Ref. Ares(2021)2562270 - 15/04/2021
From:
@IIGCC.org>
Sent:
jeudi 15 avril 2021 14:27
To:
EC PRESIDENT VDL
Cc:
(CAB-VON DER LEYEN);
Subject:
Letter from Institutional Investors Group on Climate Change
regarding draft Delegated Regulation under the Taxonomy
Attachments:
IIGCC Letter regarding EU taxonomy_April 2021.pdf
Follow Up Flag:
Follow up
Flag Status:
Completed
Dear President von der Leyen,
I am writing to you with regards to the draft Delegated Regulation under the Taxonomy Regulation.
The Institutional Investors Group on Climate Change (IIGCC) is the leading European membership body
enabling the European investment community in driving significant and real progress by 2030 towards a
net zero and resilient future. IIGCC’s 300 members representing €37 trillion AUM are in a position to
catalyse real world change through their capital allocation decisions, stewardship and engagement with
companies and the wider market as well as through their policy advocacy.
Please find the attached letter from IIGCC recommending the Delegated Regulation upholds, as a
minimum, the level of climate ambition and screening criteria recommended by the Technical expert
group on sustainable finance (TEG). To ensure the taxonomy is aligned with net zero emissions, it is of
key importance that the technical screening criteria do not diverge from a science-based approach.
The EU taxonomy provides a foundation stone for Europe’s sustainable finance agenda, not only from a
regulatory perspective, but also because investors are using the taxonomy to assess alignment of their
portfolios and investments with net zero.
In particular, we strongly discourage any inclusion of natural gas without abatement (e.g. without
carbon capture) within the scope of the taxonomy. IIGCC’s engagement with corporates is seeking to
encourage a shift in business model away from fossil fuels, and towards scaled up investments in
renewables and other zero emission technologies. If natural gas without abatement was to become
consistent with the taxonomy, many energy companies would presently demonstrate alignment with
the taxonomy but without enacting climate transition plans. This would frustrate the efforts of investors
seeking to drive the decarbonisation of emissions intensive sectors.
We welcome your consideration of these concerns, and look forward to continuing to support the
Commission to reorient capital flows towards net zero investment.
Best regards
Institutional Investors Group on Climate Change
The investor voice on climate change
Visit our new website to find out more about our work: www.iigcc.org.
Email:
@IIGCC.org |
| Twitter: @iigccnews
IIGCC | Pennine Place | 2a Charing Cross Road | London WC2H 0HF | United Kingdom
Ref. Ares(2021)2562270 - 15/04/2021
15 April 2021
Dear President von der Leyen,
Dear Commissioner McGuinness,
Following up on letter to Commissioner McGuinness dated 16 February 2021, I am writing to you with
regard to the draft Delegated Regulation under the Taxonomy Regulation.
The Institutional Investors Group on Climate Change (IIGCC) is the leading European membership body
enabling the European investment community in driving significant and real progress by 2030 towards a
net zero and resilient future. IIGCC’s 300 members representing €37 trillion AUM are in a position to
catalyse real world change through their capital allocation decisions, stewardship and engagement with
companies and the wider market as well as through their policy advocacy.
The EU taxonomy provides a key foundation stone for Europe’s sustainable finance agenda, not only from
a regulatory perspective, but also because investors are using the taxonomy to assess alignment of their
portfolios and investments with net zero.
IIGCC strongly recommends the draft Delegated Regulation upholds, as a minimum, the level of climate
ambition and screening criteria recommended by the Technical expert group on sustainable finance
(TEG). To ensure the taxonomy is aligned with net zero emissions, it is of key importance that the technical
screening criteria do not diverge from a science-based approach.
In particular, we strongly discourage any inclusion of natural gas without abatement (e.g. without
carbon capture) within the scope of the taxonomy. If natural gas without abatement was to become
consistent with the taxonomy, this would mean many energy companies would demonstrate alignment
with the taxonomy - even though their activities would not be aligned with net zero emissions and
without having enacted climate transition plans in line with achieving economy-wide net zero
emissions.
From an investor perspective, IIGCC and its members are proactively engaging with corporates to
encourage a shift in business model away from fossil fuels, and towards scaled up investments in
renewables and other zero emission technologies. Any inclusion of natural gas without abatement
within the taxonomy would frustrate the efforts of investors seeking to drive the decarbonisation of
emissions intensive sectors and align investors’ portfolios with net zero emissions. Investors will be
closely examining the lobbying undertaken by companies on the taxonomy and any misalignment with
corporate’s commitments to good governance on Paris-aligning lobbying.
We welcome your consideration of these concerns, and look forward to continuing to support the
Commission to reorient capital flows towards net zero investment.
Yours sincerely,
Contact:
@iigcc.org