A presentation on the integration of EU Taxonomy and DNSH principle into impact assessment systems, regulations, and practice

1. EU Taxonomy:
Integration of EU Taxonomy and DNSH
principle into impact assessment
systems, regulations, and practice
HUSZPO ’22 Conference
Environmental Assessment and the European Green Deal
14-17 Sept 2022, Vodice, Croatia
Ing. Jiří Dusík

2. DON’T PANIC
go for a
KISS

3. DON‘T PANIC
š Taxonomy is not applicable to all economic activities – only for those that are labeled as
sustainable
š Less than 5% of activites are currently alligned with the EU Taxonomy Objective 1-2
š This may grow with the future Delegated Act on additional four Taxonomy Objectives
š This may grow over time but we still have time to prepare
š Better prepare well – misteps may create confusion may backfire on everyone

4. KISS - an emphasis on simplicity
Means
š keep it short and simple, or
š keep it simple, stupid smart
Rationale
š The KISS principle states that most systems work best if they are kept simple rather than made
complicated; simplicity should therefore be a key goal in business management.
https://www.globalnegotiator.com/international-trade/dictionary/kiss/
š Therefore, don't make your processes any more complicated than they have to be. You'll just
end up creating more work for yourself. Even worse, a new initiative you’re launching might
produce worse results if you add too much complexity along the way.
https://www.wrike.com/blog/understanding-kiss-principles-project-management/#What-does-
KISS-stand-for.

5. BASIC KISS SOLUTIONS
Use existing systems
š Gradually integrate Taxonomy-related considerations and the relevant ESRS requirements into the
EIA/SEA assessment frameworks
š Start with the large operators that will most probably have to follow these approaches anyway,
possibly also use EU-funded projects to experiment with the Taxonomy-related considerations as
part of any DNSH assurqnce
š For the rest – leave it unregulated, monitor the practice and leave detailed regulations for later

6. USE EXISTING SYSTEMS
Require env information produced for the Sustainable Finance Disclosure (EU
Taxonomy) and Corporate Sustainability Reporting (ESRS) to be based on locally
applicable standards and systems/procedures and be produced by experts with
proper professional credentials:
• N2K assessments largely unaffected if common sense approaches used
• EIA may need to be sligthly modified – but the scoping steps in EIA can easily
integrate technical screening criteria and any other Taxonomy-related
considerations into the assessmentprocesses

7. GRADUALLY ADJUST EXISTING SYSTEMS
Example:
š Six env. objectives of the Taxonomy offer a conceptual framework for the
assessment of cumulative impacts
š EU sustainability reporting standards (ESRS) can be integrated into monitoring
systems prescribed in EIA reports
Other systems, e.g. IPPC-type permits, may be expanded with a new possibility -
‚consultations with the relevant authorities‘to generate the required information for
proposals that are outside the list of facilities that require IPPC-type permit

8. USE THE MOMENTUM FOR A KISS-INSPIRED
REFORMS IN EIA/SEA SYSTEMS
š NEPA-type moment - no one really has a full picture of the practical implications
š Key role for env professionals who can e.g. can prepare Taxonomy-compliance certificate that
summarizes infomation from relevant processes
š Opportunity for honest debates on what works well and what could be KISSed (simplified or
improved)

9. A few friendly tips for follow-up
Reach out to other platforms used by stakeholders who will be subject to Sustainable
Finance Disclosure and Corporate Sustainability Reporting
Consider using HUSZPO as a platform for debate about potential KISS sollutions in the
EIA/SEA system?
Consider potential annual HUSZPO meetings and turn them into regular Davos-type
events discussing linkages between sustainable finance frameworks and the existing
environmental decision-making systems in Europe