Österreichisches Ökologie-Institut
ÖÖI
Das Österreichische Ökologie-Institut wurde im Jahr 1985 gegründet und ist seither eine der ersten unabhängigen Ansprechadressen für alle Fragen der nachhaltigen Entwicklung und des vorsorgenden Umweltschutzes.
ID: 631721594889-14
Lobbying Activity
Response to EU taxonomy - Review of the environmental delegated act
24 Nov 2025
We welcome the possibility to give our comments to the EU Taxonomy Climate Delegated Act with focus on the criteria for nuclear activities. Firstly, we want to clarify that nuclear energy is not sustainable due to a wide range of reasons (amongst others unsolved nuclear waste management especially for HLW and uranium tailings, severe adverse impacts in case of severe accidents), and nuclear is far from being best in class compared to renewable energies. We support Austrias legal appeal and would assume that nuclear energy will be excluded from the Taxonomy altogether. As taxonomy screening and DNSH criteria might also affect other sustainability debates, the criteria laid down now in Climate Delegation Act should not be weakened. In our view, a high degree of transparency is needed to ensure the compliance with these criteria. The fulfilment of all technical criteria should be comprehensible and verifiable for the public. Especially the criterion to prove that a HLW repository will be operable in 2050 needs clear rules: How shall this criterion be proven? We believe that the respective states must not only prove technological progress, but also a step-by-step timeline, realistically presented costs and credible and a verifiable funding scheme with updates in regular intervals. The last decades have shown that timelines for HLW repositories are much too optimistic, all states had to postpone their planned repository operation date. The National Programmes reported under the Nuclear Waste Directive do not provide enough information to enable an assessment of this 2050-criterion. The technical screening criteria refer in some sections of the Climate Delegation Act to the Directive 2011/70/Euratom; however, more than half of the member states have active infringement procedures for Failure to adopt a National Programme compliant with the requirements of the Radioactive Waste Directive. There is no further information publicly available on details of the non-compliance, but the non-compliance will probably affect the fulfilment of taxonomy technical criteria. Both transparency and consequences are missing here: more transparency of details on the non-compliance of the national waste management programs, and consequences of this non-compliance for the fulfilment of technical criteria of the Taxonomy. Clear rules on how to implement the nuclear-relevant parts of the Taxonomy need to be set up. This is also true for ongoing infringement procedures of other Directives like the BSS Directive 2013/59/Euratom. We consider clarification of activity 4.26. (Pre-commercial stages of advanced technologies to produce energy from nuclear processes with minimal waste from the fuel cycle) as inevitable. Assuming that reactor technologies usually referred to as SMR are meant, the term advanced should not include e. g. Light Water Reactors over 300 MWe which are neither small nor advanced. Increasing thermal loads from cooling for into surface water bodies need to be reduced. The respective criterion (Do-no-significant-harm for Sustainable use and protection of water and marine resources) should ensure that the primary objective of the Water Framework Directive to "prevent further deterioration and to protect and improve the status of aquatic ecosystems and the terrestrial ecosystems directly dependent on them" is met. Terms like best available technology, advanced technology and accident tolerant fuel need clarification. In activity 4.28 an obligatory Environmental Impact Assessment for lifetime extensions of NPP with reference to the Espoo Guidance on the applicability of the Convention to the lifetime extension of nuclear power plants (2021) should be included in the list of technical screening criteria, amongst others to assess environmental impacts from external natural and both intended and unintended man-made hazards and to enable effective public participation.
Read full responseResponse to Nuclear Illustrative Programme
12 May 2025
We welcome the opportunity to submit a statement before the PINC will be finalized and hope that our comments will be properly taken into account. We call for a realistic assessment of the role of nuclear power in the EU The number of NPPs in the EU is constantly decreasing. 100 reactors are in operation in 2025, while in 2017 (when the last PINC was published) there were still 125. Only 2 reactors started operation in the last two decades (after being built for 17 and 18 years). And the existing reactor fleet is ageing, the mean age in the EU in February 2025 was already 38.3 years most reactor design (https://www.worldnuclearreport.org/European-Union, seen 12 May 2025). The SMR designs that are on the wish list of some countries are neither licensed yet in the EU, nor are they modularly available. Nuclear power is on the decline, not only in the EU but also globally. We call for an effective climate policy New NPP will not contribute to climate protection as they take much too long to be in operation, they are too risky and cost too much in comparison to renewables. Saving energy, increasing energy efficiency and fostering energy policies without nuclear are more realistic pathways for decarbonization and energy security than putting hope in a nuclear renaissance. We call for more efforts in nuclear waste management Backend solutions for high radioactive waste are missing in all EU member states. No member state has a final repository for HLW in operation yet. All deep geological repository projects suffer delay, and most member states have not even started their planning. When assessing the implementation of the Nuclear Waste Directive 2011/70/Euratom in the member states, the EC concluded that []the transposition and implementation of the Directive in the Member States have not to date fully achieved the Directives objectives for all categories of radioactive waste. And: [] the targets set in some national programmes are not sufficiently ambitious and envisage long implementation periods that risk burdening future generations. Several Member States keep an option for shared disposal solutions with other countries. However, this may lead to deferral of decisions rather than acceleration especially because of import bans in numerous Member States. (COM(2024) 197 final). Long-term interim storage is the solution that remains when there are no final repositories available. But this option increases environmental risks due to ageing and outdated designs of interim storage facilities and casks; interim storages were not built for hundred years or longer. They will need proper environmental impact assessments when it comes to lifetime extension. Historic legacy radioactive waste including waste from uranium mines is not fully under the nuclear waste regimes of EU member states yet, but should be. The financing of upcoming costs for the backend management is not secured in most member states, leading to burdens for taxpayers. We call for putting more effort into security and independence from Russa The ageing European reactor fleet needs to undergo a stress test on the issue of security if they are able to withstand all types of terroristic acts and acts of war. Nuclear fuel which is currently advertised as entirely European by the French company Framatome to replace the VVER fuel delivered by Russian state company Rosatom, does not exist yet and most likely never will, because Framatome announced that the VVER fuel will be produced with a joint venture with Rosatom in Germany. This is not the way to achieve independency from Russia.
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