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: 500628533851-72
Lobbying Activity
Response to Initiative on EU taxonomy - environmental objective
3 May 2023
Ich ersuche um Klärung, ob vorgesehen ist, für die Aktivitäten der COMMISSION DELEGATED REGULATION (EU) 2022/1214 of 9 March 2022 ebenfalls Bedingungen festzulegen, unter denen sie als substanzieller Beitrag zur Erreichung der vier Umweltziele (sustainable use and protection of water and marine resources, transition to a circular economy, pollution prevention and control, protection and restoration of biodiversity and ecosystems) angesehen werden können.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
18 Dec 2020
The most important fact why nuclear energy cannot fulfil the taxonomy goals is the unsolved problem of nuclear waste management in particular of the very long-lived high level waste (HLW). As of yet, no final repository for HLW such as spent fuel from nuclear reactors is in operation. The Finnish final repository, the only one under construction, is in limbo due to worrisome results of copper research experiments: This means that copper in a KBS-repository may corrode at much faster rates than acceptable and release radioactivity from the canisters already after only around 1,000 years of storage time. The issue of corrosion is now, in December 2020, still under investigation and far from certain and could derail the entire project in Sweden and Finland. The safety of future generations is at stake if a Final Repository is planned without the possibility to recover the nuclear waste. The preservation of knowledge, data and memory is another unsolved problem and it will require enormous and continuous resources, long after nuclear power production will have ceased – another clearly not sustainable aspect of nuclear energy.
In most countries, an assessment of environmental impacts of the nuclear waste management programmes is missing. This should have been done in a Strategic Environmental Assessment (SEA) for the national programmes, but most countries have not undertaken a SEA.
The EC Report on the implementation of the Nuclear Waste Directive from 2019 shows the general bad status of the Member States national nuclear waste management programmes. Without a clear concept how to deal with the nuclear waste progress cannot be expected soon. When financing, regulatory structures, inventory data and transparency regimes are not available or in a poor status, decades of improvement have to follow before a safe enough nuclear waste management programme can result.
Nuclear energy is inextricably intertwined with the risk of creating significant harm for humans and the environment: the risk of chronic illness due to a severe accident, of loosing agricultural areas due to severe contamination, disastrous social and economic impacts for people having to live in contaminated territories. These risks are by no way negligible, especially in the light of the study from Wheatley et al (2016) assessing a 50% chance that a severe accident occurs every 60-150 years.
A circular economy is characterized as an efficient use of resources followed by recycling or re-use; waste is minimized. None of this is true for the nuclear energy sector: from the very beginning, uranium mining, enormous amounts of all types of nuclear wastes are produced and have to be stored ad disposed of for up to a million years, despite efforts of reprocessing spent fuel, which is being abandoned. The nuclear chain cannot be a cycle.
In the Draft Delegated Act’s Annexes, for several energy technologies a level of 100 g CO2e/kWh is given. If the same level would be used for assessing nuclear energy, most recent data on CO2 from uranium have to be included to avoid underestimation of nuclear energy’s emissions – studies show that this 100 g level might be exceeded if using certain uranium sources.
Nuclear proliferation is often ignored because the debate usually centers on energy production. However, proliferation was brought back into the discussion by the authors of a task similar to the taxonomy effort, the 2018 IPCC report: “Nuclear energy, the share of which increases in most of the 1.5ºC-compatible pathways (…), can increase the risks of proliferation (SDG 16), have negative environmental effects.”
These facts show that nuclear energy has to be kept out of the taxonomy. We call upon the Commission to ensure that full participation for the public will be possible also for the Joint Research Centre Report on the nuclear question.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
27 Apr 2020
The TEG report was conducted in a concisive manner with a clear result - also concerning nuclear. The experts who prepared the TEG report concluded that they cannot see a sustainable way of managing nuclear waste. Since some member states and some industry representatives continue their efforts to have nuclear included at least as transition technology, we need to shine some light on some arguments, in particular nuclear waste management, where we share the TEG expert’s view that high level waste is incompatible with fulfilling the sustainability goals.
Nuclear waste remains unsolved – and it might stay that way:
After 60 years of commercial operation of nuclear power plants not a single final repository for spent fuel and other high level waste is working anywhere around the world. Here again, facts weigh more than arguing that experts agree that in theory a Deep Geological Repository might be best and R&D is almost there.
Another popular argument used by industry: The EU has strict rules on waste. However, it is an illusion to believe that the Nuclear Waste Directive 2011/70/Euratom solves all open questions. In its 2nd Report on the progress of implementation of the Nuclear Waste Directive the European Commission summarized that „[...] more needs to be done.”
Impacts of nuclear accidents affect the world forever:
While some would like to forget them as quickly, they are actually everyday business of the nuclear generation. The debris and molten core are still there, another enormously expensive shelter was recently installed, but the 1986 Chernobyl accident consequences continue being a threat for people and environment. The situation is far from safe, current forest fires threaten large parts of Europe with radioactive contamination. Also the 2011 Fukushima accident is still out of control, not even robots can work in this environment to start clean-up. The pollution of the environment is still everyday reality, currently the tanks on site will be emptied, because no other solutation seems to be viable. This water does not only contain the radioactive isotope Tritium, but also numerous other harmful radioactive isotopes.
Nuclear energy is not CO2-free:
Nuclear energy is definitely not CO2-free. Its CO2 emissions are only slightly higher than those of renewable energies like solar and wind – but only as long as the uranium ore grade is high. As uranium has to be produced from ore with a low grad, which will be the case within this century, CO2 emissions are going to rise significantly. The range seems to be differing widely, however, one of those few companies who ever mentioned this was e.g. EDF by stating that their fleet produces around 57 CO2eq/kWh currently.
Recommendations:
We agree with the assessment the TEG report arrived at and see no further need for another group of experts, a close look at the much-quoted 2018 IPCC 1.5 degrees report also refrained from recommending nuclear energy as a means to combat climate change. We would recommend the European Commission respects this assessment and does give in to nuclear industry’s call for the establishment of yet another expert group. Clearly the usual closed circle of pro-nuclear institutions such as IAEA, NEA etc. is meant who will copy-paste their reports into another format.
The Platform which is supposed to start work in autumn 2020 will be responsible for updating and extending the technical criteria. We demand that – in case nuclear energy is still on the agenda – also academics and other independent experts are included to avoid the “nuclear“ experts from hijacking this exercise.
Instead we hope that this EU policy initiative of defining a Green Taxonomy will stick to scientific evidence and simple reality and prepare a future without the threat of nuclear accidents and the production of ever more nuclear waste as a legacy to future generations.
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