use	Indirect	Please explain
	importance	use
	rating	importance
		rating
Sufficient	Vital	Important	Direct Use: Quality freshwater from nearby lakes, rivers, and groundwater is withdrawn primarily for non-contact cooling purposes. In addition, water quality is important in
amounts of			steam generation as specific chemicals, including some salts, can result in boiler and condenser tube/pipe corrosion over time. This use is rated as "vital for operations"
good quality			because without this water input, our steam electric generating facilities would not be able to operate as currently configured. While our intake systems can accommodate
freshwater			moderate fluctuations in water levels, maintaining historic lake and river levels is important to ongoing utilization of our current water intake infrastructure without
available for			significant and costly modification through 2025 for coal generation. Indirect Use: This use is rated as "important" because freshwater is essential to fuel exploration,
use			production, and processing, which is vital to our operations.
Sufficient	Important	Important	Direct: Recycled water is used for non-contact cooling and other plant processes and reduces the amount of freshwater withdrawn for these uses. Two of our generating
amounts of			facilities use primarily recycled water for condenser cooling. Indirect Use: This use is rated as "important" because recycling and reusing water is essential for fuel
recycled,			exploration, production, and processing, particularly in arid climates with less freshwater availability.
brackish and/or
produced water
available for
use

W1.2

(W1.2) Across all your operations, what proportion of the following water aspects are regularly measured and monitored?

	% of	Please explain
	sites/facilities/operations
Water withdrawals - total	100%	Water withdrawn is monitored at 100% of sites (steam electric generating facilities) due to the vital importance of water to site operations and to track
volumes		potential environmental risks. Water withdrawal volumes are required to be reported in a number of programs including water stewardship tracking, annual
		reporting of water usage to the Michigan Department of Environment, Great Lakes, and Energy (EGLE), and annual reporting to the United States
		Department of Energy, Energy Information Administration Form 923 Supplemental
Water withdrawals -	100%	Water withdrawn from surface water, groundwater and municipal sources is monitored at 100% of sites (steam electric generating facilities) for the
volumes by source		purposes of tracking water quality and availability from local systems.
Entrained water associated
with your metals & mining
sector activities - total
volumes [only metals and
mining sector]
Produced water associated
with your oil & gas sector
activities - total volumes
[only oil and gas sector]
Water withdrawals quality	100%	Water withdrawal quality is monitored at 100% of sites (steam electric generation) to determine the necessary level of treatment required for use.
Water discharges - total	100%	Water discharge volumes are monitored at 100% of sites (steam electric generating facilities) due to the vital importance of water to site operations and to
volumes		track potential environmental risks. Water discharge volumes are required to be reported in a number of programs including water quality monitoring
		associated with site NPDES permits, annual reporting of water usage to the Michigan Department of Environment, Great Lakes, and Energy (EGLE), and
		annual reporting for the United States Department of Energy, Energy Information Administration Form 923 Supplemental.
Water discharges -	100%	Water volume discharged by destinations, including Great Lakes, inland lakes, rivers, ground and municipal water systems, is tracked for 100% of sites
volumes by destination		(steam electric generating facilities) for purposes of ensuring minimal adverse impact to local ecosystems and ensuring the majority of water withdrawn is
		returned to the watershed. Additionally, these volumes are required to be reported for water quality monitoring associated with site NPDES permits, annual
		reporting of water usage to the Michigan Department of Environment, Great Lakes, and Energy (EGLE), and annual reporting for the United States
		Department of Energy, Energy Information Administration Form 923 Supplemental.
Water discharges -	100%	Water discharged following different treatment methods is tracked for 100% of sites (steam electric generating facilities) to monitor treatment system
volumes by treatment		effectiveness and capacity as well as for required water quality monitoring associated with site NPDES permits.
method
Water discharge quality - by	100%	Water discharge quality is monitored at 100% of sites (steam electric generating facilities) for compliance with National Pollutant Discharge Elimination
standard effluent		System (NPDES) surface water discharge permits as well as state-issued groundwater permits.
parameters
Water discharge quality -	100%	Water discharge quality, including temperature, is monitored at 100% of sites (steam electric generating facilities) for compliance with National Pollutant
temperature		Discharge Elimination System (NPDES) surface water discharge permits as well as state-issued groundwater permits.
Water consumption - total	100%	Water consumption is tracked at 100% of sites (steam electric generating facilities) in order to track consumptive losses through once-through cooling and
volume		cooling tower systems and makeup water needs to those systems. Consumptive losses are typically through evaporative losses or discharges to
		underground injection wells.
Water recycled/reused	26-50	Water recycled/reused is tracked at approximately 50% of sites (steam electric generating facilities) as part of the company-wide water savings goal.
		Water reuse at our coal fired generating plants include reusing once through cooling water for makeup water needs in the air quality control systems and
		routing stormwater runoff from coal pile storage to be reused as condenser cooling water onsite.
The provision of fully-	100%	Fully-functioning WASH services are provided for workers at 100% of sites (steam electric generating facilities) and are monitored for usage. Potable
functioning, safely managed		sources include groundwater wells and municipal sources, and usage from these sources is required to be reported through municipal water utility
WASH services to all		discharge permits, annual reporting of water usage to the Michigan Department of Environment, Great Lakes, and Energy (EGLE), and annual reporting
workers		for the United States Department of Energy, Energy Information Administration Form 923 Supplemental.

W1.2b

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(W1.2b) What are the total volumes of water withdrawn, discharged, and consumed across all your operations, and how do these volumes compare to the previous reporting year?

	Volume	Comparison with previous	Please explain
	(megaliters/year)	reporting year
Total	1303922	Higher	Total water withdrawals in 2021 for the Consumers Energy steam electric generating fleet were 13% higher than the withdrawals for
withdrawals			2020.
Total	1298180	Higher	Total water discharges in 2021 for the Consumers Energy steam electric generating fleet were 13% higher than the withdrawals for
discharges			2020.
Total	5742	Higher	Total water consumption in 2021 for the Consumers Energy steam electric generating fleet was approximately 19% higher than the
consumption			total consumption for 2020.

W1.2d

(W1.2d) Indicate whether water is withdrawn from areas with water stress and provide the proportion.

	Withdrawals are from areas with	% withdrawn from areas with	Comparison with previous	Identification	Please explain
	water stress	water stress	reporting year	tool
Row	Yes	Less than 1%	About the same	WRI	According to the WRI Aqueduct tool, the baseline water stress near Consumers
1				Aqueduct	Energy generating facilities are low.

W1.2h

(W1.2h) Provide total water withdrawal data by source.

	Relevance	Volume	Comparison with previous	Please explain
		(megaliters/year)	reporting year
Fresh surface water, including rainwater, water from	Relevant	1296996	Higher	Surface Water was withdrawn for cooling water purposes. Consumers Energy
wetlands, rivers, and lakes				withdrew 13% more than 2020.
Brackish surface water/Seawater	Not			Consumers Energy electric generation operations are not near brackish
	relevant			surface/seawater.
Groundwater - renewable	Relevant	2611	Higher	Process groundwater usage was 42% higher than 2020.
Groundwater - non-renewable	Not			Consumers Energy electric generation operations do not withdraw groundwater
	relevant			from non-renewable aquifers
Produced/Entrained water	Not			Consumers Energy electric generation operations do not produce well production
	relevant			water
Third party sources	Relevant	4316	About the same	Municipal water was withdrawn for cooling water purposes. Consumers Energy
				withdrew 3% less than 2020.

W1.2i

(W1.2i) Provide total water discharge data by destination.

	Relevance	Volume	Comparison with previous reporting	Please explain
		(megaliters/year)	year
Fresh surface water	Relevant	1297428	Higher	The electric generating plants which discharge water from surface water sources discharged 13% more
				in 2021.
Brackish surface	Not			Consumers Energy electric generation operations are not near brackish surface/seawater.
water/seawater	relevant
Groundwater	Relevant	234	Higher	The electric generating plants which discharge water from groundwater sources discharged 22% more
				in 2021.
Third-party destinations	Relevant	518	Higher	The electric generating plants which discharge water from municipal sources discharged 31% more in
				2020.

W1.2j

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(W1.2j) Within your direct operations, indicate the highest level(s) to which you treat your discharge.

	Relevance of	Volume	Comparison of treated volume	% of your	Please explain
	treatment level to	(megaliters/year)	with previous reporting year	sites/facilities/operations this
	discharge			volume applies to
Tertiary treatment	Not relevant				Consumers Energy does not use tertiary treatment on discharge
					water.
Secondary treatment	Not relevant				Consumers Energy does not use secondary treatment on
					discharge water.
Primary treatment only	Relevant	1297662	Higher	11-20	Consumers Energy uses settling basins, tanks and ditches for
					primary treatment on discharge water.
Discharge to the natural	Not relevant				Consumers Energy does not use discharges to the natural
environment without					environment without treatment in the electrical generation process
treatment
Discharge to a third party	Relevant	518	Higher	21-30	Consumers Energy uses municipal wastewater treatment plants for
without treatment					third party treatment of discharge water.
Other	Not relevant

W1.3

(W1.3) Provide a figure for your organization's total water withdrawal efficiency.

	Revenue	Total water withdrawal	Total water	Anticipated forward trend
		volume (megaliters)	withdrawal efficiency
Row	7329000	1303922	5620.73498261399	Consumers Energy expects to see a substantial decrease in water use over the next 5 years as we retire our coal generation sites. This
1	000			will contribute to an increase in water withdrawal efficiency.

W-EU1.3

(W-EU1.3) Do you calculate water intensity for your electricity generation activities?

Yes

W-EU1.3a

(W-EU1.3a) Provide the following intensity information associated with your electricity generation activities.

Water intensity value	Numerator: water	Denominator	Comparison with previous	Please explain
(m3)	aspect		reporting year
200603	Total water	MWh	Higher	The increase in water intensity can be accounted for by the increased surface water and groundwater withdrawals in
	withdrawals			2021 compared with 2020.

W1.4

(W1.4) Do you engage with your value chain on water-related issues?

Yes, our suppliers

Yes, our customers or other value chain partners

W1.4a

(W1.4a) What proportion of suppliers do you request to report on their water use, risks and/or management information and what proportion of your procurement spend does this represent?

Row 1

• of suppliers by number Unknown
• of total procurement spend Unknown

Rationale for this coverage

The Company is developing procedures to request and document information from its largest suppliers, on a cost basis, to discern if the supplier has the potential to negatively impact the environment, if an environmental management system has been implemented and whether cost effective measures to avoid pollution have been implemented. In addition, the Company tracks environmental regulations and rulemakings to ensure compliance with emerging contaminants.

Impact of the engagement and measures of success

Supplier surveys on environmental management and water-related metrics allow the Company to evaluate supplier performance in key sustainability areas and provides context for pursuing further engagement with suppliers in these areas.

Comment

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