世界經濟論壇：2020年歐盟分類法的應用報告：歐盟分類法有助于快速復蘇和實現歐盟綠色協議 （英文版）（27頁）.pdf

1、“Applying the EU Taxonomy”: Lessons from the Front Line Coauthors: Peter Sweatman (Lead) and Malte Hessenius 2 “Applying the EU Taxonomy”: Lessons from the Front Line Paper jointly prepared by Climate Strategy and Climate EU expenditure should be consistent with Paris Agreement objectives and with t

2、he objective of EU climate neutrality by 2050 and contribute to achieving the Unions new 2030 climate targets. EU budget expenditures also need to be consistent with the “do no harm” principle of the European Green Deal. Operational guidelines for this principle are needed alongside a necessary excl

3、usion list for fossil fuels. An effective methodology for monitoring climate-spending and its performance should ensure that the next MFF as a whole contributes to the implementation of the Paris Agreement. In this context, the EU Taxonomy should be used as climate tracking instrument in the NGEU an

4、d MFF to align EU funds, and recovery investments, with the goals of the Paris Agreement and to deliver the EU Green Deal, as: The EU Taxonomy is a proven climate tracking tool that can help identify investments which make a significant contribution to climate mitigation and adaptation. Early applic

5、ations of the EU Taxonomys recommended climate contribution thresholds demonstrate the feasibility of how this can be done at the project/ municipal, company and fund level. Existing climate tracking approaches in EU funds (the “Rio Markers”) are imperfect and are shown, in cases, to significantly o

6、verstate climate contributions, thus undermining the credibility of the EUs climate action commitment. In the three areas which the EU Taxonomy does not yet cover, Rio markers can be applied until the EU Taxonomy has been expanded. Consequently, reference to the EU Taxonomy as preferred climate trac

7、king tool should be included in the legislation on all financial instruments in the NGEU and MFF, including the regulations on the Recovery and Resilience Fund, the Just Transition Fund/Public Loan Facility, InvestEU et al. The paper targets Member States preparing Recovery and Resilience Plans, MEP

8、s and EC officials debating the final details of the EU budget and Next Generation EU, and practitioners from the sustainable finance sector. It is divided into three sections: 1) An introduction to the climate taxonomy challenge; 2) Lessons learned from practical applications of the EU Taxonomy; an

9、d 3) A comparison of EU Taxonomy with the Rio Markers for the delivery of climate objectives. The following EU Taxonomy implementation timeline fits well with that of the Recovery and Resilience Plans shown later in this paper. We show that the key elements of the EU Taxonomy are in place and alread

10、y it is can be successfully applied in practice. 3 “Applying the EU Taxonomy”: Lessons from the Front Line Paper jointly prepared by Climate Strategy and Climate Demonstrate Alignment: To demonstrate “taxonomy alignment” the project needs to make a significant contribution to climate objectives by p

11、assing its defined threshold7; Do No Significant Harm: The project needs to show it doesnt harm the other five environmental objectives as defined in the Taxonomy Regulation; and Comply with Minimum safeguards: Minimum social and governance safeguards are also set out in the Taxonomy Regulation. Fro

12、m a climate perspective, a taxonomy needs to ensure that all compliant projects build, or convert, assets that are coherent with the EUs 2030 targets and 2050 net-zero emissions trajectories. Non-compliant projects in eligible sectors are at risk of having their useful lives curtailed by future clim

13、ate regulation, or will require additional (hidden) investments to make them taxonomy compliant in the future or will risk to become stranded assets. To align with the taxonomy, projects must make a substantial contribution to climate mitigation, or adaptation, and for each project type, a threshold

14、 is used to define this substantial contribution. Further, the construction and operation of the complying asset should not significantly harm the EUs non-climate environmental objectives (water, waste, pollution prevention and biodiversity8). In many project finance and municipal transactions, envi

15、ronmental harm is covered in an Environmental Impact Assessment report9 which is usually a regulatory approval or operating license pre-condition, and is required by mainstream funders in legal due diligence processes. 7 Presently recommended in the technical annex to the TEGs final report on EU Tax

16、onomy 9th March 2020: https:/ec.europa.eu/info/ files/200309-sustainable-finance-teg-final-report-taxonomy-annexes_en 8 Formally, the sustainable use and protection of water and marine resources; the transition to a circular economy, waste prevention and recycling; pollution prevention and control;

17、and the protection of healthy ecosystems. 9 European Commission. (2017). Environmental Impact Assessment of Projects: Guidance on the preparation of the Environmental Impact Assessment Report. Retrieved from https:/ec.europa.eu/environment/eia/pdf/EIA_guidance_EIA_report_final.pdf 1. ELIGIBILITY: Ac

18、tivity fits a defines NACE macro-sector category for climate mitigation or adaptation. 2. ALIGNMENT: Activity must make a substantiall contribution defined by a threshold in climate mitigation or adaptation. 3. DNHS: Do No Significant Harm to the other five EU environmental objectives. 4. COMPLIANCE

19、: Comply with minimun safeguards. 7 “Applying the EU Taxonomy”: Lessons from the Front Line Paper jointly prepared by Climate Strategy and Climate Demonstrate Alignment: Apply the technical threshold criteria to determine if activity delivers a substantial contribution to climate action (TEG-recomme

20、nded thresholds, as for projects); Do No Significant Harm: Undertake due diligence to ensure activity does no significant harm to other environmental areas; listed companies are obliged to disclose breaches of environmental regulations, which together with sustainability reports can cover these requ

21、irements; and Comply with Minimum safeguards: Apply minimum social safeguards (again, usually companies comply with workers rights in operating jurisdictions, and report against SDGs). 16 EU Technical Expert Group on Sustainable Finance. (2020). Taxonomy: Final report of the Technical Expert Group o

22、n Sustainable Finance. Retrieved from https:/ec.europa.eu/info/sites/info/files/business_economy_euro/banking_and_finance/documents/200309-sustainable- finance-teg-final-report-taxonomy_en.pdf 10 “Applying the EU Taxonomy”: Lessons from the Front Line Paper jointly prepared by Climate Strategy and C

23、limate The old system provides no means of understanding the impacts of investments on climate change or for providing security against doing harm to other environmental objectives. The continued use of imperfect climate tracking systems in the public domain is no longer a viable approach 14 “Applyi

24、ng the EU Taxonomy”: Lessons from the Front Line Paper jointly prepared by Climate Strategy and Climate to neutral, and unfavourable. This case illustrates the institutional inertia which exists in public administration budgets and around existing classification systems. Over the years, the French s

25、ystem for performance-based budget has evolved to offer detailed data on objectives and indicators for each different national programme. Clearly, France has the proper foundation in the use of tags which have enabled its administrations to calculate and estimate the cost of environmental reforms an

26、d investments. This positive experience can be developed in coherence with the EU Taxonomy thresholds to provide greater granularity and opportunity for private co-investments. This will then allow Member States to rapidly determine the depth of its national plan, and future-proof its contributions

27、to the green and digital transitions and the climate mainstreaming target. 27 OECD. (2020). Green Budget Tagging: Introductory Guidance the EU Taxonomy must be used since the Rio Marker would inflate the climate share (e.g. energy efficiency as marked red in the long table below); neither frameworks

28、 work (e.g. we consider this dimension to be relevant or both frameworks have limitations marked in yellow); the Rio Marker should be used (e.g. Taxonomy does not cover climate-relevant activities yet marked in blue); Having done this exercise for all 143 dimensions, this table presents the aggregat

29、ed numbers of our recommendations. Table 2: Aggregation of suggestions No climate relevance For approximately 50% of the intervention field dimensions, we identified no climate relevance. This is also reflected by a Rio Marker coefficient of 0% and no exposure to the current EU Taxonomy. Therefore,

30、both frameworks could be used for these dimensions to determine the climate share of the investment and would yield the same result (a 0% coefficient or ineligibility). Use Taxonomy For approximately 40% of the intervention field dimensions, we recommend the application of the EU Taxonomy over the R

31、io Markers. For all of them we identified a direct or indirect link to the current EU Taxonomy (and the corresponding technical screening criteria). In 25 out of 61 cases (see Excel file, sheet “CPR_Tab1_Overview”), the Rio Marker is 0% but the Taxonomy potentially defines the expense as a climate s

32、pending (e.g. broadening the scope for EU member states to reach the set climate share of their Recovery and Resilience Plans). For some activities, the Rio Markers and the EU Taxonomy would yield the same result2. Nonetheless, we suggest the Taxonomy for two reasons. First, the EU Taxonomy creates

33、an enabling framework that allows to adjust technical screening criteria based on a science-based discourse (e.g. alignment with a 1.5C pathway as set out in the Paris Agreement). Second, the EU Taxonomy builds the foundation for sustainable investments aligned with the EUs environmental objectives.

34、 1 European Commission. (2018). COM(2018) 375 final: ANNEXES 1 to 22. Retrieved from https:/ec.europa.eu/transparency/regdoc/rep/1/2018/EN/COM-2018-375-F1-EN-ANNEX-1-PART-1.PDF 2 See, for instance, “028 Renewable energy: wind”. Under the EU Taxonomy wind power is currently deemed as “green” without

35、further testing and the Rio Marker assign a coefficient of 100%. Overview Evaluation Final EvaluationCountPercentage No climate relevance7150% Use Taxonomy6143% Neither frameworks work85% Use Rio Marker32% SUM143100% 19 “Applying the EU Taxonomy”: Lessons from the Front Line Paper jointly prepared b

36、y Climate Strategy and Climate Data centre must comply with the “European Code of Conduct for Data Centre Energy Efficiency”(72). 011Government ICT solutions, e-services, applications Use Taxonomy0%Partially covered 71, 72See above 022Research and innovation processes, technology transfer and cooper

37、ation between enterprises focusing on the low carbon economy, resilience and adaptation to climate change Neither frameworks work 100%Partially covered 71, 72Note: the current Taxonomy does not cover research activities. We suggest a case by case evaluation instead of applying the Rio Marker. 023Res

38、earch and innovation processes, technology transfer and cooperation between enterprises focusing on circular economy Neither frameworks work 40%Not covered Note: see rationale above. 024Energy efficiency and demonstration projects in SMEs and supporting measures Use Taxonomy100%Covered 57-60Construc

39、tion of new buildings (57), building renovation (58), individual renovation measures (59), and acquisition of buildings (60). 57: Net Primary Energy Demand (PED) must be 20% lower than the NZEB requirement (nearly zero-energy building, national directives); 58: Reduction of PED by 30% OR renovation

40、compliant with “major renovation” transposing the EPBD; 59: Long list of individual measures with and without requirements; 60: Buildings built before 2021 must be within the top 15% of the local building stock in terms of PED, Buildings built after must comply with requirements from EPBD 025Energy

41、efficiency renovation of existing housing stock, demonstration projects and supporting measures Use Taxonomy100%Covered 57-60See above 026Energy efficiency renovation of public infrastructure, demonstration projects and supporting measures Use Taxonomy100%Covered 57-60See above 027Support to enterpr

42、ises that provide services contributing to the low carbon economy and to resilience to climate change Use Taxonomy100%Covered 9Umbrella term. No threshold for essential renewable technologies; different g CO2/km thresholds for vehicles; different efficiency thresholds for energy efficient equipment

43、(e.g. U-value); demonstration of substantial GHG reduction through third party assessment 028Renewable energy: windUse Taxonomy100%Covered 22Life cycle emissions lower than 100gCO2e/kWh, declining to net-0gCO2e/kWh by 2050. Currently derogated from a test. 029Renewable energy: solarUse Taxonomy100%C

44、overed 20, 21See above. 21 “Applying the EU Taxonomy”: Lessons from the Front Line Paper jointly prepared by Climate Strategy and Climate Storage of electricity (29): No threshold applies. 034High efficiency co-generation, district heating and cooling Use Taxonomy100%Covered Several Taxonomy activit

45、ies (all linked to cogeneration, or production of heat/cool). Threshold: Life cycle emissions lower than 100gCO2e/kWh, declining to net-0gCO2e/kWh by 2050. Infrastructure for distributing heating and cooling is eligible if it follows the EU Energy Efficiency Directive. 035Adaptation to climate chang

46、e measures and prevention and management of climate related risks: floods (including awareness raising, civil protection and disaster management systems and infrastructures) Use Taxonomy100%AdaptationNote: covered by EU Taxonomy on climate change adaptation. 036Adaptation to climate change measures

47、and prevention and management of climate related risks: fires (including awareness raising, civil protection and disaster management systems and infrastructures) Use Taxonomy100%AdaptationNote: covered by EU Taxonomy on climate change adaptation. 037Adaptation to climate change measures and preventi

48、on and management of climate related risks: others, e.g. storms and drought (including awareness raising, civil protection and disaster management systems and infrastructures) Use Taxonomy100%AdaptationNote: covered by EU Taxonomy on climate change adaptation. 038Risk prevention and management of no

49、n-climate related natural risks (i.e. earthquakes) and risks linked to human activities (e.g. technological accidents), including awareness raising, civil protection and disaster management systems and infrastructures Use Taxonomy0%AdaptationNote: covered by EU Taxonomy on climate change adaptation. 039Provision of water for human consumption (extraction, treatment, storage and distribution infrastructure, efficiency measures, drinking water supply) Use Taxonomy0%Covered 45Front-to-end water supply system: 20%/ decreasing leakage by 20%