Dear President von der Leyen,
Dear Executive Vice-Presidents Timmermans and Dombrovskis,
Dear Commissioner McGuinness,
31st March 2021
We, a group of scientists and environmental and consumer experts appointed to the EU
Commission’s Platform on Sustainable Finance, are writing to express the deep concern that we
and the organisations we represent feel about the contents of the draft climate Taxonomy
Delegated Act which was leaked last week, and the process through which it was significantly
and unacceptably weakened compared to the November version.
We believe the new draft’s provisions are in breach of the Taxonomy Regulation in
several instances,
particularly the definition of transitional activities in Article 10.2 and the
requirement in Article 19 that technical criteria be ‘based on conclusive scientific evidence’.
In particular, criteria for forestry, bioenergy, and fossil gas are in clear contradiction to
climate science.
These criteria are not simply weak: they are counter-productive and label as
“sustainable” activities that may cause significant harm to the climate and the environment. If
the leaked text for these sectors were adopted, the Taxonomy would become a greenwashing
tool instead of being the gold standard in the fight
against
greenwashing that it was promised to
be. Its roll out would be even more harmful to investors than the current situation, as they would
reasonably expect the taxonomy to have set high standards of sustainability. It would also
penalise sectors which are making real efforts to align with the Paris Agreement.
At a broader
level it would openly discredit the European Green Deal,
leading to significant reputational
damage for the EU.
The process to create the climate Taxonomy lasted for three years. It involved experts from
many industries, financial institutions, civil society and academia working in the Technical Expert
Group to develop technical screening criteria in line with science. This hard work has been
dismissed in a last-minute, opaque, politicised process. This politicised process is already
hampering progress within the Platform’s work on developing technical screening criteria for the
remaining four objectives. We are concerned that the time and effort we invest - pro-bono - in
developing science-based criteria could be undone by lobbying behind the scenes without the
same due attention, debate and evidence required in the Platform.
Hence, as demanded by
226 scientists, financial institutions and civil society groups,
fossil gas
must be removed from the EU science-based Taxonomy. Similarly, the current criteria
that classify forestry and bioenergy as “significantly contributing to climate mitigation”
have no scientific basis.
While the leaked draft shows widespread and unjustified watering
down of criteria, several of which had already been weakened compared to the TEG
recommendations, these three sectors represent a red line that would fatally and openly
undermine the entire taxonomy’s credibility.
We therefore urge the Commission to remove
forestry and bioenergy from the current Delegated Act, as done with agriculture, to give
more time to the discussion on land-based sectors in order to find adequate, credible