The 10 points for success of the new Alternative Fuels Infrastructure Regulation (AFIR)

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The Platform for electromobility supports the AFIR proposal, which is vital for boosting the electrification of transport and providing the right tools to drive the growth of electromobility.

In particular, the Platform welcomes:

  • The switch from a Directive to a Regulation

As supported by our members in a previous communication, a Regulation will ensure the strong, rapid and more uniform implementation in all Member States.

  • The setting of minimum mandatory targets for light-duty vehicles (art. 3)

The AFIR sends the right signals to meet the EV demand on the roads. The sales of electric vehicles (EVs) in the EU1 continue to grow. Combined with the coming ban on sales of internal combustion engines by 2035 - as proposed in the revision of the Regulation on the CO2 emission standards for cars and vans - it is key to speed-up the roll-out of charging infrastructure across Member States. This will require the deployment of operational and accessible charging points where they are needed, and capable of delivering the right power output. Combining fleet-based targets with distance-based targets on the TEN-T ensures that the roll-out of charging stations matches the uptake of EVs.

  • New mandatory targets for heavy-duty vehicles (HDVs), maritime and inland waterway ports and stationary aircraft (art. 4, 9, 10 and 12)

The Platform fully supports the proposal for setting mandatory targets for HDVs, as this addresses the specific charging needs of electric trucks on the TEN-T networks as early as 2025. We also welcome the introduction of targets for maritime and inland waterway ports and stationary aircraft, as it helps boost the electrification of the transport sector.

Keeping those provisions is the first priority to make AFIR a success. However, the Platform believes that further improvements are needed, and has therefore set out a series of recommendations:

Clarify the definition of “alternative fossil fuels for a transitional phase”

The definition of “alternative fossil fuels for a transitional phase” (CNG, LNG, LPG, synthetic and paraffinic fuels produced using non-carbon-free energy) should specify until when this transitional phase will last.

Strengthen the level of ambition of the mandatory targets for light-duty vehicles (LDVs) (art. 3)

Currently, the power ratio of 1kW per 100% battery EV (BEV) and 0.66kW per plug-in hybrid EV (PHEV) would be already met by all but one of the Member States. In addition, the Commission’s analysis follows a methodology in terms of kW used (consumption evenly distributed during the year), which does not allow a response to peak demand. It is essential to consider the actual power delivered by a charging station, not the maximum power output (art. 2.37).

- Accordingly, the targets for BEVs and PHEVs should significantly increased until a point where a market can function organically. The targets should then be progressively lowered as the EV fleet size grows, and then ultimately phased out entirely when it reaches 7.5% of the entire fleet, as by then there will be sufficient demand to support a competitive private sector for EV recharging.

- The distance-based target of 60km between charging stations along the TEN-T network should be maintained during the upcoming negotiations. The customer-friendliness of charging stations should also be taken into consideration.

- The targets for the TEN-T comprehensive network should be brought forward by five years, so that all citizens can reach any destination within the EU using an EV.

- The deployment of alternative fuels infrastructure at the local level should be based on systematic consultation with local authorities as well as on the content of Sustainable Urban Mobility Plans (‘SUMP’).

- A density parameter can be included, to ensure that urban areas are properly covered and that there is a balanced territorial coverage.

Increase the power output for HDV-charging targets and consider the development of electric road systems for HDVs (art. 4 and 13)

Member States should have the possibility of promoting the deployment of Electric Road Systems (ERS) on sections where this is appropriate, in order to complement the targets for electric recharging stations. The Commission’s estimation of zero-emission trucks is significantly lower than the sales envisaged by truck makers.

- An increase total power output of HDV-charging pools along the TEN-T network should be considered, along with higher targets for urban nodes and for safe and secure parking areas.

- Targets for (semi-)public chargers at logistics centres and depots should also be introduced.

- The current timeline (targets starting from 2025 along the TEN-T core network) should be maintained, in order to not hinder the ramp up in the market for zero-emission trucks.

Complement rail electrification with additional guidance on deploying alternative fuels for the rail sector

We welcome the fact that the deployment of alternative fuels for railways has been included within the scope of the Regulation proposal, in the context of the National Policy Framework (art. 13). Setting decarbonisation targets for the rail sector would be consistent with the objectives set out in the European Green Deal and the Sustainable and Smart Mobility Strategy.

- Given the specific circumstances for investing in railway infrastructure, the deployment of hydrogen refuelling points or electric recharging points for battery trains are best dealt with on a national level. This should be done via the National Policy Framework of article 13, respecting the general EU principle of subsidiarity.

- Investment in alternative fuels infrastructure should take into consideration the national context as well as those rail network segments that are not going to be electrified.

- Investment in alternative fuel infrastructure for railways would be consistent with the provision -under the CEF2 Work Programme - of funding eligibility for hydrogen refuelling infrastructures for rail. Therefore, provisions of the Commission proposal for deploying rail alternative fuels infrastructure should be maintained (as set in art. 13.1 point (p)).

Improve the requirements on smart charging (art. 2 and 5.8)

The Platform welcomes the Commission’s recognition of the role of smart charging in the AFIR for enabling system integration. However, Platform has concerns over the retroactive effect of the measure. The following improvements should also be made to support smart-charging deployment.

- Amend the definition of smart charging (art. 2.59) as follows: “a recharging operation in which the power of charging can be adjusted within a specified time, based on external commands in order to enable a better integration of EVs into the whole power system to allow the possibility of a grid- and user-friendly way services”.

- Clarify the scope of ‘digitally-connected charging’ (art. 2.14), which should be limited to communication capacity needed for availability status and payment methods. The definition as currently written is confusing, as it may interfere with the smart modulation of power, thus overlapping with the definition of smart and bidirectional charging. The definition should leave a degree of flexibility, in order to take into account the differing levels of technological maturity in Member States.

- Cater for the future introduction of bidirectional charging capabilities in art. 5.8, allowing this technology to advance in the coming years. In addition, the development of bidirectional charging should not be left to an assessment by System Operators alone (art. 14); it should involve all relevant stakeholders, in order not to limit its uptake.

- The obligation in art. 5.8 should apply to all newly installed and refurbished or replaced recharging facilities as well as those financed by public funds.

- Given the environmental issues and to avoid the high compliance costs for CPOs, Member States should evaluate regularly (e.g., every three years) the need to retrofit existing charging stations.

- The reference to ‘normal power’ should be removed. Smart charging should be done in coherence with the proposal of revision of the Renewable Energy Directive. Therefore, para. 8 of art. 5 should be amended as follows: “From the date referred to in Article 24, operators or recharging points shall ensure that publicly accessible newly built and refurbished as well as publicly funded recharging stations operated by them are capable of smart charging.”

Harmonise the status of charging at EU level

The AFIR should harmonise the status of charging (as a good or as a service) without modifying the statuses that are already in place at national level in the majority of the Member States. The alignment between the different elements of legislation on the interpretation of what constitutes a recharging session would avoid business uncertainties.

In art. 2.46, the ‘recharging service’ definition should be amended as follow: “‘recharging service’ means a service consisting of multiple elements, including the  provision of electricity and services, through a  recharging point;”

Remain flexible and forward-looking, in order to be ready for future innovation while avoiding prematurely mandating standards (art. 19 and Annex II)

We welcome the proactive identification of standardisation needs. This will bring benefit from an interoperability point of view. We support the fact that the proposal is not prematurely mandating unfinished standards (such as IEC 63110 and IEC63119) as to retain the possibility to identify additional needs at a later stage and avoid possible technology lock-ins.

- In line with this approach, we would like to point out the need for additional technical specifications for communication between the EV, its owner and the EV services infrastructure. This is necessary to ensure control for the user and a fair and open ecosystem. For example, EV drivers should be able to connect their EV to any home energy or fleet management system, as well as to grant access to their charging data to the e-mobility service providers of their choice.

- This should be done in agreement with the expert group of the Sustainable Transport Forum mandated by the European Commission.

Bring forward the date of submission of the National Policy Frameworks (art. 13 and 16)

The Platform believes that the calendar for the NPFs (National Policy Frameworks) should be brought forward by one year, for both the submission of the first draft to the European Commission (to 2024) and the final NPFs (to 2025).

Maintain consistency with other ‘Fit for 55’ legislation

The Platform would also like to underline that any definition and provisions set out in the AFIR, and the revision of the Renewable Energy Directive (REDIII), should be consistent2 with the revision of the Energy Performance of Buildings Directive (EPBD), given that its art. 12 will address private charging. In particular, it will be vital to keep consistency between the different definitions on smart and bidirectional charging.


New consumer study shows that the EV transition is inevitable

Download the full report here
New Study

European consumers want electric vehicles

The Platform for electromobility – representing more than 45 organisations from industry, civil society and cities, and across all transport modes – released a report carried out by Element Energy on consumer’s perception on the shift to electric vehicles (EV). The study, which surveyed 14,000 new car buyers across Europe shows that consumers are ready to move to electric.

Our policy recommendations

Significantly strengthen CO2 standards for passenger cars and vans targets

The importance of upfront cost in unlocking massive EV uptake highlights the need for ambitious regulation on CO2 Standards for cars and vans to ensure production scale up during the 2020s. An ambitious legislation will increase the offer and promote the market uptake of zero-emission vehicles. With an increased market, zero-emissions vehicles will also become more affordable at purchase price with a continuously reduced total cost of ownership and more choice for consumers and will also help tackle air quality and noise issues, bringing an overall benefit to society. As detailed above, the study confirms the feasibility of new proposed interim targets will be met by strong consumer demand.

Under the CO2 standards for passenger cars and vans, introduce a new provision to electrify corporate fleets

The study demonstrates the importance of corporate fleets in driving markets for electric vehicles. The Platform for electromobility therefore proposes to mandate the decarbonisation of corporate cars by 2030. In a previous communication, the group outlined the environmental and social benefits which such an EU-level mandate could bring. One major motive is for the EU to act quickly and decisively electrify a segment representing over 60% of vehicles sales in Europe and subsequently create a sufficient second-hand market by 2035 as most private consumers use this channel. To enshrine electrification objectives for corporate fleets in EU law, the Platform support the proposition by Rapporteur Huitema to revise the Clean Vehicles Directive (CVD). Its scope could be extended to corporate fleets as part of the revision of the CO2 Standards for cars and vans Regulation.

Do not introduce fuel crediting in the CO2 standards for passenger cars and vans

The study shows e-fuels as a dead-end solution for consumers. Even at a seemingly unreachable price parity with BEVs, consumers would still opt for the electric option. The Platform is opposed to introduction of a fuel crediting mechanism that would consider the contribution of renewable and low carbon fuels in the compliance assessment for each manufacturer. Policies focused on decarbonising fuels and those focused on reducing emissions from cars and vans must remain in separate legal instruments.

Under the Alternative Fuels Infrastructure Regulation, we need more ambitious targets for EV uptake

The Platform for electromobility believes the Commission’s AFIR proposal is a good start but, to ensure charging points keep up with the EV uptake, the level of ambition of the mandatory targets for light-duty vehicles must be doubled. For long distance journeys, the targets for the TEN-T comprehensive network should be brought forward to 2025.

The Energy Performance of Buildings Directive should facilitate the access to private charging

The revision of EPBD must ensure the right-to-plug to all EV users in order to facilitate the installation of charging infrastructure for tenants and properties under shared ownership. Drivers willing to make the transformation often face diverse obstacles: latency between requesting a charger and installation, installation of charging infrastructure for tenants and properties under shared ownership, lack of electrical pre-equipment in collective electrical installations etc. Smart charging is also required in all types of buildings as it provides benefits to both the power sector and the EV users. The revision of the Energy Performance of Buildings Directive is therefore very timely to address those challenges and ensure a minimum level of charging points in all off-street parking lots.


Launch event: "Are consumers ready for electric vehicles?"

The Platform for electromobility is pleased to organize the first ever presentation of the study ‘Are consumers ready for electric vehicles?’

The study undertaken by Element Energy and the Platform for electromobility is the largest consumer choice study ever conducted in the mobility sector and aimed to understand consumer preferences in the mobility transitions and how these could change in the future. This event will launch the public presentation of the results.

The European mobility transition will not happen without the Europeans. With the Fit for 55 Package for discussion on the table, it is now more crucial than ever to understand whether the transition to electromobility is inevitable or not?

With a special message from Commissioner Didier Reynders

Date & Time

12th January 2020
13:00 - 14:30
Online

Download the report

Link to download the report will be published here at the start of the event.

Moderation

Event moderated by Katrina Sichel

Program

Keynote speech
Didier Reynerds, Commissioner
Presentation of study
Celine Cluzel, Element Energy

Panel discussion
Monique Goyens, BEUC
Daniel Mes, Cabinet EVP Timmermans
Amélie Pans, Chair of the Platform for electromobility
Celine Cluzel, Element Energy

Closing Speech
MEP Caroline Nagtegaal

Contact

Théo Fievet
Coordinator
theo@platformelectromobility.eu
+32 4 78 70 05 48


Platform’s reaction paper to the proposal for the revision of the Renewable Energy Directive

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Renewable energy:
Our position on the revision of the directive

The Platform for Electromobility welcomes the timely revision of the Commission’s proposal for the RED (Renewable Energy Directive). This will be key in supporting the EU in reaching carbon neutrality, notably by advancing the case for an electrified, decarbonised and efficient transport sector. In fact, clean direct electrification is the most cost-effective way of decarbonising Europe and reaching the 2030 and 2050 climate targets.

Moreover, direct electrification of transport has accelerated in recent past years, and the pace is only expected to increase. According to a recent BNEF study, in order to reach 100% CO2 emissions reduction by 2035, some 67% of passenger cars sales in Europe will need to be electric by 2030.

This rapid, massive uptake of EVs has the potential to become – thanks to smart charging – a flexible asset for grid management and an opportunity for prosumer business models. It will also provide a boost to the increased and cost-effective penetration of renewable energy in the electricity system. The combination of EVs, their batteries and smart charging functionalities as sources of ancillary services for the distribution grid will clearly bring benefits in terms of RES (Renewable Energy Sources) integration. Electromobility and renewable energy therefore offer a win-win partnership.

In this context, the Platform welcomes the recognition of smart charging and, where appropriate, bidirectional charging for integrating transport in the energy system. Two aspects in particular stand out; 1) the relevance of the charging points located at long-time-parking spaces, and 2) that national regulatory frameworks do not discriminate against electric vehicles participating in the electricity markets.

However, we do believe there are certain key aspects that can still be further reinforced within the Commission proposal. These will help support EV uptake and lead to swifter decarbonisation of both the transport and energy sectors

Greenhouse Gas based mandate

The Platform for electromobility raises concerns over the shift from an energy-based target for transport to a greenhouse gas (GHG) metric. If we support the fact that a threshold expressed in terms of GHG provides a relevant tool for accelerating the decarbonisation of transport while guaranteeing technology neutrality among low-carbon technologies, it may – within the framework of the RED – add complexity to the metric. Furthermore, it does not seem to bring any genuine added value to boosting renewable energy when compared to the existing framework. In fact, multipliers are implicitly integrated in the GHG-emission calculation method, and the GHG-emission based target of 13% is equal to the 24-26% in final energy consumption considered by the European Commission in its public consultation.

Furthermore, given that currently 24 of 27 Member States implement an energy-based target, it should be noted that using such a metric will have an impact on the current implementation of the Directive; these countries will have to start from scratch again, having just finished transposing the current RED II. This could result in delays in meeting the RES-T target and the overall EU binding RES target. France, for example, is currently working on the implementation of its credit mechanism, aimed to have this enter into force by 2022 using an energy-based RES-T target. With the switch to an emission-based target, France would have to revise its credit mechanism almost immediately following its implementation, leading to further delays.

Platform Members therefore invite the Commission to provide further information on its motive and rationale behind introducing a new GHG emission-based transport target.

Inclusion of electricity in national compliance mechanisms

The Platform is pleased that the proposal levels the playing field between biofuels and electricity by including electricity in national credit systems for fuel supplier compliance. This is a feature of the Directive that we called for in an earlier communication. The proposal shall as well ensure level playing fields between zero emissions options, especially between electricity for BEVs and RFNBOs . For instance, hydrogen can claim credits for private charging while renewable electricity for electric vehicles is restricted to public recharging stations only.

Focusing specifically on ‘public’ recharging points is discriminatory and inefficient. This is because it excludes some 80% of electricity supplied to road vehicles and provides incentives for people to charge their cars at public charging points rather than at home, as well as for companies not to charge their trucks and buses at their depots. The scope of the electricity credit mechanism should therefore be expanded to include recharging stations more generally, encompassing both public and private ones. It should also be possible for such a credit mechanism to also be applied to other types of transport such as rail, aviation or shipping.

The text is unclear as to whether it would apply to charge point operators (CPOs) alone, or whether it would also apply to electricity suppliers.  Within the current proposal, this could lead to a situation with different incentive schemes resulting in confusion amongst actors and the relevant incentive schemes.

Permitting

The Platform supports the Commission’s proposal to tackle the remaining barriers, including those relating to permitting procedures. We welcome in particular the proposed publication of a guidance on best practices to accelerate the permitting of projects. We urge the European Commission to publish such a guidance swiftly and ensure the best practices are disseminated to local authorities. Nevertheless, the review of permitting administrative procedures must be urgently addressed in the short term in the RED III and not be left until 2024. This will be key to preventing bottlenecks that may hinder the achievement of national RES commitments and the deployment of renewable installations more generally. We also recall that this should be done in cooperation with grid operators in order to preserve the security/stability of the grid.

Coherence with the Alternative Fuels Infrastructure Regulation (AFIR) and the upcoming revision of the Energy Performance of Buildings Directive (EPBD)

The Platform calls for ensuring the consistency of the RED III with the new Regulation on the deployment of alternative fuels infrastructure. The current definition on smart charging and bidirectional recharging should be aligned and any change to the related definitions and provisions in one text should be made in the other.

Furthermore, given that the European Commission has integrated provisions on the private charging points regarding smart charging in the RED III, we would like to underline the necessity of ensuring their coherence with the upcoming revision of the EPBD, which addresses private charging in its Article 8.

Coherence with Battery Regulation

On the data-sharing requirements relating to batteries, the Platform recommends ensuring consistency with proposed requirements under the EU Battery Regulation proposal and avoiding any duplication. For example, new performance and durability requirements for batteries are already included in Article 10 of the Battery Regulation proposal.[1] Similarly, the information on the state of health of the battery is included in Article 14 of the proposal.[2]

 

 

[1] The UNECE has recently developed performance and durability requirements via GTR, and therefore may be directly applied by the EU.

[2]This is also regulated by UNECE GTR on in-vehicle battery durability, namely ‘State of Certified Energy’ (SOCE), or capacity fading, and ‘State of Certified Range’ (SOCR).


Zoom in on the deployment of charging infrastructure in France

Zoom in
the deployment of charging infrastructure in France

The French government set ambitious objectives for the deployment of charging stations to deploy 100,000 charging points (CPs) by the end of 2021 and to equip all service areas on the highways with fast charging stations by 2023.

To know where to go, we need to understand where we are. This is why, UFE has launched two mapping tools, updated every 3 months, that aim to follow the state of deployment of the public CPs in France.

  • Mapping 1 reflects the deployment of publicly accessible charging infrastructure in the French regions and departments since September 2020.
  • Mapping 2 shows the (ultra-) fast CPs on the French conceded highway network since March 2021.

Methodology[1]

Mapping 1 indicates the number of EVs available for 1 CP per region and department, with reference to the ratio of 1 CP per 10 EVs set by the current Alternative Fuels Infrastructure Directive (2014/94/EU). Mapping 2 assesses the equipment rate of the service stations in at least 50-kVA CPs for all motorways operated under a concession.

Where does France stand at the end of September?

France has acquired around 46,300 CPs and 660,000 electric vehicles in circulation since 2010. Over the past year of monitoring the CPs’ deployment in regions and departments, the number of CPs has increased by 42%, while the EV fleet has grown by 78%. Even if the number of CPs keeps increasing gradually every 3 months, the threshold of 1 per 10 has been exceeded in all regions except Occitanie.

As for CPs on the highway network, (ultra-) fast charging has increased by 9% in France since June 2021 or by 42% in 6 months. 55% of the highways were equipped with at least one fast CP equal to or greater than the 50kVA.

Conclusion

UFE’s mappings show that, while the country is on the right track, more efforts are needed to reach the objectives set by the government for the deployment of public CPs in regions and departments. In this respect, the new AFIR could give France the final boost it needs with the right targets.

[1] AAA Data’s (electric vehicles) and Gireve’s (charging points) figures for UFE


Interview with Amélie Pans, Platform chair 2022

Interview with
Amélie Pans, 2022 chair of the Platform

WG Leaders will make sure to come up with excellent workplan for 2022, but beside the content, what do you think the Platform should focus on in 2022?  

The number of files relevant to the Platform keeps growing but our days weirdly are still 24-hours long. So I would recommend to refocus on key files and ensure we have a strong impact of each of them. I do not have strong recommendations on which to put up the list but that can be discussed within WGs. Secondly, I’d like to look for the Platform to gain efficiency in our internal discussions, reduce the amount of exchanged emails and multiplication of versions of our draft papers. And finally, the Platform should communicate externally more effectively  

How could the Platform communicate more effectively as you say?  

2022 will be a fight for attention among stakeholders and associations like us to talk with policy makers and raise our issues in the public debate. We’ll have to join efforts to talk louder than others. We all spend a lot of time to come up with Platform’s positions, organize events and so on; we don’t do that to put the papers up on the shelf but to communicate them around. An easy step forward would be to share them on our personal social media for example.  

You mentioned the importance of a gender balance governance, it is true that women are still underrepresented in the whole transport industry. What do you want to say  

Although it is outside the scope of the Platform to advocate for gender balance policies, we should make sure to lead by example here. Even before I take the chairwomanship, I must say with Emilia, Claire, Marie-France, Chiara and Sarah leading our working groups and Julia being our vice-chair the Platform was always at the forefront of the fight. What can we do more? There are many of transport and energy female leaders at EU and global – how about a series of interview with them to shine a light and inspire others?  And we should also walk the talk by ensuring that panels at our own events are always balanced. 

Since its birth in 2015, the Platform has been growing covering more parts of the value chain. In which direction would you like to see the Platform grow in 2022? 

Beside growing its impact on social media, I think we should also think about contacting allies outside the box. For example, the Platform could go and meet the navigator providers (Waze, Google…) regarding the mapping of the charging stations. We can also get in relation with builder associations when it comes to the EPBD to show them the added value of the charging infrastructures. 

By the way, I’d like to take some times to meet with members to discuss all those points and more during informal chat. You can plan a meeting here.