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Future generations, participative decision-making, proliferation, uranium mining – extract from Expert response to pro nuclear JRC Report

Consideration of participative decision-making in societies in the JRC Report The involvement of stakeholders is greatly oversimplified in the JRC Report and is described in very optimistic terms. For example, NGOs are not considered in the description of interest groups and their role in developing a programme for deep geological repository sites

The effects on indigenous peoples, on whose land most of the uranium mines are located, is not mentioned in the report,

Expert response to the report by the Joint Research Centre entitled “Technical assessment of nuclear energy with respect to the ‛Do No Significant Harm’ criteria in Regulation (EU) 2020/852, the ‛Taxonomy Regulation’”  2021

………………………………...6.  Future and further criteria in the Taxonomy Regulation – other sustainability goals and minimum standards  The JRC Report deals with other aspects that are important for sustainable development in conjunction with disposing of high-level radioactive waste, in addition to the ecological criteria. The JRC Report particularly highlights consideration for future generations (JRC Report, Part B, p. 258) and the importance of participative decision-making (JRC Report, Part B, p. 254) when searching for a repository site. The JRC Report formulates both aspects as important requirements when searching for a repository site. The two requirements of “considering future generations” and “participative decision-making“, however, are not considered in any further depth – e.g. mentioning the challenges associated with these requirements when searching for a repository site for radioactive waste. The report emphasises that there is still no repository for high-level radioactive waste in operation anywhere in the world (JRC Report, Part A 1.1.1, p. 17), but leaves open the question of whether there is any connection here with the challenges of “considering future generations” and “participative decision-making”.   ..

Regardless of disposal, the problem of proliferation (cf. section 6.3), which is only mentioned in a very rudimentary manner in relation to reprocessing in the JRC Report, and uranium mining (cf. section 6.4) mean that it is necessary to treat the topics of intergenerational justice and participation separately in terms of the sustainability of using nuclear energy. Even in the case of severe nuclear power plant accidents, where large amounts of radioactive substances are discharged into the environment, generational justice is an important aspect of sustainability. The example of Chernobyl shows that coping with the consequences of an accident will also plague future generations – ranging from restrictions or non-usage possibilities in the affected areas and even the planned dismantling of the damaged reactor block and disposing of the retrieved nuclear fuel.

6.1 “Considering future generations” and “participative decision-making” in conjunction with disposal ……..

Considering future generations and participative decision-making in any society represent individual sustainability goals in the United Nations’ 2030 Agenda for Sustainable Development (UN, 2015) ……..  These two sustainability goals are not adequately considered in the JRC Report with a view to nuclear disposal, but are important for assessing the fundamental issue of sustainability, which is also part of the Taxonomy Regulation 

Consideration of sustainability aspects and future generations in the JRC Report Developing and introducing a geological disposal programme/disposal system takes decades and is associated with costs that are hard to calculate. Monitoring after the closure of the repository will also continue for at least another 100 years. For example, France expects the operational time for a repository alone to exceed 100 years. During this long period, following generations will have to deal with problems that have been caused by previous generations 

The risk of long-term financial burdens that are hard to calculate (as the example of the Asse II mine illustrates) and the risks caused by geological disposal for several generations are not adequately treated in the JRC Report. ………  The report fails to provide any in-depth analysis of this aspect and provides a distorted picture, particularly with a view to the aspect of sustainability and intergenerational justice, by ignoring the negative consequences of using nuclear energy. 

Consideration of participative decision-making in societies in the JRC Report The involvement of stakeholders is greatly oversimplified in the JRC Report and is described in very optimistic terms. For example, NGOs are not considered in the description of interest groups and their role in developing a programme for deep geological repository sites (JRC Report, Part B, p. 253-254). Part B, p. 254 of the JRC Report ignores the fact that it may not be possible to reach consensus among the stakeholders. This also oversimplifies the problem of searching for a site and presents it in a one-sided way 

There is no discussion either that – where no social consensus on using nuclear energy exists – its use itself can represent a blockage factor for solving the repository issue – at least experience in Germany illustrates this. Abandoning nuclear power and therefore resolving a social field of conflict, which had continued for decades, was a central factor in ensuring that discussions were relaunched about a site election procedure and led to a broad consensus. …….


Overall, it is necessary to state that the consideration of sustainability in the JRC Report is incomplete and needs to be complemented in terms of the minimum objectives and other sustainability goals. The broad sustainability approach adopted by the United Nations is not picked up. EU taxonomy is based on this broad approach. It therefore makes sense to already analyse the use of nuclear energy and the disposal of radioactive waste specifically now – and in the context of other sustainability goals like considering future generations and participative involvement in societies. 

6.2 Preservation of records, .Preservation of records, knowledge and memory (RK&M) regarding radioactive waste repositories is only mentioned once as a quotation from Article 17 of the Joint Convention (JRC Report, Part B 1.2, p. 206) and once rudimentarily in Part B, p. 259f. This does not do justice to its importance for future generations (cf. sections 2.1 and 6.1 of this expert response). ………….  . Requirements like these are not taken into account in the JRC Report. 

6.3 Proliferation The JRC Report only mentions the risk of proliferation – i.e. the spread or transfer of fissionable material, mass weapons of destruction, their design plans or launching systems – very briefly in conjunction with the civil use of nuclear power. This analysis is inadequate to do justice to proliferation in the light of the DNSH criteria related to the environmental objectives, as it represents a considerable risk for almost all sustainability goals. 

The military and civil use of nuclear energy have been closely connected to each other historically. The technologies for their use are often dual-use items, i.e. they can in principle be used for both civil and military purposes. It is therefore necessary to create an extensive network of international controls as part of using nuclear energy and the supply and disposal of fuels associated with it in order to minimise the risk of military misuse by state or non-state players. This particularly applies to fissionable material like uranium-235 and plutonium-239, which are used when generating nuclear energy or produced in power reactors. In addition to this, significant risks are also created by other radioactive substances if they are stolen and used in an improper manner (“dirty bombs”). 

Processes that are particularly important for proliferation are created when manufacturing nuclear fuel (uranium enrichment) and reprocessing spent nuclear fuel materials: the technologies for uranium enrichment can be used with modifications to produce highly enriched uranium to build a nuclear weapon. During reprocessing, plutonium is separated and it can be used for nuclear weapons. Even if the plutonium vector, which is produced in power reactors, does not have the ideal properties for military use from a physics point of view, it is still basically suitable for making weapons (Mark, 1993; US DoE, 1994). 

Using nuclear energy to generate electricity is therefore associated with specific risks of proliferation. As nuclear weapons have unique destructive potential in many respects (Eisenbart, 2012), the issue of sustainability for this type of energy generation should not ignore this aspect. ……

6.4 Uranium mining – specific requirements for sustainable mining ………………..  There is no real discussion of the term “sustainable mining” in the JRC Report (cf. particularly JRC Report Part A, p. 76 at the bottom). The report does not examine the discussion about sustainable mining has any repercussions for investigating the environmental effects of uranium mining. However, it is important in terms of other sustainability goals or the minimum safeguards laid down in Article 18 of the Taxonomy Regulation (cf. BMK, 2020, p. 22 too) 

All those involved in mining and processing uranium ore should be mentioned in conjunction with sustainability. The effects on indigenous peoples, on whose land most of the uranium mines are located, is not mentioned in the report, for example. The rights of these people for a just share in all the resources (ranging from clean water to reasonable healthcare and even the ownership of the raw material, uranium) are not considered, but should be to an extensive degree from sustainability points of view as regards taxonomy ……………..

September 13, 2021 - Posted by | EUROPE, politics international, Reference

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