E.DSO feedback to EU Taxonomy Delegated Acts

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On 17 December 2020, E.DSO provided its response to EU Taxonomy Delegated Act setting out technical screening criteria. While recognising the significant improvements made to the Technical Screening Criteria (TSC), E.DSO believes that several shortcomings yet persist.

Key reflections

  • The investments in the networks are made to ensure a cost-effective energy transition that encompasses not only greener generation but also the so-called electrification of society.
  • The consideration of distribution activities as enabling activities can neither depend on the carbon content of the electricity that circulates in the grid, nor on the GHG emissions level of the power plants connected to the grid.
  • The delegated Regulation conflicts with the wording of the Article 10 of the Taxonomy Regulation, since it qualifies transmission and distribution of electricity as “enabling activities”, whereas the Article 10 expressly recognises that transmitting and distributing renewable energy contribute substantially to climate change mitigation (1.(a)).
  • The delegated Regulation shall define all investments in the electricity grid infrastructure as sustainable, including reinforcements under the category of construction of distribution systems.