Ref. Ares(2021)2145278 - 26/03/2021
Secretariat-General
ASR Nederland N.V.
European Commission
Executive Board
Rue de la Loi 200
1049 Brussel
Archimedeslaan 10
Belgium
3584 BA Utrecht
Postbus 2072
3500 HB Utrecht
The Netherlands
www.asrnederland.nl
Date
March 23rd, 2021
Subject
Concerns regarding the EU Green Taxonomy
Dear Ms Von der Leyen, Mr Timmermans, Mr Dombrovskis and Ms McGuinness,
With this letter we would like to express our concerns on recent developments regarding the EU Green
Taxonomy. Specifically, we would like to urge the Commission to ensure only renewable sources to be
considered green in the taxonomy and avoid gas or other fossil fuel resources from being labeled
sustainable. The recent attempt to include natural gas and other fossil fuel resources is in our view
undesirable and a risk to the credibility of the Taxonomy.
We believe there is a sufficient regulatory framework to ensure grid stability and back-up capacity that is
needed in the years to come as the transition to a renewable energy based, climate neutral economy
progresses. We firmly believe that the Taxonomy should exclusively include green and renewable
technologies, in line with the recommendations of the Technical Expert Group. Only then, the purpose of
identifying and labelling green finance can be attained. If fossil fuels are allowed under a higher threshold,
the risk of undermining the Taxonomy as a science-based standard to avoid greenwashing becomes
evident.
Analysis from civil society organisations shows that up to half of all EU gas plants are running below 2000
operational hours a year and could therefore be included in the Green Taxonomy with the new proposal.
We strongly feel this development is in conflict with the Presidents’ Green Deal and the ambition to increase
the current climate targets. In order to meet these ambitious targets, giving clear guidance to financial
institutions on what can be considered green investments are crucial in order to accelerate the transition.
As financial institution(s), we support your continuous efforts to show global climate leadership, and we
feel the Green Taxonomy could lead the way globally to empower the financial sector as accelerators of
the transition to a renewables based, climate neutral society. That is why, striking the right cord with the
Green Taxonomy is of crucial importance to us.
Of course, we are available to exchange with you on this issue.
Yours sincerely,
ASR Nederland N.V.
ASR Nederland N.V., KvK 30070695 Utrecht, BTW NL001823036B01
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ABN AMRO Bank 86.95.33.843, IBAN: NL45 ABNA 0869 5338 43, BIC: ABNANL2A t.n.v. ASR Betalingscentrum B.V.