Day: August 15, 2022

The Platform for electromobility is pleased to see the progress established by EP ITRE Committee on the recast Renewable Energy Directive (RED). This revision represents an unmissable opportunity to achieve two strongly related public policy objectives: accelerate the transport sector’s transition towards zero emissions and modernize the current legislative framework for renewable energy as a whole, and more specifically for Europe’s transport system.

With the European Parliament scheduled to formalize its position on the file in mid-September, the Platform would like to shed the light on some elements that could improve the EP’s position:

• Include private charging in fuel neutral credit trading mechanisms

The Commission’s proposed EU-wide requirement for Member States to set up a fuel neutral credit trading mechanisms is highly welcome. However, the mandated credit system, as established by art 25(2), should not, as it would as the text stands, limit the scope of this new system to public charging points only. Any charging points should be allowed for inclusion under national credit mechanisms.  Limiting the scope of the credit mechanism at EU level to public recharging stations will lead to inefficiencies and distortions, and affect the deployment of charging infrastructure. The ITRE Committee has gone in the right direction,  leaving the option for Member States to set up their system in the way they see best fit, including a voluntary inclusion of private charging.

Given that the vast majority of EVs in the EU (>70%) will be charged at home or at the workplace, the Platform believes a stronger wording is needed, namely expressly including private recharging stations in the mechanism.

• Ensure appropriate energy efficiency ratios regardless of accounting methodology 

The current RED allows countries to choose between setting transport targets based on energy volumes/content or GHG emission reductions. Contrarily, both the Commission’s proposal and the ITRE Committee Report call Member States to set targets based on GHG reductions only, in clear countertrend compared with the 24 out of 27 Member States currently using an energy-based system. With this new proposed accounting methodology comes the deletion of the existing “multiplier system” or ‘Energy Efficiency Ratio (EER)’. The multiplier or EER accounts for the superior energy efficiency of renewable electricity, and is currently set at 4 for electricity. The mandate for the new transport targets does contain an “implicit” EER, i.e. a different fossil fuel baseline.

Nonetheless, as Member States are expected to push for maintaining the flexibility to choose between GHG- or energy-based targets, it is crucial to maintain an Energy Efficiency Ratio (EER) of at least 4  regardless of the accounting methodology used (in case  a member states chose to keep an energy-based system or the current proposed implicit multiplier in case of GHG emission reductions system), reflecting the fact that EVs are between 4-5 times more efficient than internal combustion engine cars (“well to wheel” efficiency) powered by any renewable fuels.

Hence, the Platform believes that, while it would be welcomed to maintain flexibility for countries to choose their accounting system, appropriate EERs should be kept ensuring that direct electrification is able to compete on a level playing field.