Questions & Answers
Does disclosure E1-37 (b) refer to all forms of energy generated from nuclear sources, such as electricity? Does ESRS E1 paragraph 37 (b) also encompass electricity mixes that include fractions of nuclear-generated electricity?
- Energy consumption
- nuclear sources
Background
ESRS E1 paragraphs 35 to 37 state:
‘35. The undertaking shall provide information on its energy consumption and mix.
36. The objective of this Disclosure Requirement is to provide an understanding of the undertaking’s total energy consumption in absolute value, improvement in energy efficiency, exposure to coal, oil and gas-related activities, and the share of renewable energy in its overall energy mix.
37. The disclosure required by ESRS E1 paragraph 35 shall include the total energy consumption in MWh related to own operations disaggregated by
(a) total energy consumption from fossil sources;
(b) total energy consumption from nuclear sources; and
(c) total energy consumption from renewable sources disaggregated by
i. fuel consumption for renewable sources, including biomass (also comprising industrial and municipal waste of biologic origin), biofuels, biogas, hydrogen from renewable sources, etc. …’
ESRS 2 MDR-M paragraph 77 requires the undertakings to disclose the significant assumptions behind the metric, including the limitations of the methodologies used.
Answer
ESRS E1 paragraph 37 (b) requires the disclosure of total energy consumption from nuclear sources.
ESRS E1 paragraph AR32 (d) clarifies that the energy to be reported should refer to ‘final energy consumption’, which includes energy carriers such as electricity, heat and steam that can be and are frequently derived from nuclear sources.
An undertaking disclosing on the basis of ESRS 1 paragraph 35 should thus report the final energy consumption taking into account its energy mix, which may involve proportions of nuclear-generated electricity, heat, steam, and cooling; fossil-fuel generated electricity, heat, steam, cooling and fuels; or renewable electricity, heat, steam, cooling and fuels.
This disclosure requires the undertaking to understand from its consumption of electricity which portions originate from nuclear, fossil or renewables sources. When electricity, heat and steam are purchased and the mix includes fractions of nuclear-generated electricity, heat, and steam, these fractions are to be included in the disclosures under ESRS E1 paragraph 37 (b) on total energy consumption from nuclear sources. The undertaking should use the information available on the electricity, heat and steam mix to reflect its energy consumption breakdown according to ESRS E1 paragraph 35 accurately.