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Eviny AS

Eviny

Promote renewable energy, especially hydro power, follow EU energy and climate policy processes with emphasis on electrification and production of renewable energy

Lobbying Activity

Response to EU taxonomy - Review of the environmental delegated act

4 Dec 2025

Eviny AS is a public owned renewable energy company based in Bergen on the west coast of Norway. We own and operate 44 Hydro Power Plants (HPP) with an installed capacity of 1981 MW and yearly production of 7300 GWh. We align with the submission provided by our industry association Renewables Norway and emphasize the need to clarify DNSH criteria 3 for hydropower. Compliance should be based on the Water Framework Directive as implemented by Member States, including justified use of less stringent objectives. Clear and consistent rules are essential to secure financing for hydropower, which is critical for Europes energy transition. In addition, we would like to stress that the purpose of water management plans and related programs under the Water Framework Directive is to identify and determine the measures necessary to achieve the environmental objectives for each water body, taking into account site-specific conditions and the societal value of water use. If current interpretations require producers to reassess these decisions independently, this will undermine the established governance system and create unnecessary duplication and uncertainty. A clear reference to existing legislation would ensure consistency, avoid double regulation, and support the efficient development of hydropower as a key enabler of the energy transition.
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Response to Net Zero Industry Act

5 Jun 2023

Eviny AS supports the proposal for a net Zero Industry Act. Europe needs to build capacity and competence in all net zero technologies to cope with the needs that arise in the energy transformation. Streamlining of permitting, improving investment certainty and access to market will facilitate industry growth, value creation and employment. Secure access to technologies and components needed for the energy transition is a prerequisite for energy security. Hydropower a strategic net zero technology: Hydropower is today the second-most important source of renewable electricity in Europe and accounts for 20% of the total generated electricity. Besides providing baseload, hydropower also provides flexibility and energy storage at high scale, long duration, and high degree of sustainability. In its Hydropower Special Market Report IEA points out these qualities: Hydropower today has a key role in the transition to clean energy not only through the massive quantities of low-carbon electricity it produces but also because of its unmatched capabilities for providing flexibility and storage. Hydropowers multiple roles in a renewable energy system, and the fact that a major share of components for hydropower is produced in Europe qualifies hydropower technology to be one of the strategic technologies listed in NZIA. Industry capacity and development of this technology is needed to enhance hydropower production and flexibility. Norways role: Norway has a strong energy-related industry and technological know-how. Electricity production is close to 100% renewable, and Norway is a net exporter of renewable electricity. Vast renewable energy resources are still to be developed, especially offshore wind. Access to industrial expertise and affordable renewable electricity makes Norway a competitive location for new net-zero industry and technologies. The offshore-oriented industry has a lot to offer a growing European off-shore wind industry. As a reliable partner of the EU and as signatory to the EEA-agreement Norway should be included in the Net-Zero Industry Platform, and the local content criterion for public procurement should include the EEA-area.
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Response to 2040 Climate Target Plan

5 Jun 2023

EUs climate ambitions and targets should be based on realistic assessments of what is achievable considering also other societal goals such as employment, nature protection and poverty reduction as well as energy security. It is therefor crucial that policies support cost effective solutions and technologies that provides for climate neutrality by 2050. In light of the global crisis (energy, climate, nature) it is important to keep the current pace. To raise the target could lead to serious distortions and be of harm to other societal goals, to lower them would harm our ability to reach the goal to be climate neutral in 2050. Climate neutrality is a dauting task, and to accomplish this we will need public support, financing and technological development that supports the transmission from a fossil based to a renewable energy system. All technologies that bring us forward are needed, but cost efficiency and societal impacts should be carefully assessed when the regulatory framework is developed. In this context we will highlight hydropower and its advantages to a future carbon neutral society. Hydropower provides affordable, dispatchable, and secure renewable energy. It has done so for more than 100 years; it provides 20% of Europes electricity today and its significance increases when new renewable energy sources grow. By offering flexibility in all time ranges hydropower enables system integration of large amounts of new renewable and intermittent energy. Besides its role in electricity production, hydropower is important for Europes industry and security of supply as a major share of components is produced in Europe. Water management, flood and drought control will be increasingly important in a future with more extreme weather events, hydropower is essential in this regard. On this backdrop we give our full support to the EU Hydropower Alliances letter to the European Commission 4th of May this year: We need an EU hydropower strategy. The value of hydropower should be reflected in the market design. Hydropower should be treated in the same way as other renewable sources in EUs regulatory framework.
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Meeting with Erik Bergkvist (Member of the European Parliament)

28 Feb 2023 · Möte

Response to Review of EU rules on fluorinated greenhouse gases

7 Jun 2022

Eviny AS welcomes the proposal to prohibit installation and replacement of electrical switchgear containing SF6 within the timeframe suggested in the proposal. In our opinion the suggestion will expand the market for climate friendly alternatives, speed up the technological development among manufacturers, create more competition and thus lead to a cost-effective transformation. But most importantly, it will cut emissions and hence, contribute to achieving Europe’s climate goals. Europe’s aim to be climate neutral in 2050 requires an extensive energy transformation and decarbonisation of the energy sector. Electrification will be a main driver. This will require a massive deployment of new production and infrastructure, especially grid connections. Switchgears have a long lifespan, and switchgears containing SF6 will carry with it the risk of GHG-emissions in decades to come. The time to prohibit switchgear containing this extremely aggressive greenhouse gas is now. The proposed regulation and the timeframes will, in our opinion, pave way for technological development and competition among switchgear producers that in turn will lead to a cost-effective roll-out of SF6-free switchgears. About Eviny – front runner in electrification: Eviny AS is a leading energy and infrastructure company in the Norwegian renewable industry. Our aim is to take responsibility for achieving a zero-carbon society. We produce, distribute and enable use of renewable electricity in all sectors of society. With an installed capacity of 1957MW we have an average year-production of 7571 GWh of sustainable hydropower. Our distribution grid operator BKK own and operate 22 000 km of power lines, reaching 260 000 customers on the west coast of Norway. In addition to this we offer solutions and services for electrification of transportation, shore power for ships, electrification of fish farms and more. Eviny shall contribute to a zero-emission society, and we shall reduce our own emissions by at least 50 percent in 2030. SF6 emissions constitutes a considerable part of our GHG-emissions varying from 11 percent in 2020 to 3 percent in 2021(scope 1). We work actively to improve our routines on handling of SF6 in existing equipment, and to replace this with SF6 free equipment. Eviny and its subsidiaries shall not purchase switchgears containing SF6 if there are available alternatives. For 132 kV switchgear this is available today, and by 2025 we expect there to be available alternatives on all voltage levels. We also want to explore the possibility to replace SF6 in existing equipment, but as for today this technology is not applicable in all our equipment. Eviny commissioned and installed the world’s first SF6-free 132 kV switchgear: When Port of Bergen and our subsidiary Plug decided to establish shore power for cruise ships it was necessary to upgrade the switchgear at Koengen transformer substation in Bergen from 45 kV to 132 kV operating level. Our grid operator BKK then commissioned a SF6 free switchgear and challenged the manufacturers to deliver. Two years ago, this switchgear was in operation. BKK has now two such switchgears in operation and three more are commissioned. This switchgear was the first of its kind. We experienced a few challenges regarding small particles and high pressures, but the manufacturer found a solution to this, and the switchgears are now functioning as prescribed. As a first mover we had higher costs then we would have had with a conventional switchgear. The decision to implement a SF6-free switchgear with its consequently higher costs, is in line with our company’s strategy to take responsibility for achieving a zero-carbon society and be a front runner in electrification.
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Response to Climate change mitigation and adaptation taxonomy

8 Dec 2020

BKK AS is a public owned renewable energy company based in Bergen on the west coast of Norway. We own and operate 38 Hydro Power Plants (HPP) with an installed capacity of 1900 MW and yearly production of 7489 GWh. We have developed and operated hydro power assets for a century. BKK AS welcomes EUs Sustainable Finance. Mobilizing capital to support the transition to a low-carbon and sustainable economy is key to reach our common climate, sustainability and competitiveness goals. We do, however, have some concerns: • The Draft Delegated Act and its Annexes do not follow the technology neutrality principles laid out in the mother regulation and the principles in the preface of the Draft Delegated Act. • The definitions of sustainable activities should unambiguously refer to relevant existing European legislation. We see a need to streamline the reference to relevant EU legislation for all energy production technologies. • The criteria on power density are unclear and can result in misleading assessment of hydropower plants. The energy transition requires that we develop and utilize all the relevant and cost-effective renewable technologies. In our view, all these technologies have an impact on climate and the environment. It is crucial that we assess how to mitigate negative impacts. However, it is important that this assessment is transparent and non-discriminatory. We observe that the suggested screening criteria is detailed and comprehensive when it comes to hydropower, in comparison with solar and wind power. We therefore ask that hydropower is considered equally to other renewable electricity generation technologies such as wind power and solar. Electricity generation from hydropower is the main source of generation in Norway and make up 96 % of power production in Norway. Norwegian hydropower is strongly regulated by national laws and regulations. On EU-level the Water Framework Directive (WFD) sets out a clear policy to protect waterways and the Environment. The environmental objectives in WFD, Art 4.1 – 4.9, cover operation of existing hydropower plants, as well as construction of new plants (Art. 4.7), while further details are elaborated within other articles and annexes, in particular WFD Annex V. While the Commissions recent assessment of the WFD concluded that the directive is fit for purpose and not in need for revision, we see that the suggested screening criteria for hydropower goes far beyond current legislation. Electricity generation from hydropower is a capital-intensive activity, and our hydropower plants have a long lifetime. Our first power plant was built over 100 years ago and is still in operation. It is crucial that investors and operators have a predictable regulatory framework. Hence, in our opinion the screening criteria for hydropower should be in accordance with current legislation, and not more extensive. This can be done by referring to the WFD to replace the comprehensive, although incomplete, text in the proposed regulation. Annexes I and II (Ch 4.5) sets out requirements for life-cycle GHG emissions and power density that must be met if the activity is to be considered sustainable. Similar requirements are not introduced for other renewable technologies. Although hydropower ranks low on life-cycle carbon footprint, we find it appropriate to comment on the criteria on power density. We do not think that this criterion is fit for purpose as it is defined. Based on our calculations on some of our own hydropower plants (se appendix) we think that these criteria could be misleading, and counterproductive to the overall purpose of the taxonomy. To avoid misleading assessment of hydropower plants contribution to climate change mitigation, specific criteria on power density equation and requirements for life-cycle analyses should be deleted to ensure technology neutrality as intended in Article 19/1a in the Taxonomy Regulation. Please see also attached Case Study Bergsdalen
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