The letter was sent to the ambassadors prior to the MESG meeting of 25 November where the recently issued draft delegated acts on climate change mitigation and adaptation were discussed. The purpose of the letter was to express a number of significant concerns in relation to the acts. The other companies and associations that signed the letter are Uniper, Vattenfall, Finnish Energy and Swedenergy.
The signatories firmly support the objective of climate-neutrality by 2050, as well as a sound framework aimed at channelling the investments needed to implement the ambitious EU climate targets in line with the Paris Agreement.
In Fortum, we believe that transforming the European economy into a climate-neutral economy requires an approach that relies on a complementarity of energy technologies, ranging from all renewable sources (wind, solar, hydropower, biomass, geothermal, etc.), nuclear (where it exists), energy storage, and clean gases to carbon-negative technologies. The EU decarbonisation process should be founded on a market-based and climate-oriented policy, following strong carbon pricing, competition amongst climate-neutral technologies and a well-calibrated CO2 threshold.
Whilst well intended, the signatories are most worried that the EU taxonomy could provide unintended effects that undermine national decarbonisation efforts. Our main concern is that the detailed criteria are defined in a non-objective and discriminatory way, thus leading to an arbitrary selection of the desired technologies and undermining the trust in a most essential element of the European green deal and recovery.
This would be the case if the delegated acts were to exclude more than 40% of existing CO2-free power technologies in the EU net electricity generation mix. Such an outcome would also go beyond the powers conferred to the Commission by the EU Treaty, as delegated acts are intended only to "supplement or amend no essential parts of EU legislative acts". Furthermore, this could also significantly affect member states in their freedom to conduct decarbonisation strategies and identify the needed climate-neutral power mix.