European Commission s Nuclear Illustrative Programme (PINC) A EURELECTRIC response paper

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1 European Commission s Nuclear Illustrative Programme (PINC) A EURELECTRIC response paper September 2016

2 EURELECTRIC is the voice of the electricity industry in Europe. We speak for more than 3,500 companies in power generation, distribution, and supply. We Stand For: Carbon-neutral electricity by 2050 We have committed to making Europe s electricity cleaner. To deliver, we need to make use of all low-carbon technologies: more renewables, but also clean coal and gas, and nuclear. Efficient electric technologies in transport and buildings, combined with the development of smart grids and a major push in energy efficiency play a key role in reducing fossil fuel consumption and making our electricity more sustainable. Competitive electricity for our customers We support well-functioning, distortion-free energy and carbon markets as the best way to produce electricity and reduce emissions cost-efficiently. Integrated EU-wide electricity and gas markets are also crucial to offer our customers the full benefits of liberalisation: they ensure the best use of generation resources, improve security of supply, allow full EU-wide competition, and increase customer choice. Continent-wide electricity through a coherent European approach Europe s energy and climate challenges can only be solved by European or even global policies, not incoherent national measures. Such policies should complement, not contradict each other: coherent and integrated approaches reduce costs. This will encourage effective investment to ensure a sustainable and reliable electricity supply for Europe s businesses and consumers. EURELECTRIC. Electricity for Europe. Dépôt légal: D/2016/12.105/47 WG Thermal & Nuclear Contact: Sandya ABRAR, Advisor, Power Generation

3 European Commission s Nuclear Illustrative Programme (PINC) EURELECTRIC response paper September 2016 Introduction Nuclear power is one of the major sources of primary energy in the EU. The State of the Energy Union report notes that, the EU is one of only three major economies that generate more than half of its electricity without producing greenhouse gases, 27% produced from renewable energy sources and another 27% produced from nuclear energy. This report also states that the European Commission s Nuclear Illustrative Programme ( PINC) 2 should bring more clarity on long-term nuclear investment needs and on the management of nuclear liabilities. EURELECTRIC welcomes the long-awaited Communication on a Nuclear Illustrative Programme (PINC) 3, published on 4 April 2016, as a good basis to discuss the contribution of nuclear energy in achieving the EU s energy objectives. This is the first version of the PINC to be produced since the Fukushima Daiichi nuclear accident in It focuses on the investments related to post- Fukushima safety upgrades and to the safe operation of existing facilities. The PINC aims to engage all stakeholders, especially civil society, in the discussion on nuclear energy trends and related investments for the period up to Ensuring Nuclear power s contribution to Europe s low-carbon energy transition EURELECTRIC believes that a continuing contribution of nuclear power should be part of Europe s low-carbon energy transition, and that a more positive EU policy framework is needed if this is to be achieved. It is indeed helpful that the Commission s PINC document recognises the significant investment required from this sector. However we regret that the document does not adequately address the competitiveness of existing and technically well-functioning nuclear reactors, which, in some countries, are being forced to shut down due to the difficult market situation and distortive national policy measures. Nuclear energy contributes to the three major energy policy objectives of the European Union: security of supply, decarbonisation and competitive energy prices in Europe. Some 28% of electricity in Europe was produced by nuclear power in 2014 and the nuclear share in low-carbon electricity generation in 2014 was 54%. The Commission s document recognises that the projection of maintaining a nuclear generation capacity of between 95 GWe and 105 GWe in the COM(2015) 572 final. The Nuclear Illustrative Programme is a requirement under Article 40 of the Euratom Treaty. COM(2016) 177 final. 1

4 EU until 2050 and beyond would require between 350 and 450 billion to be invested in new plants to replace most of the existing nuclear capacity. However, in light of the current market conditions we are sceptical that this level of investments in new builds will actually materialise. The Commission also predicts a decline in the EU s current nuclear generation capacity (120 GWe) in the period up to 2025 with this trend reversing by Nuclear capacity would remain stable between 95 and 105 GWe by 2050 assuming 90% of the existing nuclear fleet is replaced in this time. We find it contradictory that while the Commission is assessing the investment needs in the nuclear sector, the PINC document lacks an analytical review of the role of nuclear along with guidelines for future policy, including investment policy. The PINC comments on cost over-runs and delays on new projects but refrains from proposing any solutions. Nuclear energy can contribute to energy security, as fuel and operating costs are relatively low and stable, large volumes of predictable electricity can be generated continuously for extended periods. It can also make a positive contribution to the stable functioning of electricity systems (e.g. maintaining grid frequency and other grid services), being the only baseload low carbon generation solution currently available. On the other hand, capital construction costs have risen, financing conditions are increasingly stringent and future market conditions are largely unpredictable. The Commission should propose a common framework for discussion of these issues, as it has done in other strategic communications on energy. The PINC should provide a policy vision and an indication of the sort of market reform that is needed to incentivise investments in nuclear energy and other low carbon sources. This will then help to deliver the desired transition to a low-carbon economy at least cost. 2

5 EURELECTRIC Recommendations In order to ensure a more favourable investment climate for nuclear energy, action is needed both to improve the regulatory framework for power generation generally as well as to address some nuclear-specific issues. An Effective Regulatory Framework for Power Generation - A stable and predictable regulatory framework is crucial for the transition towards a lowcarbon economy. In order to maintain investor confidence, governments should avoid retrospective or arbitrary changes to the regulatory regime. - The internal electricity market should be completed. Energy-only markets remain the reference for the completion of the internal electricity market. However, in view of the fact that in many markets the introduction of a capacity element is becoming increasingly important, EURELECTRIC recognises that properly designed capacity markets are an integral part of a future market design. Capacity markets should be technology neutral. - A level playing field must be ensured between different technologies. - A robust EU ETS is key for triggering investments in low carbon generation. Market-based solutions should be found to reduce the investment risks associated with capital intensive low-carbon energy projects. This would also have the positive effect of reducing investment costs in new nuclear. European institutions should ensure that funds are made available for low-carbon capital intensive projects. A Forward-looking Framework for Nuclear Power The average age of nuclear power plants in Europe is around 30 years, and decisions need to be taken on long-term operation, new-build and decommissioning. The PINC provides a basis for assessing the situation in different markets and for addressing market distortions. Specific tax burdens that distort the economics of long-term operation of nuclear facilities and which distort the wholesale electricity market should be avoided. In order to improve cost efficiency in the nuclear sector, EURELECTRIC would welcome the continuation of efforts from national regulators and the industry to develop harmonisation and standardisation. One option worth exploring is the development of a standalone design assessment process, as set out in the Roadmap towards European Reactor Design Acceptance 4. This would allow regulators to benefit from generic design assessment already done in other Member States. Continuous improvement of nuclear safety and security in Europe must be tackled, not only through national efforts, but also at the European and international levels. EURELECTRIC supports the continuation and enhancement of the current effective cooperation between nuclear safety regulators and the sharing of best-practice among nuclear operators. With this in mind we put forward following recommendations: - Post-Fukushima safety upgrades should be implemented for existing reactors in a timely manner, with the EU established stress test process helping to ensure this. The 4 Roadmap towards European Reactor Design Acceptance, 31 July 2012, European Nuclear Forum. 3

6 independence of national safety regulators and adequate competencies and resources must be ensured. R&D efforts should be stepped up with a view to promoting improved cost-effectiveness both in nuclear power generation and in waste management. The creation of a EU-wide legal framework for the standardised licensing of small innovative reactors would be the key prerequisite for a large-scale application. Research into innovative nuclear technologies should be supported at the EU level, building on the strengths of existing capabilities at the Joint Research Centre and within national organisations, universities and commercial companies. Any barriers to cooperation between EU Member States (e.g. in the construction of new nuclear power plants) should be removed. Public authorities, including the European Commission, should promote a facts-based dialogue on nuclear power. - The EU should take the initiative to establish a world-wide realistic regulatory regime with the International Commission on Radiation Protection (ICRP) on low-dose radiation effects, especially in conjunction with long-term waste storage. 4

7 EURELECTRIC pursues in all its activities the application of the following sustainable development values: Economic Development Growth, added-value, efficiency Environmental Leadership Commitment, innovation, pro-activeness Social Responsibility Transparency, ethics, accountability

8 Union of the Electricity Industry - EURELECTRIC aisbl Boulevard de l Impératrice, 66 - bte 2 B Brussels Belgium Tel: Fax: VAT: BE EU Transparency Register number:

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