Dear German friends : your Energiewende is threatening Germany and whole Europe

The German Federal  Court of Auditors and The Energiewende. When Germany puts herself and Europe at risk !

! this is election year in Germany and the failure of the Energiewende is of utmost importance and should really be debated. The report of the federal court of auditors (Bundesrechnungshof) is an importance piece of information and it is really, really  worrying that is practically not publicized and not debated !

As one German reaction satted : “"The power of the press also lies in not reporting certain things. So there is no problem. »

See also : Energiewende : Our dear German friends are starting to seriously break our balls; https://vivrelarecherche.blogspot.com/2019/09/energiewende-our-dear-german-friends_21.html; https://vivrelarecherche.blogspot.com/2019/09/energiewende-our-dear-german-friends_55.html ; https://vivrelarecherche.blogspot.com/2019/09/energiewende-our-dear-german-friends.html ; https://vivrelarecherche.blogspot.com/2019/09/energiewende-our-dear-german-friends_25.html

 Article Die Welt, 31/03/2021

https://www.welt.de/wirtschaft/article229449033/Energieversorgung-Bundesrechnungshof-warnt-vor-Stromluecke.html?mc_cid=64a4535f40&mc_eid=0c2b52148d

Costs are out of control - and there is a serious risk of electricity shortages! 

Now Energywende is putting Germany at risk! The federal government accepts too high electricity prices and the risk of supply disruptions in order to continue its energy transition.   Today, the Federal Court of Auditors warns that if things continue in this way, Germany and its economy will be in danger! Costs are out of control - and there is a risk of electricity shortages.

The Federal Court of Auditors accused the Federal Ministry of Economy of "failure to control Energywende and mismanagement". These criticisms were already included in a previous report three years ago, and auditors are not only renewing them, but have added an explosive security analysis.

"Since our last review in 2018, too little has been done to master and succeed in the energy transition," said Court President Kay Scheller during the presentation of the second special report: "It makes you think."  In the previous report, the main focus was on controlling the costs of Energiewende, now auditors are also analysing the security of Germany's electricity supply, and the result is alarming!

According to their findings, the federal government does not consider "real and emerging dangers to security of supply" and monitoring the energy transition is "incomplete".

If we continue to follow the current trend, electricity prices will continue to rise. The Federal Court of Auditors mentions a study that the Energiewende will require an additional 525 billion euros between 2020 and 2025 to ensure the supply of electricity, including extension of the grid. However, electricity prices for private households are already 43 per cent above the European average !

Comment: the article is not very clear: forecasts 500 billion more probably on the whole note, already estimated between 1000 and 1500 billion euros over the whole period 2000-2050

The Federal Court of Auditors warns that "the energy transition in this form endangers Germany's economic competitiveness and its international position, and threatens the financial strength of electricity-consuming companies and private households," warned Kay Scheller during the presentation of the special report: "This may ultimately compromise the social acceptance of the energy transition."

 

Population, electricity demand, reserves, weather: nothing is going right: "the key assumptions on which the current assessment of security of supply in the electricity market is based are unrealistic or outdated»

 

The explosive nature of the report is further amplified by the fact that the auditors submitted their criticism to the Federal Ministry responsible for the economy. The answers, explanations and justifications of the minister headed by CDU Minister Peter Altmaier were included in the auditor's report - and they do not, to say the least, reassure the auditors and mitigate their conclusions..

 

Specifically, auditors accuse the federal government of not properly considering the consequences of the phase-out of coal. Earlier this year, 11 coal-fired power plants were closed. Overall, the phase-out under the Coal-Fired Electricity End Act is now being implemented more quickly than anticipated in the Security of Supply Reports.

 

The Federal Ministry of economy last expressed on security of supply in 2019, that is, before the decision to phase out coal. In this document, the phasing out of coal was "indirectly reviewed" - and deemed "harmless" explains the ministry.

Comment: well, just believe it when you see what coal was like in Germany?. So far, the Germans have almost doubled their park. The real problems will begin with the elimination of fossils and nuclear power capable of ensuring baseload production and replacement by intermittent energies

In examining these statements, the Federal Court of Audit found inconsistencies. A comparison with the legal timetable for the decommissioning of coal-fired power plants shows instead that the study assumes a higher secure production from 2022 onwards than can actually be expected after the coal phase-out. There is a "planning gap" of 4.5 gigawatts between the two, which corresponds to the capacity of four large conventional power plants. 

But according to the Department of Economic Affairs, there is a "probability of grid balance" of nearly 100 percent despite the phasing out of coal. The probability that electricity demand could still be covered by electricity supply would be exactly 99.94%. This is questioned by the reviewers. The government's report's calculation of the probability of network balancing "is based on assumptions that sometimes seem unrealistic or are overtaken by current political and economic developments."

 

The auditors state: It is "not realistic to assume that the renewable energy expansion targets will be met under the currently difficult acceptance conditions, especially for wind projects".

 

It is also risky for the federal government to simply base its wind and solar energy forecasts on "historical weather conditions from 2009 to 2013. It is "inappropriate that this simulation does not take into account a year with low energy yields from wind and solar," the Federal Court auditors criticize..

 

Auditors also doubt that the need for reserve power plants has been properly identified. For example, the federal government had planned on October 1, 2020 to create a 2 gigawatt "capacity reserve" to secure the electricity market. However, with the blessing of the Federal Systems Agency, transmission system managers have acquired only half of this power plant reserve. The Federal Audit Office "doubts that the Federal Ministry of Economy has fulfilled its legal obligation to verify the size of the capacity reserve".

 

In the event of a power outage, industrial companies are already expected to voluntarily stop production temporarily - in exchange for compensation. The Ministry of Economic Affairs assumes a potential of 16 gigawatts, which will be fully developed by 2030. However, a study by the Federal Environment Agency suggests a potential of only 6 gigawatts, according to the Court of Audit. Apparently, there is no consensus within the federal government on the extent to which voluntary "load shedding" can help stabilize the power grid.

It is also questionable why the federal government expects to have more than 4.5 gigawatts of "emergency electrical systems" to address the disruption to the electrical balance. In the so-called market basic data registry, only 9.4 megawatts of backup power with it are currently registered, which corresponds to only 0.2% of the potential estimated by the federal government. The examiners are surprised by this slight discrepancy!

 

The Bonn auditors also seriously question other assumptions made by the federal government that do not seem to be more (or more) in line with reality. By predicting energy demand, the federal government is basing its forecasts on a population that fell below 75 million by 2050. On the other hand, the Federal Statistical Office predicts, "in the three most important variants examined with a high probability" a population of between 77.6 and 83.6 million people in 2050".

 

The Ministry of Economic Affairs' assumptions about the security of electricity supply are "partly overly optimistic and partly implausible," the auditors criticise. The Department also did not investigate a scenario in which several predictable factors coincide that could compromise security of supply.

 

Thus, network expansion may be delayed and cross-border transmission capacity may be limited at the same time. The Federal Ministry of Economics argues that "a stacking of various disadvantageous scenarios does not make sense according to the current technical discussion". However, the reviewers found this objection "not convincing ».

 

Comment: well, the delay in terms of the network, for sure!

Other uncertainties arise from the growing demand for electricity for the electrification of transportation and for the production of energy-bearing hydrogen in electrolysis plants. The auditors therefore do not share the federal government's assumption that electricity demand will remain more or less stable until 2030.

 

The Federal Ministry of Economy rejected this criticism: Germany has a coherent system for assessing security of supply. Hydrogen production also does not represent a charge on the grid, as electrolysis systems can be controlled in a "network-friendly" way.

 

However, the ministry as a whole fails to convince the auditors: "The Federal Court of Audit maintains that the key assumptions on which the current assessment of security of supply in the electricity market is based are unrealistic or outdated," states the conclusion of the special report.

 

Some reactions in France and Germany :

Comment: What is disappointing and really worrying  is the lack of reactions in the press and in political debates  to such  profound and fundamental criticisms of a policy that seriously threatens stability and prosperity in Germany, but not only, throughout Europe ...This is election year in Germany, and this topic ( is the energiewende the right way), which is of utmost importance should really be debated…   well, it is above all a deafening silence that seems to be the rule, in the press and among politicians, we hear only silence

 

German reactions: comments on Die Welt's website: "The power of the press also lies in not reporting certain things. So there is no problem. »

The tone of the comments (>600, rather favourable, however, shows that those who reacted already knew the magnitude of the disaster. Obviously the others, all the others, including the politicians have chosen to ignore the serious warning of the Federal Court of Auditors

"In this situation, it is totally irresponsible to close other power plants. In particular, the 6 nuclear power plants still in operation must continue to operate, especially since they do not emit CO2 in operation. »

 

« No one should say during or after the first power outage that they could not have guessed. I wonder when Mr. Scheller, as President of the Federal Court of Auditors, will retire early. Many people will want to push for its replacement. But I hope that there will be more critical voices and that they will be heard. »

 

"Which party to choose for the next election? Unfortunately, this boils down to the fact that Germany must first have a very big blackout before politicians and the majority of the population wake up. »

 

"Which party to choose for the next election? Unfortunately, this boils down to the fact that Germany must first have a very big blackout before politicians and the majority of the population wake up. »»

 

"The Federal Finance Control will certainly be given new tasks after the Greens take power. For example, they can calculate how often the wrong sex has been used or how many marginalized groups are offended."

 

Some French reactions

Gérard Grundblatt ;  https://twitter.com/grunblatt/status/1377592501872234500

"Germans are starting to open their eyes: The German Federal Court of Auditors is warning about the security of electricity supply. Three years ago, the CdCf issued a very critical report on Energiewende, which it considered to be out of control. It reiterates its criticism but with an analysis on the security of electricity supply. It is interesting that it addresses technical issues and challenges the BMWi in a rather alarmist mode. The points raised are exactly the same as in France: what future demand, what flexibility to deal with the intermittency of ENRs, what acceptability of ENRs, network, high electricity prices, ..."

Tristan Kamin ; https://twitter.com/TristanKamin/status/1393892381230043138?s=20

I could not identify the most important information in this article that presents the assessment made by the German federal equivalent of the Court of Audit, about the electricity component of the energy transition.

Is it the fact that, since the previous study in 2018, there has been little effort made to stem the loss of control over electricity costs? 31 cents per kWh for households, Denmark dethroned.

Or the new indication that there is a real risk to the country's electricity supply security?

It is mentioned that at the beginning of the year, 11 coal-fired power plants were shut down. That's good, that's a good thing, in every respect. And so we are ahead of schedule in our plan to get out of coal.

On the other hand, this advance has been achieved at the cost of assumptions that sometimes seem unrealistic or that are outdated by current political and economic developments.

This includes the development of wind power, where reaching the objectives is not considered a realistic assumption. Or on solar energy, whose production forecasts exclude the possibility of a bad year with excessively little sunshine.

Even the population assumptions diverge between the federal government, which is counting on 75 million inhabitants in 2050 against 78 to 84 for the Federal Office of Statistics. "

Michel Gay; https://www.contrepoints.org/2021/05/16/397534-transition-energetique-lallemagne-sinquiete-enfin

"Energy transition: Germany is worried (finally!) ... And the report concludes sternly that "essential assumptions on which the current assessment of the security of supply of the electricity market is based are unrealistic or outdated."  In France, the "ambitious" work of ADEME providing 100% renewable energy in 2050 in France is also totally unrealistic and the French should also be worried!

Germans for nuclear energy ?

 A remarkable initiative of the Voices of Nuclear for the inclusion of nuclear power in European taxonomy: 46 environmental NGOs, mainly European and for some foreign to the Union, have called for nuclear power to be taken into account in european taxonomy in the name of combating climate change. This initiative is unprecedented in its scale.

 Cf. Letter to Ursula Von Der Leyen président commission européenne , https://www.voix-du-nucleaire.org/46-ongs-environnementales-demandent-la-reconnaissance-du-nucleaire-dans-la-taxonomie-europeenne/ ; https://twitter.com/voixdunucleaire/status/1376856948872781831

 Among the signatory organizations, 3 Germans. The sign of a change in German public opinion ?

Deutscher arbeitgeber verbank: Liberals in favor of nuclear energy "The German Employers' Association was founded in 1948 when all professional associations were closed by the victorious powers after the Second World War. The main inspiration was Ludwig Erhard, prophet of ordoliberalism. The founders of the association, committed middle-class entrepreneurs and economists, saw the need to free the economy from the clutches of politics and to clearly define and limit the role of the state. So I would say, some kind of liberal think tank.

Positions on nuclear and energy transition:

Ten requirements: start a new energy and environmental policy now!

Energiewende must be abolished now ! : All intermittent green energy (i.e. wind, solar) that are still subsidized by the EEG today must cease to be subsidized and compete in the market - after 30 years of subsidy, they no longer need the "protection of puppies". The addition of new "green" energies may remain permitted, but without a buy-back priority or long-term fixed remuneration. 

 Section 51 of the EEG must be amended so that in the event of negative stock prices of more than five hours, the owners of the system do not receive remuneration, but on the contrary pay a charge equal to the negative prices of electricity. This would effectively prevent the injection of phantom and wasted electricity and limit the priority of powering older systems at times when electricity is worth something. The increase in network charges must also be passed on to wind and solar power plant operators

 The life of the six remaining nuclear power plants will be extended by 20 years guaranteed by an international treaty. They were commissioned between 1984 and 1989 and are still far from reaching the end of their technical lifespan. A majority of the population is already in favour of this solution

 Energy research must once again be oriented in a technologically neutral way... modern and promising developments in nuclear technology must be generously funded.

 The federal government must work to ensure that EU funding rules are changed under the 'taxonomy' and 'green pact' rules so that investments in nuclear technology are promoted or made possible. There are enough EU member states that support the inclusion of nuclear power.

 Damage and opportunity of energy policy: In December of last year, the prestigious National Bureau of Economic Research in Boston published a study on the real costs of eliminating nuclear power in Germany. The authors calculate that the elimination of German nuclear power has cost us about $12 billion a year by 2017. The majority of costs resulted from more than 1,000 premature deaths each year due to higher respiratory diseases due to nuclear elimination and higher electricity exchange prices

 The annual net costs of German energy policy are around 100 billion euros... In 2018: grid charges, which are largely due to the energy transition (17.7 billion), electricity tax 6.6 billion euros (about 0.02 euros. In total, the energy transition alone cost the electricity sector 50.4 billion euros in 2018.

 Other topics: “Nasty fibers” insist on carbon fibers in wind turbines and on the considerable carcinogenic pollution posed by the not-so-rare fire of wind turbines.

 Hydrogen economy: cheap energy sources are needed ! "The central aspect of costs when using hydrogen is the cost of production... nuclear reactors for hydrogen production could also be used in Germany. The construction and operation of nuclear reactors is also permitted after 2022. Article 7 of the Atomic Energy Act prohibits only the operation of nuclear reactors "for commercial electricity production". For the hydrogen economy, nuclear technology could therefore become the gateway to success

(https://deutscherarbeitgeberverband.de/Artikel.html?PR_ID=847&Title=)

https://deutscherarbeitgeberverband.de/dav_verband.html

Nuklearia: Fighting myths and misinformation

 Nuklearia sees nuclear energy as an essential pillar of energy supply. What for? Because nuclear power is available in far more than enough quantities, 24 hours a day. Nuclear energy requires much less space and land artificialization than wind and solar, and it is providing a baseload....The knowledge of nuclear energy is not sufficiently widespread in the population. Instead of knowledge, there is usually only misinformation or myths... We are working against this misinformation and founded Nuklearia eV for this purpose.

 Nuklearia, via Rainer Klute, seems linked to an evolution of the German Pirate Party in favour of nuclear power

 About Fukushima: "One thing struck me very quickly: what the German media reported was not what I had just learned about nuclear power plants. Nor did it correspond to what NHK World reported or what I was able to look for on the types of Fukushima-Daiichi reactors. And not only the Bildzeitung headlined on "atomic horror", but also the more serious Handelsblatt. Although I had only recently begun to study nuclear energy and radiation, I soon realized that many so-called media experts lacked basic knowledge.

 It pissed me off ! Why did the media do that? Why did they speculate wildly? Why did they play with people's fears? Why did they not provide factual and concrete information about what was happening in Japan?  For me, this has led to a strong will to counter this misinformation in the media with real information. I was a member of the Pirate Party at the time, and there I found like-minded people on nuclear power. In October 2011, we founded a working group within the Pirate Party. »

Position on Nuclear: Nuclear power is part of the Green Deal!

 "This week, 46 environmental organizations around the world, including Nuklearia e. V., sent an open letter to the European Commission. The signatories, led by the French  Voices for Nuclear, are calling for nuclear energy to be part of the European Green Deal and the EU taxonomy for sustainable financing ("EU taxonomy"). The Green Deal is an EU funding programme for green investments with a budget of one trillion euros. The EU taxonomy is a catalogue of criteria that defines which investments in energy supply are sustainable in terms of the environment...

 Rainer Klute, president of Nuklearia e. V. states: "This initiative towards the European Commission fits perfectly into our fight for the preservation of germany's last six nuclear power plants, SaveGER6. If we closed coal-fired power plants instead, it would be by far the most effective and at the same time the cheapest climate protection measure.»

ÖKomoderne: use all available techniques to counter climate change !

"We believe that technologies that other environmental organizations reject, such as civil nuclear energy and green genetic engineering, can make irreplaceable contributions to the prevention of threats such as climate change, ocean acidification, water shortages and soil erosion. The negative aspects of these technologies are often overestimated and not compared to the risks of not using the technology.»

Is there any hope, then, that Germany will question its anti-nuclear folly? We must also recall the initiative of two figures of the German ecological movement, Rainer Moormann and Anna Wendland who published in the Zeit of 20 July 2020 an article entitled: "Stop the elimination of nuclear power! (Stoppt den Atomausstieg!)

(https://www.zeit.de/2020/30/deutsche-klimastrategie-atomausstieg-co2-emissionen-bundesregierung)

  "It makes no sense to keep the lignite power plants that are particularly damaging to the climate and to shut down nuclear power plants... Without long-term electricity storage, the solution is that gas is not climate-acceptable and implies too much dependence on Russia... We must therefore stop the elimination of nuclear power and allow the remaining nuclear power plants to continue to operate for a decade... If the necessary essential progress on the path of large storage had not been made by 2030, the construction of new nuclear power plants should also be considered. »

 Cf. https://vivrelarecherche.blogspot.com/2020/09/allemagne-une-hirondelle-pro-nucleaire.html

Energiewende and European green taxonomy : Our dear German friends are starting to seriously break our balls (5)

Nuclear and climate emergency, alert! Nuclear energy excluded from green taxonomy

European green taxonomy, what is it ?  

The European Commission is working on a green taxonomy, a kind of labeling designed to guide financial investments to the most appropriate sectors and activities to achieve Europe's climate targets, transition to a low-carbon economy and a sustainable development model. The objectives are: combating climate change, adapting to climate change, sustainable use and protecting water and marine resources, transition to a circular economy, waste prevention and recycling, combating pollution (prevention and control), protecting healthy ecosystems.

It must also not create a significant negative impact on other objectives (in English, DNSH criterion, Do No Significant Harm), comply with minimum social standards (??? given the achievements of Social Europe, it is quite worrisome !)  and comply with technical selection criteria (Yes, please!)

What's the point ? According to its proponents, this taxonomy is indicative and non-binding, "it is not a standard, nor is it a mandatory list of activities in which to invest." Well, then what's the point? In fact, it can be expected to have an impact on the definition of sustainable finance and European subsidies.

Comment 1: the fight against climate change is only one of the criteria. However, as Brice Lalonde pointed out about the EPP (French multi-year energy programme), too many priorities mean no priorities!

Comment 2: I quote : "taxonomy will include activities in sectors that have a negative impact on the environment provided that they substantially reduce their negative impacts. The purpose of taxonomy is to encourage the transition to greener ways of operating, and not just activities already recognized as green, it makes sense to include sectors that need to improve their practices. »

Translation (and this will be the fourth time this week on the theme our dear German friends are starting to break our balls): green taxonomy can be used to subsidize German coal miners who will close their plants, but not for investments in French nuclear power (upgrading historical nuclear and new nuclear)!

Warning: nuclear energy excluded from green taxonomy !

Mea maxima culpa, I'm a little late on this blog! After the vote of MEPs last March 2019 excluding nuclear energy from green taxonomy. There is an open European consultation on green taxonomy where everyone can give their opinion; finally could until Monday 16 September, but perhaps the deadline was still extended: site

https://ec.europa.eu/info/publications/sustainable-finance-teg-taxonomy_en

N.b.  The association “ les Voix du Nucléaire”, which does a wonderful job, has provided an argument in English to answer this consultation: contact them on:

https://www.voix-du-nucleaire.org/contact-2/

You can find useful references on Tristan Kamin's threads (perfect, as usual):

https://twitter.com/TristanKamin/status/1173521368937312256

Following consists of excerpts translated into French from the argument  des Voix du Nucléaire !

The context: "We started our public action a few weeks ago with an open letter to MEPs after their vote last March excluding nuclear energy from green taxonomy. We must now convince them to reconsider this decision. It is very strongly counterproductive when the fight against climate change should be the priority. If the European decision came into force, France would also be penalised in view of what nuclear power represents for its economy, its trade balance, its territorial development, its jobs and its energy independence. »

"The European Commission's (TEG) Group of Technical Experts has considered the inclusion of nuclear energy in the taxonomy of sustainable EU financing as a sustainable activity and investment. The TEG technical report published in June 2019 proposed not to use nuclear energy in the first version of taxonomy, pending further evaluation. The TEG recommends that further technical work be undertaken on the aspects of nuclear energy (Nb in particular DNSH - Do No Significant Harm - Do not cause significant damage]

Arguments :

Why nuclear power should not be excluded on the basis of the DNSM: All commercial nuclear activities in the EU (including spent fuel management) are already governed by EU and state legislation, regulations and procedures "Do No Harm" (DNSH).  On the other hand, the global scientific consensus concludes that the maintenance and expansion of nuclear energy is necessary to achieve sustainability goals, such as mitigating the effects of climate change.

General arguments in favour of nuclear power:

Nuclear power provides low-carbon, solid and affordable basic electricity that can withstand a decarbonised electricity mix in parallel with an expansion of renewable energies such as solar and wind in the European Union  Nuclear energy also has one of the lowest contributions to carbon generation throughout its life cycle - even less than solar and wind power per kWh (see IPCC report, "Climate Change 2014: Mitigation of climate change"). Excluding nuclear from access to sustainable financing risks undermining climate change mitigation scenarios and roadmaps identified as achievable and necessary by some of most credible institutions and organizations and authorised countries, including the IPCC (2018), the IEA (2019) and the European Commission (2018). All conclude that nuclear energy should continue to play a role ...

The exclusion of nuclear energy from taxonomy risks making it even more difficult to mitigate climate change by reducing funding opportunities for nuclear projects and unnecessarily increasing the cost of capital nuclear energy projects.

In May 2019, the International Energy Agency highlighted the important role that both existing and new nuclear power play in the future transition to clean energy. In the UK, National Grid published its future energy scenarios in July 2019, including a "zero path" with a nuclear capacity of 18.6 GW by 2050. The opinion of the Committee on Climate Change (CCC) to the UK Government - which led to the adoption of the "UK zero target" for 2050 - played a crucial role in identifying the need for additional energy production of 30GW-60GW by the end of the year. 2050 in the CCC's  zero path scenario.

Although the taxonomy report takes into account the contribution of nuclear energy to the fight against climate change, nuclear is not included in the current list of sustainable activities and no framework for assessing inclusion nuclear power was not provided. The inclusion of nuclear energy as a source of sustainable low-carbon and sustainable production in August 2019 should be reviewed at the next phase of the EU taxonomy review with the participation of life cycle experts nuclear power.

The consideration of all forms of low-carbon electricity generation should be the same (technological neutrality). The TEG technical report does not take into account the relative qualities of the different low-carbon electricity generation options.

In particular, the treatment of nuclear production in the TEG technical report differs from that of other technologies in terms of waste disposal and management. All forms of low-carbon electricity generation generate waste and involve an element that cannot be considered 'ecologically sustainable'. The full life cycle of electricity generation must be taken into account and compared fairly for all technologies. According to OECD statistics, nuclear power is the safest way to generate electricity. By comparison, polluting activities - such as steel and concrete manufacturing - are included in the taxonomy project, provided they operate at "unprecedented" levels. These activities were included in recognition of their crucial importance in achieving net zero and the desire to improve their environmental performance while at the same time respecting the most rigorous regulations.

The regulatory and governance requirements for the nuclear sector are subject to extremely stringent global standards for all aspects of the nuclear lifecycle, including waste management, safety. All commercial nuclear activities in the EU (including spent fuel management and final disposal) are already governed by DNSH (Do Not Significant Harm) standards in accordance with EU and Member State laws, regulations and procedures.

Need of a credible process/classification system:

"All forms of low-carbon production will be necessary for the clean energy transition and should therefore be subject to equal treatment under the 'no significant damage' (DNSH) procedure, and should therefore be treated included in taxonomy. It should be noted, for example, that photovoltaic solar panels and wind energy are not required to carry out an assessment of emissions over their life cycle, despite the lower emission threshold proposed by the European Union. It should also be noted that there is no waste metric in the "circular economy" criterion to which solar photovoltaic must comply, whereas there is a metric for wind energy. 

On the other hand, nuclear power is supposed to be excluded on the basis of waste, despite the fact that nuclear and radiological safety, through all elements of the uranium fuel cycle (including waste and decommissioning), is one of the most more regulated in the EU. EU waste management regulations set out clear requirements, which could be described as benchmarks or as the best appropriate standard (as has been done for other activities, such as aluminium and cement).

In the context of the search for "net zero", the exclusion of nuclear activities from taxonomy as a recognized and commercially viable form of low carbon production, undermines the credibility of taxonomy.

Other parts of the EU's financial mechanism recognise the need for nuclear power to achieve net zero: at the end of July, the EIB published a draft energy loan policy outlining how the EIB can help the EU cope with change climate change and the rapid abolition of fossil fuel loans. In this context, the EIB stated that: "Zero net emissions will involve a diversified portfolio of technologies, including renewable energy, but also nuclear, carbon capture and storage, the conversion of excess energy into a other energy vector, as well as bioenergy, storage and digital technologies. In this document, the EIB further states that in addition to nuclear power generation, the full nuclear fuel cycle, decommissioning and waste management are eligible as projects that meet the bank's criteria.

In addition, the European Commission is obliged to facilitate investments in the development of nuclear energy in accordance with Article 2 of the Euratom Treaty. It is essential that all regions of the EU are aligned on the safest path to net zero. This will further damage the credibility of taxonomy in the financial community if some organizations recognize the ecological nature of nuclear power, and others do not!

By creating a different set of requirements for one activity (nuclear) compared to the others, the TEG compromises its own integrity and credibility as a group of technical experts. By requiring long-term empirical evidence for nuclear waste depots, although no other evidence is required from any other sector or industry, TEG risks undermining the so-called technological neutrality of taxonomy. Significant inconsistencies in the application of the EU's principle of equal treatment in relation to the significant non-injury criterion (DNSH) in August 2019 may undermine the confidence of financiers that the definition of sustainable activity has been made rigorously, robustly and objectively.

This unequal treatment and the current exclusion of nuclear power (despite its critical role in achieving net zero emissions) could damage the reputation and credibility of taxonomy and TEG, which could limit the adoption of taxonomy and the EU's green obligation by the wider financial community.

The EU's Sustainable Financing Initiative is an important development that could significantly increase the amount of financial capital spent on sustainable activities. However, for this benefit to materialize, it is important that the financial community largely adopts the EU taxonomy and the European standard on green bonds, which requires financiers to be assured that the definition of an activity sustainable development is developed rigorously and objectively.

In the context of low-carbon electricity generation, this requires a technologically neutral approach and consistent application of DNSH criteria across low-carbon technologies. However, there are clear inconsistencies in the application of the EU's principle of equal treatment in relation to the DNSH criteria. This unequal treatment of all economic activities and the current exclusion of nuclear power (despite its critical role in achieving zero net emissions) damage the reputation and credibility of taxonomy and TEG, which may limit the adoption of Taxonomy as the European standard on the green bonds of the financial community.

Taxonomy defines sustainable criteria for multiple activities in different sectors (manufacturing, agriculture, transport) based on the carbon intensity of electricity consumed in the course of their activities. This approach is inconsistent with the approach applied to the definition of sustainable activities in the electricity generation sector, where nuclear power is excluded although it is definitively (and recognized by the taxonomy project) at low Carbon.

Potential impact on hydrogen-based and electrointensive technologies.

The TEG report states (pages 50, 186 and 205 to 208) that future decarbonization projects involving (i) the use of hydrogen or (ii) the manufacture of hydrogen, will only be considered "sustainable" in relation to taxonomy if hydrogen is produced at from electricity from renewable sources.  As a result, some industries (such as aluminum, iron and steel manufacturing in countries such as France) may not be able to finance some of their decarbonisation efforts by referring to taxonomy given their heavy dependence on nuclear energy! !

In addition, the exclusion of nuclear from taxonomy risks undermining confidence that electrification in all sectors will be considered sustainable in the future …

The crucial role that electrification plays in achieving net zero means that it is vitally important that all low-carbon production is considered sustainable, and that nuclear power contributes significantly to production. low-carbon electricity today and in the future.