Posted on 13 January 2022

1. Politicised not scientific criteria. The EU Taxonomy contains a legal requirement which requires it to be based on 'conclusive scientific evidence'. The evidence on fossil gas is overwhelming: the International Energy Agency (IEA) has found that further investments in fossil gas are incompatible with the Paris Agreement, while the EU’s own experts have found that gas use must decline rapidly this decade. Yet the draft would potentially allow many new gas plants to be classed as sustainable. 

2. Special treatment for fossil gas. The increased thresholds for gas compared to renewables breach requirements for 'technological neutrality' and ‘equal treatment’ for activities in the same sector. In the first Delegated Act, all power sources must emit less than 100 g CO2/kWh over their lifetime, while in this proposal, gas-fired plants can emit up to 270 g CO2/kWh of direct emissions.

3. Promises, promises. The draft relies on the promise that gas plants will fully use ‘green’ gases by 2035, use carbon capture or run fewer hours a year over 20 years. The EU has previously allowed coal plants to be built with the promise that they would use ‘carbon capture’ technology in the future – a promise which entirely failed. If they fully rely on  ‘green’ gases in 2035, gas plants could be included in the Taxonomy at that point on the basis of ‘conclusive scientific evidence’ – not as from today as a blank check.

4. Fossil gas framed as ‘transitional activity’ – In order to prevent baseless transition claims, the Taxonomy regulation states in Article 10.2 that transitional activities are those for which there is no clean alternative and which do not lead to carbon lock-in. Gas does not satisfy these requirements as there are massive alternatives: in 2020 renewables like wind and solar represented 80% of new power generation globally according to the IEA..

5. Stranded assets or carbon ‘lock-in’? A bad choice to have to make. Greenwashing these criteria will create either stranded assets – activities which must be shut down early and at a loss – or carbon lock-in – tying the EU into dirty investments for decades.

6. No need for solutions to radioactive waste. In 70 years of commercial operation, tens of thousands of tonnes of radioactive waste have not yet been stored conclusively. However, the EU’s draft greenwashes nuclear as a long-term promise is made to create a plan to store this radioactive waste by 2050. This is not conclusive scientific evidence. 

7. New nuclear for the climate transition. The draft states new nuclear plants until 2045 are green. The EU must reach a zero-carbon electricity sector by 2035 - in thirteen years. However, according to the IPCC, nuclear power plants decided on today could take up to 19 years to be commissioned - on top of which, construction times must be added. France has announced six new reactors which are scheduled, in a best-case scenario, to begin operating in 2040 only. This is too late for the climate transition for electricity.
 
8. ‘Fake green’ bonds – The global green bond market excludes fossil gas and nuclear power. The EU taxonomy would do worse than what the market is already doing.

9. Green finance laggards. The Chinese taxonomy excluded gas-fired power in April 2021 and the South Korean taxonomy excluded nuclear in December 2021. The EU taxonomy would lag behind. 

10. Behind closed doors. Unlike the first ‘chapter’ of the Taxonomy on renewables, the gas and nuclear chapter was written behind closed doors without first consulting the Platform on Sustainable Finance – the experts appointed to advise the EU on the Taxonomy – or giving citizens the chance to provide their opinion through a public consultation. The draft was published at 22.00 on the 31st of December, leaving the EU open to accusations of trying to hide this controversial proposal.