CAN EECCA and Ecostan News reaction to low-carbon strategy of Kazakhstan.
CAN EECCA and Ecostan News share their reaction to the adopted strategy and updated Nationally Determined Contribution (NDC) of Kazakhstan. We also present some remarks voiced by Kazakhstani eco-activists that were not taken into account by the developers.
On February 2, 2023, President Tokayev approved the country’s low-carbon development strategy. Its official title is “Strategy for Achieving Carbon Neutrality of the Republic of Kazakhstan by 2060.” The Ministry of Ecology and Natural Resources initially developed the strategy, followed by the Ministry of National Economy of Kazakhstan. The draft strategy went through several rounds of public discussion; however, the public’s comments were not significantly considered.
On April 19, the Government of Kazakhstan adopted the updated document of the country’s Nationally Determined Contribution (NDC) to global climate response. In the international negotiation process, such country commitments are referred to as Nationally Determined Contributions or NDCs.
Thesis #1: “However, simultaneously with significant reserves and active use of fossil fuel energy resources, Kazakhstan has significant potential for the development of renewable and alternative energy, namely wind, solar, geothermal, nuclear, hydrogen, and bioenergy. Atomic power plants will be included in the power structure as a stable energy source, so a long-term vision for the development of atomic energy will be developed.”
Comments: We are pleased that the potential of renewable energy is recognized as a priority for decarbonization. However, we do not support the idea of developing nuclear energy in Kazakhstan. Recently, the CAN EECCA released an official position on this matter, which includes 16 arguments against the use of nuclear power plants as a climate and energy solution.
The principle of “Nuclear energy regardless of anything” could result in a tragedy for the entire region. For example, in the case of building nuclear power plants on the shores of Lake Balkhash and in the event of an accident, the ecosystems and population of the entire Balkhash-Alakol basin, which includes the megacity of Almaty, could be affected.
Moreover, the construction of one or several large nuclear power plants will not solve the main problem of providing electricity and heat to Kazakhstanis, which is the centralized distribution through mostly worn-out infrastructure.
Thesis #2: “The implementation of the Strategy is based on the following principles:
Just transition: creating new opportunities in regions affected by decarbonization policies, with targeted support for the population;
Openness and engagement with society: broad involvement of all stakeholders at all levels of monitoring and decision-making, including representatives from central and local authorities, quasi-governmental sectors, science, business (associations and enterprises), non-governmental organizations, and local communities.”
Comments: The strategy includes good implementation principles, namely a just transition and engagement with society. We look forward to the plan of action for implementing this strategy being open for public discussion to ensure that these principles are reflected in the planned activities.
Thesis #3: “The largest reduction in GHG emissions in the energy sector will be achieved by shifting towards more sustainable energy sources: gradually reducing the volume of fossil fuels and transitioning to the use of electricity and heat instead of direct fossil fuel combustion. Decarbonizing the energy sector requires the use of natural gas as an intermediate fuel, and for this purpose, geological exploration will be conducted to identify new gas deposits. Alternative and renewable energy sources will receive active development during the decarbonization process.”
Comments: As evident from this thesis, Kazakhstan does not plan to abandon gas extraction in the near future and, moreover, intends to use it as a transitional fuel or a fuel that supposedly allows for a transition to clean energy. There has been ample discussion about how gas serves as a barrier rather than a bridge to energy transition. We would like to draw the attention of decision-makers to the fact that using natural gas as an intermediate fuel prolongs Kazakhstan’s dependence on fossil fuels.
However, Kazakhstan also recognizes the importance of developing alternative energy sources and reducing dependence on gas, oil, and coal. The Government of Kazakhstan is actively working to increase the share of renewable energy in the country’s energy balance. In 2018, the “Green Economy Development Strategy of Kazakhstan until 2050” was adopted, which envisages increasing the share of renewable energy to 50% by 2050. Currently, the share of renewable energy generation in the overall electricity production balance is 4.5%. We welcome this progress!
Thesis #4: “In the coal mining sector, the reduction in GHG emissions will occur through a decrease in coal usage in other economic sectors. At the same time, due to sufficient coal reserves in the country, a long-term vision for alternative coal utilization will be developed.”
Comments: This quote from the strategy sounds ambiguous. What does “alternative coal utilization” mean? We are concerned that this formulation may be a form of greenwashing by the coal lobby, which promotes the idea of “alternative coal utilization” as an alternative energy source. In any case, even understanding the full harm and damage caused by coal usage, Kazakhstan is not prepared to set a date for phasing out this dirty fuel.
Thesis #5: “In connection with this, a vision will be developed for decommissioning coal-fired power plants with remaining operational lifetimes of over 30 years and implementing carbon capture and storage technology for those units that will continue operating after 2035.”
Comments: Out of Kazakhstan’s 68 thermal power plants, 28 operate on coal with an average age of 55 years. Thus, this could mean the closure of almost all coal-fired power plants. We eagerly await the emergence of a just transition strategy, with socio-economic analysis for all regions where coal-fired power plants are planned to be phased out.
Thesis #6: “Centralized heat production will be decarbonized through a shift from coal to natural gas, the use of renewable energy such as geothermal energy (heat pumps) and biofuels. Decentralized (individual) autonomous heating systems will become the main target of technological changes. In the medium and long term, geothermal energy and hot water supply through solar energy will be actively developed, and a vision for their development will be formulated.”
Comments: We welcome plans for the development of decentralized renewable energy sources to meet the needs of rural populations and eagerly await the availability of the corresponding vision for public review. We are also pleased with the opportunity to utilize small-scale renewable energy sources in the Concept for Rural Territory Development for 2023-2027, which was approved by the Government of Kazakhstan on March 28. However, currently, rural populations in Kazakhstan still heat their homes by burning coal and various types of waste.
- During the public discussion of the strategy draft, many commentators criticized the lack of references to information sources. The authors of the strategy responded to this criticism consistently, stating, “The Strategy uses official data and widely known facts, and therefore, we believe there is no urgent need for active use of references, as the Strategy is a high-level document aimed at implementing policy decisions.” Unfortunately, such an approach creates opportunities for data manipulation.
- Some commentators pointed out that the strategic document does not meet the requirements of the recent IPCC Assessment Report. According to climate scientists from the Intergovernmental Panel on Climate Change (IPCC), to keep global warming at 1.5 degrees Celsius, the international community must reduce greenhouse gas emissions by 50% by 2030 compared to 2019 levels. If we are willing to take the risk and allow a temperature increase of 2 degrees, we still need to reduce emissions by 25% by 2030. However, according to this strategy, Kazakhstan intends to reduce emissions by only 15% by 2030 compared to 1990 levels, which is critically unambitious.
- During the public discussion of the strategy draft, environmental activists noted the absence of a section on adaptation and goals for ecosystem restoration in the document. The developers’ response was that this document lays the foundation for future adaptation policy rather than defining it.
The component on adaptation, including ecosystem restoration as one of the adaptation measures, appeared in the updated National Adaptation Plan. We hope that the roadmap for implementing the National Adaptation Plan, frequently referenced in the document, will soon be made publicly available and have a legal status that allows other government agencies to follow it.
Meanwhile, we welcome the inclusion of a chapter on climate change adaptation governance in Kazakhstan’s Environmental Code. We are also pleased to see the inclusion of an activity to develop climate change adaptation measures in the action plan for the recently adopted Concept for the Development of Rural Territories, with a deadline set for November 2023. We urge the Government of Kazakhstan to enhance the capacity of national and local executive bodies in climate change adaptation and to engage the expertise of civil society organizations working in this field.
- The strategy places significant emphasis, as seen in its earlier version, on increasing carbon sequestration. According to the developers’ plan, this should be achieved through planting 2 billion trees. According to the national project “Green Kazakhstan,” this number should be planted by 2025.
However, as reported by representatives of the Public Council under the Ministry of Ecology, the cost of planting a single tree is already inflated by twice, and there are concerns that, at best, only 1 billion trees will be planted. Moreover, the issue of the survival and care of this billion trees remains open.
- The Association “Ecoforum Kazakhstan” submitted its remarks through the “Open NPA” platform during the public discussion and directly addressed them to the developers (a file with their statement can be attached). They also voiced their concerns during the meeting of the Public Council under the Ministry of Ecology and Natural Resources of Kazakhstan. We are particularly interested in the developers’ response to the remarks regarding the development of nuclear energy. We would like to comment on these responses.
“Regarding the proposals for the development of nuclear power plants (NPPs) in Kazakhstan, the position of the United Nations Framework Convention on Climate Change (UNFCCC) and the Paris Agreement has already been formed: NPPs are not a climate solution! It is sufficient to mention the fact that representatives of nuclear energy were not even allowed to participate in the climate change negotiations in Glasgow. Numerous authoritative international institutions have also demonstrated that nuclear energy is much more expensive than energy efficiency and renewable energy sources (RES), significantly increases risks to the economy and public health, shifts the costs onto construction and the growing expenses of storing radioactive waste for future generations. Such a proposal in the Strategy is politically erroneous, burdensome for the country’s population, significantly reduces national security, and demonstrates our country’s dependence on military and nuclear lobbies.”
Excerpts from the developers’ response and our comments on them:
“According to the European Union’s green taxonomy, nuclear power plants (NPPs) are considered a technology with no greenhouse gas emissions.”
- We would like to remind that this decision is currently being challenged in European courts. Last year, eight non-governmental organizations sued the European Commission for including nuclear and gas energy in the green taxonomy.
“Proper operation of NPPs mitigates the risks associated with their operation. This has already been proven by the successful operation of the BN-350 in the city of Aktau for 25 years. Moreover, the technology used in Aktau (a fast neutron reactor) is the most complex among the existing types of technologies.”
- Preliminary estimates indicate that it would require 131 billion tenge (almost 300,000 USD) to bring the nuclear power plant facilities into a safe state. Conveniently, this response fails to mention that the reason for shutting down the reactor in Aktau after 25 years of service was the risks associated with the potential use of uranium for nuclear weapons production.
“NPPs do not release pollutants into the atmosphere that negatively impact public health. Furthermore, coal generation, at the same capacity, has significantly higher levels of radioactive substances contained in coal. From an economic perspective, NPPs are also more preferable to renewable energy sources as they contribute to the development of industries such as medicine, food industry, agriculture, materials science, and many others. NPPs create opportunities for a wide range of research and development activities that lead to new types of economic activities. Thus, being a cheaper form of energy, NPPs also generate additional products through related industries, which are not considered when calculating the electricity costs. It is also necessary to add that Kazakhstan is a leader in uranium fuel production, which positively affects the cost of energy from NPPs. It should be noted that radioactive waste is actually not waste but a valuable source of chemical elements for future generations. Currently, scientific research is being conducted worldwide to utilize radioactive waste for future economic development purposes.”
- Nuclear power is not a zero-emission energy source. The carbon footprint of nuclear energy can average around 66 grams of CO2 equivalent per kilowatt-hour of electricity generated, which, according to several estimates, is higher than the carbon footprint of wind power and comparable to solar photovoltaic power. Therefore, nuclear energy does not have significant advantages over renewable energy sources in this regard.
- The cost of nuclear energy is increasing, while the cost of renewables is decreasing. In the United States, the unsubsidized average production costs of solar energy decreased by 90% and wind energy by 72% from 2009 to 2021, while the cost of nuclear energy increased by 36%. The cost increase of nuclear energy is often not apparent as many of its components are shifted to government budgets, and energy prices may be regulated by the state.
- There are still no known reliable long-term solutions for the isolation of radioactive waste. These wastes remain hazardous for hundreds and thousands of years. The remediation of the historical uranium tailings site in Mangistau, for instance, faced difficulties in finding funding for a long time, and when it finally started in 2021, there was insufficient funding to complete it.
“As for military and nuclear lobbying, there are not enough grounds to assume the emergence of this situation in the future.”
- Placing an entire region under the dependence of a large nuclear power plant means becoming dependent on nuclear lobbying. We can observe how nuclear energy facilities are used in armed conflicts, as demonstrated by Russia’s actions in Ukraine.
Kazakhstan’s new low-carbon strategy is undoubtedly an important step towards climate and environmental protection. The fact that Kazakhstan has developed and adopted such a strategy, committing to carbon neutrality, reflects a high level of awareness of climate threats and international climate policy trends.
In the near future, every country aspiring to develop and build international partnerships will set a goal of climate neutrality. However, to successfully achieve such a goal, it is necessary to ensure a broad consultative process and support from all stakeholders. Special attention should be given to the development of renewable energy sources, improving energy efficiency and conservation, and preserving ecosystems.
CAN EECCA and Ecostan News, as representatives of the environmental community, support the overall direction of the new low-carbon strategy and will monitor its implementation. Civil society organizations and individual eco-activists can play a key role in informing the public about the importance of such a strategy, drawing attention to socio-environmental problems arising from climate change, and the vital necessity of adapting to these changes.
Overall, if Kazakhstan adheres to the new low-carbon strategy, timely and openly adjusts it, and ultimately successfully implements it, it will lead to a real reduction in greenhouse gas emissions and improve the environmental situation in the country. It can also serve as an example for other countries in the fight against climate change and environmental protection.
Position was written by:
Aliya Wedelich, Editor at Ecostan News, Kazakhstan
Olha Boiko, coordinator of CAN EECCA
For more information, please contact Baktygul Chynybaeva, Communication Manager of CAN EECCA