Updated European Taxonomy Top15 and Top30: what lessons can be learned?

Now that players have had to declare their European Taxonomy alignment rates this year, the OID has published the new updated Top15 and Top30 for 2023. Reflecting the actual energy profiles of French buildings and the climatic and economic impact on them, these thresholds provide an initial view of buildings that are correctly managed in terms of their consumption, but have limits of interpretation in terms of the decarbonization of energy sources.

 

Taxonomy: a resolutely elitist text

For several years now, the European Taxonomy has been working on the deployment of a reference framework that will enable economic activities to be classified as sustainable in a uniform and as exhaustive a manner as possible. The aim of this text is to support the ecological transition of the economy by directing investment and financing towards these so-called sustainable activities. To achieve this, the text sets out criteria for meeting six environmental challenges (climate change mitigation, adaptation to climate change, pollution prevention, sustainable water management, healthy ecosystems and the circular economy), as well as minimum social guarantees.

The text is based on a principle as simple as it is formidable: to be considered sustainable, economic activities must make a substantial contribution to one of the environmental challenges (CCS), while not harming the others (DNSH). In this sense, it is particularly innovative, as it forces players to adopt a systemic vision of the environmental issues affecting their assets.

For buildings in operation, the mitigation challenge offers buildings the opportunity to satisfy the CCS by demonstrating that they are among the 15% best-performing buildings on the market (Top15), or the DNSH if they are among the 30% best-performing (Top30). If they meet this criterion, while respecting the DNSH for other issues, the buildings can be included in the basis for calculating the Taxonomy alignment rate.

After a few months of feedback on the scheme, a study published by the OID in partnership with the ASPIM in October 2023 confirms the elitism of the text: the average alignment in sales on all funds classified Article 8 and 9 amounts to 5%, with only 4 funds declaring an alignment greater than 20%.

 

How will the Top15 and Top30 evolve?

In this context, the 2023 update of Top15 and Top30 is of particular importance. It should also be noted that for existing buildings, players will calculate their alignment rate on the basis of the Top15 (corresponding to the CCS), by applying the DNSH adaptation. This Top15 is therefore crucial for steering the financing strategy for the ecological transition of buildings.

In addition, the figures published this year include consumption data for 2022, which can be considered as the year in which the health crisis will end. However, in some business segments, a real economic recovery was observed in 2022: this is notably the case for hotels, which saw their occupancy rate jump by 20 points last year. This rise in occupancy logically leads to a 25% increase in thresholds this year. The Top15 hotels are down to 246 kWhEP/m².an this year, establishing a level more in line with the sector’s cruising speed. Similarly, the increase in shopping center footfall is reflected in this year’s thresholds, with the Top15 rising by 5% to 103 kWhEP/m².an.

By contrast, indicators for healthcare assets and offices are trending downwards this year: for standard offices, the Top15 stands at 161 kWhEP/m².an, down 5% on last year. Healthcare assets followed a similar trend, with the Top15 for this type dropping by 10% to 255 kWhEP/m².an!

 

What building profiles are found in the Top15 and Top30?

First of all, it’s essential to bear in mind that the use of the primary energy consumption indicator restricts the profile of sustainable buildings to those that are reasonable in their energy consumption.The indicator does not allow conclusions to be drawn regarding any decarbonization strategy implemented on a park or building. The Top15 and Top30 building profiles presented below are simply those whose energy consumption is properly managed by their owners.

In this respect, it would make sense to use an alternative criterion based on Energy Performance Diagnostics (EPD), for which the European directive on the energy performance of buildings (EPBD) currently being revised plans to impose a dual energy and carbon scale on all member countries.

This criterion would enable only those buildings meeting this double constraint to be considered as making a substantial contribution to the mitigation objective.

This is essential, because at present, building profiles are not distinguished by their less carbon-intensive energy sources… For example, in the OID database, the Top15 offices follow the same distribution as the whole database in terms of heating energy: a large half of the offices are heated by electricity (58%), while district heating networks concern a quarter of the sample. The remaining buildings are heated mainly by gas, with other energy sources remaining very anecdotal in the mix.

 

Assessing buildings according to their primary energy consumption is a first step, but remains limited in terms of strategies for decarbonizing energy sources. In this respect, the buildings studied are neither better nor worse than French buildings as a whole. It will therefore be essential to cross-reference these criteria with carbon criteria in the future, and to analyze how the alternative mitigation criterion based on the DPE can be deployed. Finally, the complementarity of adaptation criteria with those relating to mitigation will also need to be monitored, in order to assess whether players will rely on the benchmark to implement action levers on their buildings.

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