Feedback to EU Taxonomy criteria on climate change adaptation & mitigation

ShareAction has provided feedback to the EU Taxonomy draft Delegated Acts on the Technical Screening Criteria for climate change adaptation and mitigation.

Please find our full response in the document attached.

The EU Taxonomy has been hailed globally as a milestone in creating the much-needed tools for financing the transition to a low-carbon economy. For this tool to effectively facilitate reaching the EU emission reduction targets and commitments under the European Climate Law to meet climate-neutrality by 2050, it needs to fully endorse the ambition of the Technical Expert Group’s (TEG) recommendations, if not going even further.

Our key recommendations concern the following areas:
– Maintain the proposed climate change mitigation criteria for electricity generation of 100g CO2/kWh to effectively exclude natural gas without abatement (CCSU)
– Exclude the burning of all forest biomass for energy as well as reverse the inclusion of all bioenergy feedstocks with higher lifecycle emissions compared to fossil-fuels
– Explicitly exclude hydrogen produced with non-renewable power
– Reconsider the inclusion of activities such as short-term forestry rotation, livestock and small hydropower
– The inclusion of sea and coastal water transport should be conditional on the examination by the Platform on Sustainable Finance
– Exclude the burning of refuse-derived fuel (RDF) in cement plants, as recommended by the TEG

We have also supported a civil society joint-statement on the draft Delegated Acts, which is available here.