Ms. Ursula von der Leyen, President of the European Commission
Mr. Frans Timmermans, Commission VP for the European Green Deal
Mr. Valdis Dombrovskis, Commission VP for an Economy for People
Ms. Mairead McGuinness, Commissioner for Financial Services and Markets
Ms. Kadri Simson, Commissioner for Energy
Mr. Thierry Breton, Commissioner for Internal Market
Dear Madam, Dear Sir,
On behalf of RePlanet NL, an NGO dedicated to advocating science-based solutions to environmental and economic development challenges, and of the undersigned like-minded groups and individuals, we hereby offer for your information our critical review of the leaked draft of the Delegated Regulation Sustainable Finance Taxonomy.
The European Commission commissioned a thorough review of nuclear energy by the Joint Research Centre (JRC). The result is an almost 400-page report on the topic. The analyses did not reveal any science-based evidence that nuclear energy does more harm to human health or to the environment than other electricity production technologies already included in the Taxonomy as activities. In addition, the JRC found that storage of spent fuel in deep geologic formations is ‘appropriate and safe’, citing countries including France and Finland in advanced stages of developing such sites.
The JRC compared the environmental impacts of various electricity generation technologies on human health and the environment, and found that:
Average lifecycle GHG emissions determined for electricity production from nuclear are comparable to the values characteristic to hydropower and wind.
Nuclear energy has very low NOx (nitrogen oxides), SO2 (sulphur dioxide), PM (particulate matter) and NMVOC (non-methane volatile organic compounds) emissions. The values are comparable to or better than the corresponding emissions from the solar PV and wind energy chains.
With regard to acidification and eutrophication potentials, nuclear energy is also comparable to or better than solar PV and wind.
The same is true for freshwater and marine eco-toxicity; ozone depletion and POCP (photochemical oxidant creation potential).
Land occupation of nuclear energy generation is about the same as for an equivalent capacity gas-fired power plant, but significantly smaller than wind or solar PV.
The conclusion could not be clearer. Nuclear is as sustainable as any other activity already included in the Taxonomy, or even more so. Based on this evidence, nuclear energy should be included in the EU Sustainable Finance Taxonomy.
We consider it crucial for Europeans and indeed the world that the Taxonomy is amended to efficiently and effectively encourage the role civilian nuclear energy technology can and must play for sustainable development.
At the same time, we consider it important that the use of fossil fuels is clearly constrained in scale and time to ensure a safe, predictable and comprehensive fossil fuel phaseout in Europe and – ultimately – the rest of the world.
We are aware of the political complexity of the Taxonomy but we know that you care as much about our common future as anyone and that you will do everything you can to make sure the Taxonomy works to support sustainable development. Our review is intended to help you argue your case.
Olguita Oudendijk, LLM (Director, RePlanet NL)
Joris van Dorp, MSc (Advisor, RePlanet NL)
Michael Shellenberger (President, Environmental Progress)
Mathijs Beckers (Chairman, e-Lisa Foundation)
Kristy Gogan (TerraPraxis)
Michel Simon (General Secretary, PNC-France)
Gijs Zwartsenberg (Chairman, Thorium MSR Foundation)
Eric Meyer (Executive Director, Generation Atomic)