VIEWPOINTS ON THE UPDATE TO THE METHODOLOGY TO DETERMINE THE GREEN FINANCE ATTRIBUTION OF EBRD INVESTMENTS

Women Against Nuclear Power: Ulla Klötzer
Women for Peace: Lea Launokari
November 23, 2025

Viewpoints on the Update to the methodology to determine the green finance attribution of EBRD investments

Concerns about potential inclusion of nuclear energy in EIB Green financing

To EBRD,

Acknowledging the importance of increasing transparency in EBRD decision making, we thank you for the opportunity to submit our views on the Update to the methodology to determine the green finance attribution of EBRD investments.

We want to express our concerns that at some stage also nuclear energy could enter the EIB’s portfolio under the guise of “green investment”. There are evidently discussions going on within the EIB on an “evolving view” on new nuclear projects. Also the fact that the European Commission took up nuclear energy as interim technology under art 10(2) of its Taxonomy on Sustainable Financing is pointing at this direction.

We strongly want to emphasize, that even though several countries with large financial and corporate interests in the nuclear energy sector are pushing for new nuclear projects – including SMR projects offering unsubstantiated promises of “cheap and fast” reactors – nuclear energy cannot be considered sustainable or green. It does not fulfil the urgent need for extensive climate action. Furthermore, the entire life cycle of nuclear power burdens the environment in many different ways over a long period of time.

• Nuclear energy is too risky

Nuclear energy production conflicts with the “Do No Significant Harm (DNSH)” principle. The risks for large accidents causing radioactive emissions into the environment are substantial due to natural disasters, technical or human failures or attacks on nuclear power facilities – deliberate or accidental – in a situation of war or social unrest. This applies for current generation nuclear power plants as well as for advanced designs.

• Nuclear energy waste problems burden current and future generations

Leaks in low- and mid-level radioactive waste facilities are a known issue, primarily caused by aging infrastructure, corrosion, or water penetration, such as at the Asse II salt mine in Germany and the Sellafield site in the UK. These leaks pose risks of contaminating groundwater and causing serious health problems.

The final disposal of spent fuel cannot be regarded as solved.

Finland is on the verge of becoming the first nation to bury spent nuclear fuel rods  deep underground in a final bedrock facility. The primary risks of the Onkalo facility are long-term safety concerns, including potential environmental and human harm from radioactive leaks over thousands of years. The risks of corrosion affecting the disposal canisters has been brought up by scientists in Sweden. The potential for the site to be disturbed by future human activities must be considered as well as how the multiple barriers and the bedrock can withstand natural events like earthquakes and future glaciations. Risks also include the challenge of marking the site as dangerous for future generations.

• Nuclear energy is too expensive

Nuclear energy cannot compete with truly green technologies already on the market due to high upfront capital costs and long construction times of nuclear  compared to renewables. It is becoming increasingly clear that nuclear power acts as a significant hurdle to the roll-out of renewables and fossil fuel phase-out.

This also holds true for new nuclear designs currently under development. Market developments in countries that invest in nuclear power, i.a. Bulgaria, the Czech Republic, France, Finland, Hungary, the Netherlands, Poland, Romania, Slovakia, the UK and Ukraine, clearly show a detrimental impact on the development of sustainable renewable energy sources as well as other urgent climate action.

In Finland LUT’s analysis of the nuclear power expansion scenarios in the Finnish energy system reveals that prioritising nuclear power over renewables leads to significantly higher costs and financial risks (LUT- University in Lappeenranta).

• Nuclear energy is delivering too little

Pledges to triple or double nuclear capacity by 2050 might be theoretically possible but would require an unprecedented, epic effort to overcome significant challenges. Obstacles include high costs, long construction times, massive supply chain scale-up, project delays and cost overruns.

The OL-3 EPR in Finland is one of the latest major reactors built worldwide. The project was plagued by significant delays. It was originally scheduled for a 2009 startup but began commercial operation in May 2023. The costs ballooned from an initial estimate of around €3 billion to approximately €11 billion. This led to costly lawsuits between the owner (TVO) and the contractor (Areva-Siemens consortium).

Tripling or doubling nuclear capacity by 2050 would require global grid connection for some 140 new large reactors annually between 2040 and 2050, the second still over 90. Currently less than 10 reactors on average are brought to the grid per year. In Europe, only 10 new reactors were brought on-line in the last 25 years, whereas 67 reactors were shut down in the same time.

Furthermore an eventual doubling of the nuclear capacity would lead to a reduction of carbon emissions of only some 4 %.  

• Nuclear energy is too slow to meet the urgent need for climate action

The OL-3 project is clearly indicating that whatever capacity would be brought on-line, it will come largely after 2040. The carbon emissions need urgently to be reduced well before that in order to lighten the decarbonisation burden for the next generation and to save the planet from accelerating climate disasters. This can cost- effectively be done by a consequent focus on decarbonisation of the power sector with truly clean, sustainable, renewable technologies.

• Nuclear energy and proliferation

With growing interest in nuclear energy, there is also growing concern of nuclear proliferation. The key risk lies with the nuclear fuel cycle since facilities and technologies used in the enrichment and reprocessing of nuclear fuel can also be used to produce fissile material for use in nuclear weapons. 

Without a truly changing security environment, increasing nuclear energy utilization implicitly increases the risk of nuclear weapons proliferation, either by sub-state actors or by states themselves. It must be taken into consideration that great power competition is currently seriously challenging the non-proliferation regime.

We hope that EBRD, claiming to “use its investments and policy dialogue to catalyse systemic change that makes green investments economically viable” in the decision making about the “Update to the methodology to determine the green finance attribution of EBRD investments” – in order to promote a policy that serves the society to the fullest extent – truly considers all the negative impacts of nuclear energy listed above.

Remaining available for further discussion, sincerely,

Ulla Klötzer

Lea Launokari