Antinuclear

The science-based case for excluding nuclear power from the EU taxonomy

Not green and not sustainable,  The science-based case for excluding nuclear power from the EU taxonomy, Beyond Nuclear, 15 Jan 2022,

A statement by Dawn Slevin, Dr. Erik Laes, Paolo Masoni, Jochen Krimphoff, Fabrizio Varriale, Andrea Di Turi, Dr. Ulrich Ofterdinger, Dr. Dolores Byrne, Dr. Petra Kuenkel, Ursula Hartenberger, Kosha Joubert, Dr. Paul Dorfman, Anders Wijkman, Prof. Petra, Seibert, Rebecca Harms, Joseph Kobor, Michel Lee, Dr. Stuart Parkinson, and Dr. Ian Fairlie

One of the most influential policy initiatives of the European Commission in the past years has been the “EU Taxonomy”, essentially a shopping list of investments that may be considered environmentally sustainable across six environmental objectives

To be deemed EU Taxonomy aligned, the activity must demonstrate a substantial contribution to one environmental objective, such as climate change mitigation, whilst causing no significant harm to the remaining five environmental objectives (climate change adaptation, sustainable use and protection of water and marine resources, transition to a circular economy, pollution prevention and control, and protection and restoration of biodiversity and ecosystems).  

All eligible activities are required to comply with technical screening criteria (TSC) for ‘substantial contribution’ and ‘do no significant harm’ and to demonstrate that social safeguards are in place. The EU Taxonomy provides a common language for sustainability reporting, a foundation for green bond reporting and much more. It is intended to be used by international financial markets participants whose products are sold within the EU in order to evaluate the sustainability of their underlying investments.  

The use of the EU Taxonomy is furthermore compulsory for the EU and member states when introducing requirements and standards regarding environmental sustainability of financial products, such as an EU ecolabel for investment products or an EU Green Bond Standard. It will also apply to 37% of activities earmarked as ‘climate-friendly’ financed by the EU COVID-19 recovery funding. Its science-based approach is designed to give confidence to a wide range of international stakeholders that environmental claims are not greenwashing. 

The question whether nuclear fission energy complies with the ‘do no significant harm’ (DNSH) criteria of the EU Taxonomy was the focus of the Technical Expert Group (TEG) DNSH assessment on nuclear fission technologies which recommended to the Commission that nuclear should not be included in the EU Taxonomy of environmentally sustainable activities.

Taking into account the significant financial implications of adopting the TEG recommendations, it became the starting point of intense behind-door lobbying. France led a coalition of 10 EU Member States arguing that nuclear fission as well as gas-fired power plants should be included in the Taxonomy. Together with Finland (Olkiluoto-3), France is at present the only EU country constructing a new nuclear power plant (Flamanville-3). 

The Finnish and French construction sites were meant to be the industrial demonstration of an evolutionary nuclear technology (the “European Pressurised water Reactor” or EPR). Olkiluoto-3 was meant to start generating power in 2009, followed by Flamanville-3 in 2012. Instead, the projects turned out to have multiple engineering difficulties and financial constraints that resulted in significant delays culminating in missed deadlines for various production start dates and tripling unit cost. 

Nevertheless, in October 2021 president Macron announced that France will continue to invest heavily in the construction of EPR ‘light’ versions, next to research into small modular reactor (SMR) technology. Following consultation with Member States, the Commission charged its former nuclear Joint Research Centre (JRC) to draft another technical report in 2020 – the “Technical assessment of nuclear energy with respect to the ‘do no significant harm’ criteria of Regulation (EU) 2020/852”. This report was reviewed by two sets of experts, the Group of Experts on radiation protection and waste management under Article 31 of the Euratom Treaty (having no specific competences in sustainability impact assessment other than impacts incurred by radiation) and the Scientific Committee on Health, Environmental and Emerging Risks on environmental impacts (Sheer). 

While the Sheer group pointed out some omissions, the Article 31 Group of Experts, unsurprisingly supported the conclusions of the JRC. Nevertheless, a minority report opposed the lack of integration of economic and environmental aspects, as put forward by the Rio principles for Sustainable Development. 

The JRC, supported by the Art. 31 experts, concluded amongst others that:  “…deep geological repositories are considered, at the state of today’s knowledge, appropriate and safe means of isolating spent fuel and other high-level waste (HLW) from the biosphere for very long timescales and the necessary technologies are now available;” “..the standards of environmental control needed to protect the members of the public are likely to be sufficient to ensure that other species are not put at risk;” “… the requirements in the [EU Taxonomy] TSC regarding protection of humans and the environment from harmful effects of ionising radiation are automatically satisfied in the EU if a licence can be issued.” 

Notwithstanding the findings of the JRC and the Article 31 Group of Experts, members of the TEG DNSH maintain our position that nuclear fission energy should not be included in the EU Taxonomy of environmentally sustainable activities. We the TEG DNSH members observe that the above JRC/Article 31 Group of experts’ statements and conclusions drawn thereof cannot be fully based on scientific evidence as deep geological disposal of high-level nuclear waste entails the need for adequate quality assurance and control of waste form compatibility, as well as for monitoring of health impacts and preservation of knowledge and memory for possibly thousands of years. It also requires operational demonstration of disposal within Europe. 

The fact that according to the current technical state of knowledge there is no alternative to deep geological disposal as a ‘solution’ for the nuclear waste problem does not take away from its ethically problematic character. Moreover the independent scientific evidence which the TEG presented to the European Commission, shows evidence of adverse impacts to the natural environment arising from the many processes involved in the nuclear power lifecycle (from uranium mining to waste disposal) that are operational today.  

Therefore, we maintain our recommendation to the European Commission that nuclear fission energy has no place on the EU Taxonomy of sustainable activities, whether or not it is licensed. It is furthermore our view that the proponents of nuclear energy have guided the interpretation of scientific knowledge and the framing of sustainability assessment in order to use the EU Taxonomy to place a ‘scientific’ stamp on what is primarily a political position on nuclear fission energy aiming to satisfy the few EU member states that wish to promote the associated technologies.  

Does the present generation of nuclear fission power plants ‘do no significant harm’? ……… 

The Taxonomy architecture is not designed to cater for such risks that carry an intergenerational impact lasting for thousands of years, making it an unsuitable instrument to decide on the sustainable nature of nuclear power. ………..

Other concerns with regard to DNSH criteria ……………………………..

Should nuclear fission power be included in the taxonomy as a transition activity? ……………………………………..

Further issues of justice beyond the DNSH criteria …………………….

The Way Forward .

Controlling nuclear technologies, investments, and practices requires a high level of technical expertise, which emphasizes the need for expert structures which are independent of the nuclear industry and can therefore better safeguard the common good at international, European and national levels. 

The nuclear industry is currently self-regulating with oversight provided by the IAEA (with a mandate to promote the peaceful applications of nuclear technology), EURATOM framing and international committees such as UNSCEAR depending too much on international diplomacy (which recently cast doubt on the health effects of exposure to low levels of radiation). 

We highlight the need for an independent international agency requiring revision of the EURATOM treaty as well in order to be able to review nuclear power issues with a focus on society’s need of sustainable development above nuclear sectoral interests, in terms of safeguarding public and environmental health, economic and energy security and general issues of justice. 

The proposed inclusion of nuclear fission energy in the EU Taxonomy will channel much needed capital away from proven sustainable energy sources, create more long-term operational and waste management risks and adverse environmental and social impacts that will undermine the principles and technical screening criteria of the EU Taxonomy and crucially, undermine Europe’s credibility and standing amongst its own citizens and international peers. 

Instead of giving the nuclear industry a new financial injection for solutions of the past such as the large scale EPR, the EU should focus on pressing issues such as looking for common solutions to the existing HLW problem in EU Member States (and internationally) and taking up a strong regulatory position on nuclear safety and peaceful developments in nuclear technology. 

It is the responsibility of Euratom to demonstrate a real European collaboration in solving the technical as well as the environmental and economic challenges related to HLW management (emergency management, harmonised safety and QA/QC criteria for waste forms, insurances). 

The signatories of this letter understand the need of the nuclear industry to receive ongoing regulatory support to ensure that their current operations, management of waste, and decommissioning are authorized and carried out in a safe manner. We therefore encourage the JRC and EU Institutions to extend and harmonise their support and strategic direction of the nuclear industry in the new energy transition paradigm, but we state categorically that the proposed inclusion of nuclear fission energy on the EU Taxonomy  of environmentally sustainable activities is contrary to the TEGs recommendation to the European Commission. 

The above is the content of a Statement of Concern sent by the EU Taxonomy subgroup DNSH TEG members and expert supporters to the Commission on December 21, 2021. The statement can also be downloaded in PDF format. https://wordpress.com/read/feeds/72759838/posts/3774941784

January 17, 2022 - Posted by Christina Macpherson | Uncategorized