Pollution

Identification process for impacts, risks, and opportunities

In order to identify material IROs, Alpiq conducted a DMA as described in the chapter Material Sustainability Matters.

The DMA identified two material negative impacts due to pollution. The first one relates to the CO and NOx emissions stemming from Alpiq’s gas power plants, which are primarily dependent on the fluctuating production of electricity and steam. The second negative impact relates to Alpiq’s upstream value chain and the risk of groundwater contamination by chemicals and heavy metals resulting from mining and fracking activities, for example through hydraulic fracturing for natural gas extraction or lithium mining.

Targets related to pollution

ESRS E2-3

Limiting air pollutant emissions is an important goal that Alpiq pursues and is taken into account when making strategic decisions. Alpiq deploys certified management systems in accordance with each specific production technology and national regulatory framework to track the effectiveness of its progress in limiting pollutants.

For the CCGT and OCGT power plants, the following emissions limits are in place and adhered to:

Gas turbine emission limits [mg/NM3]

NOx

CO

Plana del Vent

50

100

San Severo

22.5

31

Novara

30

50

Vercelli

30

30

Csepel

90

50

Auxiliary boiler emission limits [mg/NM3]

NOx

CO

Plana del Vent

450

100

San Severo

200

n/a

Novara

200

250

Vercelli

n/a

n/a

Csepel

200

100

The above emissions limits can vary within the same country because they depend on plant technology, age, and regional authority intentions. Some authorities intend to reduce these thresholds to contribute to national emission reduction goals.

In addition, the Group companies are legally required to conduct environmental impact assessments (EIAs) for assets that are newly constructed, upgraded, or modified, in order to ensure that potential pollution impacts are avoided, mitigated, and addressed appropriately. Those pollution-related requirements are integrated into the respective licence conditions.

For Alpiq’s power plants, spill and leakage prevention and mitigation/response measures are in place. Spill and leakage prevention includes the proper storage of hazardous materials and waste, regular inspections, training and awareness raising, and containment measures. These measures help prevent potential negative impacts caused by the discharge of water that is too warm or that differs from the pH limit mandated by authorities. Mitigation is ensured among other things through the use of spill response kits.

In the business unit Hydro Generation Switzerland, environmental incidents (without impacts on the environment) and accidents (with impacts on the environment) are continuously monitored, allowing Alpiq to identify, consolidate, and analyse such events. This ensures that appropriate measures can be taken and that lessons learned can be used to improve practices if necessary.

Pollution of air

ESRS E2-4

In 2025, Alpiq’s CCGT and OCGT power plants emitted the following amounts of air pollutants under the operational consolidation approach. Under this approach, Alpiq’s majority shareholding in Novara is consolidated at 100%, despite an actual ownership stake of 51%.

CO [kg/year]

NOx [kg/year]

Italy

San Severo

38,244

133,000

Novara

10,439

91,961

Vercelli

1,684

3,000

Spain

Plana del Vent

16,430

39,680

Hungary

Csepel

16,382

169,000

Total

83,179

436,641

To track pollution, Alpiq applies different measurement methodologies depending on the plant and the type of pollution to be measured.

For air pollution measurement at gas-fired power plants, Spain uses an air vector measurement methodology, whereby the meters used are subject to legally mandated meteorological controls. In Italy and Hungary, all gas-turbine plants are equipped with Continuous Emission Monitoring Systems (CEMS) that measure pollutant levels and flow rates. An alarm is triggered if emission limits are exceeded. In these situations, the plant’s operating parameters are assessed and, based on the severity and duration of the exceedance, restoration actions are defined. These may include adjustment of the electrical load, verification of the proper functioning of measuring instruments, intervention on combustion parameters and inspection of equipment, extraordinary maintenance activities, and/or contacting external contractors. Once normal operating conditions have been restored, a notification is sent to the relevant authority detailing the emission parameters and the time at which compliance was re-established (on average within the first hour).

Furthermore, annual analyses are performed by an externally certified laboratory, and methane (CH4) sensors and leakage detection systems are used to prevent air pollution in Italy.

In Spain, carbon monoxide (CO) and nitrogen oxides (NOx) are measured in real time using the company’s own stack-mounted sensors. A third party checks for particulates and sulphur oxides (SOx) every six months. Sulphur hexafluoride (SF6) and fluorinated gases are checked whenever refilling is required.

In Italy, air pollution is measured through stacks downstream of the gas turbines, and the auxiliary boilers of the power plants are equipped with sensors for continuous measurement of air pollutants. Sensor data is processed by CEMS and recorded by distributed control systems (DCS). Data can be accessed continuously by connecting to the system or can be extracted and compiled into daily, monthly, and annual reports.

In Hungary, air quality is measured through stacks downstream of the gas turbines, which are equipped with sensors for continuous measurement of air pollutants. Sensor data is processed by CEMS and recorded by DCS. Data can be accessed continuously by connecting to the system or can be extracted and compiled into daily, monthly, and annual reports.