The European Association of Co-operative Banks welcomes the possibility to answer the TEG consultation on taxonomy. Our contributions are focused on:
- Agriculture and forestry: Growing of perennial and non-perennial crops; Livestock production;
- Electricity, gas, steam and air conditioning supply: Storage of Energy
- Buildings: Construction of new buildings; Renovation of existing buildings; Individual renovation measures, installation of renewable on-site and professional; Acquisition of buildings.
Indeed co-operative banks, as members owned, locally-oriented are best placed to facilitate the greening of buildings, which are responsible of 40% of the total CO2 emissions of the EU. This is why we believe it is important to create a workable framework. We appreciate that the new report consider as one of the mitigation activities in the buildings sector the acquisition of buildings, as it was suggested in our previous position paper on the 1st round climate mitigation activities of the TEG report on taxonomy.
Co-operative Banks are also deeply involved in supporting the Agriculture as one of the most important sectors of the regional and rural economy of Europe. The food supply chain contributes 19-29% of global greenhouse gas (GHG) emissions, the majority of which, for most supply chains, occurs at the farm level (80-90%). At the same time, agricultural productivity is simultaneously vulnerable to climate change (as it is stated in the TEG report p. 111). For those reasons, the EACB answer to the agriculture part of the questionnaire provides very specific comments and remarks on the different activities considered. One among the many proposals presented aims to include an incentive or a clear time horizon (preferably within 5 years) to move from the prescriptive metric option of management practices, to the outcome metric option (quantitative reduction of GHG), based on international IPCC standards. Furthermore, the EACB suggests to replace the assessment of total absolute gCO2e emissions at farm level by a GHG intensity assessment per unit.
Finally, as new sources of energy like the so called “neutral” gas clean gas could impact a share of bank’ green investments and financing in local and regional pure green renewable energies, the European Association of Co-operative Banks has decided to provide comments on the “Storage of Energy” section of the consultation.
Having said that, we hope that the co-operative banks’ point of view could be integrated into the final TEG report on the EU Taxonomy.
To see our responses to the Consultation in detail please see the attached document.
For further information or questions on this paper, please contact:
Ms. E. Bevilacqua, firstname.lastname@example.org
Mr. G. Betti, email@example.com