top of page
  • Writer's pictureGeoff Russell

EU Sustainability Taxonomy ... why allow solar PV?

Updated: Jan 19, 2023

The EU sustainable development rules are in the news again. I wrote about them back in January, but there have been some developments. Here's a quick recap on what's happening; based on the 2020 EU Regulation and the new additional detail contained in the June 2022 Supplement.


The EU is ready to aim a fire-hose attached to a multi-trillion dollar cash dam at any projects which might help it meet the Paris climate targets, but any wannabe project will need to comply with a raft of regulations.

In addition, they will also have to do "no significant harm"; meaning they must not adversely impact the other four environmental goals of the EU's sustainable investment goals of the 2020 Regulation:

  1. sustainable use and protection of water and marine resources,

  2. transition to a circular economy,

  3. pollution prevention control, and

  4. protection and restoration of biodiversity and ecosystems

Germans pushing for gas over nuclear

The Australian Financial Review reported back in January that the Germans were pushing for gas to receive funding and for nuclear power to be excluded:

The German government’s letter to the European Commission, sent just before the Friday deadline, opposed classifying nuclear as sustainable but supported the concept of gas as “a bridging solution”.

The Germans didn't manage to exclude nuclear, but they were abundantly successful in getting gas accepted. The 2022 Supplement is very particularly crafted not to optimise climate change mitigation, but instead to shower largesse on the gas industry.

In the most recent EU regulatory machinations, a motion was put up to disconnect both nuclear and gas from the cash pipeline; but the motion failed by 278 to 328 with 33 abstentions.

The German problem is, of course that they are far more anti-nuclear than they are pro-climate. They don't even mind killing their own citizens in their anti-nuclear zeal with some 9,000 additional premature deaths over the past decade as a result of added fossil fuel pollution as they burn these in preference to running their nuclear reactors. Having closed most of their nuclear plants the Germans are finding, surprise, surprise, that they are dependent on gas; much to the delight of Vladimir Putin ... he can either take German money for his gas, which he's been doing in large quantities or punish them by cutting it off. Either way, Putin is laughing and Ukrainians are dying.

The other problem for the Germans is that the Joint Research Centre (JRC) report on nuclear power, commissioned a couple of years back by the European Commission, and completed in 2021 didn't find what they probably expected. More on that later.

Adaptation and mitigation

The new 2022 Supplement consists mainly of two big annexes, one for "mitigation" projects and one for "adaptation" projects. I dare say that the size of the cash shower nozzle will vary according to which of these categories your project falls.

The magic number for "mitigation" is 100 grams of CO2-eq/kWh while the magic number for "adaptation" is 270 grams of CO2-eq/kWh.

These magic numbers are embedded wherever a quantification is needed on the greenhouse gas emissions of a project. If you want to make "mitigation" aluminium, then you need to get the associated emissions below 100 g-Co2eq/kWh for the electricity you use. If your aluminium is "adaptation" aluminium then the figure is 270 g-Co2eq/kWh. Similarly if you are making electricity for distribution.

Given that nuclear power can supply electricity for (less than) 28 g-Co2eq/kWh , then why not use that as the magic number for mitigation projects? Because that would exclude solar PV and the flaming forests of Germany; not to mention Russian gas.

Circular economy goals in the EU regulations

It's worth commenting on this "goal" in passing.

Recycling metals makes sense; recycled copper or aluminium is identical to the original and typically requires less energy during production than extracting the metals from newly mined ore. But any recycling process has to be driven by energy so it's not as if you get back to the state you started in. Suppose a metal is used in a process where it is tightly bound, sparsely distributed and very expensive to reuse. Consider nails in fenceposts. Does it really make sense to drive around old fencelines and extract the nails? I suspect not; especially in a petrol powered vehicle. Even in an EV, you have to consider the pollution from brakepads and tires as a cost of the recycling; in addition to the energy in making the vehicle.

For non-metals, the problems are even more complex. For many essential parts of a decarbonised future; the concept of a circular economy is simply bizarre. How is burning wood for electricity, much beloved by the Germans and the British, consistent with a circular economy? And what about hydroelectricity? Restoring a river system after it's been dammed isn't returning it to its original state. And what about plastics? We will need to make them from plant based carbon rather than oil based carbon, but when we've finished with them, the best thing to do with them may well be to send them to land-fill ... which, when done properly is actually just carbon sequestration (a good thing!). This is probably better than using additional energy recycling them. But the devil will be in the details ... with some plastics, recycling will minimise climate impacts, but with others, burying will win out.

A science based approach to resource use would be framed as a mathematical minimisation problem; a set of equations rather than a slogan.

Does a circular economy minimise waste and maximise the land available for maintaining biodiversity? That will depend on details. The EU regulations have elevated the circular economy slogan way above its level of usefulness; which wasn't high to begin with.

At a guess, I suspect that the only reason for including the circular economy goal was that somebody thought it would spell the death knell for nuclear. Such people would have been really annoyed at the environmental findings of the JRC report on nuclear.

Here are the key environmental findings of the JRC report, based on its assessment of published studies, and with respect to head-to-head comparisons of the full life cycle impacts of nuclear with those of wind and solar power.

Nuclear power:

  • has much lower life cycle CO2eq emissions than solar PV. Nuclear's life-cycle emissions are similar to wind except that nuclear doesn't require batteries or additional transmission infrastructure. Emissions for nuclear were put at 28 grams-CO2eq/kWh compared to 85 grams-CO2eq/kWh for solar PV and 25 for wind. The range of emissions among studies was particularly large for solar PV, probably reflecting the large input of coal in production processes in China; which dominates PV supply chains.

  • produces less nitrous oxide and sulphur dioxide than solar PV

  • caused less acidification than either wind or solar in all studies

  • caused less eutrophication than wind or solar in 3 of 4 studies

  • caused less marine ecotoxicity than wind or solar in all studies

  • caused less freshwater ecotoxicity than wind in 2 of 3 studies

  • used a tiny fraction of the abiotic (metals and minerals) resources used by wind and solar in all studies

  • used far less land than solar in all studies and less than wind in 3 of 4 studies

  • produced a small fraction of the chemical waste produced by wind and solar

  • produced less NMVOC and PM2.5 pollution than wind or solar

  • produced less ozone depletion potential than solar in 2 of 2 studies and less than wind in 1 of 2 studies ... in the other study wind and nuclear were equal

  • produced less human toxicity potential in 3 of 4 studies

  • had fewer human health and mortality impacts in the only study to compare the three and were very low in the other 3 studies ... which didn't consider wind or solar

  • produced less total ecotoxicity than wind or solar in 3 of 3 studies

None of this would be a surprise to anybody paying attention to the literature. Clearly, those who thought a report was required haven't been paying attention.

Here's a more recent life cycle analysis and comparison of various electricity technologies; it is from the European Economic Commission and it is more detailed and recent than the JRC report. You can see that it has a lower emission figure for nuclear and on-shore wind but a similar figure for solar PV. Most importantly, it has additional breakdowns for emissions from PV thin film technologies; which are much better than the market leader based on silicon.

In 2017, the latest year available when the JRC report was commissioned, nuclear produced 25% of EU electricity, compared to 21% from non-hydro renewables (some of which are definitely not clean ... like burning forests). Pretty obviously, closing these reactors and not building new ones would make getting to net-zero by 2050 impossible.

If that's not obvious, then please consider this graph of energy sources and observe how little wind and solar power have been built over the past 20 years and how much is still to be done. The graph is of global energy, but the implications for the EU are still clear.

Why stop at one report?

The obvious implication of the report's findings is that there needs to be, at least, an additional special report by JRC ... into whether silicon solar PV technology should be allowed to shower under the EU cash stream. It is clearly inferior in all respects to both nuclear and wind.

Anybody with a passing familiarity with life-cycle analyses (LCA) on energy sources knows that silicon solar PV has a higher carbon footprint than nuclear power. Anybody with a reasonable understanding of the land requirements of solar farms would suspect that harm to the protection and restoration of biodiversity and ecosystems was clearly much greater with solar PV than with nuclear. Whether such damage was "significant" would seem to be a valid question. So why didn't the EU Commission ask for a report on solar PV?

Given that wind farms kill birds and bats in considerable numbers why didn't the EU Commission ask for a report into whether those wildlife impacts constitute "significant harm"?

EU Commission hypocrisy: what about food?

As I've pointed out in other posts, dietary change features prominently as a climate change mitigation strategy in the most recent IPCC report (AR6 WG3). It's worth repeating a key fact (p.12-74):

... even if fossil fuel emissions were eliminated immediately, food system emissions alone would jeopardize the achievement of the 1.5 degrees C target and threaten the 2 degrees C target.

But dietary change as a project category is entirely missing in the EU Regulation and its Supplement. Why?

The Supplement mentions that it is deferring agricultural project technical screening issues in view of the Common Agricultural Policy negotiations in the EU. But that's irrelevant for projects concerned with changing consumer habits; which are demand-side activities needing policy assistance and direct financial help. Why does the European Commission refuse to consider demand-side action on food? They are happy to consider demand-side action in the use of electricity; so why not food?

But back to that nuclear report

I've presented the key environmental findings of the JRC above, but there is plenty else worth commenting on in the report.

The findings above show that the environmental footprint of nuclear is pretty close to being Pareto optimal, meaning it is lower in almost all respects than any other energy generation technology. And that's before we factor in the battery material mining and the vast expansion of transmission networks required to compensate for renewable wind intermittency and the total failure of solar power every evening.

But that won't influence people worried about radiation risks associated with nuclear accidents and waste. Many people will dismiss the JRC report arguing that waste is a show stopper as is the risk of "catastrophic" accidents. I've written recently about the nuclear waste problem. It's big and real, but perhaps not what you'd think ... please read.

Dealing with nuclear fear: consult the experts, but get the right kind

Unfortunately, the EU JRC nuclear report was written by the wrong kind of experts to deal with the kind of concerns that prompted its commissioning.

Radiation is a Class 1 carcinogen; meaning it can cause cancer and that's the thing that worries and misleads people.

The EU's report should, at the very least, have had an Annex written by oncologists and epidemiologists. These are the people who can put the risks associated with radiation exposures into context alongside the really big cancer risks associated with lifestyle choices.

Nuclear industry radiation experts have failed spectacularly over the past 30 years in communicating the relative size, range and nature of radiation risks. For the general public they are truly trivial. But the only way to understand risks is by using comparisons with things people understand; or at least think they understand. Industry experts seem allergic to this task and prefer arcane and irrelevant numbers and discussions. This is particularly true of the JRC report.

The report's use of irrelevant concepts like "man Sievert" (aka collective effective dose) is typical. It isn't the politically incorrect language that bothers me. "Person-Sievert" is no better than "man-Sievert". This rose would be useless by any other name. It is simply an irrelevant unit for discussing risk. As far back as 2007, the International Commission on Radiological Protection advised:

Collective effective dose [man-Sievert] is not intended as a tool for epidemiological risk assessment, and it is inappropriate to use it in risk projections.

If such measures aren't useful for risk assessment, then what are they good for? Definitely nothing at all if you aren't talking to other experts and probably nothing at all if you are.

The problem is that normal people hear these things and think you are talking about risk when you aren't. They hear something like "A million man-Sieverts!" and are unsurprisingly terrifyied.

Any explanation of nuclear risk should probably start by explaining that being a Class 1 carcinogen says nothing about the size of any associated risk.

Let's do it.

Falling off a ladder can kill you. Calling ladder falls a "Class 1" killer doesn't imply that ladder falls always kill, only that the causal relationship between a death following a ladder fall is clear. Similarly, processed meat is a Class 1 carcinogen. It can definitely cause bowel cancer (among other things) but mostly doesn't. Why not? Because the DNA damage caused by every mouthful you eat is almost always repaired. It's not quite like a ladder fall in that any particular bowel cancer might have had some other cause; like an inherited gene mutation which reduced the quality of your DNA repair mechanisms. Radiation, like processed meat, is also a Class 1 carcinogen, it can cause cancer, but mostly doesn't. And even when it does, it can be hard (usually impossible) to know that it was radiation and not something else that was the culprit.

With red meat, you can collect bowel cells from your feces after a meal and they have the exact same kind of damage as you can find in tumors of bowel cancer patients. The mechanisms are increasingly well understood.

But ... knowing that radiation and bacon are Class 1 carcinogens tells you nothing about which is more dangerous at relevant exposure levels and rates.

Consider the following graph of the wave of bowel cancer in Japan after red and processed meat intake dramatically increased during the 1960s. It's very similar to the lung cancer wave that occurred in the US (and elsewhere) after the introduction of tobacco; and as with that wave, the bowel cancer wave lagged behind the behaviour change by about 15-20 years. Cancers take time to grow and get noticed. Processed meat is a Class 1 carcinogen and red meat is a Class 2A carcinogen. The 2A means "probable" but not certain. The World Cancer Research Fund recommends that red meat should be limited, while processed meat should be avoided totally. In Japan, following the dietary change, bowel cancer went from being relatively rare ... 20,000 cases a year ... to depressingly common. The 20,000 cases are mostly from genetic mutations that a few percent of people inherit.

These graphs are from a 2006 study and the growth rates past that time are predictions. The predictions were pretty good; in 2020, Japan had 148,000 cases of bowel cancer. 20,000 to 148,000 ... that's a serious jump in risk!

Did the Chernobyl accident in 1986 produce a wave of cancers like this? Despite vast areas of radioactive contamination, there were only a few thousand (treatable) thyroid cancers spread over the past 35 years ... ie., the answer is a definite no. Will the Fukushima meltdowns produce this kind of wave? No. You could have Chernobyl-sized accidents annually and never produce cancer waves like this. These are the kind of relevant comparisons that are totally missing in the EU commissioned report; instead there is complicated but useless talk using obsolete and meaningless jargon.

People are making decisions about nuclear risk based on the wrong kinds of comparisons. You need to think about radiation risks compared to the big lifestyle causes of cancer; red and processed meat, obesity, inactivity, alcohol and tobacco. The JRC report's discussion of radiation risk is simply irrelevant.

In Japan, billions of dollars have been spent collecting good topsoil into black plastic bags despite that soil being less radioactive than some well-known tourist beaches of Brazil.

Areas of Kerala in India where people have lived, with extremely low cancer rates, for thousands of years, are also in the category. What drove, and continues to drive, the Japanese response to Fukushima was an irrational fear based on mythology, not science and an up-to-date understanding of cancer and DNA biology. The Japanese reaction was the logical outcome of decades of nuclear industry incompetence in explaining risks in a way people can understand. As with the Germans, the Japanese killed people to protect them from things which were never going to hurt them.

The deadly Japanese response to the Fukushima meltdowns was also the logical outcome of the ALARA doctrine. "As Low As Reasonably Achievable" is a doctrine that determines radiation levels in the nuclear industry. It is mentioned many times in the JRC report. It's presented as a good thing! But to normal people, it screams "danger". If radiation is so dangerous that you must get it as low as possible, then it must be terribly dangerous. But it isn't. Far more dangerous carcinogens are on sale in bars and supermarkets.

The nuclear industry has been shooting itself in the head, the foot and every limb for decades instead of fighting fear with robust rationality. When people hear "radiation limit of X mSv" per year, they presume that this is a safety limit ... what else could it be? That's what "limit" means to most people. Actual safety limits for radiation would be vastly greater than today's ALARA fear-inducing fictions. The IAEA knows what reasonable limits are. It uses them in its perfectly reasonable emergency guidelines. Those guidelines were ignored in Japan after Fukushima because the industry has been incompetent for 30 years in selling itself as what it is; simply better, cleaner, and greener.

Getting rid of ALARA and everything it entails and replacing them with sensible risk-based limits should be an urgent priority for the nuclear industry. Among other things, it will make reactors cheaper and faster to build.

In Conclusion

The two annexes of the regulations have been carefully crafted to keep solar PV and gas in the game; the 100 gram limit allows cash to be funnelled to solar PV under the mitigation annex while the 270 gram limit will see funds flowing to gas under the adaptation rules.

Solar and wind have both been allowed to avoid their uncosted externalities; meaning there has been no attempt to look at the system-wide emissions when you include the additional transmission and storage requirements. Comparing a dispatchable electricity and heat source like nuclear with one that needs a whole lot of hand-holding to be useful is simply dishonest. Given the 85 gram emission median for solar PV in the JRC report, it looks highly likely that silicon solar projects, at least, would fail the 100 gram limit if these uncosted externalities were included.



bottom of page