1. Economic activities that should remain out

  • Nuclear power was rightly excluded by the TEG as it significantly harms the taxonomy’s pollution prevention and circular economy objectives, due to long term impacts of nuclear waste with regards to the “do no significant harm principle”. The TEG report highlights the international consensus that a safe, long-term technical solution is still needed to address this problem.

  • Fossil fuels clearly operate on emissions that are far beyond the 100 gCO2/KWh threshold identified by the TEG. The TEG has correctly excluded them – and should in fact reduce the threshold. Midstream oil and gas should not be reincluded either.

  • Waste incineration undermines upper-tier activities of the waste hierarchy which are more protective of the climate. Indeed, as the circular economy is one of the taxonomy’s objectives, much of what is currently used as incinerator feedstock will have to be recycled or composted. By recognising the environmental impact and lock-in caused by incineration, the TEG recommendation is consistent with the hierarchy of the EU Waste Framework Directive.

 

  1. Economic activities to be removed from the EU sustainable taxonomy

  • Biofuels and biogas use in transport

Under the TEG’s proposals, trucks, coaches, and vessels that use liquid biofuels or biogas would be eligible. But such vehicles and vessels can also use fossil diesel or gas, so a truck could use advanced biofuels one day and diesel the next. As enforcement is impossible, the taxonomy should exclude trucks, coaches, and ships, and the related refuelling infrastructure, that can also run on fossil diesel or gas.

  • Livestock

We recommend to not include livestock activities in the taxonomy for the time being as it is difficult to assess livestock’s greenhouse gas emissions. The industry is highly carbon-intensive, emissive, polluting, and strongly linked to deforestation. In addition, there are major animal welfare and human health concerns. Including livestock risks slowing down the transition to a more sustainable, plant-based diet, as required in Paris-compliant climate scenarios. Organic livestock could exceptionally be included.

 

  1. Economic activities requiring tighter criteria

  • Bioenergy

The Commission should improve feedstock criteria by removing feedstocks which will increase emissions compared to fossil fuels – tree trunks, stumps, energy crops and so called ‘low indirect land-use change-risk’ food and feed crops – and fuels based on fossil carbon.

  • Forestry

Logging operations and forest management should not qualify if they reduce forests’ carbon sink function overall, thus harming the climate, or lead to irreversible forest degradation or biodiversity loss. Forest management should generally be adapted to the respective site/soil/forest conditions. We also need to protect natural forests against deforestation and degradation. The Commission should accordingly tighten forestry criteria.

  • Hydropower

The more than 20.000 dams in the EU are heavily disrupting freshwater ecosystems. Greenfield hydropower plants should therefore no longer be developed in Europe and there should instead be a refocus on retrofits. Outside Europe, the EU’s stringent standards should be followed.

  • Passenger cars and vans

The final TEG taxonomy report allows for vehicles with tailpipe emission intensity of 50 g CO2/km to be eligible until 2025. For full compliance with the EU’s 2050 targets, the threshold for this activity should be set at 0g of CO2/km.

  • Cross-cutting ‘do no significant harm’ criteria on biodiversity

The ‘do no significant harm’ criteria for infrastructure still need to be improved further, to ensure that risky infrastructure developments in any environmentally protected area or biodiversity hotspot cannot be taxonomy-eligible.