2019 guide to Foreign Private Issuer status
A company organized outside the US subject to provisions of the US federal securities laws receives benefits if it qualifies as an FPI.
Different applications for electricity storage are being explored within global markets. Many markets are at a cross-roads brought about by the convergence of innovation, digitisation, reducing technology costs, increased penetrations of intermittent renewable generation and accompanying regulatory change. Added to this is the potential of electric vehicle-to-grid technology to provide grid network services.
The market in Britain is a prime example: legislators and policy makers are eager to capture the manufacturing opportunities provided by battery storage and electric vehicle technologies, but how will this ambition affect the British electricity storage market?
2017 saw 200MW of new battery storage projects coming online in Britain. Whilst impressive, it is reported that almost 18GWs of new grid connections have been requested for storage assets. There is also diversity in the storage projects we see coming to the British market. In the last year we have acted on stand-alone and co-located lithium-ion battery storage assets, and the refurbishment of a pumped storage power plant. With the potential for storage to be deployed at scale, we consider some of the key issues and opportunities facing developers in the British market.
For many storage technologies, scale can be a challenge. Clearly larger projects with a high number of hardware components can offer economies of scale, but some projects are often relatively small scale, especially where used for the provision of grid services. Site risks and access can also be challenging, with some projects on old brown-field sites or in remote locations. Where projects are proposed to be co-located with and complement an existing power source, issues around the location of the metering point need to be considered, particularly where storage will interact with a renewable energy support scheme. The constantly changing and improving technology market has also led to some interesting discussions around the documents governing the operating phase of an energy storage project. For example, will technology have advanced so much within the next ten years that the tail end of a fifteen year services agreement is defunct?
The business case for electricity storage is still emerging and is often specific to a particular project, with operators often "stacking" (i.e. combining) revenue streams, perhaps relying on different income sources across the project life or at different times of day or year. Changes to regulations are impacting potential revenue streams: for example, wholesale reform is underway to frequency response product procurement, where historically battery storage operators have secured contracts. Changes were also introduced to the British capacity market, with new de-rating factors as low as 17.89 per cent to be applied to storage with a maximum duration of 30 minutes discharge (compared to 96.11 per cent de-rating factors applicable to longer, 4 hour duration storage such as pumped hydro). More positively, the regulator, Ofgem, confirmed that the addition of storage to renewable energy projects receiving support under the Renewables Obligation or Feed-in Tariff regimes may be accommodated under these schemes, paving the way for increased co-location of renewable and storage assets.
Looking to the future, the debate around revenues for storage assets is set to continue. In the independent Cost of Energy Review published in autumn 2017, Oxford University Professor Dieter Helm advocated that future government innovation policy include a general capital grants and supportive tax regime, aimed at key technologies such as battery storage. It is not yet clear to what extent these recommendations will be translated into government policy, with the outcome of a government call for evidence expected later in 2018.
The energy storage sector is a very fast moving market. Our experience of, and our involvement with, projects to date shows that developers are under pressure to develop assets at a very fast pace. This in itself offers challenges such as the procurement of long lead items, logistics and securing development consent but we are also seeing both the government and the market respond to overcome these challenges.
The 3rd edition of Lazard’s report finds that 1) selected energy storage technologies are increasingly attractive for a number of specialised power grid uses, but none are yet cost-competitive for the transformational scenarios envisioned by certain advocates; 2) industry participants expect costs to decrease significantly over the next five years, driven by scale and related cost savings, improved standardisation and technological improvements, supported in turn by increased demand as a result of regulatory/pricing innovation, increased renewables penetration and the needs of an aging and changing power grid; and 3) as the energy storage market continues to evolve, several potential sources of revenue available to energy storage systems have emerged but, ultimately, the mix of available revenue streams for a particular energy storage system varies significantly across geographies.
According to Bloomberg Business Week, demand for vanadium in the past year has soared more than 130 per cent, outperforming better known battery metals like cobalt, lithium and nickel. Although much of the demand has come from orders from the steel industry, analysts are predicting greater use of vanadium for industrial-scale batteries. The metal has some significant advantages over traditional battery metals. It lasts longer and it can be charged and discharged repeatedly without any significant drop in performance. In China, vanadium-flow batteries are already emerging as an alternative to lithium-ion. For analysis of lithium markets, see the FT’s analysis (paywall) here.
AES and Siemens are combining their efforts to launch new energy storage start-up called Fluence, which received regulatory approval in the USA in January 2018. Fluence will become the supplier of AES’ 100MW/400MWh Alamitos power centre energy storage project in Long Beach, California serving Southern California Edison and the Western Los Angeles area.
This article considers Stem’s artificial intelligence platform, Athena, and how AI can facilitate and optimise the stacking of storage revenues. Stem have raised over US$100 million from backers such as Constellation, Mitsui and RWE, as well as US$500 million in project finance to align the customer payment model with the intelligence-based optimisation solution.
A recent report by Bloomberg New Energy Finance has forecast that the energy storage market will grow 12-fold in the years to 2030, increasing to 125GW of capacity globally, with future growth in energy storage investments of up to US$103 billion. The report also finds that the cost of utility-scale battery systems will likely decline significantly by 2040, falling from around US$700/kWh of storage capacity in 2016 to less than US$300/kWh.
Crown Agents, a non-governmental organisation, are combining solar photovoltaic with storage in off-grid applications. A recent report by Crown Agents suggests that the levelised cost of energy for new off-grid or grid-tied distributed solar-plus-storage could come down to less than US$20 cents/kWh, compared to US$60 cents/kWh for small diesel and petrol generators.
Maghreb Industries, a Casablanca-based confectionary producer, is in the process of implementing what it claims to be the largest rooftop solar project in Morocco. Maghreb is developing a 1,361kWp rooftop solar plant that uses an ice-based storage system to allow the factory to store power during off-peak hours and use it during peak hours, cutting costs. Though unfinished, the Maghreb solar plant is already producing 60 per cent of its factory’s electricity needs. The EBRD, provided a EUR 4.6 million loan through its Finance and Technology Transfer Centre for Climate Change program.
BayWa r.e., a German PV developer, has completed its first solar project in Africa. The 86kW PV + storage project is located in Zambia and will supply power for the irrigation of 90,000 m2 of Zambian farm land for up to 13 hours at a time. BayWa r.e. indicated it sees great potential for African projects and plans to expand its involvement on the continent.
Australia’s oil and gas company Woodside has signed an agreement with ABB Australia Pty Ltd to install microgrid solution with a lithium-ion PowerStore Battery energy storage system on its "Goodwyn A platform" during the second half of 2018. The installation marks the first time such technology has been used on an offshore gas platform. It is expected that the installation will reduce Goodwyn A’s use of fuel gas by more than 2,000 tonnes per year.
Contemporary Amperex Technology Ltd. (CATL) is looking to raise YUAN 13.1 billion (US$2 billion) to finance construction of a battery-cell plant second in size only to Tesla Inc.’s Gigafactory in Nevada. The new assembly lines would quintuple CATL’s production capability and make it the world’s largest electric-vehicle battery cell manufacturer, ahead of Tesla, Warren Buffett-backed BYD Co. in China and South Korea’s LG Chem Ltd.
French renewable energy developer and independent power producer Neoen has signed a "support agreement" with local authorities to develop the world’s first protected crop farm, powered by renewable energy at the Bulgana Green Power Hub. The total expected investment for the project is AU$665 million which will see Nectar Farms build 30 acres of glasshouse in which to grow fruit and vegetables for local sale and export alongside the 63 wind turbines and battery energy storage.
British billionaire, Sanjeev Gupta, is establishing himself as a major player in South Australia’s energy market through a combination of solar, pumped hydro and battery storage projects. Although the projects are still very much in their infancy, plans include a 120MW pumped hydro facility at a disused mine in the Middleback Range near Whyalla, Australia.
State-owned coal mining company NLC India has decided to retender its requirement for a battery plant in the Andaman and Nicobar Islands due to a change in requirement. NLC India will now call for bids for a smaller 8MWh project. In the last three years, more than 10 energy storage tenders have been cancelled.
China is leading efforts to deliver an almost threefold increase in global graphite processing capacity by 2020, to meet lithium-ion battery industry demand. Shanshan Technology, BTR New Energy Materials and LuiMao Graphite (in association with BAIC Automotive Group) are building lithium-ion battery graphite anode megafactories with a total processing capacity of 260,000 metric tons per year. Hitachi Chemical in Japan is planning another facility to process 100,000 metric tons of graphite a year. The increases compare to a total estimated global processing capacity of around 200,000 metric tons at present. In 2016, graphite production amounted to just 100,000 metric tons.
Two California-based start-ups, Stem and Sunverge, have joined forces with Mitsui for a series of virtual power plant projects for Tokyo Electric Power Co. (TEPCO), utilising batteries on various commercial and industrial sites, to dispatch power across a portfolio of sites and reduce demand charges. The two projects announced are relatively small scale given TEPCO’s position as Japan’s largest utility company however, it demonstrates TEPCO are embracing a future with more distributed and renewable power.
Technology specialist Moixa has partnered with Japan’s Itochu Corporation to market its GridShare platform in Japan. The deal with also see Itochu invest a further GBP 5 million in Moixa to support its international expansion plans.
The world’s tallest wind turbine will be combined with a 70 MWh pumped hydro energy storage facility. The 246.5 metre wind turbine is part of a four-turbine wind farm in Limpurg Hills, on the outskirts of Stuttgart, Germany. The wind turbine stands in a 40 metre deep natural water reservoir which generates electricity when its reserves are dropped through turbines into an additional pool. The pumped hydro storage system can transition from storage to production in 30 seconds.
Statoil has awarded Younicos the contract to deliver its Batwind project, a 1MW/1.3MWh battery system. The battery storage system is designed to streamline fluctuations electricity output of the Scottish Hywind floating offshore wind farm by storing excess energy and reinjecting it into the grid to correct variations in production of the six 5MW Siemens turbines.
Danish wind systems developer, KK Wind Solutions, is turning to battery storage as a solution to output fluctuations. The company is collaborating with turbine maker Vestas, engineering company PowerCon and Aalborg University to design a system that can store up to 8 per cent of its total wind farm capacity. According to its estimates battery storage can reduce fluctuations by 90 per cent. In another sign of growing interest in battery storage by the wind power sector, industry giant Vestas announced a US$12 million investment into its wind energy grid storage partnership with Northvolt.
German battery maker Akasol opened a new EUR 10 million factory. The facility, now Europe’s largest production facility for battery systems for hybrid and electric commercial vehicles, has a capacity of 600MWh of battery systems per year; enough to equip up to 3,000 hybrid or electric vehicles. The plant’s production lines will supply Akasol’s Akasystem OEM batteries.
BP has invested US$5 million (GBP 3.6 million) in FreeWire, a US-based manufacturer of mobile electric vehicle rapid charging systems. BP will trial the fast charging technology at selected retail sites in the UK and Europe during 2018. Meanwhile Japanese vehicle manufacturer Nissan has announced it will participate in a GBP 9.8 million programme with the UK Government to develop “electric vehicle-to-grid” systems. The demonstration project will use a fleet of 1,000 electric vehicles to store excess solar and wind power on the grid.
Greensmith Energy, a Wärtsilä Company, and American Electric Power have agreed to install a 4MW energy storage system integrated with the Buck and Byllesby hydroelectric power plants in southwest Virginia, USA. The integration of advanced energy storage and software with hydroelectric generation is seen to be the first hybridised system of its kind to provide ancillary services. The system, due to begin operating in the first quarter of 2018, will deliver PJM (Pennsylvania, Jersey, Maryland power pool) frequency regulation market one of the first new energy storage systems since the adoption of new frequency regulation signals and requirements for regulation service.
US renewables company Enel Green Power North America, Inc. (EGPNA), a subsidiary of Enel, signed three Capacity Storage Agreements (CSA) with California utility Pacific Gas and Electric (PG&E) for a total capacity of 85MW/340MWh. Under the agreements, Enel will build Kingston, Cascade, and Sierra stand-alone lithium-ion energy storage projects, all to be located in California, in order to better integrate renewable generation into PG&E’s grid, increasing grid reliability, while also easing congestion. The projects are developed with Sovereign Energy Storage, an independent developer of large-scale utility battery energy storage projects, and are expected to be operational by 2023, pending review and approval by the California Public Utility Commission as well as local and regulatory agencies.
The Los Angeles Department of Water and Power (LADWP) recently approved procurement of a 20 MW/10 MWh lithium-ion system to go into the Beacon Solar Plant in the Mojave Desert, USA. The system will increase utilisation of the desert's solar generation, as well as provide grid reliability service in the wake of the Aliso Canyon natural gas disruption. This is the first time that full-wrap, turnkey EPC services will be provided by a company such as Doosan GridTech, which is traditionally focused on software solutions for optimising storage.
Mercedes is investing more than US$1 billion to upgrade a U.S. plant for assembling batteries and electric SUVs. Along with a nearby battery factory, Mercedes will upgrade factory lines to build its EQ brand electric SUV, the EQ C, starting sometime around 2020. Mercedes will offer electric versions of all of its models by 2022, plus a new series of plug-in hybrids, for about 50 new models in all. In total, Daimler plans to invest US$11 billion in electric vehicles (EVs) over the next five years. Daimler’s strategy is being matched globally. Volvo announced in July 2017 that every new vehicle model released starting in 2019 will be either a hybrid or electric. Audi is scaling up EV production at its Brussels plant. Volkswagen has committed to investing US$10 billion over the next five years to bring 25 new EV models to market by 2025. And Ford plans to invest US$4.5 billion in electrification by 2020.
Duke Energy is investing US$30 million into the two biggest battery storage projects in North Carolina. The projects may indicate new interest in storage among regulated utilities, as battery prices continue to fall. Both of Duke’s projects, a 9MW project in Asheville and a 4MW project in Hot Springs, will use lithium-ion technology.
Dynamic Energy Networks (DEN) will deploy capital raised by the Carlyle private equity group to create microgrids then operate them in an energy-as-a-service model for long-term contracts. This model has been deployed in a few instances already; it eliminates upfront capital requirements and caters to customers that want cleaner or more reliable power but do not want to be in the energy asset management business.
Cox Energía, a Spanish developer and which won 140GWh at a price of US$34.40/MWh in Chile’s latest renewable energy auction, is likely to use solar PV-plus-storage technology to cover the night time energy requirements which formed part of its bid. Cox Energía is likely relying on the cost of solar PV-plus-storage falling before its projects enter operations in 2024.
Hurricanes that devastated the Caribbean, Puerto Rico, and Houston have spurred an interest in using battery-connected microgrids to ensure power grid reliability. Tesla CEO Elon Musk tweeted his interest in using solar power and batteries to rebuild Puerto Rico’s power grid to which Puerto Rican Governor Ricardo Rosselló responded, “Let’s talk.” Interest in battery microgrids is expected to grow as the cost of batteries declines. Following a request by the Puerto Rican Energy Commission, AES has recommended mini-grids with hardened critical tie-lines to lower cost to consumers and increase distribution reliability.
The Jamaica Public Service Company committed US$21 million to develop a 24.5MW hybrid energy storage facility to safeguard against power outages. The facility will use a combination of high-speed and low-speed flywheels and containerised lithium-ion batteries. The project is being described as the first of its kind in the Caribbean.
Tesla is in talks with Chile-based lithium mining firm SQM about sourcing future lithium supplies. Chile is home to the Atacama desert where some of the largest lithium reserves are located. Tesla will need to increase its lithium supplies if it hopes to expand at the rates its projected to.
AES Dominicana brought online 20MW of battery-based energy storage arrays at two sites in the Dominican Republic. These arrays played a major role in maintaining grid reliability in September 2017 when Hurricanes Irma and Maria ravaged most of the Caribbean. In fact, both storage arrays performed more than double the amount of work during the storms as normal, allowing Dominica’s grid to continue operating, even though nearly 40 and 50 per cent of the island’s power plants were forced offline during the hurricanes.
Storage is an essential element in the transition to greater penetrations of renewable energy. In this article, we consider the issues which are required to be addressed when financing storage assets, drawing lessons from our experience gained in financing the US Southland repowering project and the Australian Lakeland hybrid project.
According to a report released by Crystal Market Research, the global energy storage market is expected to grow to over US$3.4 billion by 2022, more than double the 2012 valuation of US$1.5 billion. The 2022 valuation , which translates to a compound annual growth rate of 7.63 per cent, will be driven by the development of a rising number of alternative energy sources and consumer demand for advanced energy storage systems in the face of high electricity costs. The report forecasts that the Asia Pacific region will be the fastest developing geographical sector for advanced energy storage systems.
A new report by the International Renewable Energy Agency (IRENA) predicts that the cost of battery storage for stationary applications could fall by up to 66 per cent by 2030. According to the IRENA’s report, economies of scale will accelerate the adoption of lithium-ion batteries, making them more competitive in large-scale projects, in comparison with the pumped hydro systems that currently dominate the market. The report also highlighted the growing use of lithium-ion batteries in electric vehicles.
The World Bank plans to make energy storage an integral part of its "Scaling Solar" program, that until now has been focused purely on facilitating large-scale solar tendering, predominantly in Africa. The new Scaling Solar and Storage program, which has yet to be formerly announced and is expected to be rolled out over the next couple of years, would work on utility-scale tenders that pair solar PV with battery storage technology.
As part of the effort to increase reliance on renewable energy, Jordan signed a Memorandum of Understanding with 23 companies and consortia to implement a US$40 million storage project of up to 30MWs. Developers have six months to submit their technical and financial offers to the ministry after which the selection will be made.
Australia’s Green Party recently proposed a new national energy storage target of 20GW by 2030. The policy, announced before meetings with Tesla and other renewable energy stakeholders, is designed to incentivise a transition from coal and gas to renewable energy systems. Key aspects of the proposal include over AUD 2 billion in funding for new energy storage projects across the country and the construction of small to medium scale pumped hydro plants to complement wind and solar power.
The Australian Solar Council and the Australian Energy Storage Council have merged to form the national Smart Energy Council. Prior to the merger, the two trade associations represented the solar photovoltaics and products and the energy storage industries respectively. Australia’s solar energy market now boasts over 4 million solar rooftops, and more recently has begun developing large-scale solar projects and solar-plus-storage projects with an installed capacity of over 6GW. The new Smart Energy Council will be the national voice of the solar, storage and smart energy management industries and will support utility companies to integrate these technologies into the national grid.
Construction has begun on India’s largest energy storage project, a 10MW battery storage project in Rohini, Delhi, being developed by AES and Mitsubishi. The project, which is said to be of "strategic importance" for the country’s regulators, will serve to enhance grid reliability for more than 7 million customers and aid with integration of rooftop solar. Despite adding 1.5GWh of storage capacity between 2013 and 2017, renewable integration challenges persist in India, which has the third largest solar PV market in the world.
The marketing and provision of primary control reserve is probably the most important element of business cases for battery storage systems and other energy storage technologies in Europe. The power facilities which provide such control reserve are called FCRs – Frequency Containment Reservers. To pre-qualify for the tenders, one important criterion is the minimum time interval for which an FCR, such as a battery storage system, must provide full power. German TSOs have filed a request to the German Federal Grid Agency (BNetzA) as the responsible regulatory authority to set the minimum time interval for FCRs to 30 minutes as a pre-qualification requirement. The BNetzA will decide whether the minimum time interval for pre-qualification will be 15 or 30 minutes and is likely to affect the ability of battery storage systems to participate in the primary control reserve market.
The UK Government published its response to a consultation, confirming plans to lower the de-rating factor for storage in future electricity capacity market auctions from the previously set level of 96 per cent. The main question under consultation was to what extent various electricity storage technologies contribute to security of supply, if for example a technology requires recharge after 30 minutes, while a stress event is estimated to last 2 hours on average. De-rating factors are as low as 17.89 per cent for half-hour duration batteries. These increase in half-hour increments, with only batteries that have a four hour duration or more qualifying for 96.11 per cent de-rating. The results of the 2018 T-1 and the T-4 capacity market auction, showed a reduction in storage capacity procured; storage constituted 1.80 per cent of successful participants, representing 104.189MWs in the T-1 auction and 5.32 per cent, representing 2,680MWs in the T-4 auction.
Four projects have been awarded GBP 42 million in UK government grants to research on solid state batteries for electric vehicles. This is the first tranche from a total of GBP 246 million that the UK government has pledged in its Clean Growth Strategy to invest in battery technology. The first tranche of funding will be divided into four projects looking at solid state batteries, extending battery life, battery system modelling and battery reuse and recycling.
The Office of Gas and Electricity Markets (Ofgem), the UK’s energy market regulator, recently released a new consultation document proposing changes to the electricity storage licensing regime. If approved, the new regulations will seek to prevent distribution network operators (DNOs) from using consumer-funded battery storage facilities to sell services to the National Grid. The consultation was released just as DNO Northern Powergrid begun using a GBP 4 million battery in Darlington to provide grid frequency services to the National Grid.
The Federal Energy Regulatory Commission (FERC) has adopted a new rule aimed at removing market barriers preventing energy storage resources from participating in wholesale energy markets in the US. The rule directs each independent system operator and regional transmission operator to revise its tariff to establish a participation model that recognises the physical and operational characteristics storage resources. The changes are expected to help storage expand service offerings into larger ancillary services and wholesale energy and capacity markets. FERC will continue to study proposed reforms related to distributed energy resource (DER) aggregations.
This article describes changes in the US market that are driving deployment and improving the economics of storage and then identifies unique risks for storage projects and how participants in such projects can mitigate the risks. The article summarises the most recent regulatory reforms at the federal and state levels and describes results from a simulation of the operation of a battery storage device in the US eastern interconnection system, suggesting that improved economics will send storage across the break-even point in the next few years.
New York is launching an initiative to deploy 1,500MW of energy storage by 2025. To support that goal, Governor Andrew Cuomo has proposed that the NY Green Bank commit at least US$200 million for storage-related investments. The 1,500MW deployment initiative builds on energy storage legislation signed by the governor at the end of 2017 that directs the public service commission to determine by the end of this year what policies will drive a long-term storage goal for the state.
The California Public Utilities Commission recently approved new market rules for energy storage aimed at enabling the resources to stack incremental value and revenue streams through the delivery of multiple services to the wholesale market, distribution grid, transmission system and other venues. The previous rules meant battery assets were unable to realise their full economic value but the changes will help ensure correct pricing and improved economic viability.
California is on the cusp of a dramatic jump in deploying cost-saving, climate-solving technology in the form of customer-sited energy storage but the industry needs help cutting red tape that keeps the cost of the technology unnecessarily high for customers. A new bill to clarify good permitting practices and to make permits and related fees more consistent was signed by Governor Jerry Brown on September, 30 2017. AB 546 will speed up the process of siting storage by requiring application documents to be accessible online by 2019, requiring jurisdictions to accept electronic submissions and making the processes and permit fees more consistent across jurisdictions. The bill could dramatically cut the costs associated with storage permitting.
Arizona is setting out to prove clean energy leadership doesn't exist solely in coastal states like California and New York. Andrew Tobin, a member of the Arizona Corporation Commission, recently proposed a clean energy overhaul that would put the state at the front of the pack. The Energy Modernization Plan aims to produce one of the cleanest energy mixes in the nation, while lowering prices for consumers and improving grid reliability.
A bill that would expedite hydroelectric pumped storage projects was recently passed by the U.S. House of Representatives. The bill would accelerate the permitting process for closed-loop hydropower plants and require the Federal Energy Regulatory Commission to examine the potential siting of such projects in abandoned coal mines.
Latin America is in the midst of a dramatic energy transformation. Countries across the region are rapidly transitioning from fuel oil and hydroelectricity as the main power sources to a more diverse energy mix, including natural gas, solar and wind. This article discusses the role that energy storage will play in this transformation.
Despite bearing the brunt of climate change, most of the world’s 3,600 island economies have continued to rely on oil for their energy needs due to its cost competitiveness in comparison with clean energy. However, a report released in September by GTM research predicts that by 2025, solar, battery storage and hybrid energy resources will have a lower levelised cost of energy (LCOE) than oil. According to the report, though solar energy and battery storage currently has the highest LCOE at US$216 to US$319 per MWh, by 2025, the LCOE for solar photovoltaic and lithium-ion batteries will fall by 45 per cent. The dramatic drop in cost will allow solar-battery storage systems to rival solar-diesel systems. The report studied the lifetime scenarios of a range of energy generation and storage combinations in four key island regions, including the Caribbean.
The Energy Storage Summit 2018 – February, 27 and 28, London, UK
Infocast Storage Week 2018 – February 27 – March 1, San Francisco, USA
Middle East Electricity – March, 6-8, Dubai, UAE
Energy Storage Europe 2018 - March,13-15, Düsseldorf, Germany
UK Energy Storage Conference 2018 – March, 20-22, Newcastle, UK
Australian Energy Storage Conference 2018 – May, 23 and 24, Adelaide, Australia
A company organized outside the US subject to provisions of the US federal securities laws receives benefits if it qualifies as an FPI.
Sustainable finance is a key priority for the EU and is high on the regulatory agenda for asset managers and other financial institutions.