ENTSO-E would like therefore to express its concerns related to the latest draft and the process of this legislation and requests the European Commission to consider the following recommendations:
To postpone approval of the draft regulation until further impact assessment and studies are performed. The regulation initially targeted only the medium voltage transformers and consequently the TSOs and other high voltage transformers’ users experience and suggestions were not sought and considered.
To exclude transformers above 100 MVA from the scope of the present legislation. Since all large transformers are currently highly efficient, establishing one single set of ambitious values covering all types of units may be too restrictive. Instead ENTSO-E recommends setting a minimum energy efficiency level ensuring in this way that all the units, independent of their capacity, will least reach the desired efficiency threshold.
The full ENTSO-E position paper can be accessed here.