An activity can contribute to the climate goals:
- based on its own performance (for example, in the case of the EDF group: the production of electricity from renewable sources);
- when it directly enables the exercise of other sustainable activities. It is then qualified as an enabling activity (for example, in the case of the EDF group: the electricity transmission activity);
- if it supports the transition to a climate-neutral economy and there is no technologically and economically feasible low-carbon alternative. It is then qualified as transitional. This is the case for nuclear and gas activities in the Delegated Act adopted on 2 February and submitted to the European Parliament and the Council of the EU.
An eligible activity will be considered aligned if, in addition, it complies with the technical criteria of contributing substantially to one of the six environmental objectives (e.g. in relation to emission thresholds), if it meets the so-called “Do No Significant Harm” (DNSH) criteria, i.e. it does not significantly harm the other environmental objectives and, finally, if it is carried out in compliance with the minimum safeguards relating to human rights or fundamental labour rights.
3.8.3.3 Analysis of EDF group activities with regard to eligibility and alignment
3.8.3.3.1 Analysis of activities with regard to their eligibility under the regulations in force on 31 December 2021
3.8.3.3.1.1 Main EDF group activities eligible for the taxonomy
Under the previous definition, the following activities contribute substantially to
mitigating climate change:
- electricity distribution (NACE codes D35.12 and D35.13): construction and operation of interconnected electricity distribution and transmission networks
(4.91);
- electricity generation from renewable energy sources excluding hydro (NACE
codes D35.11 and F42.22), which include:
- electricity generation using solar photovoltaic technology (4.1 (1)),
- electricity generation from onshore and offshore wind power (4.3(1)),
- electricity storage (4.10 (1)),
- installation, maintenance and repair of renewable energy technologies (7.6 (1)) ;
- electricity generation from hydropower (NACE codes D35.11 and F42.22):
construction and operation of power generation facilities using hydroelectric
power plants (reservoir power plants, run-of-river power plants, and pumped
storage power stations – 4.5; 4.10 (1)) ;
- district heating/cooling distribution, cogeneration of heat/cold and power from
bioenergy (4.15; 4.20 (1))
- energy efficiency and performance services, research and development that correspond to:
- installation, maintenance and repair of energy efficiency equipment (7.3 (1)),
- specialised services related to the energy performance of buildings (9.3 (1)),
- research, development and innovation expenditures to reduce or avoid
emissions (9.1 (1)).
3.8.3.3.1.2 Group activities not explicitly mentioned in the Delegated Act
Some of the Group’s activities are not explicitly mentioned in the regulation but, after analysis, have been considered as contributing substantially to mitigating climate change because they can be linked to activities listed in Annex I of Delegated Act 2021/2139 of 4 June 2021. The following activities were considered eligible:
- sale of electricity from Purchase Obligations: this legislative and
regulatory mechanism obliges EDF to purchase electricity produced by certain
100% renewable energy sources and to sell it to customers on the same basis
as EDF’s own production. As a producer with control over this electricity sold,
the Group considers the sales eligible;
- sale of electricity from renewable sources in long-term contracts (PPA or Power Purchase Agreement) when the EDF group is the producer of the renewable electricity and sells it to third parties.
On the other hand, with regard to the aggregation activity: this activity consists of selling the electricity purchased from (renewable) electricity producers or from players with load-shedding capacities. Even though aggregation plays a key role in the development of renewable energy, and therefore in the mitigation of climate change, it was not selected as eligible because the core of the business model is similar to marketing, which is excluded from the Taxonomy.
3.8.3.3.1.3 Activities not eligible under current legislation
The activities below are those for which the Group has not identified a direct contribution to one or more objectives of the European Taxonomy and are not covered by Annexes I and II of the Delegated Act:
- marketing of electricity not produced by EDF or whose source of production is not eligible;
- production of energy from gas installations and marketing of gas;
- optimisation and trading;
- nuclear power generation and nuclear services;
- other
For this first year of implementation, the Group has excluded from the analysis the activities of certain entities that are not significant in terms of the indicators at the Group level, and the coverage rate is therefore over 97% for both turnover and CAPEX. The activities of entities that were not subject to detailed analysis are presented in “non-eligible”.
3.8.3.3.2 Analysis of the alignment according to the regulations in force on 31 December 2021: Description of the method used for the substantial contribution criteria, the DNSH and the minimum guarantees
In order to assess the alignment of its activities, each Group entity has verified compliance with the criteria for substantial contribution to climate change mitigation.
For example, eligible district heating/cooling distribution using more than 50% renewable energy, 50% waste heat, 75% heat from co-generation, or 50% a combination of these types of energy or heat were considered aligned. Only a tiny fraction of the activities 4.5 “Generated from hydropower” do not meet the technical criteria for substantial contribution.
(1) Refers to the categories listed in Annex I of Delegated Act 2021/2139 of 4 June 2021.
