Alors que le Conseil de l’Europe laissait la porte ouverte pour décarboner l’Europe,
attendant que la rationalité scientifique supplante l’électoralisme et le lobbying des gaziers⁸ et des industries de l’intermittence électrique, des ONG cherchent à consolider le statut quo qui perdure : le gaz russe qui explose, et des aérogénérateurs dix fois plus consommateurs en métaux et béton, peu efficaces aux heures où on en a besoin, qui ne foisonnent que peu vu le régime des vents et Europe de l’ouest.
Ce communiqué qui mêle adroitement le vrai et le faux pour s’attirer l’accord des naïfs et de ceux qui n’ont pas le temps d’approfondir la question et forment quand même une opinion … C’est révoltant.
Traduction du Communiqué en français :
SUBJECT: EU Taxonomy and Nuclear Finance: Technical Expert Group (TEG).
TO: Valdis Dombrovskis (Executive Vice President, EC), Kadri Simson
(Commissioner, DG ENERGY), Frans Timmermans (Executive Vice President, EC).
FROM: Nuclear Consulting Group (NCG), Alliance of Regions for Phasing out
Nuclear Power Across Europe (Initiator Stefan Kaineder, Regional Minister Upper
Austria), Aarhus Konvention Initiative, Amanadamaji ry, Atomstopp-Atomkraftfrei
Leben, Ausgestrahlt – Gemeinsam Gegen Atomenergie (AGGA), Bi Stoppt Temelin
(BST), Bund für Umwelt und Naturschutz (BUND) Friends of the Earth (FoE)
Germany, Bürgerinitiative Umweltschutz Lüchow-Dannenberg (BULD), Calla –
Sdružení pro záchranu prostředí, Cities for a Nuclear Free Europe (CNFE),
Commission de Recherche et d’Information Indépendantes sur la Radioactivité
(CRIIRAD), Don’t Nuke the Climate Coalition (DNCC), European Environmental
Bureau (EEB), Folkkampanjen Mot Kärnkraft-Kärnvapen (FMKK), France Nature
Environnement (FNE) – French National Federation of Nature and Environment
Protection, GLOBAL 2000 Friends of the Earth (FoE) Austria, Forum Wissenschaft &
Umwelt (FWU), Friends of the Earth Europe (FoEE), Fundacja Strefa Zieleni – Green
Zone Foundation, Grup de Cientifics Tecnics per un Future No Nuclear – Scientists
and Engineers for a Non Nuclear Future, Laka Foundation – Stichting Laka (Laka),
Hnutí DUHA Friends of the Earth (FoE) Czech Republic, International Network for
Sustainable Energy (INFORSE) – Europe, Klima-Bündnis Lëtzebuerg, Miljörörelsens
Kärnavfallssekretariat (Milkas) – Swedish Environmental Movement’s Nuclear Waste
Secretariat, Miljöorganisationernas Kärnavfallsgranskning (MKG) – Swedish NGO
Office for Nuclear Waste Review, Mütter Gegen Atomgefahr (MGA), Nationalen
Aktiounskomitee géint Atomkraaft (NAA), Naturskyddsföreningen – Swedish Society
for Nature Conservation, NOAH Friends of the Earth (FoE) Denmark, UK and Ireland
Nuclear Free Local Authorities (NFLA), Nuclear Transparency Watch (NTW),
Österreichisches Ökologie-Institut/Austrian Institute of Ecology, Österreichischer
Naturschutzbund (ÖNB), Réaction en Chaîne Humaine (RECH), Réseau Sortir du
Nucléaire (RSN), Salzburger Plattform Gegen Atomgefahren (PLAGE), South
Bohemian Mothers, Sveriges Energiföreningars Riksorganisation (SERO),
Stowarzyszenie Ekologiczno-Kulturalne Wspólna Ziemia, Stowarzyszenie
Ekologiczno-Turystyczne Lubiatowska Wydma, Towarzystwo Solidarności Globalnej
im. Róży Luksemburg, Umweltdachverband (UWD) (Austrian umbrella organisation
comprising WWF Austria, Naturfreunde Austria, Bird Life Austria), Umweltinstitut
München e.V. – Munich Environmental Institute, UK Campaign for Nuclear
Disarmament (CND), Uranium Network, Wiener Plattform Atomkraftfrei (Viennese
Nuclear-Free Platform), World Information Service on Energy (WISE), Women
Engaged for a Common Future (WECF), Women Against Nuclear Power – Finland,
Women for Peace – Finland, Zelený Kruh/Green Circle (Representing 86 Czech
- The EU Taxonomy
1.1 The European Commission has recently published the rules for sustainable
finance, known as the EU taxonomy, intending to identify economic activities that
can be considered economically and environmentally sustainable. As part of this, the
EU Taxonomy Technical Expert Group (TEG) delivered their final recommendations
to the Commission; excluding nuclear from the Sustainable Finance Taxonomy ‘at
this stage’, stating that ‘it was not possible to conclude the nuclear energy value
chain does not cause significant harm to other environmental objectives on the time
scales in question’.
1.2 As key pan-EU national and regional organisations, national and regional
NGOs, institutions, and scientists with long-standing involvement in the field of
nuclear energy, we have, over time, sought to constructively engage in the EU
Technical Expert Group (TEG) Taxonomy process. In this context, we remain
concerned that the nuclear industry and a very few Member States now seek to
revisit this key recommendation.
- The EU Energy Landscape
2.1 The EU energy landscape is one of differences between state and market,
choices and trade-offs over supply-side, demand-side, transmission and load-
balancing infrastructure. Although EU States may diverge in terms of economic,
cultural and industrial landscapes, public opinion, technological structures,
institutions, regulatory practices and energy mixes – there remains the real possibility
of evolving open and flexible frameworks to develop collective action on energy. This
is critically important, since recent reviews of the impact of climate change suggest
that, over the next few decades, we will be subject to significant change in human
health, welfare and environmental systems. Key to adapting to this change is the
transition to a low carbon and resource efficient energy economy, involving major
structural changes to the way we work and live – including how we source, manage,
use and conserve our energy. We need to secure clean, safe, affordable,
sustainable, low carbon energy to power industry, transport, hospitals, homes and
businesses before 2050.
2.2 The challenge of achieving this may involve a series of technically and
economically viable options, including the expansion of renewable energy sources in
all sectors, rapid growth and modernisation of electricity grids, improvements in
energy efficiency, the use of modern technologies to minimise electricity
consumption, rapidly enhanced storage technologies, market innovations from
supply to service provision, the fundamental re-structuring of the built, transport,
industry and agriculture environments and, some argue, continued reliance on
nuclear power. Yet, at the heart of the nuclear issue are differing views on how to
apply foresight, precaution and responsibility in the context of the relative economics
of nuclear, the uncertain role of nuclear in combating climate change, the possibility
of accidents, the consequence of those accidents, the production of highly
problematic waste, and whether there exists a role for nuclear within the swiftly
expanding renewable energy evolution.
- New Nuclear
3.1 World-wide and in the EU, the fate of new nuclear is inextricably linked to, and
determined by, renewable energy technology roll-out. Market trends for new nuclear
are in stark decline and renewables are markedly rising. The, perhaps obvious,
explanation for this dynamic can be found in the ramping costs of the former and the
plummeting costs of the latter. In this sense, not all lower carbon options are equal,
benign or effective – and there are choices to be made.
3.2 For nuclear to be considered a feasible option, new reactor build should be
able to be completed economically, efficiently and on-time. However, practical
experience suggests otherwise. Nuclear new-build represents a high-risk technical,
regulatory and investment option, with a marked tendency for significant delay and
cost over-run. Sets of substantive market analysis strongly suggest that investment
in nuclear power is uneconomic – this holds for all plausible ranges of investment
costs, weighted average costs of capital, and wholesale electricity prices. The slow
implementation of nuclear energy into the power system and limited scalability over
the short-term in comparison with other sustainable options significantly questions
the effectiveness of further investments in new nuclear.
3.3 There seem no resounding new revelations over the vulnerability of nuclear to
unforeseen natural disasters or through human or engineering-based fault
conditions, including accidental or deliberate harm. Accidents are by nature,
accidental, and the cost of ignoring this common-sense axiom can prove
radiologically catastrophic. Whatever one’s view of the risks and benefits of nuclear,
it is clear that the possibility of catastrophic accidents or incidents, and consequent
economic liability, must be factored into energy policy decision-making.
3.4 When considering the entire nuclear life-cycle (including mining, transport,
enrichment, plant construction, operation, dismantling, and waste management),
nuclear is significantly more carbon intensive than renewable power. In addition, the
production of radioactive waste, including the unresolved issue of nuclear waste
management, places nuclear technology counter to the key ‘Do No Significant Harm’
(DNSH) principle. This is because, despite 70 years of operation and research, the
nuclear industry has yet to provide proven and sustainable methods of management
that neither increases radioactive waste volumes nor decreases the potential risk to
- Climate Change
4.1 With mounting public concern and policy recognition over the speed and pace
of the low carbon energy transition needed to mitigate climate change, nuclear has
been re-framed by some as a partial response to the threat of global heating.
However, given the costs, risks, proven slowness of implementation, and cradle-to-
grave emissions of CO2; nuclear will struggle and fail to compete with renewable
technological, economic and security advances.
4.2 The Intergovernmental Panel on Climate Change (IPCC) has recently
reported that extreme sea-level events that used to occur once a century will strike
every year in many coasts by 2050, whether climate heating emissions are curbed or
not. Thus, EU coastal nuclear plant will be increasingly vulnerable to sea-level rise,
storm surge, tidal ingress, and flooding of reactor and spent fuel stores – and these
impacts may occur quicker than nuclear regulatory or industry have planned for.
Inland reactors may fare no better due to flooding risk associated with extreme
precipitation events, or loss of cooling due to river flow reduction or heating.
4.3 The illusion that nuclear energy is necessary to prevent climate change, is
dangerous. Climate change poses a number of unique challenges to humanity. One
of the most difficult is that the world not only needs to get to a specific place – a
carbon neutral global energy system; but it must also get there by a specific time –
the middle of the century. Otherwise the policy has failed. The reality is, you simply
could not build enough nuclear reactors fast enough even to replace the existing
reactors that will reach the end of their life by 2050, let alone to replace fossil fuels in
the existing electricity system – and even more so for the more electricity intensive
economy that European states are currently building. This would be true even if you
were willing and able to overcome all the other unsolved problems that nuclear
reactors face: affordability, accidents, waste management, proliferation, special
materials and talent scarcity, and system inflexibility.
4.4 The very great cost of proposed life-span extension of ageing nuclear plants
is complicated by the fact that the first and second wave of EU nuclear plants were
constructed well before the impacts of global heating were considered in their design
base. Thus, even after any proposed life-span extension improvements, ageing
nuclear plant would have significantly less protection against external hazards and
the risks of a long-term loss of cooling due to poor redundancy and lower quality
spent fuel pool standards.
4.6 Nuclear sucks funds and vital political attention away from imperative zero-C
investments. It displaces renewables on the grid and diverts essential research.
Achieving a zero-C Europe is made slower and far more expensive. Heavyweight
nuclear lobbying undermines implementation of renewable energy systems, energy
efficiency and demand side management zero-C efforts. The ramping opportunity
costs of new nuclear significantly compromises other, more flexible, safe, productive,
cost-effective and affordable technologies – and comes at a time when the
development of renewable, sustainable and affordable low carbon energy is a
growing economic sector with a huge potential for employment creation in the EU.
- The EU Technical Working Group (TEG)
5.1 We strongly urge the European Commission to maintain good faith in the EU
TEG Taxonomy recommendations – that, essentially, nuclear does not meet the
criteria for sustainable investment. We also urge the Commission not to consider
forming any further technical working group on the nuclear issue in the context of
sustainability criteria. However, if the Commission were to do so, we would make a
very strong case for our representation in any further technical working group – in the
context of the Commission’s adherence to its fundamental collective values.
The letter :
Mr Valdis Dombrovskis (Executive Vice President, European Commission),
Frans Timmermans (Executive Vice President, European Commission),
Mrs Kadri Simson (Commissioner, DG ENERGY)
Dear Vice-President of the European Commission,
We are group of scientists representing academia and civil society and strongly support the goal to achieve climate neutrality by 2050. Climate change is one of the biggest challenges faced by the world today and we are convinced that leaving a better planet to those coming after us should be our legacy. If we do not act now, we will very likely face many more challenges in the future including pandemics, natural disasters, migration waves and irreversible changes to the environment creating huge costs both for the global economy and human society. That is why we have welcomed and embraced both the Long-Term Strategy (Clean Planet for All) published in 2018 and the European Green Deal, published at the end of last year.
We welcome the initiatives and instruments that are proposed for the Financial Sector to enable the Green Transition
Although the sustainable transition should be considered a top political priority, we realize it comes at a significant economic cost. Therefore, we strongly support the Sustainable Finance Action Plan which should ensure that finance flows into projects support both economic and climate change ambitions (preserving our planet for the future generations). The Taxonomy Regulation, once implemented, should provide investors with reliable information on which activities and technologies contribute to the sustainability goals. It will be a crucial tool for investors to guide finance in the right direction and as such, needs to be carefully and thoughtfully designed.
Energy Sector Faces Major Transformation
The energy sector still contributes the largest share of total greenhouse gas emissions (28.2 % in 2017 based on Eurostat data). To achieve climate neutrality, the sector will inevitably have to undergo the biggest transformation. We fully agree with the conclusions of the communication “Clean Planet for All”, which acknowledges that nuclear power together with renewables will form the backbone of a carbon-free European power system. Both can provide European industries and households with low-carbon and pollution free energy. In other words, technologies that can make the energy transition possible already exist and are operating today.
Nuclear Should Be an Element of Stability in the Climate Neutral Europe
To fight climate change and limit the global temperature increase (ideally) below 1.5 °C, we must act now. Many European countries have decided to phase-out fossil fuels as soon as possible and others are currently developing strategies to join them. Electrification will probably be the key enabler of the clean energy transition and will create a growing demand for electricity. This will be the case, even with wide application of the “Energy Efficiency First Principle” that will offset some of the increased demand. The EU must be supplied with enough generation capacity to match the demand for clean, affordable and reliable power.
Even though developing rapidly, renewables will not be able to provide the required generation adequacy. Also, a power system built solely on renewables, demand side solutions, and flexibility, would create significant system stability issues. In addition, it would require major restructuring and new build of power grids across the EU.
Therefore, we call on the European Commission and all EU policymakers to adopt the pathway set by the “Clean Planet for All” long term strategy (and the IPCC) and build the decarbonized energy system with renewables and nuclear power “providing the backbone”. Nuclear provides low-carbon, zero pollution and reliable power to help meet the needs of European citizens and industries. However, to be able to do so efficiently, effectively and at least cost to consumers, like renewables it also needs a predictable policy framework that sends clear signals to investors on the future role of nuclear, as an important part of the solution in the fight against climate change
We Call for an Evidence-based Assessment of Nuclear within the EU Taxonomy
The EU Technical Expert Group (TEG) on Taxonomy concluded that there is a clear evidence that nuclear substantially contributes to climate mitigation. Nevertheless, the TEG also concluded that at this point “the evidence about nuclear energy is complex and more difficult to evaluate in a taxonomy context” regarding the potential significant harm to other environmental objectives. It recommended that more extensive technical work be undertaken.
The debate around nuclear energy is often political. It is therefore essential that the assessment of the Do No Significant Harm (DNSH) issue for nuclear remains strictly technical, evidence-based and is conducted by qualified experts. It must not be conducted by those with political or ideological agendas.
Some anti-nuclear groups are already calling for the exclusion of nuclear from the list of sustainable activities under the Taxonomy. It is clear that most of the arguments being put forward are not based upon scientific evidence, Therefore, as scientists and researchers, we feel the need to clarify some of the statements used to discredit the nuclear sector:
Nuclear currently provides more than 47 % of the low-carbon electricity generation in the EU. Without nuclear, there will be half a billion tonnes of extra CO2 emissions every year in Europe, which is more than the emissions of the UK or France alone;
life cycle emissions produced by nuclear compare favourably with those from renewables technologies. According to the Intergovernmental Panel on Climate Change (IPCC) figures, with 12g of CO2/KWh, nuclear life-cycle emissions are equal to those of wind power and are four times lower than solar power. The IPCC analysis for nuclear includes the whole life cycle, including uranium mining, enrichment and fuel fabrication, plant construction, use, decommissioning and long-term waste management;
an analysis of recognised levelized cost of energy (LCOE) figures, clearly shows that nuclear energy is competitive with other low-carbon power sources.. Again, based on the IPCC figures, the LCOE of nuclear is on average half of solar or offshore wind and comparable to onshore wind;
moreover, the calculations do not consider the value of stable, reliable power supply. Nuclear power generation doesn´t rely on weather conditions and provides reliable power to industry, transport, hospitals, homes and businesses 24 hours a day/365 days a year. The current covid-19 crisis has provided clear evidence that it is in the time of a crisis when scarcity defines value. Ensuring reliable power should always remain an imperative during policymaking;
with a strong, positive regulatory framework in place, there is huge potential to decrease build time and cost of new nuclear projects. Recent projects on modernization and harmonization of nuclear supply chain have shown that streamlined requirements on vendors, combined with the benefits of series build, can rapidly increase the speed of new-builds while decreasing costs and maintaining safety;
nuclear can be flexible and does not undermine deployment of renewables. Recent findings by the Massachusetts Institute of Technology (MIT) have shown that operating nuclear plants flexibly can reduce overall electricity costs and cut carbon emissions in electric power systems. Developing and releasing the potential of the Small Modular Reactors (SMRs) can also contribute to making nuclear reactors more scalable and potentially decreasing costs and build time requirements;
flexible nuclear operation can help add more wind and solar to the grid. Nuclear and renewables should be partners in fighting climate change and it is sad that some anti-nuclear activists are building barriers and support the narrative of nuclear power undermining the deployment of renewables. The time for action to fight climate change is very tight and all low-carbon and clean technologies that can contribute to the fight against climate change must be allowed to contribute and be part of the solution;
nuclear power plants are protected against rising sea levels and flooding. The International Atomic Energy Agency (IAEA) global safety standards require operators to take account of risks arising from rising sea levels. It is also important that even in the worst case scenarios modelled by the IPCC, if sea levels rise one metre by 2100, the current nuclear fleet will be already decommissioned, and the new-build power plants can easily be adapted to any potential challenges when being designed and built;
both IAEA and EU regulatory framework ensure that nuclear power plants comply with the highest safety standards. The framework applies to the full nuclear life-cycle including the management of nuclear waste and ensures that nuclear waste is safely managed in the long-term. Interim storage solutions that are fully operational worldwide are licensed by competent authorities, comply with the highest safety regimes, are developed in a transparent manner and undergo strict environmental impact assessments;
at the same time, the nuclear industry in cooperation with regulators identify and, in some cases, already commence of deliver facilities to safely dispose nuclear waste in the long term. The European Commission has recently acknowledged that Finland, France and Sweden are advancing their solutions for long term storage of high-level waste.
Nuclear power is an important and established power source for European citizens and industries and is crucial for the stability of energy systems. The existing strict regulatory regime define the “Do No Significant Harm” principle for nuclear sector and guarantees that nuclear power plants are operated in a safe and sustainable manner, including their decommissioning and spent fuel management.
International bodies including the Intergovernmental Panel on Climate Change and the International Energy Agency acknowledge the role of nuclear in the fight against climate change and their analysis and conclusions provide compelling evidence that nuclear power is safe, competitive and sustainable. Also, the European Commission itself has recognized that nuclear power, together with renewables, should be the backbone of the climate neutral energy system.
For the reasons mentioned above, we call on the Commission to follow-up on the TEG Report and enable a “just” expert assessment of nuclear power with regard to the DNSH criteria. This assessment must be based on scientific evidence and should not be influenced by any political or ideological agenda. Fighting climate change is a matter of the highest urgency, all low-carbon energy sources must be allowed to contribute, and the final Taxonomy on Sustainable Finance must respect these points.
Czech Technical University
Faculty of Electrical Engineering, Czech Technical University in Prague
Faculty of Mechanical Engineering, Czech Technical University in Prague
Faculty of Nuclear Sciences and Physical Engineering, Czech Technical University
Brno University of Technology
Technical University of Ostrava
Technical University of Liberec
Institute of Technology and Business in České Budějovice
University of West Bohemia
Nuclear Research Institute
Research Centre Řež
Institute of Applied Mechanics Brno
Czech Nuclear Education Network
Czech Nuclear Society
Women in Nuclear Czech
South Bohemian Dads
Třebíč Energetic Region