Taxonomie verte : Consultation Européenne sur le rapport du groupe d’experts (2)

Suite du blog précédent https://vivrelarecherche.blogspot.com/2020/04/taxonomie-verte-consultation-europeenne.html

Energie atomique : La France n’est pas seule ! Nuclear Energy : France is not alone

Dans le précedent blog, j’expliquais l’enjeu de la taxonomie verte (qui, pour l’instant, mais avec une possibilité de repêchage), excluait le nucléaire de l’accès à des financements privilégiés environnementaux, et je me réjouissais du nombre de contributions françaises montrant la fin d’un certain nuclear bashing.

Dans cette partie 2, je veux insister sur le nombre et la qualité de contributions étrangères allant dans le même sens, montrant que la rationnalité scientifique et technique, le bon sens, le refus de la démagogie et de l’ignorance peuvent encore s’imposer. Et que si l’Allemagne et l’Autriche persistaient dans leur volonté d’exclusion du nucléaire, l’Europe piurrait entrer dans une grande période de tension ;;et même éclater !

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 contributions showing the end of a certain nuclear bashing. 

In Part 2, I want to emphasize the number and quality of foreign contributions along the same lines, showing that scientific and technical rationality, common sense, the rejection of demagoguery and ignorance can still prevail. And that if Germany and Austria persisted in their desire to exclude nuclear power, Europe would enter a great period of tension;; and even burst!

So some contributions, starting with a very documented paper of the Czech government :

Government of the Czech Republic (Czech)

The role and necessity of nuclear power have been acknowledged and well documented by various credible sources. For example, the report of the Intergovernmental Panel on Climate Change (IPCC) calls in its findings for the sharp increase of nuclear energy production to keep the global temperature below 1.5°C. Likewise, the study Nuclear Power in Clean Energy System published by the International Energy Agency (IEA) focuses on achieving the pace of CO2 emission reductions in line with the Paris Agreement and states, that accomplishing this goal is a massive challenge for the developed economies. To make it possible substantial increases in energy efficiency and a renewables investment, as well as an increase in nuclear power generation is required. The Czech Republic further supports the interpretation of the European Commission, which declares the undisputable role of nuclear power as an energy source necessary for the transformation towards climate-neutral EU and its role as a backbone of the carbon-free European power system along with renewables. Not including the nuclear among sustainable activities in the taxonomy would lead to an unfavourable signal to the financial institutions and markets and consequently to its dismissal from the discourse and financing. Lowering supply of financing of the nuclear would lead to higher interest rates jeopardising the investments to new low-carbon sources with negatively affected energy production and stability of the energy supply. Such an approach would consequently hinder the efforts of some EU member states to decarbonize their energy sectors and would lead to a negative economic outcome.

Almost half of the EU member states do count with the use of nuclear power in the foreseeable future, and it is imperative to ensure favourable framework including investment conditions which are critical for the future development of new nuclear sources. Given the strict general conditions under international and national law for the operation of the nuclear power plants already guarantee their safe operation as well as current requirements for the storage of the used fuel respect the necessity to eliminate any potential safety, environmental or health risks. Furthermore, continuous extensive research tackling the issue of nuclear waste is underway and safe storage of spent nuclear fuel while meeting the highest standard is paramount to all states that use nuclear energy in the EU. Spent nuclear fuel and radioactive waste are being tackled through various precaution measures, such as meeting strict radiation safety standards and being subject to numerous controls from IAEA and European Commission. Given the strict general conditions under aforementioned international and national law for safe storage of radioactive waste as well as current requirements for the storage of the spent fuel respect the necessity to eliminate any potential safety, environmental or health risks. Furthermore, continuous extensive research tackling the issue of nuclear waste (spent fuel is considered as a resource) is underway and safe storage of spent nuclear fuel while meeting the highest standard is paramount to all states that use nuclear energy in the EU.

The Czech Republic believes in technological neutrality and that enough empirical data are sufficiently indicative regarding the radioactive waste repositories in Finland, France and Sweden. Furthermore, even countries that decided over nuclear energy phase-out, such as Germany, follow this concept and proceed to build and operate a deep repository. As such, this should have been reflected in the TEG report. The Czech Republic requests that panel formed by experts from radiation safety, geology, and relevant scientific areas with sufficient in-depth knowledge and in-situ experience should be gathered and supplement the current TEG report with its findings. The Czech Republic would like to further contribute with the following remarks:

· Regarding the long-term management of High-Level Waste (HLW) or Spent nuclear Fuel (SNF), there is an international consensus that a safe, long-term technical solution is needed. A combination of temporary storage plus permanent disposal in geological formation is the most promising. An underground permanent repository is being built in Finland, the other EU member states are in various stages of preparations (e.g. Sweden is finalising the steps before construction). Such a process will take place in subsequent countries, in the Czech Republic, for example, which are preparing necessary steps to ensure such process as well.

 · Materials that are used throughout the nuclear power generation life cycle are mostly recyclable, except for a small number of materials that become radioactive waste. Unlike toxic waste that remains toxic, radioactive materials cease to be radioactive over time. The impact of the end of the fuel cycle on the environment is negligible. It is a material that is possible to safely secure, its effects on the environment are entirely marginal and at the moment none at all. The used fuel is in a clean environment, in formidable, proven containers in the warehouse. There has been practically no effect on the surroundings. It does not burden it - noise, dust, land use, not at all radiation (collective dose). The real results of the (loosely) used fissile material on the surroundings can be perfectly observed. For example, in the Oklo natural habitat in Gabon (where there were natural nuclear reactors), when there was no spread of substances into the environment, and its burden was marginal.

· Nuclear energy has many positives. For instance,

 1) Transition to the circular economy - Spent fuel should not be taken as a waste but as a raw material. There is app. 95% of usable uranium remaining. Through recycling, waste from spent fuel is significantly reduced;

2) Prevention and reduction of pollution - Nuclear power plants consume a minimum amount of material and have minimal impact on land use and natural habitats per installed capacity, and consequently do not pollute the environment;

 3) Protection of healthy ecosystems - The discharge of hot water into water sources has a local effect, both positive and negative. It is always carried out in accordance with national regulations and EU directives;

 4) Nuclear energy (even considering the impacts of previous accidents) causes the least deaths from TWh produced when compared esp. with the impacts of coal energy production (and its air pollution implications);

 5) Nuclear energy has the highest ratio of Energy Return on Energy Invested (EROEI) among available energy sources. The Czech Republic calls on the Commission to assess the DNSH criteria in a timely manner and include the nuclear energy in the delegated act in 2020. The Czech Republic reiterates that the Taxonomy regulation stipulates that all relevant existing technologies need to be assessed based on the scientific and technology neutral basis and that the climate change mitigation criteria should be adopted in one delegated act.

Romanian Atomic Forum (Romania)

As the Taxonomy regulation incorporates the principle of technology neutrality, and given that the TEG has not treated all technologies in the same way, we do not believe this principle has been met. For example, the TEG Report recommends that certain renewable technologies be exempted from an LCE assessment. We do not believe that such an exemption is justified only for certain technologies. Therefore, the delegated act should identify the criteria first and then apply it equally to all technologies. - The Taxonomy regulation does not currently exclude specific low-carbon technologies, indicating that they should be assessed against the criteria developed. Given that the criteria have not yet been developed under the Delegated Act, it would be premature to take forward the TEGs opinion that nuclear should not be included at this stage. - In order to ensure a robust scientific approach to the taxonomy, it is urgent as the independent group of experts with an in-depth knowledge on the nuclear lifecycle

Teollisuuden Voima Oyh (TVO Finland)

When the nuclear power plant unit Olkiluoto 3 is completed, TVO will contribute approx. 30% of Finland’s electricity. If nuclear power’s crucial role is not recognized and it is excluded from the taxonomy, the EU cannot achieve its climate targets.

This was also acknowledged by the Technical Expert Group (TEG) in its final report stating, that ‘Evidence on the potential substantial contribu-tion of nuclear energy to climate change mitigation objective was extensive and clear’. TVO supports TEG’s recommendation, that a group with in-depth knowledge on nu-clear life cycle technologies is launched. The group must also evaluate the existing and potential environmental impacts in such an assessment. In order to evaluate nuclear energy within the EU context objectively and robustly, the Commission needs to ensure the transparency and expertise of this group, including the call for members and how the group is going to be organized and execute its work.

In addition, the Platform on Sustainable Finance must also have members with indepth exper-ise on nuclear. The principle of technology neutrality must be included into the future Taxonomy regulation. TVO requests that all power producing technologies are evaluated according to the same criteria. The International Energy Agency (IEA, 2019) has shown that all scientifically proven and commercially available low-carbon energy solutions must be used in flexible and clean energy transition that is a must to reduce the growth of emissions and to stop further climate change. The life cycle emissions produced by nuclear energy compare reasonably with those from renewable energy sources. According to the IPCC (2014), the nuclear life-cycle emissions (12g of CO2/KWh) are equal to those of wind power and are four times lower than from so-lar power. The IPCC analysis for nuclear includes the whole nuclear life cycle, including uranium mining, enrichment and fuel fabrication, plant construction, use, decommissioning and long-term waste management. In Finland TVO already has a sustainable solution for high level waste (HLW)

 – The Finnish Government granted a licence a construction of a final disposal facility for HLW in 2015, the first licence in the world. Currently HLW is placed safely in interim storages for cooling and dealt with in a highly responsible manner under the Eur-atom legal framework. The nuclear sector produces a very small amount of all haz-ardous waste that is produced in the EU each year. In the EU, responsible actions for radioactive waste and especially for HLW are taken care of by the nuclear industry and national authorities according to the EU’s Radioactive Waste and Spent Fuel Management Directive (2011/70/Euratom). Each Member State has a national policy for spent fuel and radioactive waste management. According to the Commission's 2nd report COM (2019) 632 final on the progress over 95 % of the radioactive waste in the EU territory had already been disposed of in 2016. HLW made up 0.2% of the radioactive waste inventory in 2016 and in the stepwise process of implementing ge-ological disposal solution for HLW Finland, France, and Sweden are the most ad-vanced.

Finnish Energy (Finland)

Include nuclear power and Waste-to-Energy in the sustainable finance scheme by considering all energy sources according to equal, technology neutral, principles. Including nuclear power in the sustainable finance scheme is indispensable in order to achieve climate neutrality. Demand for clean electricity is growing fast and nuclear power is enabling the decarbonisation of other sectors. Financing must be secured for maintenance, lifetime extensions of the existing nuclear fleet and new construction. Nordic nuclear power most certainly meets the sustainability criteria. The first final waste repositories are under construction in Finland and Sweden.

Polish Electricity Association (PKEE) (Poland)

The taxonomy and the relevant technical screening criteria established in delegated acts under the draft Regulation of the European Parliament and of the Council on the establishment of a framework to facilitate sustainable investment (Taxonomy Regulation) should be technology neutral so as not to exclude enabling and transitional activities which reduce the negative impact on the environment in comparison to activities which are not regarded as sustainable. Transitional energy sources and bridging technologies, such as generation sources based on natural gas should be the important elements of energy transformation, significantly reducing emissions. Nuclear energy should also play an important role in this transformation.

Energiforetagen/Swedenergy (Sweden)

Although the TEG clearly state their ambition to use technology agnostic screening criteria, a large part of their criteria is in fact technology specific. Swedenergy urges the Commission to express its technical screening criteria as technology neutral as possible. One example is that waste management is expressed to be an issue for some technologies but not for other….

Nuclear power competence is included in the Sustainable Finance Platform to be established in the fall of 2020. Swedenergy proposes that competence from the nuclear waste management programs of the Nordic countries is included in the expert group. • Sustainability criteria for nuclear power should be developed through a graded approach. The sustainability of a once-through fuel strategy of a light-water reactor fleet can be described in a first stage, whereas the sustainability of closed fuel cycles and Generation IV systems etc. could be evaluated further on.

Confederation of Finnish Industries EK (Finland)

There are many economic activities central to the transition into carbon neutral economy where the current form of the Taxonomy’s technical screening criteria does not meet the above-mentioned principles according to which the EK is ready to support the preparation of the Taxonomy. These fields vary from gas infrastructure, biofuels and bio energy to nuclear energy.

Fortum (Finland)

Nuclear: To date, 54,1 % of electricity generated in the EU is CO2-free and more than half of it, is produced from nuclear sources. A CO2-free power supply is a key enabler to electrify and thereby decarbonise the essential parts of our European economy. Fortum thus calls on the European Commission to swiftly appoint a process with the aim to provide a timely and in-depth assessment on nuclear’s environmental impact for the preparation of the related delegated act by the European Commission. We favour involvement of JRC experts and the Art 31 Committee (Euratom Treaty).

GEN Group (Slovenia)

Therefore we propose to: - evaluate all technology options described in taxonomy at the same level of details, contrary to the report published on March 9, 2020, where only nuclear option is burdened with questions regarding the waste;

- perform strategic environmental impact assessment for the taxonomy, in accordance with Strategic Environmental Assessment (SEA) directive , since taxonomy is more than just the strategy;

 - provide that all technology options described in taxonomy are evaluated on same level with comparable requirements for impacts and risk perception, based on life cycle impacts in accordance with environmental impact assessment concept, since we live on the same planet;

-take into consideration aspects of electricity grid stability parameters with encouraging the deployment of flexible and dispatchable low-carbon technologies, as nuclear is, to help back up variable renewables – thereby maintaining reliability and resilience of the future energy system;

Eurelectric (Belgium)

Additional expertise is needed regarding nuclear to guide the adoption of DAs by the end of 2020. We call on the EC to swiftly appoint an expert group of scientifically qualified radiation protection specialists to finalise the assessment of nuclear energy under the Taxonomy. Any delay in the nuclear assessment risks undermining the ability of the Member States to develop a pathway towards climate neutrality.

CEZ Group (Czech)

In energy sector, the ultimate goal of the taxonomy should be to support cost–efficient decarbonisation through low-carbon electricity production. The nuclear electricity generation represents an important low-emission source of energy, which has an irreplaceable role in climate mitigation, electrification and reaching the climate goals, as recently stipulated in the IEA study IPCC Report and EC long term strategy. It is also a backbone of energy mix of the Czech Republic. Since TEG didn´t assess nuclear in its final report, there is a strong need for additional expertise regarding nuclear to guide the adoption of delegated acts by the end of 2020. An expert group of scientifically qualified radiation protection specialists representing all Member states should be established to finalise the assessment of nuclear energy under the taxonomy. Any delay in the nuclear assessment could lead to undermining the ability of the Member States to develop a pathway towards climate neutrality, taking advantage of nuclear as a major low-carbon source.

CEZ Group strongly believes, nuclear should be included as sustainable in the taxonomy, as there is sufficient evidence that nuclear waste is well accounted for and managed. Spent Fuel and Radioactive Waste Management are controlled and managed under the Euratom legislation and repositories are subject to environmental impact assessments and Article 37 of the Euratom Treaty in contrast to other technologies which generate toxic waste. The nuclear industry stores and keeps records of its waste while isolating it from the biosphere and from society. Since there is no actual harm proven, nuclear with such a large mitigation potential should be included in the taxonomy as sustainable.

FORATOM (Belgium)

Regarding the Climate Mitigation aspect, we welcome the TEG’s recognition that nuclear has near to zero greenhouse gas emissions. However, we do feel it necessary to clarify that this applies to the entire nuclear life-cycle, and not just the energy generation phase as the TEG indicates. The greenhouse gas emissions from the lifecycle of nuclear power are very low (12 grammes CO2 eq/kWh), as recognised in the IPCC 2014 report. Indeed, nuclear power plants have a long lifespan (60+ years) compared to some other technologies. Furthermore, nuclear can be used to generate low-carbon hydrogen. Together with low-carbon electricity, this will help decarbonise other sectors such as industry and transport.

In the case of nuclear, for example, the DNSH group have focused on the issue of waste and used it as an excuse not to include this low-carbon technology in the taxonomy. For other technologies, however, the waste criteria do not appear to have been applied in the same way (eg power producing technologies which generate toxic waste at the end of their useful life). Whilst we recognise that the Commission has organised various stakeholder consultations on the Taxonomy, we would like to draw attention to the fact that, as recognised by the TEG, a group of experts with an in-depth knowledge of the nuclear life-cycle needs to be established to tackle this matter. In our view it is essential that the Commission continues to maintain an open and transparent dialogue with FORATOM – as the voice of the nuclear industry – on this matter and so we call for the opportunity to continue contributing to the debate.