MINISTER
MINISTRY OF ECONOMIC AFFAIRS AND CLIMATE POLICY

Ms. Mairead McGuinness
Member of the European Commission

The Hague, 19 May 2022
22204446

Dear Commissioner,
The EU taxonomy can serve as the gold standard in guiding the
reallocation of capita] from fossil fuel activities to sustainable
activities. The Dutch government considers two principles of key
importance. First, the taxonomy should be technology-neutral.
Second, the taxonomy should be based on scientific evidence. I would
therefore cal) your attention to the following.
The Dutch government is not satisfied with the inclusion of natural
gas in the Complementary Climate Delegated Act as this is not in line
with these principles. Natural gas is not subject to the same
standards as set for other energy carriers in the taxonomy. Moreover,
the Platform on Sustainable Finance stated, with reference to reports
of the IEA and IPCC, that the inclusion of natural gas, even under the
proposed criteria, is largely incompatible with the path towards a
maximum of 1.5 degrees of global warming. The Dutch government
therefore takes the view that natural gas should be considered only
as a transitional activity in an 'amber' category in a general
taxonomy, and not as sustainable in a green taxonomy.
The Dutch government is satisfied that the inclusion of nuclear
energy in the taxonomy is based on a comprehensive and
independent process of scientific evaluation and therefore welcomes
it. However, two major concerns with respect to the criteria remain
unaddressed. First, the requirement that accident tolerant fuel must
be used as of 2025. This is problematic because this type of fuel is
not well defined, it is currently unavailable and its effectiveness has
not yet been proven. Second, the requirement to operate a disposal
facility for high-level radioactive waste as of 2050 is unnecessarily

MINISTER
MINISTRY OF ECONOMIC AFFAIRS AND CLIMATE POLICY

burdensome and fails to take into account national differences in
nuclear waste policies. In short, if the Netherlands were to operate a
disposal facility by 2050, instead of 2130 as envisioned under current
policies, this would result in at least € 2 billion in additional costs in
the short term without any benefits for the climate, the environment
or security. Furthermore, it is unlikely that the full process of public
consultation, site selection, construction and operationalisation can
be completed by 2050.
On 21 January 2022, we provided technical feedback on the draft
Complementary Delegated Act to explain our position. We have
shared this feedback with the Dutch parliament. The Netherlands is
disappointed to note that our feedback has not resulted in
amendments to these criteria in the Complementary Delegated Act.
Given the inclusion of nuclear energy in the taxonomy and the
assessment that there is sufficient support in the Council for the
Complementary Delegated Act, the Dutch government decided not to
object to the act. Nonetheless, we stand by our criticism concerning
the inclusion of natura! gas and the aforementioned two specific
concerns regarding nuclear energy.
The Taxonomy Regulation requires the technical screening criteria to
be revised every three years. Accordingly, the Dutch government will
remain a vocal advocate for allocating natura! gas to an 'amber'
category in a genera! taxonomy, and for aligning the requirements for
nuclear waste management with the Dutch system. Moreover, the
Dutch government wilt remain vigilant on whether future delegated
acts adhere to the principles of a scientific basis and technological
neutrality. For now, the Dutch government calls on the Commission
to provide further elaboration and clarification on the interpretation of
the criterion of accident tolerant fuels.
Yours sincerely,

Rob Jetten
Minister for Climate and Energy Policy

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