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VGB PowerTech e.V.

VGB

Der VGB ist der technische Verband der Energieanlagen-Betreiber.

Lobbying Activity

Response to Revision of the Machinery Directive

8 Jul 2021

In der Praxis treten immer wieder Fragen in Bezug auf den Anwendungsbereich, die Abgrenzung gegenüber Anforderungen aus anderen Rechtsbereichen, die Verwendung von unvollständigen Maschinen und die Herstellung für den Eigengebrauch auf. Dies führt bei den Beteiligten zu großer Unsicherheit und erfordert regelmäßig erheblichen Klärungsaufwand. Daher wird diesbezüglich eine Anpassung angeregt, damit die neue Verordnung aus sich selbst heraus besser verständlich und so eindeutig ist, dass der Interpretationsspielraum minimiert wird. Eine ausführliche Stellungnahme finden Sie im Anhang.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Comments of VGB VGB 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. VGB | Hydro represents leading companies from the European hydropower sector (74 operator, 19 suppliers, 22 consultants) and is part of the VGB PowerTech e.V., the international technical association of power and heat with more than 430 members. VGB | Hydro functions as first address for interested parties in techno-economic and ecological challenges regarding hydropower in Europe and has a close cooperation with Eurelectric for topics on EU-level. We welcome that hydropower is classified as sustainable renewable technology that contributes substantially to climate change mitigation and adaptation. However, we are concerned about the technical screening criteria and the general assessment of hydropower for its classification as a fully sustainable technology. The screening criteria for hydropower should be in accordance with current EU legislation. In contrast to other renewables defined in the Renewables Energy Directive, hydropower has to comply with general technical screening criteria to prove that lifecycle emissions are below the threshold or that the power density is above 5 W/m². In addition, hydropower is missing in Section 7.6. “Installation, maintenance and repair of renewable energy technologies”. Furthermore, hydropower is subject to environmental requirements under the ‘Do no significant harm (DNSH)’ criteria that are not aligned with existing EU law such as the Water Framework Directive. Also, the technical screening criteria and DNSH-criteria remain vaguely defined in practical terms, which makes the fulfilment of the criteria difficult to prove. Establish a fair level playing field for renewables and storage technologies. Treating hydropower and pumped hydro storage unequal compared with other renewables will not only hamper development of sustainable hydropower and other renewables within the EU and thus put a central and enabling element of the safe energy transition in question. It even may lead to a loss of flexible clean electricity needed in keeping the level of security of supply. Refer within the Delegated Act and its Annexes only to existing EU environmental legislation. This could facilitate the application of the EU taxonomy in case EU environmental legislation is updated and further contribute to “the export” of EU environmental standards to non-EU countries while imbalances, double standards and additional burden would affect the opposite. An unbalanced approach in taxonomy with an additional "burden of proof” would be a clear competitive disadvantage (e.g. manufacturers) on international markets compared to competition from non-EU countries. All electricity storage technologies should be classified as economic activities making a significant contribution to mitigating climate change and not as enabling activities. The draft Delegated Act and its Annexes fail to put forth a technology-neutral approach for electricity storage technologies. No differentiation should be made between “mixed“ and “closed-loop” pumped storage. Closed-loop hydropower storage is a niche in Europe, nearly all existing pumped storage assets have either natural inflow or are connected to river bodies. They provide valuable grid services and play an important role for grid stabilization. In all, we find the draft in terms of content unbalanced and it should not be adopted in the current form. Therefore, we fully support the detailed adjustment proposals of Eurelectric (see Attachment) and we ask the EU Commission to amend the proposed Delegated Act so that - it ensures technology neutrality as foreseen by the Taxonomy Regulation - it complies with and refers to existing EU law only - it ensures that the EU climate and energy objectives can be met Thank you for considering our aspects
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