Document QkY3rLEOO41vzK82gmGboqVXk

Deutsche Umwelthilfe e.V. | Hackescher Markt 4 | 10178 Berlin President of the European Commission Ursula von der Leyen Executive Vice-President Frans Timmermans Cc: Commissioner Kadri Simson Commissioner Virginijus Sinkevicius Commissioner Thierry Breton Executive Vice-President Margrethe Vestager Executive Vice-President Valdis Dombrovskis , Director General, DG Climate Action , Deputy Director General, DG Climate Action , Deputy Head of Unit, DG Climate Action BUNDESGESCHFTSSTELLE BERLIN Hackescher Markt 4 Eingang: Neue Promenade 3 10178 Berlin Tel. Fax @duh.de www.duh.de 21. March 2022 Revision of the EU F-Gas-Regulation: Ban SF6 from our future energy supply Dear President of the European Commission von der Leyen, Dear Executive Vice-President Timmermans, Putin's war in Ukraine shows quite plainly the negative impact of our dependency on fossil oil and gas. In order to end this dependency and to approach compliance with binding climate policy, the expansion of renewable energies becomes more exigent than ever. Apart from the immense demand for green electricity from industry, private households will play an increasingly important role: The growing share of e-mobility and the expansion of electricity-based heat pumps in buildings will lead to an increasing demand for electricity and its infrastructure. The expansion of this decentralized energy generation and increase in infrastructure entails an immense uptake of switchgear. Exemplarily for Germany, the growth rate of switchgear is expected to be 2 % every year until 2050. This uptake of switchgear would be synonymous with an increase of the most potent greenhouse gas, sulphur hexafluoride (SF6), which is used as insulating gas in switchgear. An increase in SF6 needs to be inhibited due to its strong climate impact: The Sixth Assessment Report of the IPCC underlines the issue of SF6. It has repeatedly upgraded the GWP value of SF6 to now 25.200 and determined an atmospheric lifetime of about 1000 years. Moreover, it states that atmospheric concentrations of SF6 are rising continuously, taking a millennium to degrade into less climate-impactful compounds. These alarming research results emphasize the urgent need for action. An increase of SF6 is in strong contrast to EU climate targets; a switch to climate and environmentally friendly alternatives for SF6 needed urgently. SF6-free alternatives are market-ready and available for a wide portfolio of middle and high voltage switchgear. Particularly in regards to the expansion of renewables, this sustainable energy generation must be combined with a likewise sustainable power distribution without the most potent greenhouse gas on earth. Deutsche Umwelthilfe e.V. | Bundesgeschftsfhrer: Vorstand: Geschftskonto: , Spendenkonto: , | VR: Hannover Nr. 202112 Die Deutsche Umwelthilfe e.V. ist als gemeinntzig anerkannt. Das DZI Spenden-Siegel ist das Gtesiegel fr serise Spendenorganisationen. Currently, the revision of the European F-gas regulation (EU) 517/2014 offers a substantial opportunity to introduce strict bans and containment measures for SF6-based switchgear. This includes immediate sectoral bans for new switchgear containing SF6 and other fluorinated substitutes up to 145 kV and prospective bans with ambitious transition periods for SF6 application over 145 kV. We urge you to push for a climate-friendly and strong revision of the regulation. We must not leave future generations with the burden of SF6 emissions. Similarly to many other sectors where F-gases are used, we see the risk of establishing fluorinated substitutes rather than F-gas free climate- and eco-friendly alternatives. In the switchgear industry, companies and grid operators increasingly use perfluorinated nitrile and perfluorinated ketone instead of SF6 as a drop in solution. Although these have lower GWP values compared to SF6, both substitutes belong to the problematic group of per- and polyfluoroalkyl substances (PFAS). PFAS are "forever chemicals", since their lifetime is around 1,000 years before they degrade. Accordingly, they accumulate increasingly in our ecosystems. Experts worldwide, including the European Chemicals Agency, express their concerns, identifying PFAS as a global threat to human and environmental health. PFAS are linked to many adverse health and environmental effects such as kidney cancer and ground water contamination, and research on them is just in the beginning. Following the precautionary principle, SF6-free substitutes, which are PFAS, are no alternatives for SF6 applications. It is crucial to raise awareness for the issues of PFAS substitutes and to succeed the SF6 phase-out with fully sustainable alternatives. More and more companies increase their efforts to operate sustainably and an upswing for sustainable alternatives appears in every industry. With the revision of the EU F-gas regulation, the time is right for businesses to move forward and this can be seen already: Leading switchgear manufacturers are ambitious frontrunners in the debate on SF6 and PFAS-free technologies and demand stricter regulations for SF6 and PFAS substitutes. Right now, it is time for political leaders to show ambition and to enable the change towards a truly sustainable and future-proof energy supply. Thank you for considering these views. Yours sincerely, CEO, Deutsche Umwelthilfe e.V. Annex: DUH Backgroundpaper on SF6