kom (2018) 0353 - Bilag 6: Brev fra Danmark, Østrig, Spanien og Luxembourg til Kommissionen vedr. udkast til delegeret retsakt, hvor naturgas og atomkraft inkluderes i EU-taksonomien

Europaudvalget 2021-22
KOM (2018) 0353 Bilag 6
Offentligt

Mr. Frans Timmermans

Executive Vice-President for a European Green Deal

Mr. Valdis Dombrovskis

Executive Vice-President for an Economy that Works for People

Ms Kadri Simson

Commissioner for Energy

Ms Mairead McGuinness

Commissioner for Financial services,

Financial Stability and Capital Markets Union

Mr Virginijus Sinkevičius

Commissioner for Environment, Oceans and Fisheries

Dear Executive Vice-Presidents, dear Commissioners,

This letter aims at bringing to your attention our deep concerns on the draft

Complementary Delegated Act (CDA) published by the European Commission

amending Delegated Regulation (EU) 2021/2139 as regards economic activities

in certain energy sectors.

The European Taxonomy has already been the inspiration for green taxonomies

in more than 15 countries around the world and a reference to those investors

and financiers that have started decarbonising their portfolios.

We, the undersigned, have always advocated for a science and evidence-based,

usable and credible Taxonomy. Today its usefulness and credibility are at stake.

We find the new draft problematic both from a political and technical point of view,

and that it goes beyond the principles of the Taxonomy Regulation. The

Commission proposal puts the energy transition in the EU and globally at risk and

endangers the Taxonomy by classifying gas and nuclear as sustainable, de facto

granting them the same treatment as unquestionable green technologies such as

wind and solar energy.

We regard the draft CDA as a step backwards. This draft sends a wrong signal

to financial markets and seriously risks being rejected by investors. It jeopardises

the purpose of the taxonomy to create a common language. Given the long

lifespan of both nuclear energy and natural gas facilities, an inclusion in the

taxonomy risks to lead to a technological lock-in for many decades and divert

investments away from renewables.

kom (2018) 0353 - Bilag 6: Brev fra Danmark, Østrig, Spanien og Luxembourg til Kommissionen vedr. udkast til delegeret retsakt, hvor naturgas og atomkraft inkluderes i EU-taksonomien

We reiterate that natural gas and nuclear power do not meet the legal and

scientific requirements set in the Taxonomy Regulation to qualify as sustainable

economic activities.

The proposal goes against one of the fundamental pillars of the Taxonomy, which

is to be based on science. It includes substantial contribution technical

thresholds, 270 g CO2e/kWh in the case of natural gas, which are above the

scientific recommendations of institutions and agencies such as IPCC and IEA).

They are higher than the limits set by other countries such as Russia. It would

also mean removing

de facto

the "do no significant harm" principle established

today in the first delegated act on climate taxonomy, which rightly sets the limit

for DNSH at 270 g CO2e/kWh. Two of the criteria are based on future promises,

e.g. the condition of a gradual switch to renewable or low carbon gasses towards

2035. This is at odds with the inherent need of financial markets to only count as

green those revenues generated from activities that meet the criteria now as

opposed to those that might or will meet the criteria sometime in the future.

Regardless of the fact that nuclear power does not meet the requirements of the

Taxonomy Regulation at all, the proposed criteria for nuclear power are

inconsistent and partly also based on future plans. The extremely high costs

linked to this power are documented as is the significantly harmful impact of high-

level radioactive waste - incompatible with the “do no significant harm” principle.

Furthermore, after more than 60 years of using nuclear power, not a single fuel

element has been permanently disposed anywhere in the world. We have no

operational experience with deep geological repositories for high active waste.

For decades to come, there will be no effective waste disposal solution for the

large amounts of dangerous waste generated. It is unacceptable to circumvent

the problem by demanding member states to have a mere plan for a disposal

facility for high-level radioactive waste that should be in operation by 2050. Not

to mention that severe accidents will do significant harm as evidenced in

Chernobyl and Fukushima.

Both proposals would give an ex ante classification and resources allocation that

require a difficult long ex post surveillance with no clear actions in case of non-

compliance.

It is important to take notice of the appetite that institutional investors are showing

towards sustainable investments. In particular since there is growing evidence

that these truly sustainable investments can generate returns that exceed those

obtained in non-sustainable investments and are the key for their future growth.

We strongly encourage the European Commission not to jeopardise the

courageous path it has taken towards making the EU the first carbon neutral

continent and the leader in the global sustainable finance market.

Yours sincerely,

kom (2018) 0353 - Bilag 6: Brev fra Danmark, Østrig, Spanien og Luxembourg til Kommissionen vedr. udkast til delegeret retsakt, hvor naturgas og atomkraft inkluderes i EU-taksonomien

Teresa Ribera

Deputy Prime Minister and Minister for the

Ecological Transition and the

Demographic Challenge

SPAIN

Leonore Gewessler

Minister for Climate Action, Environment,

Energy, Mobility, Innovation and

Technology

AUSTRIA

Dan Jørgensen

Minister for Climate, Energy and Utilities

DENMARK

Claude Turmes

Minister for Energy and Spatial

Planning

LUXEMBOURG

Carole Dieschbourg

Minister for the Environment, Climate

and Sustainable Development

LUXEMBOURG