TY 2021 Form 990 Schedule O

efile Public Visual Render ObjectId: 202243139349304189 - Submission: 2022-11-09 TIN: 43-1943334

SCHEDULE O
(Form 990)

Department of the Treasury
Internal Revenue Service

Supplemental Information to Form 990 or 990-EZ

Complete to provide information for responses to specific questions on
Form 990 or 990-EZ or to provide any additional information.
MediumBullet

Attach to Form 990 or 990-EZ.
MediumBullet

Go to www.irs.gov/Form990 for the latest information.

OMB No. 1545-0047

2021

Open to Public
Inspection

Name of the organization

Great Rivers Environmental Law Center

Employer identification number

43-1943334

Return Reference	Explanation
Pt VI, Line 11b	The 990 draft was emailed to all board members for review. Each was requested to respond within the comment period with either an approval or with additions/revisions. Responses were then summarized and any changes forwarded to the tax return preparer for inclusion in the final version of the return.
Pt VI, Line 12c	Each board member and member of a committee with governing board-delegated powers annually signs a statement which affirms that the person: a. Has received a copy of the conflict of interest policy; b. Has read and understands the policy; c. Has agreed to comply with the policy; and d. Understands the Organization is a charitable one and, in order to maintain its federal tax exemption, it must engage primarily in activities which accomplish one or more of its tax-exempt purposes. In addition, every time the board discusses whether or not to accept a new case,the board members must disclose any interests that might give rise to a conflict.
Pt VI, Line 15a	During 2021 there were six attorneys who worked for Great Rivers. Bruce Morrison was the President. The other five were staff attorneys. The board members compare the salaries of the attorneys annually to similar positions in the St. Louis area and confirm that the attorneys chose to have lower salaries than the going rate for attorneys with their experience in small firms and with a specialized practice of environmental protection so more funds can be used for the program.
Pt VII, Col (F)	Great Rivers makes its governing documents, conflict of interest policy, audited financial statements, and 990's available to the public upon request. The audited statements and 990's are on its website. The 990's and other information can also be found on the Candid (formerly Guidestar) website.
Other	Pt.VII - line 1 - Officer of the Organization - Bruce Morrison, the President, was an officer of the Organization and also an employee. Missouri law allows employees to be officers of a not-for-profit organization. He is not paid for his officer duties nor is he a board member.
Pt VI, Line 15b	See the description above for Pt. VI, Line 15a
Other	Pt. XII, line 2a and 2c - The executive committee is responsible for monitoring the accounting processes and selecting who provides the accounting and auditing for the organization. The organization obtains an audit every other year. In the off years our CPA provides "preparation" engagement statements which are comparable to "compiled" statements. She completes a thorough review of the accounting transactions each year and consults with staff during the year about accounting and other business issues. She prepares our 990's.
Other	Part III, line 4 - Statement of Program Service Accomplishments - I.CLIMATE AND ENERGY PROGRAM Great Rivers works to address climate change by decreasing carbon emissions and encouraging cleaner energy. Missouri's electricity is among the most coal-intensive in the country, at 80%. Almost no coal is mined (or oil or gas drilled) in Missouri, and we have good wind and solar potential. Our utilities' coal-burning power plants are old and lack up-to-date pollution controls, which keeps them relatively cheap at the expense of the public's health and a stable climate. Great Rivers appears regularly before the Missouri Public Service Commission, the state's utility regulator. Where environmental voices were never heard before, we represent traditional environmental advocates like Sierra Club and Natural Resources Defense Council along with front-line social justice organizations like the Missouri NAACP, Dutchtown South Community Corporation, and Metropolitan Congregations United. Together, we advocate for more energy efficiency programs, more wind and solar generation, and for electrification of transportation. In 2021, we were before the Missouri Public Service Commission (PSC) on a variety of matters, pressing Missouri's investor-owned utilities for change. II.ENVIRONMENTAL JUSTICE PROGRAM Great Rivers is committed to monitoring permitting actions that will unfairly burden minority, low-income communities. On behalf of clients across the State, Great Rivers evaluates proposed pollution sources to determine whether government authorities have unfairly targeted disadvantaged populations. Matters include those involving air pollution, solid and hazardous waste, safe drinking water, energy, and lead poisoning. In 2021, we worked with community partners who have concerns about elevated lead levels in drinking water inside the City of St. Louis Juvenile Detention Center. The facility's director is receptive to reducing lead levels in drinking water within the facility. For the St. Louis County NAACP, we engaged with USEPA regarding EPA's "Strategy to Reduce Lead Exposures and Disparities in U.S. Communities." We continued to work with the Hyde Park Neighborhood Association to address trash and hazardous waste dumping as well as possible zoning violations at a facility in the Hyde Park Neighborhood. We continue to help the St. Louis County NAACP to draft and execute its advocacy plan concerning radiation surrounding Coldwater Creek in St. Louis County. We created and hosted an interactive training for the public on Missouri's environmental boards and commissions. The purpose of the training was to educate the public about these positions and help interested persons apply to these commissions. These boards and commissions make decisions that affect everyday health. Great Rivers continued to collaborate with the Mo. State Conference of the NAACP, the NAACP's national office, and Missouri NAACP local branches on environmental justice matters, and Bruce continues in his role as the Environmental and Climate Justice Committee Chair for the Missouri State Conference and the St. Louis County branch. III. SUSTAINABLE LANDS PROGRAM Our sustainable lands program consists of assisting individuals, citizens' groups and environmental organizations in their efforts to preserve and protect parks, open space, forests and wilderness areas. In 2021, the National Park Service released for public comment a Roads and Trails Management Plan and Environmental Assessment for the Ozark National Scenic Riverways (ONSR). Great Rivers joined in group comments on the Roads and Trails Management Plan submitted by a coalition of organizations. Great Rivers also drafted and filed separate comments on behalf of Missouri Confluence Waterkeeper. In 2021, Shannon County refiled its lawsuit regarding unauthorized roads and trails within the ONSR, which we are defending for L-A-D Foundation. We also began helping a community in Howell County, Missouri, to organize and advocate over its concerns about water quality impacts to the Wild and Scenic Eleven Point River. IV. AIR QUALITY AND PUBLIC HEALTH PROGRAM Great Rivers seeks to protect the public health by preventing further deterioration of the region's air quality, and by reducing and preventing exposure to toxic substances. An important part of our Air Quality and Public Health Program involves monitoring actions taken by federal, state and local governments that will impact the quality of the air we breathe. Measures taken by Great Rivers include drafting comments to proposed rules, issuing position papers about pollutants, representing individuals in agency proceedings, and, as a last resort, handling litigation for clients seeking to improve air quality and public health. In 2021, we started discussions with several community partners interested in joining us in a community air monitoring effort, and we collaborated with two others regarding their community air monitoring projects. We engaged the Missouri Department of Natural Resources (MDNR) on a number of draft air pollution permits. We also engaged with federal officials on several matters (with USEPA's National Environmental Justice Advisory Council, with USEPA on air monitoring, and with USEPA on lead issues.) Regarding U.S. EPA's investigation of our environmental justice complaint against MDNR, MDNR decided no longer to resist entirely the complaint and investigation and, instead, will attempt to work with EPA toward a voluntary resolution of the concerns. In 2021 we began a relationship with community members in Sikeston, Missouri, regarding air pollution issues associated with the Sikeston Energy facility (primarily through the NAACP Sikeston Branch). V. WATER QUALITY PROGRAM On behalf of our clients, Great Rivers seeks to protect and preserve the waters of Missouri and surrounding states. Our water quality program begins with monitoring proposed federal, state and local actions that will adversely affect water quality. Great Rivers is frequently involved in matters that adversely impact water quality. This includes assisting environmental groups, citizens' organizations and individuals in their legal challenges designed to protect the quality of the waters. In 2021, we continued to assist our community partners regarding water quality and coal ash through administrative processes and enforcement actions. We worked with Missouri Confluence Waterkeeper (MCW) to submit comments to MDNR regarding Ameren's proposal to ineffectively treat groundwater through underground injection at its Portage Des Sioux facility. MCW's position is that the waste needs to be removed, not left in the floodplain, 50 feet from the Mississippi River and perpetually posing a risk to St. Louis City's water supply and recreationists who use the river in the vicinity. In 2021 we worked with MCW to identify new targets for Clean Water Act enforcement efforts. These efforts lead to the discovery of facilities that are violating their permits. We continued to stay involved in water quality standards and attended various stakeholder meetings and submitted comments on MDNR's efforts to update water quality standards. In 2021, we served Sugar Camp Energy and its parent company with a notice of violation letter for violations of the Clean Water Act, RCRA and SMCRA resulting from the company's application of PFAS and toxic firefighting foam into a mine to extinguish a mine fire. The use of foam resulted in a discharge of PFAS and other toxic materials into nearby creeks. VI. WETLANDS AND FLOODPLAIN PROTECTION PROGRAM: MISSISSIPPI & MISSOURI RIVER BASINS On behalf of our clients, we challenge environmentally detrimental floodplain development and the over-engineering of rivers by means of levees and dams that destroy floodplains and aggravate flood risk. We monitor permit applications to dredge and fill wetlands. Great Rivers submits comments on proposals and assists environmental groups and individuals in their legal challenges to protect wetlands. These activities affect all of the people who inhabit and work in the watersheds of the Missouri and Mississippi Rivers which drain major portions of the central and northwestern United States. In 2021, we continued to collaborate with partner organizations about unlawfully elevated levees. Several levee and drainage districts along the Mississippi River have elevated their levees without required approvals and without mitigating for increased flood Heights caused by these elevations. As a result, nearby communities in Illinois and Missouri are at increased risk of flooding.

Return Reference

Explanation

Pt VI, Line 11b

The 990 draft was emailed to all board members for review. Each was requested to respond within the comment period with either an approval or with additions/revisions. Responses were then summarized and any changes forwarded to the tax return preparer for inclusion in the final version of the return.

Pt VI, Line 12c

Each board member and member of a committee with governing board-delegated powers annually signs a statement which affirms that the person: a. Has received a copy of the conflict of interest policy; b. Has read and understands the policy; c. Has agreed to comply with the policy; and d. Understands the Organization is a charitable one and, in order to maintain its federal tax exemption, it must engage primarily in activities which accomplish one or more of its tax-exempt purposes. In addition, every time the board discusses whether or not to accept a new case,the board members must disclose any interests that might give rise to a conflict.

Pt VI, Line 15a

During 2021 there were six attorneys who worked for Great Rivers. Bruce Morrison was the President. The other five were staff attorneys. The board members compare the salaries of the attorneys annually to similar positions in the St. Louis area and confirm that the attorneys chose to have lower salaries than the going rate for attorneys with their experience in small firms and with a specialized practice of environmental protection so more funds can be used for the program.

Pt VII, Col (F)

Great Rivers makes its governing documents, conflict of interest policy, audited financial statements, and 990's available to the public upon request. The audited statements and 990's are on its website. The 990's and other information can also be found on the Candid (formerly Guidestar) website.

Other

Pt.VII - line 1 - Officer of the Organization - Bruce Morrison, the President, was an officer of the Organization and also an employee. Missouri law allows employees to be officers of a not-for-profit organization. He is not paid for his officer duties nor is he a board member.

Pt VI, Line 15b

See the description above for Pt. VI, Line 15a

Other

Pt. XII, line 2a and 2c - The executive committee is responsible for monitoring the accounting processes and selecting who provides the accounting and auditing for the organization. The organization obtains an audit every other year. In the off years our CPA provides "preparation" engagement statements which are comparable to "compiled" statements. She completes a thorough review of the accounting transactions each year and consults with staff during the year about accounting and other business issues. She prepares our 990's.

Other

Part III, line 4 - Statement of Program Service Accomplishments - I.CLIMATE AND ENERGY PROGRAM Great Rivers works to address climate change by decreasing carbon emissions and encouraging cleaner energy. Missouri's electricity is among the most coal-intensive in the country, at 80%. Almost no coal is mined (or oil or gas drilled) in Missouri, and we have good wind and solar potential. Our utilities' coal-burning power plants are old and lack up-to-date pollution controls, which keeps them relatively cheap at the expense of the public's health and a stable climate. Great Rivers appears regularly before the Missouri Public Service Commission, the state's utility regulator. Where environmental voices were never heard before, we represent traditional environmental advocates like Sierra Club and Natural Resources Defense Council along with front-line social justice organizations like the Missouri NAACP, Dutchtown South Community Corporation, and Metropolitan Congregations United. Together, we advocate for more energy efficiency programs, more wind and solar generation, and for electrification of transportation. In 2021, we were before the Missouri Public Service Commission (PSC) on a variety of matters, pressing Missouri's investor-owned utilities for change. II.ENVIRONMENTAL JUSTICE PROGRAM Great Rivers is committed to monitoring permitting actions that will unfairly burden minority, low-income communities. On behalf of clients across the State, Great Rivers evaluates proposed pollution sources to determine whether government authorities have unfairly targeted disadvantaged populations. Matters include those involving air pollution, solid and hazardous waste, safe drinking water, energy, and lead poisoning. In 2021, we worked with community partners who have concerns about elevated lead levels in drinking water inside the City of St. Louis Juvenile Detention Center. The facility's director is receptive to reducing lead levels in drinking water within the facility. For the St. Louis County NAACP, we engaged with USEPA regarding EPA's "Strategy to Reduce Lead Exposures and Disparities in U.S. Communities." We continued to work with the Hyde Park Neighborhood Association to address trash and hazardous waste dumping as well as possible zoning violations at a facility in the Hyde Park Neighborhood. We continue to help the St. Louis County NAACP to draft and execute its advocacy plan concerning radiation surrounding Coldwater Creek in St. Louis County. We created and hosted an interactive training for the public on Missouri's environmental boards and commissions. The purpose of the training was to educate the public about these positions and help interested persons apply to these commissions. These boards and commissions make decisions that affect everyday health. Great Rivers continued to collaborate with the Mo. State Conference of the NAACP, the NAACP's national office, and Missouri NAACP local branches on environmental justice matters, and Bruce continues in his role as the Environmental and Climate Justice Committee Chair for the Missouri State Conference and the St. Louis County branch. III. SUSTAINABLE LANDS PROGRAM Our sustainable lands program consists of assisting individuals, citizens' groups and environmental organizations in their efforts to preserve and protect parks, open space, forests and wilderness areas. In 2021, the National Park Service released for public comment a Roads and Trails Management Plan and Environmental Assessment for the Ozark National Scenic Riverways (ONSR). Great Rivers joined in group comments on the Roads and Trails Management Plan submitted by a coalition of organizations. Great Rivers also drafted and filed separate comments on behalf of Missouri Confluence Waterkeeper. In 2021, Shannon County refiled its lawsuit regarding unauthorized roads and trails within the ONSR, which we are defending for L-A-D Foundation. We also began helping a community in Howell County, Missouri, to organize and advocate over its concerns about water quality impacts to the Wild and Scenic Eleven Point River. IV. AIR QUALITY AND PUBLIC HEALTH PROGRAM Great Rivers seeks to protect the public health by preventing further deterioration of the region's air quality, and by reducing and preventing exposure to toxic substances. An important part of our Air Quality and Public Health Program involves monitoring actions taken by federal, state and local governments that will impact the quality of the air we breathe. Measures taken by Great Rivers include drafting comments to proposed rules, issuing position papers about pollutants, representing individuals in agency proceedings, and, as a last resort, handling litigation for clients seeking to improve air quality and public health. In 2021, we started discussions with several community partners interested in joining us in a community air monitoring effort, and we collaborated with two others regarding their community air monitoring projects. We engaged the Missouri Department of Natural Resources (MDNR) on a number of draft air pollution permits. We also engaged with federal officials on several matters (with USEPA's National Environmental Justice Advisory Council, with USEPA on air monitoring, and with USEPA on lead issues.) Regarding U.S. EPA's investigation of our environmental justice complaint against MDNR, MDNR decided no longer to resist entirely the complaint and investigation and, instead, will attempt to work with EPA toward a voluntary resolution of the concerns. In 2021 we began a relationship with community members in Sikeston, Missouri, regarding air pollution issues associated with the Sikeston Energy facility (primarily through the NAACP Sikeston Branch). V. WATER QUALITY PROGRAM On behalf of our clients, Great Rivers seeks to protect and preserve the waters of Missouri and surrounding states. Our water quality program begins with monitoring proposed federal, state and local actions that will adversely affect water quality. Great Rivers is frequently involved in matters that adversely impact water quality. This includes assisting environmental groups, citizens' organizations and individuals in their legal challenges designed to protect the quality of the waters. In 2021, we continued to assist our community partners regarding water quality and coal ash through administrative processes and enforcement actions. We worked with Missouri Confluence Waterkeeper (MCW) to submit comments to MDNR regarding Ameren's proposal to ineffectively treat groundwater through underground injection at its Portage Des Sioux facility. MCW's position is that the waste needs to be removed, not left in the floodplain, 50 feet from the Mississippi River and perpetually posing a risk to St. Louis City's water supply and recreationists who use the river in the vicinity. In 2021 we worked with MCW to identify new targets for Clean Water Act enforcement efforts. These efforts lead to the discovery of facilities that are violating their permits. We continued to stay involved in water quality standards and attended various stakeholder meetings and submitted comments on MDNR's efforts to update water quality standards. In 2021, we served Sugar Camp Energy and its parent company with a notice of violation letter for violations of the Clean Water Act, RCRA and SMCRA resulting from the company's application of PFAS and toxic firefighting foam into a mine to extinguish a mine fire. The use of foam resulted in a discharge of PFAS and other toxic materials into nearby creeks. VI. WETLANDS AND FLOODPLAIN PROTECTION PROGRAM: MISSISSIPPI & MISSOURI RIVER BASINS On behalf of our clients, we challenge environmentally detrimental floodplain development and the over-engineering of rivers by means of levees and dams that destroy floodplains and aggravate flood risk. We monitor permit applications to dredge and fill wetlands. Great Rivers submits comments on proposals and assists environmental groups and individuals in their legal challenges to protect wetlands. These activities affect all of the people who inhabit and work in the watersheds of the Missouri and Mississippi Rivers which drain major portions of the central and northwestern United States. In 2021, we continued to collaborate with partner organizations about unlawfully elevated levees. Several levee and drainage districts along the Mississippi River have elevated their levees without required approvals and without mitigating for increased flood Heights caused by these elevations. As a result, nearby communities in Illinois and Missouri are at increased risk of flooding.

For Paperwork Reduction Act Notice, see the Instructions for Form 990 or 990-EZ.

Cat. No. 51056K

Schedule O (Form 990) 2021

Software ID:	21013422
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