The Romanian Atomic Forum (Romatom) sent to the European Commission its position on public consultation on the subject of sustainable financing - EU classification system for ecological investments - The delegated regulation of the Commission on a taxonomy of mitigation and adaptation to the climatic changes - the roadmap
The Romanian Atomic Forum (Romatom) welcomes the intention of the Commission to allow EU citizens and interested parties to provide feedback for the development of the first two delegated acts under the taxonity regulation, first to establish the economic activities and the technical screening criteria, with an emphasis on the attenuation and adaptation of the climatic changes, based on the recommendations of the group of technical experts for sustainable financing (TEG) and the second which establishes the appropriate activities and the technical criteria of screening associated with the other environmental objectives defined by the regulation.The assessment of the initial impact, which is the subject of this consultation underlines "Lack of clarity on economic activities that can be considered sustainable for the environment for investment purposes”.
Regarding the "final report of the Group of Technical Experts for Sustainable Finance", March 2020 and the related technical annex, indeed, is recognized "The substantial contribution of nuclear energy to the climate reduction objectives ”, as well as the fact that this statement "It is well documented”, Citing the IAEA 2018 and IPCC 2014 reports, to which IPCC 2018 report is to be added. We draw attention to the fact that these reports, as well as other recent analyzes elaborated by OECD / AIE or WEC, consider the entire nuclear cycle, without focusing exclusively on the electricity production phase.
But, we must draw attention to important topics on nuclear energy, which are not completed by the TEG experts, due to the limitations they have encountered in the understanding and evaluation of the whole "nuclear cycle”.
We completely agree that it is not advisable to analyze the role of nuclear energy in climate change "while [this] does not produce a significant harm to any of the other EU environmental goals, Without "Extensive technical analyzes regarding aspects without bringing significant damages (do not signify Harm - DNSH) brought by nuclear energy in the future, by a group with in -depth technical expertise on the technologies of the nuclear life cycle”, As recommended by the TEG report.
Unfortunately, this recommendation is not something new, being found in the initial phase of the July 2019 TEG report, finding that so far the Commission has had no initiative in this regard.More than a month has passed since the final form of the TEG report is published and there is still no clarity regarding the establishment of the expert group mentioned above.But this is not the only weakness of the TEG report, the substantial reference in the drafting of the delegated acts mentioned above and which puts the nuclear energy in an inequitable position compared to the other sources with reduced carbon emissions.
Being firmly convinced that "renewable energy production technologies together with nuclear energy will be the spine of a carbon -free European energy system", during a carbon -free economy in 2050, we make the following recommendations, to have a fair process in defining the DNNSH aspects for nuclear energy in relation to other technologies:
- As the taxonomy regulation incorporates the principle of technology neutrality and given that TEG has not treated all technologies in the same way, we do not believe that this principle has been met.For example, the TEG report recommends that certain renewable technologies be exempted from a Life Cycle of Emissions -LCE).We do not believe that such exemption is justified only for certain technologies. Therefore, the delegated act should first identify the criteria and then apply them equally to all technologies.
- The regulation on taxonomy does not currently exclude specific technologies with low carbon emissions, which indicates that they should be evaluated according to the developed criteria. Given that these criteria have not yet been elaborated under the delegated act, it would be premature to promote the opinion of the TEGs according to which the nucleaera energy should not be included at this stage.
- To ensure a solid scientific approach to taxonomy, It is urgent as the independent group of experts, having in -depth knowledge of the nuclear life cycle to be created and become operational, to evaluate this problem, as TEG recommends.
Today, Romania has a significant energy production based on fossil fuels, with a visible share of coal.The ambition to replace these fossil sources exclusively with renewable sources, during the decarbonization until 2050, without maintaining the existing nuclear fleet, prolonging its life and further developing it through new nuclear units, is not realistic, even under the conditions of an increase of the interconnections.Nuclear energy for Romania contributes about 33% of the total clean energy produced, provides 12,000 jobs and contributes with 5.7 billion euros (see the report "The economic and social impact”, Deloitte 2019, EU27 + Great Britain). Therefore, the nuclear industry in Romania, most being members of the Romanian Atomic Forum, requests the European institutions unequivocally reconsidering its role to achieve a clean environment, prosperity and increased energy security.
About Romatom: Established on January 10, 2001 by 14 private or state companies, as well as two non-governmental associations.Currently, Romatom has over 30 members, totaling a total of over 250 employees.The association aims to promote the peaceful use of nuclear energy in Romania and to support the national nuclear program, as well
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E-mail: romatom.secretary@gmail.com
