Universal Registration Document 2021

1. The group, its strategy and activities

Progress on consents and permitting

In June 2020, Planning Inspectorate accepted the application for the Sizewell C development consent order (DCO) for examination. The examination process took place between April and October 2021. As part of the planning process, the executed Deed of Obligation (the mitigation measures program) and Environment Trust (additional support to environment protection) have been agreed.

The Examining Authority is now considering the final version of the draft DCO as well as all the other documents (technical assessments, mitigation measures etc.). A decision on the DCO application by the Secretary of State is expected by the end of May 2022, which will then be followed by a six-week period open to potential judicial review.

The Environmental Permits Application and the Nuclear Site Licence Application were submitted in May and June 2020. The applications are currently under review. The conditions to obtain a Nuclear Site Licence are currently expected to be fulfilled in 2022.

Conditions for a final investment decision

EDF’s ability to participate in the final investment decision on Sizewell C alongside other investors and to contribute to the financing of the construction phase depends on the fulfilment of some conditions including:

  • sufficient funds to finance the development costs until a Final Investment Decision;
  • a regulation model, risk-sharing mechanism and Government Support Package, allowing private investors (debt and equity) to invest;
  • an appropriate financing structure during construction and operation and sufficient investors and debt holders willing to invest into the project. This is subject in particular to achieving an investment grade credit rating by the credit agencies;
  • an agreement with the key suppliers on the key construction and operation contracts;
  • obtaining the required consents and permits, including Development Consent Order, Nuclear Site Licence and Environmental Permits;
  • the ability not to consolidate the project in the Group’s financial statements (including in the calculation of the economic indebtedness by the rating agencies) after the final investment decision.

Not meeting these conditions could lead the Group not to take a final investment decision (see section 2.2.4 “Operational Performance related risks”, risk factor 4A

– “Management of large and complex industrial projects (including EPR)”).

BRADWELL B

EDF and CGN signed agreements alongside the HPC and Sizewell C contracts on 29 September 2016 in order to:

  • obtain the design certification of the Chinese-based design HPR1000 in the UK (UK Hualong Pressurised Water Reactor – UK HPR1000) through the Generic Design Assessment (GDA) process. This process is supervised by a joint venture between General Nuclear Systems Limited (GNSL) and EDF (owned 65.5% by CGN and 5% by EDF);
  • develop a nuclear power plant at Bradwell-on-Sea in Essex using the UK HPR1000 technology. This process is led by a joint venture (“Bradwell” or BRB) currently owned at 5% by CGN and 33.5% by EDF.

The HPR1000 technology has been developed by CGN. Two Hualong units are under construction in China at CGN’s Fangchenggang plant and are expected to be commissioned in 2022.

The GDA is a 4-step process, which started in 2017 and was completed on 7 February 2022 when the ONR issued a Design Acceptance Confirmation (DAC (1)) and the Environment Agency a Statement of Design Acceptability (SoDA (2)). It confirms that the UK HPR1000 reactor meets regulatory expectations on safety, security and environmental protection at this stage of the regulatory process. Therefore, this reactor is suitable for construction in the UK, subject to the necessary licensing, planning permission and environmental permits. The GDA process is separate from applications to build reactor power plant at specific sites.

There is great uncertainty around the development perspectives of the Bradwell Project, mainly related to the political opposition to a Chinese company leading a critical UK infrastructure project and from the lack of local stakeholder support (see section 2.2.4 – risk 4A). The risks of not being in a position to carry out the Bradwell project are high and have increased in 2021.

EDF’s commitment to fund GNSL and Bradwell is subject to an equity cap, without any obligation to fund the project beyond the funding cap.

1.4.5.1.3 Brexit

The UK left the European Union (EU) on 31 January 2020, entering into a Transition Period that ended on 31 December 2020.

The EU–UK Trade and Cooperation Agreement (TCA), agreed on 24 December 2020, sets the basis for the EU-UK relationship from 1 January 2021. Nevertheless, it was widely recognised that further work would be required to develop several important aspects of the new EU-UK relationship. Although there has been progress in some areas during 2021 (e.g. the EU-UK Data Adequacy Agreement), there remain some important outstanding issues.

EDF had identified the business risks arising from the UK’s exit from the EU and was well prepared, enabling the business to manage most of the adverse impacts.

During 2021, EDF’s main focus has been to manage the impact of cross-sectorial issues affecting international trade, including the implementation of border controls, access to EU labour and services and the risks arising from some companies (particularly small and medium sized) not being fully prepared for the new trading arrangements.

Some risks still remain despite elements of the new arrangements are finalised, including full UK border controls and the introduction of the UK Conformity Assessed (UKCA) marking regime (replacing EU CE marking in the UK).

EDF believes that the risks are relatively low and are manageable in respect of issues specific to the electricity sector, including the longer-term relationship in the areas of energy trading, new interconnector trading arrangements and North Seas Co-operation.

The civil nuclear agreement, the EU-UK Nuclear Cooperation Agreement (NCA), is similar to other NCAs that the EU has signed with third countries. It will operate for an initial period of 30 years, providing a commitment to cooperation on civil nuclear, including safeguards, safety and security. It also provides a framework for trade in nuclear materials and technology, facilitates research and development, and enables exchange of information.

EDF will continue to work closely with the UK Government and trade associations to monitor and adapt to the evolving EU-UK trade relationship as the new arrangements are fully implemented.

1.4.5.2 Italy
1.4.5.2.1 EDF group market and footprint in Italy

Italy is one of EDF’s four key markets in Europe alongside France, the UK and Belgium. The Group is mainly present in Italy through its 97.172% shareholding in Edison (3), which is a major player in the Italian electricity and gas markets and a well-known Italian brand. The EDF group is also present in Italy via Citelum.

1.4.5.2.2 Edison strategy

Like the majority of European energy systems, the Italian market is currently facing a certain number of challenges. Thanks to its current position and integrated presence in the gas and electric power value chain, Edison is well-placed to seize opportunities created by market changes, while pursuing efficiency and profitability, in line with the EDF group strategic priorities and international and Italian energy policies.

(1) DAC : DAC: Design Acceptance Confirmation.

(2) SoDA: Statement of Design Acceptability.

(3) Equity stake; 99.473% share of voting rights.