In 2018, the European Commission commissioned a Technical Expert Group (TEG) to compile a Taxonomy for sustainable investments. It is a technology neutral list of activities that can be, given certain adherence to environmental legislation and regulations, considered sustainable. Basically, it would be a go-to place for investors, funds, banks and others to easily check out how to fill their investment portfolio with sustainable investments, without heavy due-diligence done for each project separately.
Great idea! Facilitate more clean investments and help us get into a low-carbon society faster!
So how does it work?
First, an activity needs to support a sustainability objective, like help us mitigate climate change. Second, the activity must be regulated to “Do No Significant Harm”-standards (DNSH) on half a dozen environmental objectives. This is commendable, as we don’t want to “save” the environment somewhere and destroy it somewhere else. So, while some activity might provide us with low-carbon energy, it should not harm water resources, release harmful pollution or destroy ecosystems while doing so.
And how can we make sure this happens in the real life? By demanding that existing environmental regulations, laws and best practices are followed, and credible Environmental Impact Assessments are done. It’s simple really.
Regulation is enough, but not with nuclear?
The interesting topic here is nuclear energy. Is it included in the taxonomy as well? No, not in the first version that just came out [link]. And the reasoning behind that is both understandable and bizarre. Some people in the technical expert group seem to be worried about the potential for nuclear waste doing significant harm to some of the environmental objectives. That is understandable, as nuclear waste seems to be one of the issues people fear about nuclear energy.
But it is also bizarre, because the criteria for proving Do No Significant Harm are totally different for nuclear energy than for anything else. Suddenly, regulation, legislation, best practices and spotless track record of the industry managing their waste streams are brushed aside. Nuclear energy is the only industry for which existing regulation and legislation is dismissed. The potential for toxic substances being released in the manufacturing of solar panels is acknowledged, but it is also mitigated by following regulations. Why is this not enough for the nuclear sector?
Nuclear sector is basically the mother of Do No Significant Harm
In fact, nuclear energy’s whole lifecycle has been regulated to “Do No Harm”-standards for decades. And man, has it delivered. During the 60+ years of civilian nuclear in the EU, the waste it has produced has hurt nobody, and all that waste is safely contained and accounted for. Any nuclear operator not doing this would soon lose their licence.
And from an environmentalist’s point of view, that is great news! The nuclear industry is the only industry that takes full responsibility for ensuring that all of its operations across the full life cycle, including waste management protect people and nature from harm. The problem is that we now have an entire industry producing clean energy that has been underused due to our misunderstanding of its environmental benefits and potential. We can do so much more for climate, but we need to allow ourselves to do it.
Still, some people insist that there is a great uncertainty regarding the DNSH of nuclear energy. The uncertainty, according to these people, is so large that we should forget nuclear energy’s role in providing a third of global clean energy and half of Europe’s clean energy. We should forget that nuclear saves us hundreds of millions of tons, if not billions of tons, of co2 emissions each year, and thousands of lives in Europe alone by preventing air pollution. To dismiss all these benefits nuclear energy can offer us, one would expect solid evidence and reasoning to be presented to back the case. But there is practically none.
The Evidence Is Out There
The Taxonomy is technology neutral, and even according to EU law, these things should be treated equally and with a sense of proportion. But right now, that is not happening. Nuclear is being treated with a set of different rules. Mainstream evidence and science is being dismissed, while non-peer reviewed reports from publicly anti-nuclear organisations and people are being read and cited as “conflicting evidence.”
This is simply wrong. I have seen this exact same thing before in the climate debate, and before that in the tobacco health-effects debate, where the only goal of these deniers and vested interests is to sow doubt and keep the “debate” going. We don’t need any more of that. We don’t need ideologues pushing a political, anti-science agenda. We need policies that are based on mainstream evidence and scientific understanding.
To facilitate that, we pulled together a team, read the evidence regarding nuclear energy life cycle, and compiled it into a rather comprehensive report we call “Sustainable Nuclear – An Assessment of the Sustainability of Nuclear Power for the EU Taxonomy Consultation 2019.” (pdf)
We will be supplying it to the Technical Expert Group members and other stakeholders in the coming days, weeks and months. You can help by spreading the word and by leaving a comment on the public consultation[link]. Download the report from this link, read it (or the summary at least), and share.
 Yes, the difference between “Do No Harm” and “Do No Significant Harm” is significant.
 Depends what you compare it with. If IPCC median emissions are used and nuclear is compared to coal, the global fleet saved over 2 billion tons of CO2 in 2017.