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