Green taxonomy : European Consultation on Technical Expert Group (3)

In the previous blog, I explained the issue of green taxonomy (which, for now, but with a possibility of change), excluded nuclear power from access to privileged environmental financing, and I was pleased with the number of French and foreign  contributions showing the end of a certain nuclear bashing. 

(https://vivrelarecherche.blogspot.com/2019/09/urgence-nucleaire-et-climatique-alerte.html)

https://vivrelarecherche.blogspot.com/2020/04/taxonomie-verte-consultation-europeenne_22.html

In Part 3, I want to communicate extracts of a major French Trade Union (CFE-CGC Energie) contribution, one of the few trade unions that acknowledges and answered to the concerns provoked by the Green Taxonomy.

Sustainable Finance and "Green Taxonomy" - POSITION of CFE-CGC Energy on the report of the Technical Expert Group (TEG) April 2020)

The European Union, through the Green Deal, has confirmed its desire to achieve a carbon-neutral economy by 2050, and, to go beyond wishful thinking, to draw up a concrete and responsible roadmap to carry out this agenda. The Green Taxonomy Regulation is a way to put in place a framework that directs investors and facilitates significant investment flows to the most relevant innovations, technologies and projects to achieve this goal. As a representative organisation of employees of the energy sector, the second trade union of the branch in France, a member of the European trade unions EPSU and Industriall, the CFE_CGC Energy federation legitimately wishes to contribute to the Technical Expert Group's evaluation on taxonomy and to relay a number of criticisms or concerns expressed by its constituents.

The CFE-CGC Energy Federation supports the Commission's objectives and the sustainable financing initiative, which is an essential tool with important consequences that needs to be carefully evaluated and weighed. Our organization shares the international consensus on the technologies to be embarked on to succeed the Green Deal, and fully agrees with  the IEA calling on industrialized countries to focus on renewable energy, nuclear and gas, the latter as a substitute for more carbon-intensive fossil fuels such as oil and coal. As a result, we wish to clarify the following points.

1) Low-carbon technological neutrality has not been respected.

 Only an agnostic technological approach can properly identify the most effective and relevant outcomes. However, the TEG report does not follow this method ; in particular, it does not require all energy sources without exception to  be evaluated over their entire life cycle, and according to a methodology whose rigour is validated and internationally recognized (for example, ISO 14040 and 14044). Any choice that would not be supported by this type of analysis seriously undermines the credibility of this text.  The facts that Renewables Energies are exempted of this whole  life cycle analysis and that, for nuclear, it is not recognized that the low greenhouse gas emissions not only results from the exploitation phase, but also from the entire life cycle (12gCO2/kWh according to the 5th GIEC report) constitute flagrant violations of the principle of technological neutrality that need to be corrected.

Finally, the DSNH (Do Not Significantly Harm) criterion, if necessary, is rather vague and must also be considered according to the criterion of technological neutrality and the state of scientific knowledge, and not according to criteria depending on the desired result.

This obviously has not always been the case, especially for nuclear waste (see below).  This reflects the consideration of the non-technical and highly political agendas of certain countries or organisations that have no monopoly on scientific ecology and seriously undermines the very relevance of the TEG report.

2) Exclusion “at this stage” of nuclear energy from the “green” taxonomy.

While nuclear power is well identified as a highly decarbonised energy source (6g CO2/kWh in French industry, according to Ademe assessment), it is not sufficiently stressed that it is non-intermittent and flexible and does not need to be combined with other means of power generation or large-scale storage; its low impact on, among others, air pollution, consumption of raw materials, use of lands are not highlighted, and, in general, the lack of consideration of these criteria constitutes a general and important methodological weakness of the TEG work on taxonomy.

The exclusion of nuclear power at this stage is claimed to come from the fact that the management of its waste would not meet the DNSH criterion. CFE-CGC Energy disagrees  with this claim, which clearly ignores the technological realities and the state of science. Radioactive waste is managed according to strict protocols and its management is supervised by national security authorities and is subject to numerous Euratom Treaty specifications; it would be appropriate that taxonomy  do not ignore the existing European treaties!

With regard to low-level radioactive waste, there is a European consensus to define a threshold for release from which these materials can be considered as ordinary materials: IAEA (RS-G-1.7 guide), directive 2013/59/ Euratom. Recycling of nuclear fuel can be expanded to make better use of uranium resources and reduce waste. The volume of high-activity waste, after reprocessing, represents 3% of all  radioactive waste in France, i.e. the equivalent of an Olympic swimming pool for the entire French nuclear  park since its creation. For those ultimate waste, deep burial in geological deposits (stability greater than 150 million years against a detectable radioactivity of 15,000 years for waste) is a solution validated by the security authorities of many countries (France, Finland, Switzerland for Europe, but also USA, Japan, Canada, Russia, China). In France,  CFE-CGC  Energy supports the Cigéo project.

It should be noted that the TEG, after its principled position on the exclusion of nuclear power, nevertheless acknowledges its lack of competence on the subject and opens the door to a specific international expertise. CFE-CGG Energy calls for this recommendation to be followed and to appoint an expert group to assess the sustainability and the DNSH aspect of known solutions for the treatment of nuclear waste, respecting technological neutrality.  This group should be made up of experts from national security authorities, public agencies in charge of radioactive waste management, representatives of research organizations active in nuclear science and technology, and radiation protection.

CFE-CGC Energy  stresses the importance of dealing with this problem rationally and quickly. The TEG report does not treat with due importance an abundant, competitive, highly contributor to GDP energy, which is currently the main source of decarbonised energy in Europe ! It is necessary to eliminate the current uncertainty about nuclear power: firstly, for its own importance in the climate challenge (remember that electricity is also bound to replace massively some uses of fossil fuels); and secondly, because the exclusion of nuclear power from green taxonomy would also have a strong impact on all user industries that would be denied access to preferred financing to optimize their energy transition processes….

4) Responsibility of Member-States in their energy mix

 CFE-CGC Energy recalls that energy policy mix are the responsibility of Member-States that have very different geographical, economic and historical contexts and constraints, and which must be able to choose their range of low-carbon tools and make their own technological choices to succeed in their energy transition. Again, respect for technological neutrality is essential, for if States were to be denied access to green financing for important and structuring projects according to technologically unjustified criteria (for example in the case of nuclear projects in Finland, Czech Republic, Slovakia, Romania, Bulgaria, Hungary), this could simply cause the explosion of institutional Europe at a time when it is facing multifaceted and unprecedented crises and tensions.

5) The DSNH criteria must take into account social and strategic aspects

 A green investment cannot be an investment that would violate the minimum social guarantees recognised by the Member-States, or that would cause serious employment difficulties, even temporary ones, without offering satisfactory solutions for retraining.

Moreover, the current sanitary Covid crisis obliges us to review our dependence on foreign countries and industries and to embark on a policy of re-industrialisation. Green investments must take into account the negative aspects of an excessive and uncontrolled globalization, as well as strategic aspects. European green funding should not lead to an increase in dependence on states outside the EU, which everyone can now see as dangerous, nor should they be used to finance value chains almost exclusively established outside the EU.

Finally, it would be absurd to label green funding which would simply outsource the negative impacts (CO2 emissions, pollution, health consequences, costs and negative externalities of transport) outside Europe. The lessons of the financing of wind and especially solar industries  by Europe and Member-States resulting in the massive creation of value and jobs in China must not be forgotten.

Green taxonomy is an important tool for the success of a climate-efficient, economically favourable and socially just energy transition. Its potential is immense, its consequences must be carefully evaluated. CFE-CGC Energy considers it essential to respect technological neutrality in all its aspects, otherwise this tool will lose all legitimacy and will face the refusal of Member States and their citizens and employees.  It hopes that future discussions on taxonomy will include social and strategic aspects, be transparent and open to stakeholders, and will enable the development of a European model of more environmentally and socially responsible companies.

These are essential conditions for taxonomy to achieve its objectives and be indeed useful in directing investments towards a successful and Green Deal-compliant energy transition.