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SYNERGRID, Fédération des Gestionnaires de Réseaux Electricité et Gaz en Belgique

Synergrid, the Belgian Federation of Electricity and Gas System Operators, is committed to safeguard the common interests of its members, the Belgian Transmission System Operators (TSO’s: Elia, Fluxys) and Distribution System Operators (DSO’s).

Lobbying Activity

Meeting with Kathleen Van Brempt (Member of the European Parliament) and AGORIA and

21 Jan 2025 · Rondetafel industrieel beleid, clean industrial deal en blik op komende wetgeving

Response to Update of minimum requirements for certification programmes for switchgear

11 Oct 2024

The revised F-gas Regulation (EU) 2024/573, compared to its predecessor, considers an extended set of substances (potentially) applied in stationary electrical switchgears; next to SF6, also gas mixtures which contains F-gases mentioned in Annex I are put in the scope of the Regulation. The scope of certification, as addressed in the draft Implementing Regulation at hand and repealing Implementing Regulation (EU) 2015/2066, is extended accordingly as well, referring to gases and gas mixtures. In this context, it is important to note that the scope of Implementing Regulation (EU) 2015/2066, forming the legal basis for todays certification, was referring to SF6 only. This is indeed relevant to consider, as the draft rules for certification, in accordance with Art. 3 of the draft Implementing Regulation and specified in Annex I, do not distinguish between the various possible gases and gas mixture types, but requires theoretical and practical tests for both, gases and gas mixtures. Practically, this means that a natural person that requires certification for an asset containing SF6 (a single gas) only would also have to undergo certification for gas mixes (e.g. mixtures containing fluornitrils), even though handling gas mixtures is not part of a given persons tasks (or a companys asset base), and vice versa. It is therefore of utmost importance that the Implementing Regulation distinguishes between certification for the different types, as otherwise - natural persons requiring certification for one specific type of gas or gas mixture need to undergo practical training and tests for gases and / or gas mixtures that are beyond his or her given tasks, leading to unproportional training and test requirements with unnecessary increased personal health and safety risks; - certification bodies that are set-up for certifying the handling of a specific gas (or gas mixture), such as SF6, would need to consider and install other F-gas containing assets and gas handling equipment for training and testing purposes, even though the related gas / gas mixture might not even be applied in assets in a given region. Therefore, to avoid disproportional and unnecessary burden for certification bodies and natural persons requiring certification alike, the revised Implementing Regulation must ensure that certification and in particular related practical training and tests can be set up for individual gases / gas mixtures. Further context: Distribution and transmission system operators in (at least) Belgium are currently organized to let their workforce perform related tests with a singular gas, namely SF6, considering its prevalent use as of today. Given the phase out of F-gas containing gas mixtures due to the cascading principle and the ban on F-gases below 52 kV (as defined in article 13.9 of the F-gas Regulation), a phase out of gas mixtures with F-gases is to be expected in the short to mid-term, making an obligation for training and tests for ALL gases and gas mixtures even more obsolete for natural persons who only operate assets containing a singular gas (first and foremost SF6 in our case, as stated before). The certification for gas mixtures (e.g. fluornitril) will be limited to people working on very specific Gas Insulated Switchgear (GIS) installations in the high and very high voltage range. This also results in a limited need of training sites where the training and practical test of the certification for gas mixtures can be performed. Given the limited and decreasing use of F-gas containing gas mixtures, we propose to clearly specify the scope of a certificate in article 3 as to allow certification on a single gas (e.g. SF6) and/or a specific gas mixture.
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Response to Proposal for a legislative act on methane leakage in the energy sector

12 Apr 2022

Synergrid is focusing in its response on the: • Regulation on methane emissions reduction in the energy sector. Our paper and response starts with a general position on the proposed EU legislation, followed by the main attention points in the new proposed legislation. Amended text proposals can be found in the Annex I (still in elaboration). Paper in attachment.
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Response to Revision of EU rules on Gas

12 Apr 2022

Synergrid is focusing in its response mainly on the: • Directive on common rules for the internal markets in renewable and natural gases and in hydrogen. • Regulation on the internal markets for renewable and natural gases and for hydrogen. Our paper and response starts with a general position on the proposed EU legislation, followed by the main attention points in the new proposed legislation. The energy landscape scheme promoted by the Belgian TSOs and DSOs can be found in Annex I. Amended text proposals for the Directive on common rules for the internal markets in renewable and natural gases and in hydrogen can be found in the Annex II. Paper is attached.
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Response to Revision of EU rules on Gas

12 Apr 2022

Synergrid is focusing in its response mainly on the: • Directive on common rules for the internal markets in renewable and natural gases and in hydrogen. • Regulation on the internal markets for renewable and natural gases and for hydrogen. Our paper and response starts with a general position on the proposed EU legislation, followed by the main attention points in the new proposed legislation. The energy landscape scheme promoted by the Belgian TSOs and DSOs can be found in Annex I. Amended text proposals on the Regulation on the internal markets for renewable and natural gases and for hydrogen can be found in the Annex II. Paper is attached.
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

Synergrid is the Belgian association representing all Belgian TSOs and DSOs (electricity and gas). In our response we are focussing mainly on article 25 about energy transformation, transmission and distribution in the recast EED. Synergrid can comfortably state that energy efficiency runs already for many years through the ‘veins’ of its member companies. Our members already push for greater efficiency in the way they perform their activities. When doing so, energy efficiency is linked to many other considerations that are complementarily taken into account by system operators when carrying out their multiple tasks and duties. Regarding the EED proposal, Synergrid would therefore like to highlight the following main messages: 1. As an overarching principle, the Energy Efficiency First principle must be approached in a proportionate way, taking a holistic approach. While energy efficiency related solutions are certainly key to achieve decarbonisation objectives, other legitimate and valid objectives (system security, reduction of CO2 emissions, market integration, sector coupling, etc..) also need to be given appropriate consideration and should not be set aside or see their significance diminished. 2. The application of the EE1st principle to both NRAs and system operators enhances the guarantees which are already provided by the current legal framework. Furthermore, demand response, flexibility, optimisation of the use of existing infrastructure first and creation of synergies between carriers is also a way of increasing market efficiency and reducing the risk of investing in stranded assets. The proposed provision regarding stranded assets should therefore be deleted. 3. The foreseen requirements in Art.25, §3 of the EED proposal related to network loss reduction are not adapted to the realities of the energy transition and the evolution towards a sustainable energy system. Network loss reduction should not be the focal point for network development, operation and maintenance activities. A “holistic” approach, including with respect to the future changes and evolution of the “energy system” is to be taken when referring to network losses. 4. In order to promote and guarantee efficiency of processes related to network planning, including as regards application of the EE1st principle, the methodologies on how to assess alternatives in the cost-benefit analysis (“CBA”) should be developed and provided by network operators, while ensuring a proper monitoring competence as to their implementation for the National Regulatory Authorities (“NRAs”); 5. Energy efficiency should be one amongst other criteria that are to be taken into account in the context of tariff methodologies or tariff related decisions.
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Response to Proposal for a legislative act on methane leakage in the energy sector

26 Jan 2021

Synergrid, Association representing the Belgian gas TSO Fluxys and DSO’s Fluvius, Ores, Resa and Sibelga welcomes the possibility to provide feedback to this public consultation and acknowledge the efforts of the EC to accelerate methane emissions reduction to support the EU’s climate ambition for 2030 and its 2050 climate neutrality objective. We recognise the potential benefits of the holistic approach on methane emissions covering energy, agriculture and waste sectors, which will contribute to exploit the synergies and to help avoiding emissions. Avoiding leaks and the reduction of methane emissions has always been a high priority objective of the Belgian gas TSO and DSO’s. LDAR is part of our core business. Decades ago, LDAR was performed mostly for safety raisons, but in recent years, the environmental aspects became also more important. Synergrid and its members are also intensively involved in several European and International Organisations dealing with methane emissions, such as GERG, GIE, MARCOGAZ, CEDEC, OGMP, MGP, … The implementation of a well-structured, harmonised, fit for purpose MRV (measurement, reporting and verification) system in the EU, will foster the transparency, improve the reporting accuracy as well as the credibility of the data. It will also allow a fair goal setting for the reduction of methane emissions taking into account the efforts already done. We support an EU legislation to be applicable to the full energy supply chains (from production, upstream, mid and downstream, excluding utilisation), and including as well the gas, oil, coal sector and the biogas/biomethane production plants. Renewable gases like synthetic methane, biogas, biomethane will become more important in the future and their effectiveness on the global methane emissions should be taken into account. This European legislation should include already performed work by the European Gas Organisations and could be supported by harmonised documents. However, this legislation should take care and recognise the specific differences between the different sectors, the differences over the chain, and also the differences between the different continents. As regulated entities, we welcome a harmonised European legislation engaging the Member States and National Regulators in order to avoid emissions reporting duplications and/or individual local debates. It is important to highlight (as already mentioned in the communication COM(2020) 663) that the investments on MRV, LDAR and mitigation measures undertaken by infrastructure operators should be recognised within the scope of regulated activities. Concerning the mitigation measures, we agree that priority could be given to the harmonisation of the LDAR programmes (Leak Detection And Repair) and the routine venting and flaring mitigation with regards to the operational conditions. Legislation about LDAR should be ‘smart’, efficient and affordable taking into account risk assessment which should be based on experience, historical data, type of material, the environment and local situation. The members of Synergrid stand ready to offer their expertise in this field to help achieving the climate neutrality objective.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

SYNERGRID reply to EC public consultation Draft delegated Act on Taxonomy – climate change mitigation and climate change adaptation Synergrid supports globally the delegated acts on climate change mitigation and adaptation and specifically the Annex I, chapters 4.9 and 4.14 in its current reading. We would however like to enhance the coherence with others European texts such as The Clean Energy Package and more specifically the new Electricity Directive (EU) 2019/944 (DIR), new TEN-E draft, REDII, …but also the Taxonomy regulation (*), to avoid potential legal and interpretation difficulties in the next phase of implementation. Terms, definitions and concepts are not always aligned, in electricity and especially in gas and DA do not take in consideration these specific texts. Annex 1 : Chapter 4.9 : The electricity transmission and distribution activities must be read either on the basis on the article 10 (a) either on the article 10 (g), that is to say : as an activity in se that contributes substantially to climate change mitigation. In other words, the text of the delegated act on mitigation (Annex I) as proposed conflicts with the wording of Article 10 of the Taxonomy Regulation. The delegated act qualifies transmission and distribution of electricity as “enabling activities”, whereas Article 10 of the Regulation explicitly recognises that transmitting and distributing renewable energy contributes ( directly, in se ) substantially to climate change mitigation (Art. 10.1.(a)). With the current wording, it would be difficult to assess what activities concretely would be categorized as having ‘direct substantial contribution’ or ‘enabling’ at a later stage for the purpose of implementation of other related activities, e.g. in non-financial reporting in accordance with the Regulation. Amendment proposal: In the description of the activity: p. 118 of the draft delegated act delete the sentence - as it is done for chapter 4.14 in the same Annex 1 - : The activity is an enabling activity in accordance with Article 10(1), point (i), of Regulation (EU) 2020/852 where it complies with the technical screening criteria set out in this Section. Justification: Clarification to ensure alignment with the Taxonomy Regulation art. 10 (1) ( a) and (1) (g) as the economic activity described in chapter 4.9, construction and operation of transmission/distribution systems, may also itself make a substantial contribution (own performance activity) pursuant to Art. 10 (1a) and (1g). Annex 1 : chapter 4.14 : Transmission and distribution of renewable and low-carbon gases: We welcome the inclusion of distribution of these types of gases among the sustainable activities, also considering the investments necessary to reduce methane emissions in existing gas pipes (e.g. LDAR). However, we worry about the possible confusion on the use of the words “renewable and low-carbon gases”: contrary to the title of section 4.14, the descriptive part systematically uses the formula “hydrogen or other low-carbon gases” which could misinterpreted (hydrogen as low-carbon gas). We recommend therefore to replace “hydrogen or other low-carbon gases” by “renewable and low-carbon gases”, thus including other forms of renewable gases such as biomethane. Biomethane is an important sustainable substitute of fossil gas, with an important role to play in the circular economy. We propose also to include the retrofitting and conversion of current gas storage and LNG terminal infrastructures for renewable and low-carbon gases as taxonomy eligible to enhance investor confidence and lower costs of the energy transition. See Annex to this paper for comments on chapter 4.14 _______________________ (*) (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088)
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Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

Synergrid response to Commission Delegated Regulation on climate change mitigation and adaptation taxonomy https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12302-Climate-change-mitigation-and-adaptation-taxonomy ________________________________________________________________________________ Synergrid ( Belgian Federation of electricity and gas TSO and DSO) and her members share the EU’s climate neutrality objective by 2050. We welcome the European Commission’s efforts to mobilise the financial sector towards a prosperous and sustainable Europe and are committed to fulfil the European Union objectives whilst guaranteeing the supply of affordable energy for all citizens. The taxonomy, cornerstone of the EU sustainable finance, will have a wide-ranging impact on the European energy sector and will be key for a successful European energy transition. Therefore, when drafting the respective delegated acts, it is crucial to carefully consider all potentially sustainable activities and avoid legal uncertainty in order to steer investments in these sectors. The screening criteria for economic activities must be based on technology neutrality with the aim not to prevent further future technological developments contributing to a decarbonization of the European energy sector and industry. Synregrid and her members share the view of the European Commission that hydrogen will play a key role in the EU Green Deal, in particular in decarbonising sectors difficult to decarbonise with electricity. We kindly ask for consideration of the following requests and clarifications. Synergrid would like to suggest the inclusion of the following as sustainable activities: • The transmission, distribution and gas storage infrastructures fit to transport,distribute and store hydrogen, biomethane and other decarbonised gases. TEG has defined the transmission and distribution of electrons. It should also be defined the same way for molecules and the corresponding mitigation criteria. • The operation and where necessary construction of new infrastructure that connects production facilities of renewable/low carbon gases to the existing gas infrastructure as well dedicated infrastructure for hydrogen. This will foster the transition from natural gas to renewable and low carbon gases. TEG report excludes any gas network construction and expansion independent of the transported gas and its CO2-content, while including the manufacture of hydrogen and biomethane for example. • The retrofitting and upgrading of current gas storage infrastructures for renewable and low carbon gases to enhance investor confidence and lower costs of the energy transition. Gas transmission, distribution and storage infrastructures are able to provide necessary flexibility to the market at an affordable price. • The operation and construction of LNG applications for maritime and heavy-duty transport. The transport of goods will be the result of the most efficient combination between shipping, road and railway. Already today, LNG is the universally clean, sustainable, affordable, available and flexible solution to decarbonize this multimodal system. These LNG applications are already fit for bio-LNG, Liquefied synthetic methane, … and will contribute to the decarbonisation of transport sector. • Investments in “virtual piping” should be fostered, regarding the pooling of treatment infrastructures for biogas. This would reduce financial barriers for small producers of biogas and avoid unprofitable network extension. Contact : Christine Declercq – Email : christine.declercq@synergrid.be Public identification number Synergrid : 850726637028-25
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