Statement on EP ITRE Committee on RED ahead of Plenary vote
Renewable Energy Directive
Our statement ahead of Plenary vote
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:
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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.
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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.
[Video] Batteries are well placed to help Europe navigate the current energy crisis
Batteries Regulation
Europe's main asset toward energy security
Batteries are necessary to fast forward electromobility, they store green energy, and can ensure critical infrastructure runs smoothly. In other words, batteries are critical to achieving the EU Green Deal objectives, and for the transition to renewables and electrification.
But the battery industry needs a fit for purpose policy framework to do so. In December 2020 the European Commission, proposed the new Batteries Regulation which is now being negotiated in trilogue.
It is key that the new Regulation enables a sustainable and competitive batteries value chain on our continent. The Regulation needs to introduce regulatory visibility for all players along the value chain on key aspects, including:
First, well-thought through timelines that would balance the need for a quick implementation of the Regulation, whilst ensuring robust methodologies are developed.
Second, future potential restrictions of substances must take into consideration the impact onachieving strategic autonomy for the EU battery sector, the performance of EV batteries, and the closed loop of the substances needed for batteries.
And finally, correct definitions: of batteries as final products, and of the battery producer for Extended Producer Responsibility coherence. This will help establish a level playing field within and outside of the European Union.
We salute the Czech Presidency’s emphasis on promoting the EU energy security amid these uncertain times, and want to stress that batteries are naturally well placed to help Europe navigate the current energy crisis. We call for the Presidency to focus its attention on the Batteries Regulation
[Video] The importance of the Energy Performance of Buildings Directive with Luka De Bruyckere (ECOS)
EPBD
The importance of private charging
If Europe is to succeed in its transition towards zero-emission mobility, the correct charging infrastructure needs to be put in place
Here, the deployment of private charging is of the utmost importance: 90% of all charging takes place at home or in the workplace. About 10% of charging will be done at public charging stations, either at fast charging stations on the highway for long distance trips or at slower charging stations for drivers who cannot charge at home. We at the Platform for electromobility want to make sure as many people as possible can charge at home.
The European Commission has recently proposed requirements to ease the installation of charging stations in building like condominiums or offices, as well as mandatory installation of charging stations at new and renovated buildings. These are very positive steps forward.
But we also need to make sure charging stations are easily installed in existing buildings as well because 4 out of 5 buildings will still be in use by 2050, and a large proportion will not be renovated any time soon it’s clear that we need to include existing buildings in the legislation now.
Also, the legislation should require the deployment “smart” technologies for vehicles. These can postpone charging or return electricity to the grid or the building. This presents opportunities for EV drivers: reduced energy prices, improved charging experience and increased renewable energy use. It is key that all newly installed chargers in buildings are capable of smart charging.
Finally, the right to plug should truly facilitate the installation of a charging station. This right does not really exist if construction costs are too high. This is why we also need to reinforce the measures to ensure pre-cabling: installing the cables needed to connect a charging station later on.
Let’s not let 40% of EV batteries go missing!
End-of-Life Vehicle DirectiveOn how the End-of-Life of Vehicles Directive revision can make the uptake of EVs faster and more sustainable.
For Europe to become carbon neutral by 2050, road transport needs to be entirely decarbonised by this date. Considering the average retirement age of petrol and diesel vehicles in Europe (around 15 years), the Platform for Electromobility believes that an EU-wide phase-out date for sales of new pure internal combustion engine passenger cars and vans no later than 2035 is necessary to achieve this objective with a clear emissions reductions trajectory.
Last year, the sales of new BEV accounted for 5.3% of the total (1). In other words, European market will need to grow from 530.000 battery cars today to around 16 million in less than 15 years.
Considering that to produce the corresponding amount of battery cells will require huge quantity of critical raw materials. There are several critical raw materials for which these market requirements mean a significant challenge. For example, major manufacturers (2) have already announced they will not use Ni in their entry level models. On average, it takes 10 years from taking the internal decision to have a new mine in operation. Accelerating the recycling capacities is therefore key for the deployment of accessible and sustainable electric vehicles (LDVs and HDVs alike).
Yet, in 2014, 4.66 million end-of-life vehicles (ELV), representing 39% of the total vehicles being decommissioned, were at ‘unknown whereabouts’ (3). From 2007 at least, the ‘unknown whereabouts’ share has remained at a constant level4. The two main elements that explain most of the issue with ELVs at ‘unknown whereabouts’ are vehicle dismantling at illegal sites, and exporting of ELVs outside of Europe as used cars.
Consequently, it’s of key relevance for the deployment of electromobility and to reach 2030 and 2050 EU climate goals not to spoil 39% of used batteries from future EU battery ELVs. Reinserting those ELV into the recycling system will reduce the stress of primary production as well as cost impact and a potential slowdown of the BEV uptake by lack of affordable materials.
While it is true that vehicle registration procedures are the national competence of the Member States, each EU legal act has to comply with two fundamental principles laid down in the Treaty on European Union, proportionality and subsidiarity. The content and scope of EU action may not go beyond what is necessary to achieve the objectives of the Treaties. Also, given that transport is a shared competence, the EU may act only if — and in so far as — the objective of a proposed action cannot be sufficiently achieved by the EU countries, but could be better achieved at EU level.
As Member States have not been able to reduce since 2007 the number of ELVs at unknown whereabouts, the Platform for electromobility proposes to introduce the following dispositions in the revised ELVD:
- Registering any road transport vehicle – including heavy-duty – when the owner is a resident (or registered company) in that Member State will have a large and cost effective impact on reducing the amount ‘unknown whereabouts’. By doing so, vehicle owners will face at least two payment obligations (i.e. insurance and Periodical Technical Inspection – PTI). Owners will therefore be incentivised financially to send the vehicle to an authorised treatment facility (ATF) when it reaches its end of life and therefore avoid those costs.
- Provide necessary safeguards to avoid as much as possible temporary deregistration that currently causes loopholes and increase the amount of ‘unknown whereabouts’
- In case of sale in the same Member State, or change of ownership (typically to its insurance company), the new owner will have to be updated in the vehicle registration system.
- It will only be possible to deregister a vehicle under one of the following circumstances:
- Destruction, after presenting a certification of destruction (CoD) issued by an ATF.
- Export within the EU, after presenting the certificate of having been registered in the second Member State.
- Export outside the EU, after presenting the customs declaration for export.
- Theft, after presenting the police report. If the vehicle was recovered, the vehicle will beregistered again to its legitimate owner.
- Additionally, it should be made compulsory to have a valid roadworthiness certificate for a vehicle to be exported outside EU as used car.
To achieve the ambitious but necessary objective of decarbonizing road transport by 2050, transport must be seen holistically and therefore all upcoming legislations should, like the End-of-Life of Vehicles Directive revision, should consider needs that a fast and sustainable uptake of electromobility requires.
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1 https://www.eafo.eu/vehicles-and-fleet/m1
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2 VW Power Day and Tesla Battery Day
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3 https://ec.europa.eu/environment/waste/elv/pdf/ELV_report.pdf. In the Assessment of the implementation of Directive 2000/53/EU on end-of-life vehicles, is defined the term “ vehicles of unknown whereabouts”: vehicles that are deregistered but without a Certificate of Destruction (CoD) issued or available to the authorities and also with no information available indicating that the vehicle has been treated in an Authorized Treatment Facility (ATF) or has been exported.
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4 http://ec.europa.eu/environment/waste/pdf/target_review/Final Report Ex-Post.pdf
[Video] The need for flexibility services for deployment of electromobility - Brieuc Giard (SmartEN)
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EV Charging:
How to smart in the grid smartly?
Smart charging is a technology that enables communication between the electric vehicle and the electric grid when the car is plugged. Smart chargers can adjust the power input into the car very quickly depending on external signals like, prices, the stress on the grid or renewable energy production nearby. Those adjustments of power provide benefits to the EV driver and to the grid.
By turning EVs into a flexible asset, smart charging would help to integrate road transport into the energy system. This means we can optimize the use of the grid and reduce the investment needed . Smart charging will also help manage the availability of renewable energy, inherently variable. And therefore increase renewable penetration.
Smart charging will empower consumers in the energy transition by transforming their own vehicle into an flexible energy asset, a battery on wheels, and allow them to charge when electricity price is low.
Bidirectional charging is a technology that allow EVs to not only modulate the flow of energy, but send it back to a connected asset or to the grid. It would multiply the benefits for users and the grid.
[Video] The win-win relationship between EVs and renewable energies with Ivan Komusanac (WindEurope)
EV - RES
Synergies for the climate
We need to electrify our transport sector to cut our reliance on fossil fuels. This is needed to achieve our climate goals and energy security. And the more electric vehicles we have on our roads, the more wind turbines we will need to power them.
It’s possible to use electric vehicles without adding pressure on the electricity grid. Smart and bidirectional charging allow us to do that. And it can also help us integrate additional renewable energy capacity.
Everyone wants to pay less for charging their electric vehicles and that is achievable by installing more renewable power capacity. Legislation must help as much as possible. But how to make it happen?
European countries should ensure that permitting of renewable energy sources is done much simpler and faster. And they should allow electric vehicles to realise their full potential by allowing them to provide grid services.
Finally, the joint development of electric vehicles and renewable energy power plants represents great job opportunities for many Europeans. We must ensure that they have the right skills they need to accompany the transition. Find more details on our recommendations on the platform’s website.
[Video] The importance of decarbonising corporate fleets first with Thomas Neumann (AVERE)
Corporate fleet
We must look at the 99%
Corporate fleets are both a challenger and a great enabler for the decarbonation of transport. Europe should act and here is why:
Company cars are often underestimated because they represent 20% of the car park but, they are usually driven twice more than individual cars, they emit 50% of total road transport CO2 emissions and represent 62% of new car registrations! This is therefore a key lever to decarbonize transport. Company cars quickly become private cars via the second-hand market. This is called the “Trickle-down effect”
At the Platform for electromobility, we therefore believe we should first act to decarbonize corporate fleets by mandating their decarbonization. There would be a clear benefit: ensuring a large second-hand market after they are no longer used by companies and therefore making clean transportation more accessible to all. It is urgent to act at EU level to take the cost of the transition off people’s shoulder.
The is at the moment only one legislation at EU level to push large fleet to drive cleaner: the clean vehicle directive. Since 2021, it pushes member states’ public service to change their fleet to new, non-polluting vehicles. On paper it is a great idea but it only cover 1% of all fleets. We need to decarbonize the 99% left
EV Charging: how to tap in the grid smartly?
EV Charging :
How to tap in the grid smartly?
With a market penetration of 10% in Europe in 2021[1], and with a purchase price and total cost of ownership outperforming that of the internal combustion engine (ICE) before the end of 2027[2], the take-up of electric vehicles (EVs) is expected to accelerate significantly in the coming years. The widespread electrification of transport is the most efficient way to reach Europe’s climate objectives for the sector. Challenges may lie ahead, but smart charging must not be overlooked as the main asset for overcoming these hurdles.
A critical mass of EVs on the market will impact electricity consumption patterns and create an overall increase in electricity demand, particularly during peak-time periods. Smart charging can be a crucial tool for increasing the adoption rate of EVs, by mitigating the stress on the grid and supporting the transition towards sustainable electricity; each connected EV helps reduce CO2 emissions further. Smart charging can reduce CO2 by an estimated annual 600,000 tons by 2030, through the greater integration of renewables in the grid.[1]
With the electrification of usages, a rapid increase in decentralised and local loads could – if not managed correctly – overstretch the current low-voltage distribution grids, particularly in residential or commercial areas[2]; smart-charged EVs provide a solution. Bidirectional charging and other flexible services – where appropriate – can also provide solutions and benefits, both to the grid and to the end-user (of the grid and of the vehicles), and should not be overlooked.
The Platform for electromobility therefore welcomes that the ‘Fit for 55’ package recognises the importance of smart charging for integrating transport in the energy system but we encourage more robust and consistent support for smart charging throughout the package. In order to unlock all the benefits smart charging can deliver to the electricity system, to EV users, to the environment and to society at large, the following considerations should be respected in a coherent manner throughout all relevant legislative files.
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What should be classified as smart charging?
Definitions of smart charging differ between legislations. Indeed, different levels of ‘smartness’ are possible, depending on the business solution deployed and the level of involvement of the consumers. The Platform for electromobility believes that charging installation should be considered smart if:
- it provides real-time adjustment
- it adjusts charging in response to external signals
- the adjustments give additional clear benefits to the EV driving consumers, providing flexibility to the grid.
Bidirectional charging comes to complement smart charging services. While unidirectional charging enables adjustment to the charging process depending on external signals, bidirectional charging – also known as V2X (‘vehicle-to-everything’) goes a step further. It allows the vehicle to exchange energy with the connected asset (grid, home, building) in both directions, as well as charging or discharging for as long as it is plugged in. This means that the vehicle can offer services for a longer timeframe, as unidirectional charging stops once the battery is full.
What are the benefits of smart and bidirectional charging?
Flexibility services are a vital enabler for grid management in the energy system of a carbon neutral Europe, and smart charging can play a crucial role in delivering this flexibility. New and refurbished charging installations (public and private) should therefore be smart.[1] The timeframe for a potential eventual retrofit of existing stations should be defined through a comprehensive impact assessment, coordinated with the stakeholders of all affected sectors and Member States. Such an impact assessment will allow a comprehensive overview of the requirements for retrofitting, and will therefore optimise both the cost and the deployment of smart charging points.
- Smart charging will have a key role for the user in:
- Empowering consumers in the energy transition, by transforming electric vehicles into an energy asset.
- Taking full advantage of low electricity prices in the system for consumers and reduce the consumer’s bill of electricity (savings are estimated between €60 and €170 per year[2]).
- In the heavy-duty vehicle (HDV) segment such as e-buses, smart charger capability offers the possibility to optimise the charging process according to the e-bus’s schedule, managing the allocation of the available power at charging depots (e.g. identifying and setting different priorities and criteria for charging the vehicle based, for example, on the order of arrival, departure-time priority, etc.).
- Smart charging will have a key role for the grid in:
- Increasing system efficiency, by integrating the road transport sector into the energy system. This will optimise the use of the electricity grid and reduce the investments required in the power grid (which could reach €375-€425 billion by 2030[3]) compared to those of unmanaged charging.
- Avoiding grid congestion, by lowering the load pressure and consequently enabling the more efficient integration of EVs into the power system.
- Taking full advantage of the availability of renewable electricity, therefore increasing the penetration of variable renewable energy within our energy system.
- Bidirectional charging could also have a key role for the user in:
- Empowering the consumer in the energy transition to an even greater extent, by transforming the electric vehicle into a ‘battery on wheels’.
- Taking full advantage, and in particular Vehicle-to-Home (V2H), of self-consumption while mitigating their exposure to high prices for customer exposed to dynamic tariffs.
- Selling back electricity to the grid to bring further significant financial benefits for the consumer.
- Generating further revenue streams for public transport operators and/or fleet managers, in particular in the case of depot charging, allowing reductions to the total cost of ownership and thus offsetting the cost of charging infrastructure while generating additional revenues.[4]
In addition, other technological innovations capable of bringing flexibility to the system in the future – as well as a proper determination of the correct balance between charging modes using a case-based approach – should not be ignored but rather be carefully considered.
How to make smart charging work?
An enabling policy framework is needed to unlock these benefits and deliver them to both the electricity system and to society at large. The legal framework should be consumer-focused, consistent, future-oriented, and should allow appropriate reactivity, coordination and data sharing:
- Consumer focused: Any legal framework should create provisions that ensure that those EV drivers who provide flexibility by adopting smart charging solutions receive net positive effect for so doing. Consumer adoption is key to a successful implementation of smart charging technologies, and therefore should be made the central stakeholder.
- Consistent: Any definition and provisions set out in the AFIR, the REDIII and in the revision of the EPBD, should be both mutually consistent and consistent with energy directives in general, in line with the definition of storage. In particular, it will be essential to maintain consistency between the different definitions for smart and bidirectional charging. Furthermore, it will be vital that regulations consistently pursue a level playing field for smart charging and other technologies that provide flexibility to the grid. Consistency between legal definitions should also be ensured by avoiding overlap with the definition of ‘digitally connected stations’. To run the smart charging system in a coherent way, regulatory framework must also support the different actors of the eco-system to cooperate together, including OEMs, to optimize the benefits while ensuring that batteries are preserved.
- Future-oriented: A legal definition of smart charging should be sufficiently broad, and mention benefits without mentioning technicalities, so as to include future technologies.
- Reactivity: Smart charging should allow adjustments that are rapid enough to deal with grid disturbances and emergencies.
- Data: To ensure this necessary level of reactivity, smart charging requires access to information from the battery management system. On the basis of a contractual agreement, relevant and necessary data should be made available to vehicle owners and users, as well as third parties acting on their behalf.
- Cooperation: Smart charging needs the different actors of the eco-system to work together, including OEMs, to optimize the benefits while ensuring that batteries are preserved.
Our specific policy recommendations for smart and bidirectional charging
Incentives and support for the uptake of smart charging should be proposed, as it can offer a full range of additional services compared to regular charging. Bidirectional charging should also be encouraged when demonstrating the positive socioeconomic impact and creating a net benefit for the EV driving consumer who is contributing to the energy efficiency of the entire system.
The Platform calls for ensuring the consistency of the RED III with both the new Regulation on the deployment of alternative fuels infrastructure and with the energy performance of buildings directive (EPBD). The current definition of smart charging and bidirectional recharging should be aligned, and any changes to the related definitions and provisions in one text should also be made in the other.
The Platform welcomes the Commission’s recognition of the role of smart charging in the AFIR for enabling system integration. Improvements should also be made to support smart charging deployment. We therefore call for improvements to the requirements on smart charging (art. 2 and 5.8). You can read more details in our paper dedicated to AFIR here.
Time with the vehicle plugged: as important as using a smart charger: To realise the full potential of smart charging, the recharging points should be deployed at locations where vehicles park for extended periods of time. This allows the flexibility of choosing when to start and stop charging. At or near home is the main one, followed by the workplace. On average in EU, 60% of passenger cars have access to off-street parking at home, where is relatively easy to install a small charger. The other 40% of the car fleet will depend on the urban public infrastructure to recharge their batteries, as most of them won’t have access to a parking space at work.
On average, a battery passenger car in the EU consumes around 50 kWh/week. Three main prototypes of public recharging exist: high-power charge stations (equivalent to a petrol station), chargers in commercial areas (typically 22-90 kW) or chargers in residential areas (3.7-11 kW). High power chargers have limited flexibility. Here drivers usually seek the maximum power in the shortest amount of time possible In a commercial area, the vehicle will need between one to two hours a week, while in a residential area, the car can be plugged in for more than 12 hours a day (even more during weekends) replicating the use case of people with off-street parking at home. In other words, in residential areas, the vehicle can be plugged in for 64-times longer than in a commercial location.
[1] https://insideevs.com/news/564628/europe-plugin-car-sales-2021/#:~:text=Thanks%20to%20the%20strong%20second,in%20ten%20was%20all%2Delectric. [2] https://www.transportenvironment.org/discover/evs-will-be-cheaper-than-petrol-cars-in-all-segments-by-2027-bnef-analysis-finds/ [3] Elia Group “Accelerating to net-zero: redefining energy and mobility” [4] Smart charging: integrating a large widespread of electric cars in electricity distribution grids – EDSO, 2018 [5] Exceptions such as underground parking lot, where Wi-Fi to is impossible may exist or through location management system. [6] https://www.concerte.fr/system/files/concertation/Electromobilite%CC%81%20-%20Synth%C3%A8se%20vFinale.pdf [7] “Connecting the dots: Distribution grid investment to power the energy transition”, Monitor Deloitte, E.DSO & Eurelectric, January 2021 [8] Currently, and assuming that the availability band made available by the e-buses in depot is 50 KW, it is expected that “Bus 2 Grid” will reduce the costs of the infrastructure to zero and generate additional annual revenues of €1000 per bus. Enel Foundation 2021 “Scenari E Prospettive Dell’elettrificazione Del Trasporto Pubblico Su Strada”.
Ou response to the consultation on the Transeuropean Network of Transport (TEN-T)
Transeuropean Networks - Transport
Our response to the consultation
The Platform for electromobility welcomes the EC proposal for a revision of the TEN-T guidelines as a necessary instrument to make transport modes more sustainable by setting firm incentives and requirements for transport infrastructure development.
In particular, we welcome:
- The introduction of “The promotion of zero emission mobility in line with the relevant EU CO2 reduction targets” as first point in the Sustainability’s objective of TEN-T.
- The direct link to AFIR provisions on the deployment targets of charging infrastructure for LDV & HDV as well as for the onshore power supply infrastructure.
- The extended core network to be completed by 2040.
However, some adjustments to the proposal are deemed necessary:
Promotion of the transition towards a clean and zero-emission transport system and fostering its charging infrastructure. The “energy efficiency first” principle should be reflected in planning and investment decisions related to the deployment of recharging and refueling infrastructure. The “zero-emission” solutions and deployment of related infrastructure should be explicitly identified within the additional priorities in the promotion of projects of common interest (PCI) for all transport modes. The TEN-T is closely linked to the TEN-E, hence it is paramount to reinforce and support the seamless integration of EV and charging infrastructure with the energy system stimulating solutions such as “energy storage” and “vehicle grid integration”.
Covering regions beyond the Core Network. The deployment targets of charging infrastructure along with the comprehensive TEN-T network as foreseen in the AFIR proposal for LDV should be brought forward as per the Core network. It will fill the gap in terms of social and economic disparity.
Consistency with the AFIR revision. The proposed TEN-T regulation includes clear provisions on indicators for the provision of alternative fuel recharging/refueling infrastructure for the different modes of transport. Its successful implementation will strictly depend on the synergies between the TEN-T and the AFIR, as both are intrinsically dependent on each other. For example, the AFIR proposal regulates the provision of charging/refueling points on the TEN-T network, while the TEN-T Regulation provides the infrastructural basis for their wide deployment from an EU network perspective.
Introduction of the reference to alternative fuels for rail. There is potential for alternative fuels as a complement, particularly where direct electrification is not a viable option. In particular, Art. 14 extends the list of rail infrastructure components including rail services facilities, rail access routes and last mile connections. However, it is sometimes not feasible or economically relevant to mandate direct electrification for some of these segments of the network. In these specific cases, possibility should be opened to offer zero-emission solutions based on alternative propulsion systems (e.g., battery trains). A more flexible derogation process under Art. 15 should also be considered to allow for the deployment of such technologies.
Guarantee of an appropriate level of funding. In this sense, the EC considers that the largest part of investments is estimated to originate from public funding (national public funds, EU funds) and would amount to €244.2 billion over 2021-2050. As possible and suitable additional funding support, the budget for Connecting Europe Facility (CEF) transport could be increased. In addition, given the significant funding allocated to mobility infrastructure including the TEN-T Network within Member States’ National Recovery Plans (NRPs), the tight deadline for the commitment of funds (2023) and its subsequent implementation (2026), the Platform supports the Commission to increase and facilitate further synergies between CEF and funding from the NRP and the Cohesion Policy Programs.