Open Letter to Prof. Draghi and EU Heads of States on EU Competitiveness Strategy

Open letter

Platform Chair: Prioritizing EU Competitiveness in the Transport Sector

to Prof. Mario Draghi and EU Heads of States

Our open letter on CO2 Standards

Industrial competitiveness will be high on the agenda of the Special European Council of 17th and 18th April in Brussels. It has lately tended to overshadow sustainability. We, members of the Platform for Electromobility, a unique coalition of industries, NGOs, and civil society organizations committed to advancing electric mobility across all modes of transportation in Europe, firmly believe there can be no industrial competitiveness without sustainability. The Green Deal has set the course. It is imperative to implement it swiftly and continue in that direction.

The EU does need an industrial strategy to ensure its businesses can complete the transition as planned. In our latest publication, “A 360° e-mobility industry strategy“, you will find five recommendations we believe should be a priority of the next strategic agenda:

  1. Ensuring regulatory stability for industries and investors. This means first and foremost ensuring that the European Green Deal legislations as voted in the 2019-2024 mandate remain steady over time.

  2. Enhancing value chain competitiveness and resilience. European industrial policy initiatives should see their focus widened from specific components to a more comprehensive approach, spanning from raw materials to end products and from individual to all modes of sustainable transportation.

  3. Financing the short-term transition through accessible opportunities. Existing EU funds can already serve as valuable assets if they are distributed efficiently and intelligently, notably by streamlining access to finance, particularly for net-zero industries, through instruments such as the Innovation Fund and InvestEU.

  4. Establishing a Net Zero Investment Plan for long-term financing. The STEP platform, although welcomed, unfortunately far from the pan-European response to global competition on cleantech that the EU needs.

  5. Strengthening international cooperation. Strengthening ties with diverse regions would diversify sources, reduce geopolitical risks and uncertainties, ensure a secure supply chain, enhance global industrial collaborations, and uphold a fair competitive environment for all clean transport industries.

We urge the European Council and the upcoming report of the future of European Competitiveness to recognise that industrial competitiveness and sustainability are intrinsically linked and cannot go one without the other. Hoping that our recommendations will help shape the policy priorities of the upcoming EU legislative cycle, we stand ready to contribute to the discussions further.

Céline Domecq
Chair of the Platform for Electromobility, 2024

Five steps towards a 360° e-mobility industry strategy

EU Industrial Strategy

Our recommendations for a “Green Deal Industrial Plan”

Any “Green Deal Industrial Plan” would not be complete without a strong chapter on the electromobilities manufacturing ecosystem.

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In the context of the forthcoming EU legislative mandate, the Platform for electromobility endorses the overall shift in European policy priorities set by the European Green Deal as a welcome long-term compass. Recent institutional declarations[1] aligned with Platform’s EU Election Manifesto[2] support  the development of a robust industrial policy. This is essential to ensure Europe’s competitiveness, resilience in a rapidly evolving global landscape, and maintain its leadership in climate change mitigation. Any “Green Deal Industrial Plan” would not be complete without a strong chapter on the electromobilities manufacturing ecosystem. To achieve these goals, we propose a multifaceted approach that considers the entire value chain’s competitiveness in green transport solutions while revitalizing their financial support. Such policies must be implemented within a framework of regulatory stability and close international cooperation with other regions.

We will set out these proposals below under 5 headings:

  • Ensuring regulatory stability for industries and investors
  • Enhancing value chain competitiveness and resilience
  • Financing the transition in the short term: the “low hanging fruits”
  • Financing the transition in the long term: Net Zero Investment Plan
  • Strengthening international cooperation

We welcome questions and cooperation with the Platform for Electromobility on our proposals.

1. Ensuring regulatory stability for industries and investors

A stable regulatory system is crucial. Attracting investment to create the net-zero industrial ecosystem for electromobility will be facilitated by maintaining a consistent, clear regulatory framework and climate objectives. This means first and foremost ensuring that the European Green Deal legislations as voted in the 2019-2024 mandate remain steady over time. We strongly warn against disruption of the Green Deal and their long-term planning notably by limiting the scope of major reviews. At a more granular level, we call for stability in the regulatory frameworks of all transport modes. It is a key element for successful risk management. A consistent, clear regulatory framework secondly means performing sound impact assessments before proposing new legislation. Potential legislations should be in line with the direction taken by the Green Deal as voted during this mandate. Thirdly, regulatory stability means  focus on proper implementation through the swift adoption of all necessary complementary acts In a nutshell, implementing before reviewing.

2. Enhancing value chain competitiveness and resilience

a. A 360° e-mobility industry strategy

While recent European industrial policy initiatives, such as the Net Zero Industry Act (NZIA), have focused on key components and sub-systems[1], we have observed that an emphasis and consideration of full value chain competitiveness is lacking. It is crucial that these policies take into account the comprehensive nature of mobility industry value chains across sectors and support their global competitiveness as they navigate the green transitions. We call for a 360° e-mobility industry strategy, widening the focus from specific components to a more comprehensive approach, spanning from raw materials to end products and from individual to all modes of sustainable transportation.

B. Upstream and downstream

While the presence of gigafactories is fundamental for the development of green industries in Europe, with production capacity on some parts of the value chain (so far mostly focused on end products), it is important to highlight that they alone do not guarantee a competitive and non-dependant industry[2]. Indeed future industrial policy should go beyond the end-product and also consider upstream (refining) and downstream (recycling), both sectors being, so far, not located in Europe. A European industrial network of innovative companies from all sizes would help securing all stages of e-mobility value chains for the manufacturing and recycling of key components. The EU should channel purchases toward “made in Europe” products and increase production chains within Europe. Given the high demand for strategic raw material to manufacture electric vehicles, securing the value chains also includes a strong focus on security of supply of such materials and other available alternative technologies, as well as the recyclability of engines and batteries.  The creation of new industrial hubs in Europe should go hand-in-hand with this strategy.

c. Energy-cost efficient strategy

Energy costs play an integral part of manufacturing competitive transport solutions. The availability of affordable, decarbonised energy is paramount to maintaining Europe’s competitiveness in the global low-carbon technology competition. We ask policymakers to work urgently on mitigating electricity prices disparities between the Union, China and the US, which are severely disadvantaging EU manufacturers. We endorse other calls[3] for the introduction of incentives that reward low-carbon technology producers favouring local materials and components.

d. Public procurement driven sectors

Similarly, for mobility sectors where investment decisions are predominantly the responsibility of public authorities, such as rail, the relevant EU legal framework must be properly enforced. That starts with public procurement, ensuring that tender evaluation criteria set the right focus on the sustainability of the selected solutions but also include all available tools to ensure fair competition, such as the foreign subsidy regulation. We strongly support the NZIA’s non-price criteria proposal in public procurement supporting sustainable development and resilient European industries. Those criteria will help favour European industries in public auctions and ultimately promote technologies produced in Europe.

e. Accompany workers and employers in skills transition

Industrial sectors must be supported in their skills development and employment policies for a successful decarbonisation of its values chains. For this purpose, EU institutions and Member States should undertake a mapping of skills shortages. This should consider both traditional and new skills. That way, we can assess the needs for jobs and skills in each sector, developing tools to identify and publicise available training, and highlight those that need to be created. Based on the identified needs, measures should be undertaken by the EU – such as NZIA’s initiative for “Net-Zero Academy” – and the Member States to support existing training structures in Member States as well as to ensure that the trainings are conducted by practitioners from companies.

3. Financing the transition in the short term: The “low hanging fruits”

Existing EU funds can already serve as valuable assets if they are distributed efficiently and intelligently, notably by streamlining access to finance, particularly for net-zero industries, through instruments such as the Innovation Fund and InvestEU. To do so, we have identified five “low-hanging fruits” measures that can be taken without further delay:

  • Low hanging fruit 1: Guarantees. As a matter of priority, public investment tools should crowd in private investments by increasingly making use of instruments like guarantees. Firstly, the InvestEU Fund should be further mobilised in support of a 360° e-mobility industry strategy. Secondly, the European Investment Bank (EIB) Group should strengthen the provision of commercial bank guarantees for investments by companies across the EV value chain, replicating the recently announced €5 billion guarantee facility for the wind sector[1].
  • Low hanging fruit 2: Innovation Fund. We welcome the recent initiative under the Innovation Fund to dedicate €3 billion to the EV battery value chain. This new mechanism needs to focus on the most sustainable EU battery and components manufacturers[2]. A robust mechanism needs to be built, including for channelling increased funding from Member States to match EU funding.
  • Low hanging fruit 3: Capacity building. To enhance accessibility, we propose that EU or national administrations train and appoints specific staff to provide advisory services to both applicants and national authorities responsible for distributing EU funds. A substantial portion of these funds, especially in the case of Recovery funding, may remain unallocated due to the constrained administrative capacity of Member States[3] to prepare projects or process applications. Supporting project preparation and speeding up authorization procedures at the national level would thus benefit both the applicants and the authorities involved.
  • Low hanging fruit 4: Mid-term MFF revision. The mid-term revision of the MFF is the opportunity for European institutions and Member States to significantly raise funds of strategic programmes (STEP but also CEF) to provide appropriate financing instruments to support a competitive decarbonisation of the EU industry and support investments in clean, sustainable mobility solutions.

3. Financing the transition in the long term: Net Zero Investment Plan

a. Why a Net Zero Investment Plan now?

The climate investment gap is deepening by the day and the way to fill the gap will be a major challenge for decision-makers in the coming years. European elections are the democratic the window of opportunity to set priorities about where EU funds should flow and the level of support that EU will provide to shift the continent to clean mobility. 2024 is thus a milestone year for the green transition. The STEP platform is, although welcomed, unfortunately far from the pan-European response to global competition on cleantech that the EU needs. Therefore, we support the creation of a major Net-Zero Investment Plan after the EU elections.

b. Predictable and upfront support for op-ex

The EU should ensure that financial instruments do not exclusively prioritise innovation but also consider the importance of providing strategic support for operating expenses and production, for a limited duration. We highlight the fact that operational expenses (op-ex) are not covered by the current InvestEU funding framework. This means that in addition to promoting innovation, financial support should be directed towards sustaining and optimizing day-to-day operations and the production processes of net-zero industries, thereby creating a more balanced approach to funding allocation. Beyond deciding the level of support that will be provided to the green and digital transition of the transport sectors, upfront predictability and certainty about possible funding should also be provided. A rulebook for financing should make sure op-ex support is both predictable and upfront.

c. Consider ventures with higher risk profiles

To complement this new approach and move closer to a truly comprehensive funding allocation, it’s essential to also consider ventures with higher risk profiles. For instance, when it comes to the Alternative Fuels Infrastructure Fund, the current financing terms are notably stringent. These terms often exclude high-risk endeavours, as they require a minimum of 50% funding from national banks or partners, effectively limiting opportunities for investment in riskier projects. This, in turn, disproportionately affects emerging industries and initiatives in Central and Eastern Europe. To address this issue, the European Investment Bank (EIB) should explore investments in riskier ventures, and InvestEU should be equipped to provide loans and equity for such undertakings. The InvestEU Program, designed to offer guarantees to both public and private banks, can play a pivotal role in enabling them to take more substantial risks in their lending and equity operations. This approach can facilitate the inclusion of ‘investments in riskier ventures’ and contribute to a more diverse and dynamic investment landscape.

d. How to finance a Net Zero Investment Plan?

This Net-Zero Investment Plan should be structured under the EU Multi Financial Framework on the one hand, and via new bond issuance programme replacing the Next Generation EU programme on the other hand. In addition, this broader investment plan should ensure that sufficient European and national funding resources, leveraging private sector investment, are available to achieve Europe’s objectives as set in the Climate Law and in the Smart and Sustainable Mobility Strategy. On top of the achievement of dedicated programs such as the TEN-T, it should include a dedicated Green Industry fund. State Aid measures should be re-designed and local supports coordinated at EU level to ensure a level playing field at European level,. The future State Aid regime should mandate EU governments to integrate environmental and social considerations to their support schemes, so that only best-in-class projects benefit from public support at regional and national level.

5. Strengthening international cooperation

Stability also requires robust international cooperation. Strengthening ties with diverse regions would diversify sources, reduce geopolitical risks and uncertainties, ensure a secure supply chain, enhance global industrial collaborations, and uphold a fair competitive environment for all clean transport industries.

  1. Proactively setting a Level Playing Field

The EU response to other regions’ recent green industry support program should be prepared with care, to avoid provoking a global subsidy race. The goal should be to create an international level playing field between all economies, aimed at reaching Paris Agreement climate targets (COP21) together and aligned on WTO rules. For certain industries, level playing field can only be reached by matching competitors’ support: for examples, for battery manufacturing, the US IRA provides a significant op-ex support per kWh produced; for reskilling workers, massive support for training automotive workers is proposed. We call for EU policymakers to match such support in some manner to help its European battery industry compete on more equal terms. Without such matching, there can be no global level-playing-field for e-mobility related manufacturing.

  1. Cooperation to avoid trade disruption

With several studies by the OECD[1] highlighting the challenges faced by European railway producers in the Chinese market, as well as the public assistance received by their companies, the question of China’s undisclosed subsidies benefiting its products is not new for the railway industry. Cooperations should be reinforced to ensure there are no such practices risking unbalancing global competition.

  1. Cooperation to diversify sources

Dependence on one single third country for green transport technologies is tangible[2] and should also be mitigated. China dominates the production of solar panels, batteries for EVs and part of the world trade in wind turbines. To diversify sources, we support proposals to form a green technology partnership between governments and businesses of the major economic powers to reduce strategic dependencies. Such partnership would be intended to complement, not replace, existing supply chain. Beyond cooperation with third countries, cooperation should also be within European countries and industrial partnerships to multiply joint purchases and thus secure supply of strategic raw materials at advantageous prices.

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[1] President von der Leyen’s State of the Union, European Commission’s Work Programme. Executive Vice President Sefcovic’s speech at Environment Council. [2]2024-2029: Five years to make e-mobility transition a success”, Platform for electromobility, September 2023.


[1] A "sub-system" refers to a specialized and interconnected set of components that collectively perform a specific function within the overall system.

[2]How to Meet the Industrial Challenge of Electric Mobility in France and in Europe?”, Notes de l’Ifri, Ifri, November 2023.

[3]Call for EU Clean Industrial Deal and urgent actions to keep Europe in the world’s clean technology race”, Eurofer, October 2023.


[1] Press Release, EIB, December 2023

[2] Press Release, European Commission, December 2023

[3]How Europe should answer the US Inflation Reduction Act”, Bruegel, February 2023


[1]Measuring distortions in international markets: The rolling-stock value chain”, OECD, February 2023

[2]De-risking and decarbonising: a green tech partnership to reduce reliance on China”, Bruegel, October 2023.

[Video] Charging Infrastructures: A perspective on 2024 by Jayson Dong

Our five recommendations to CO2 Standards for trucks and buses trilogue negotiators

CO2 Standards for HDVs
Our recommendations to trilogue negotiators

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The members of the Platform for Electromobility welcome the position adopted in November by the European Parliament on the revision of the CO2 Standards for trucks and buses Regulation. Welcomed overall, the text provides a robust and ambitious yet realistic and business-friendly path toward decarbonisation of road transport in Europe. Ahead of trilogue negotiations, we hereby highlight key elements that negotiators should keep in mind to safeguard the Regulation’s added value


First and foremost, we urge negotiators to reach a conclusion before March 2024 to avoid losing one year in our collective fight against climate change. Considering the deadline of the text, a late agreement would delay its application by a full year, hence jeopardising our joint effort to reduce CO2 emissions and reach net-zero society in 2050. A timely resolution is paramount to providing certainty to the truck and bus industries, its customers as well as adjacent infrastructures and energy industries, enabling them to plan and invest in the necessary innovations for compliance.


Industrial certainty and environmental progress are also jeopardised by a potential loophole that could open the way for unrealistic use and expectation of e-fuels and biofuels. Both alternative fuels solutions are inherently inefficient[1] and should remain out of the CO2 standards. Renewable and low carbon fuels and, most notably, e-fuels will not be carbon-neutral in time to decarbonize the road transport sector and meet our climate targets, and as a result should be limited where direct electrification is not feasible, namely in maritime and aviation sectors. These fuels are scarce resources sorely needed to reduce greenhouse gas emissions in the aviation and shipping sectors, whereas the road transport sector is well-suited for electrification. They do not provide a viable alternative to existing zero-emission solutions. In addition, e-fuels aren’t currently produced at commercial volumes. Scaling up additional renewables, electrolysers, direct air capture (DAC) and e-fuel production facilities would take time and larger e-fuel quantities would likely not be available before 2040.


Thirdly, considering that in 2022 30% of new buses in Europe were already zero emission, an urged confirmation of the 100% Zero Emission mandate target at 2030 for urban buses, with no postponements, is an optimal option, notably with the move of the two subcategories of urban buses, namely class II low-entry (i.e. 31L2 and 33L2) into the coach segment, as they are often used by local and regional authorities for longer distance public transportation. While reducing the CO2 emissions of those groups of vehicles, this choice would also bring substantial public health benefits by lowering the amount of particulate matters (PM) emitted.


Fourthly, we praise the European Parliament’s extension of the emission debts and crediting system from 2030 to 2040 gives additional flexibility to manufacturers to earn credits (when reducing emissions more than required) and use them to offset debts (if emissions are above what is required). Credits now can be used for 15 years to offset debts. Credit’s lifetime should have a maximum of 5 years as do the debts. This would force manufacturers to continuously invest in reducing their CO2 emissions. This mechanism is pivotal in encouraging industry players to adopt sustainable practices and contribute meaningfully to the reduction of greenhouse gas emissions.


 Platform members also recognise the positive impact a fleet mandate mechanism would have on the decarbonation of heavy-duty vehicles. On this point, Platform members equally stress the importance of support mechanisms for the rollout of office-based charging, from subsidies to tax discounts.

With a timely conclusion, unequivocal standards without place for questionable alternative fuels, the strongest ambition on decarbonization of urban buses, an ambitious definition of zero-emission heavy-duty vehicles and fit-for-purpose emission debts and crediting system, the CO2 Standards for trucks and buses would truly be the regulatory framework that promotes sustainability, innovation, and the accelerated adoption of zero-emissions road transport.

[1] Estimates indicate that the electricity requirements for the production, transportation, and distribution of various e-fuel types are significantly higher, ranging from approximately 1.6-1.8 times greater for compressed gaseous hydrogen to between 2.2 and 6.7 times higher for liquid e-fuels, in comparison to the direct use of electricity, depending on the specific fuel type. When we account for not just the fuel production phase but also the efficiency losses within the vehicle powertrain during e-fuel usage, the overall efficiency diminishes even further.

Our reaction to the revision of the End-of-Life Vehicles Regulation proposal

ELVR: Our reaction to the revision of the End-of-Life Vehicles Regulation proposal

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We express our support to revise the ELVD and to combine it with that of the Directive. As a pivotal legislative tool to enhance the lifelong sustainability of EVs, this revision is key for the e-mobility transition and can accelerate the growth of a robust recycling value chain within the EU.

While our primary focus is on elements of the ELVR directly relevant to ZEVs, we welcome the overall text and notably the decision to turn the directive into a regulation, setting a comprehensive, harmonised regulatory framework across Europe.

We welcome Chapter 5, introducing provisions on the export of used vehicles. The export ban on non-roadworthy vehicles must remain a key point. We welcome the circular economy provisions addressing the design, production and end-of-life treatment of vehicles, effective dismantling, recycled content rate and the recoverability of raw materials. Measures have been forecasted to support the market for reuse, remanufacturing and refurbishment of parts and components of a vehicle

Binding targets for the reuse, recycling and recovery of ELVs must be preserved and their practical achievability ensured. Certain aspects of the proposal require clarification:

  • Potential overlaps with other existing legislations, e.g. the Batteries Regulation (BR) and the Ecodesign for Sustainable Products Regulation. To reduce excessive administrative burden it t is imperative to clearly define the interlink between the ELV passport and the Battery passport – i.e. how the information is communicated between these platforms and who has access to what information, with the aim of avoiding any redundancy, and if feasible, merging requested information behind a single QR Code. Such a tool has to take into account confidentiality of information and also differentiate on levels of data accessibility depending on stakeholder type, considering the information sharing requirements in the BR.
  • The annex on roadworthiness needs refinement to ensure that non-functioning batteries will not be exported, and aligning the provisions with the BR’s article on the export of waste batteries.
  • A close examination of Article 7, on the design of the removability of ‎certain parts of the vehicle, particularly in the context of EV batteries and ‎drive modes (7.2), is needed. Consistency between the BR and the ELVR needs to be ensured with clear roles and responsibilities between the different actors of the value chain (battery and vehicle manufacturers, second-life manufacturers, end-of-life operators).
  • When regulating the removability and replaceability of EV batteries, safety and appropriate qualification considerations is a priority. Batteries removed from vehicles need to be directed to the right recycling channels to be treated in line with the BR.

We would also encourage co-legislators to consider:

Legacy substances dilemma: The question of whether legacy substances can be used as recycled content must be addressed in a future-proof manner. The regulation needs to anticipate the potential time gap and regulatory changes between the production of EVs and their end-of-life phase. This will help mitigate contradictions between what automakers are required to do and what must be accomplished when permitted recycling facilities receive ELVs.

Beyond the proposed regulation, we would also welcome incentives for consumers to further drive the market to ever more sustainable EVs.

Incentives for low-carbon materials: Similarly to the BR, the revision should be leveraged to incentivise the use of low-carbon materials and processes. While we support the introduction of targets for producers and public procurement provisions to increase the use of low-carbon materials such as steel and plastics to drive ever more sustainable EVs, those targets should be accompanied with incentives for producers. Beyond the proposed regulation, we would also welcome incentives for consumers to further drive the market to ever more sustainable EVs.

[1] Reusability, Recoverability, and Recyclability

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Solutions for a smooth integration of e-mobility into the grid

Energy & Infrastructures

Solutions for a smooth integration of e-mobility into the grid

Fifteen policy recommendations for sustainable governance and development of the power grid in front of the electric vehicles uptake.

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As the adoption of electric vehicles (EVs) increases, it becomes imperative to step up our efforts to achieve their seamless integration – and related charging infrastructure – into the existing power grid. While the development of electric mobility is a significant asset to a clean energy system, it nevertheless raises questions over the management of power grids and connected charging infrastructure.

Some 60% of the EU car fleet has access to off-street parking space at home, and ‘unmanaged charging’ can create substantial peak loads. To a greater extent than passenger cars – which would only require a manageable 40kWh/week on average – the electrification of heavy-duty vehicles is a modality that requires specific attention. We have therefore dedicated a specific paper to this topic This current position paper aims to offer recommendations and potential solutions for ensuring that the development of the power grid is consistent and aligned with the growth of electric transportations of all modes.

There are many topics to consider under the heading of ‘e-mobility and the grid’, and this paper will present a succinct overview of a number of them. This will be followed by more in-depth papers on selected topics.

I. Communication, Coordination and Collaboration

1. Collaboration to reduce uncertainties

One of the main challenges in planning the electrical grid in a way that can absorb EV charging infrastructure lies in the uncertainty that surrounds how different types of EVs will recharge in different places. This also makes it difficult to assess needed investments. These uncertainties can be addressed through cooperation, knowledge-sharing, and effective planning.

Early coordination between stakeholders is key to success. Coordination around how charging infrastructure is deployed will ensure convenience and cost-effectiveness for users. We therefore recommend close cooperation between policymakers, regulatory authorities, energy companies, flexibility service providers, fleet managers, charge point operators (CPOs) and – most importantly – Distribution System Operators (DSOs). Such collaboration will benefit all parties.

In practise, this collaboration should:

  1. Be initiated and moderated by public and regulatory authorities
  2. Assess the grid in advance – even before any connection requests – and prioritise the flexible use of the grid
  3. Recommend reinforcing network components, should any overload be anticipated;
  4. Foster communication with municipalities to address network construction requirements when connecting charging stations
  5. Streamline the permitting and connection process.

2. Formalising this collaboration through ‘EV charging Blueprints’

It is important that this stakeholder cooperation also produce a state of play in the form of ‘Blueprint for recharging infrastructure’.

Adopting a ‘Blueprints for recharging infrastructure’ approach would help local authorities ensure an organised, planned and coordinated deployment of charging stations. This document – defined by local authorities and designed in consultation with the relevant stakeholders (in particular DSOs) – will comprise the local planning rules for implementing recharging infrastructure in main highways, national roads, and urban areas, including suburbs, could offer a solution. The ‘Blueprint’ would assess charging infrastructure required (such as the number of points to be installed, their location, their power and the types of socket), taking into account both the existing publicly accessible infrastructure and the existing and expected private charging infrastructure.

From the public authorities’ side, local authorities can leverage these ‘Blueprints’ in their Sustainable Urban Mobility Plans (SUMPs) as relevant tools for promoting cooperation and engagement with DSOs and CPOs in the short term. When fully deployed, SUMPs enable an iterative approach with DSOs and other economic actors from the outset, allowing for proactive planning and network development in the short, medium and long term.

3. Coordination & system governance changes needed at all levels

In order for the European regulatory framework to evolve in a way capable of supporting grid optimisation and investment in a coordinated manner, there should be discussions between all regulators at EU level, as well as between the Council of European Energy Regulators (CEER) and the Agency for the Cooperation of Energy Regulators (ACER). The former should be encouraged to act, and the latter to update network codes as needed (see further details below).

4. Implementing existing EU legislations

However, until EU coordination can be established, the work required should be undertaken at national level. This national level work includes the proper implementation of existing articles of legislations, such as the Electricity Directive of 2019 (notably its Article 32, which incentivises flexibility procurement by DSOs), the recently adopted Renewable Energy Directive and the reform of the Electricity Market Design, which should be adopted soon and strengthen the existing legislation.

II. Support for Network Operators and grid infrastructure

5. Improve effectiveness of Network Development Plans for EV integration

With the aforementioned coordination and advance information sharing, network development plans – which not least for charging infrastructure for battery trucks are ineffective – can be vastly improved. National governments must be reminded of their responsibilities – most notably those set out in the Alternative Fuels Infrastructure Regulation (AFIR) – to enforce these regulations effectively.

Member States, via their National Regulatory Authorities (NRAs) and involving market parties, should make sure – and even encourage – DSOs and TSOs to plan and invest in anticipation. This should be under the supervision of the energy regulator, prior to connection requests for charging infrastructure and should also take into account flexibility options into account.

6. Resources and digital solutions to support DSOs

Many DSOs lack the digital infrastructure to implement solutions that would facilitate and simplify the EV charging connection process. The gaps include:

Digital connectivity between DSOs and CPOs, for the purpose of transparently sharing available grid capacity (for charging). Enhancing transparency offers a crucial advance that could optimise the charge point deployment procedure. A substantial number of charge points are still awaiting installation in a number of countries, as a result of a lack of available information to CPOs on existing capacity. While some DSOs do provide heat/capacity maps, which enable CPOs to plan their deployments accordingly, the majority do not. Generating such maps would significantly enhance the overall process. In addition, there should be:

Digital Ticketing Systems, so that applicants can know the status of their grid connection request and timeframe for replies. Digital and automatic tools, which could give historic information on the connection of charging stations in different locations (map-based).

7. Establish cross-functional working group within the DSOs

Coordination and knowledge sharing is also essential within the network operators, in order to share expertise and project information across departments, for example. Therefore, DSOs should establish a cross-functional working group within the DSO to address any issues relating to charging station connections.

8. Proactive, anticipatory grid investments required

While private EVs will represent only a fraction of the total grid investment required by 2030, European distribution grids will still require substantial investments[1] to be able to support e-mobility and to integrate EV charging infrastructure. As DSOs are regulated entities, there must be an adequate regulatory framework established in each country that would allow proactive, anticipatory investments in the grid. This could be on the basis of a small fee approach.

Inspired by the UK’s Green Recovery Scheme managed by Ofgem, there should be European funding mechanisms established to enable DSOs to apply for funds specifically for grid reinforcements for EV charging. Moreover, investments should be made not just in grid expansion but also reinforcement, modernisation, efficiency and flexibility.

DSOs should be empowered to initiate initial investments  that follow with incentives and proper business model to plan ahead. The market needs to develop incentives for the timing of necessary upgrades.

9. Promote local energy hubs through smart regulation

The impact of local electricity consumption for clean mobility can be mitigated, if it is matched with the local energy generation connected and delivered through the grid through smart management of consumption and generation. Building on the energy-sharing Article 15a in the revised Electricity Market Design, this has the dual potential to facilitate grid integration, while increasing direct consumption of clean energy. Realising this dual potential would require valuing ‘energy hubs’, where local consumption is matched with local generation.

10. Invest in and implement smart and flexible solutions

Smart and bidirectional charging can play an important role in optimising the grid integration of EVs, as well as alleviating their impact during peak hours. Thanks to smart meters – in synergy with dedicated measurement devices – the needs for, and costs of, network capacity reinforcement can be minimised and the deployment of new charging points optimised, by providing information of the relevant distribution network parameters. Likewise, it would help flattening load peaks. This would ultimately reduce the carbon intensity of the energy system and alleviating the impact on the distribution network.

As non-wire technologies[2], smart and bidirectional charging enable the application of the Energy Efficiency First Principle. Indeed, by using already existing technologies, whose initial purpose lies somewhere else, we avoid expensive investment in new capacity.

The benefits of such service are even more striking when EVs are turned into energy storage assets that can return power to the grid through bidirectional charging. This allows for grid balancing, thus boosting grid reliability and stability while lowering the charging cost for consumers. EV charging can also be aligned with local renewable energy production and electrical solutions, such as heat pumps in buildings. Last, much greater amounts of electricity can be moved via existing cables by deploying optimisation tools such as dynamic line rating.

11. Reform of grid connection agreements between (D)SOs and CPOs

To enable flexibility, smart charging and bidirectional power transfer at scale will require smarter grid connection agreements between DSO and CPOs. In particular, in those cases where market-based alternatives for congestion have been shown by the NRA to provide insufficient volumes (in line with article 32 of the Electricity Directive), flexible grid connections should be considered. This will allow for flexible and time-bound contracts or for capacity contracts where the contracted transport capacity is partially or not guaranteed. Such an approach can be implemented in various ways, for example through a so-called ‘non-firm Connection and Transport Agreement’  or via other flexible agreements.

Clear conditions, to guide consumers, operators and system operators on their rights and responsibilities, are required.

Alongside grid connection agreements, dynamic network charges can assist the adoption of flexibility. These would allow flexible solutions, such as smart vehicle charging and other demand-side measures, to play their part in solving grid congestion.


[2] Technologies which do not need any grid, Capex investments or more material to install.

III. Market models and rules to foster smart & flexible EV charging

12. Market models to incentivise consumers and Charge Point Operators

To provide the required flexibility for the energy system, proper market models and regulatory frameworks are needed. Flexibility first requires a regulatory-friendly business model, given the scale of the deployment. While the technology of smart charging is already being developed and recognised within the EU legislative framework, bidirectional charging – despite its considerable potential – still encounters many hurdles hampering its proper development.

Governments, system operators and market regulators must recognise both technologies as beneficial for grid stability, instead of seeing them as beneficials for consumer and as a generator. Fostering a functioning market model will incentivise operators/aggregators to ensure that flexibility is offered on a large scale. Flexibility market demands should be driven by the value they bring both to the consumer and the energy system as a whole, not by technology or capabilities. Adopting market models where flexibility plays an important role will only become a reality if consumers see clear benefits or receive incentives to participate. Without clear rights and conditions for both CPOs, System Operators (SOs), FSPs and consumers, market models will not develop at scale, and consumers will not feel incentivised to participate in flexibility. This results in a small market where flexibility, V2G and grid support will not be adopted, and grid integrations would remain local initiatives without perspectives at scale and harmonised roll out. In this sense, as already mentioned, it is paramount that Member States swiftly implement the 2019 Electricity Market Design and to already prepare the new changes brought by the current revision of the EMD, which will further strengthen such friendly business models.

IV. Standards to ensure proper functioning of the grids systems

13. Standardise and integrate technologies

Smart metering[1], or at minimum dedicated measurement devices, are necessary at the DSO side for grid state information and to measure levels of flexibility delivered. Meanwhile, smart charging technology is required at the CPO side for adapting the charging power and the digital connection between DSO and charging infrastructure. The development of both technologies – smart metering and smart charging – requires standardised and transparent procedures to facilitate connections for CPOs. In addition, it needs future-proof communication standards in EVs and in energy management systems, charging infrastructure and building energy management systems.

This requires simplified conformance testing and compatibility checks, by means of a harmonised certification on the side both of EVs and charge points. The existing regulatory connection requirements from the ACER may require readjustment to align with current technology. It is important to acknowledge and address obstacles arising from technological limitations.

14. Update network codes

To ensure that EVs and their flexible capacity are able to be integrated into grids, it is important to adopt EVs in EU based grid codes, starting with the amendments to the Grid Codes RfG (requirements for Generators) and the new Grid Code Demand Response. It is also important to adopt them in EU grid codes so that SOs and Member States adopt and embrace EVs and corresponding  charging point in harmonised rules and regulations.

We also call on legislators to pay particular attention to the revision of the Network Code RfG and the new grid code on Demand Response, taking into account the requirements for V1G and V2G in the grid codes.

15. Workforce development

To guarantee that these measures are truly effective, energy companies and relevant stakeholders must be supported in their efforts to develop jobs and skills required to manage the grid and the install charging points. Thus, a comprehensive framework also requires addressing this shortage of skilled and certified workers.

To improve the attractiveness of these jobs and to promote the available training and retraining offers, the EU institutions and Member States should undertake a mapping of skills shortages. This should consider both traditional and new skills. That way, we can assess the needs for jobs and skills in each sector, developing tools to identify and publicise available training, and highlight those that need to be created. Practitioners from CPOs and DSOs should be involved in organising training programmes funded by national and regional funds. Last, national and regional communication campaigns should be highlighting attractiveness of these sectors.

[1] Smart meters in particular, as one of the solutions allowing smart charging, play an important role in grid management optimisation and flexibility services promotion. The combination of both technologies could provide the system with the necessary data to manage more efficiently the charging process and, thus, reducing the impact on distribution network.  Dedicated measurement devices can complement smart meters by providing more data granularity for demand response and flexibility purposes, or substitute them in the situation where a consumer does not have one.

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