Position paper on the Revision of the F-Gas Regulation

KEY MESSAGES

Eurelectric fully embraces the European Commission’s decarbonisation objectives and its ambition to cut F-gas emissions, which have a very high global warming potential. DSOs and electricity generation companies are committed to adopting a sustainable approach to the development and operation of their assets. Therefore, DSOs and generators are committed to adopting electrical SF6-free equipment for new installations.

Eurelectric welcomes the Commission’s prohibition of electrical switchgear with high GWP. The EC suggests phasing out these technologies following a transition period varied according to the voltage levels – this too supported by Eurelectric. However, to achieve these objectives without jeopardising network reinforcement, or the connection of ever more EVs, heat pumps, and renewables, Eurelectric recommends the following: 

• Regulation should not disrupt network operation, security of supply, or the EU’s decarbonisation process. The power sector and DSOs in particular have a key role in the EU’s decarbonisation. Anything that disrupts DSO operations will risk security of supply and jeopardise these efforts. In the next 8 years, the EU needs to deploy 750 GW of new wind and solar PV according to the Commission’s RePowerEU plan. This is more than twice what was achieved in the past decades. 70 % of this will be connected to distribution grids. Meanwhile, RePowerEU could add 100 TWh of electricity demand in the next 5 years which is unprecedented in the history of Europe. This will further strain the distribution grids. 

• Regulation should not limit competition. The current proposal could significantly limit competition in switchgear manufacturing in the EU. First, only one European HV switchgear manufacturer can supply solutions compliant with the proposal. Others who have already invested in different technologies during last 8 years will be left out. Second, there is only one compliant technology, which could create a ‘technology monopoly’ and a supply chain risk due to the limited number of suppliers. Establishing clear and comprehensive preconditions for POM (Placing on the market) prohibitions is necessary to avoid this situation. The preconditions in the draft proposal are inadequate, they must be clearer in the regulation of both standard and non-standard applications. Eurelectric considers the following preconditions essential:
  • For the relevant voltage level or application area, the availability of proven SF6 alternative solutions that fulfil common quality requirements must be ensured. These solutions must be compliant with IEC/CENELEC and other EU standards, tested by at least two pilot applications, and must not entail disproportionate costs to the users.
  • There must be at least two manufacturers providing proven solutions fulfilling common quality requirements with sufficient delivery capacities. These products must be offered for specific application areas. This ensures sufficient competition and production capacity for alternative technologies and avoids the risk of monopolistic market structures. Insufficient production capacity creates the risk of a significant delay in grid expansion which is urgently needed to integrate renewable energy resources and new types of end-user technologies.
• Reconsider the transition times for switchgear in the voltage level 12-24 kV: Eurelectric is deeply concerned that manufacturers will not be able to enlarge production capacities and deliver enough SF6-free switchgear for up to 24 kV from 1 January 2026 for the whole EU market. Therefore, this date should only apply to 12 kV. For voltage levels above 12 kV and up to 24 kV, the date should be postponed by two years.
• Clarify how to handle the dates of prohibition specified in Annex IV Nr. 23. Confirm that switchgear that does not fulfil the GWP requirements after the prohibition date specified in Annex IV Nr 23 but which was purchased and due to be delivered before this date can be installed and operated for its whole technical lifetime.
• Revise the GWP (Global Warming Potential) threshold from 10 to 1000 for voltage levels above 24 kV. The GWP value of 10 will exclude meaningful and worthwhile technologies which significantly reduce greenhouse gases in comparison to SF6. Some of these technologies have a GWP around 1000 which is significantly lower than SF6-based technologies. They will be needed when technologies with a GWP <10 cannot be used. It will be detrimental from an ecological and economic perspective to force switchgear operators to buy products with a GWP <10 if this implies that existing housing can no longer be used. This means developing new sites and changing the network topology which increases the carbon footprint and costs. 
• Clarify the status of SF6-free solutions (excluding vacuum ones). Eurelectric would like to stress that some alternative technologies are based on gases containing substances currently under regulatory assessment for the EU Chemicals Strategy for Sustainability. Coherence should be ensured to avoid prohibiting a solution which can be useful for some applications should SF6 be further restricted. As a no-regret option, a clear roadmap would provide visibility to the industry.
• Clarify the continuation of existing SF6 based installations until the end of their lifetime. The operation, maintenance, and repair of existing SF6 switchgear must be permitted until the end of their lifetime. While the Regulation is clear on the permission to buy the gas itself (Art. 11.5), it remains unclear on the procurement and installation of spare parts. Art 11.1 includes spare parts in the POM prohibition. It should be clarified that this prohibition does not apply to the parts for existing installations. Furthermore, the replacement and the expansion of existing Gas-insulated switchgear (e.g. addition of new circuit breaker cells) must also remain allowed during the entire lifetime of the switchgear. If existing switchgear were forcefully decommissioned prematurely because of a prohibition on the purchase of spare parts this would seriously endanger the security of supply.