Platform comments the EU Renewable Energy Directive in light of the EU Green Deal

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In the past years, electricity-based transport technologies, such as electric vehicles (EVs), have significantly developed and decreased in cost. These technological improvements and demonstrated benefits of electrification call for an improvement of the sectoral target for renewable energy in transport to better reflect the positive environmental contribution of electric transport, as part of the envisaged reopening of the Renewable Energy Directive 2018/2001 (RED II). In parallel, EU Member states’ National Energy and Climate Plans (NECPs)’ pledges show prospects for an accelerated deployment of renewables in the energy mix, and in particular in the electricity system, supporting the decarbonisation of transport along the full lifecycle of the fuel.

While many studies have demonstrated the scope for an increased volume of renewables in transport[1], it is critical that the Renewable Energy Directive’s framework for renewables in transport is revised to accelerate the electrification of the transport sector with renewable electricity generation.

The Platform therefore recommends introducing an obligation for Member states to introduce fuel-neutral credit trading mechanisms as a mean for obligated fuel suppliers to account for renewable energy used in transport.

The implementation of the RED II, which all Member states (MS) are required to transpose by June 2021, offers a great opportunity to accelerate EV uptake and the efficient penetration of renewable electricity in the transport sector. Yet, most MS and their national policies on renewable transport fuels still do not allow electromobility to contribute to the achievement of the RES-T target[2]. Most national policies still implement the RED II by means of a blending mandate imposed on the obligated parties, i.e the fuel suppliers. Yet, renewable electricity is not a drop-in fuel that can be blended and is not properly accounted in RES-T targets, creating a missed opportunity to properly reflect the decarbonisation of transport and creating a missed level playing field.

The introduction of fuel-neutral credit trading mechanisms could support the adaptation of the RED II framework to the accelerated electrification of transport. Fuel-neutral credit trading mechanisms consists in requiring obligated parties to meet their renewable energy obligation by means of fuel-neutral credits, accounted in energy equivalent (kWh, KJ, Gcal or other). In parallel, fuel-neutral credits are allocated by a public authority to defined parties for each energy unit of renewable fuel used in transport. As for electricity, various possibilities exist concerning the party entitled to receive credits (charging station operator, electricity supplier, etc.). Obligated parties can then either acquire fuel-neutral credits by increasing blending in their fuel supply or by procuring credits from third parties through a dedicated platform. Such schemes have already been introduced in the Netherlands, in Germany, in California and in France, and are being elaborated in Canada[3]. The Platform believes credit revenues shall be used as a leverage to support electromobility in Member States.

Electricity credit mechanisms represent a low hanging fruit that could adequately value the contribution of renewable-based electromobility to the decarbonisation of transport. Importantly, they would also generate resources for the diversity of players in the electromobility sector without weighing on state budgets. For instance, credit revenues could support charging point operators to improve the business case of charging infrastructure and – as a result – accelerate the roll-out of the millions of chargers needed and help the EU reach its objective of establishing 1 million charging points by 2025, as set out by the European Commission in its European Green Deal communication[4].

Further, future credit trading mechanisms should follow the specific principles below, subject to implementation in Member states:

  • Fuel neutral credits should be granted for the renewable share of the electricity used in EVs, calculated on the basis of the share of renewable electricity in the national mix as close as possible to real-time. This would incentivize for a better real-time match between the renewable generation and EV charging.
  • Future credit mechanisms should allow for the accounting of 100% renewable electricity used in transport. As a principle and as specified in article 27 of the RED II, fuel neutral credits should be granted for the renewable share of the electricity used in EVs, calculated on the basis of the share of renewable electricity in the national mix in the previous maximum two-year period. Yet, Member states should also allow for the accounting of 100% renewable electricity supply to transport, such as electricity supplied through a direct connection to a renewable energy generator or via an innovative supply contract such as Power Purchase Agreement (PPA).
  • As most kWhs used by EVs will be charged at home or in the workplace and not at public chargers, it should also be assessed how future credit mechanisms could account for the renewable kWhs charged at home or in the workplace, which will also enable to maximize the share of electrons captured.

[1] Among other studies: 17% of final energy demand in transport will be renewable by 2030 (in final energy demand, without multipliers or subtargets) according to SolarPower Europe (2020). 100% Renewable Energy Europe

[2] Transport & Environment (2019) Using Renewable electricity in the Renewable Energy Directive

[3] On the Dutch, German and Californian example, see Transport & Environment (2019) Using Renewable electricity in the Renewable Energy Directive.

The government of Canada is considering establishing a clean fuel standard that will count and credit clean electricity used. Networked charging operators (including utilities operating charging) and, in its 2018 Proposed Regulatory Approach, proposed that automakers be able to participate using vehicle telematics in the crediting system and market.  Canada’s program is expected to start in 2022. For further information: https://ww2.arb.ca.gov/resources/documents/lcfs-electricity-and-hydrogen-provisions

https://www.emissionsauthority.nl/topics/themes/energy-for-transport

The French government is designing a crediting system too as part of the revision of its 2021 budget bill, in current article 15. For more information, see http://www.assemblee-nationale.fr/dyn/15/textes/l15b3360_projet-loi

[4] https://ec.europa.eu/info/sites/info/files/european-green-deal-communication_en.pdf


An ambitious revision of the AFID consistent with the EU Green Deal

Key recommendations
The Platform for Electromobility calls for an ambitious revision of the Alternative Fuels Infrastructure Directive (2014/94/EU, AFI) consistent with the EU Green Deal
February 2021
An ambitious revision of the AFID is vital to accompany and boost the electrification of transport and reduce GHG emissions as requested by the EU Green Deal and the EU Smart and Sustainable Mobility Strategy. The current AFI Directive was adopted at a time the market for alternative fuels was still an emerging market. Europe must now equip itself with the right public and private charging infrastructure to support the surge of electric vehicles (EVs) and the transition to a zero-emission mobility.
In this context, the Platform for Electromobility calls for:
EXTENDING THE SCOPE OF THE DIRECTIVE
Given the EC’s goal to reduce EU GHG emissions by 55% by 2030, the revised AFID must incentivise the uptake of low and zero emission vehicles.
Key actions:
• Prioritise the electrification of transport as the most effective and efficient pathway compatible with the objectives of the EU Green Deal and the decarbonisation of mobility. In particular, the Platform underlines that the decarbonisation of the transport sector cannot be achieved with the fossil fuels still supported in the current AFID.
• Set minimum mandatory targets for the availability of recharging points in all public parking facilities from 2025 (e.g. supermarkets, shopping malls, car park operators etc.).
• Introduce an updated definition of charging points based on their power levels to the existing one, i.e. ultra-fast (≥150 kW) and fast charging (22-150 kW). Criteria for minimal requirements should embrace the number of points, charging power, ratio to the number of EVs. The market should decide the most useful power level to apply.
• Apply the revised directive also to charging infrastructure for Heavy Duty Vehicles (HDVs) (trucks and buses), electric charging for two wheelers and rail infrastructure. For HDVs, the specific charging needs of electric trucks should be addressed by introducing requirements for the roll-out of public charging infrastructure and electric road system for electric heavy-duty commercial vehicles (vans and trucks) in medium and large urban areas by 2025, as well as along the TEN-T Core Network.
• Require Member States to propose to the EC a decarbonisation strategy for their rail system, identifying the alternative fuels that they intend to make available on the parts of their network that are neither electrified nor mandated to be electrified under an existing EU regulation. In particular, MS should include in their strategy a plan to replace current refueling facilities as defined in point 2.(i) of Annex II of the Directive 2012/34/UE “Recast”.
• Revise consistently the AFID and the Energy Performance of Buildings Directive (2010/31/EU, EPBD) to ensure the same level of ambitions in both texts. The way article 8 of the EPBD imposes an obligation for the deployment of charging infrastructures in non-residential buildings may have an impact on publicly accessible charging infrastructure since some non-residential buildings are open to the public such as malls. Besides, the EPBD should address the issue of private charging in all types of buildings as it is also important for the development of electromobility.
SETTING MINIMUM BINDING TARGETS for the deployment of publicly accessible charging infrastructure
Key actions:
• Introduce minimum binding targets per Member States on the number of public chargers deployed per type of transport (Light Duty Vehicles, Heavy Duty Vehicles) starting in 2025. Minimum binding targets should also be set for the deployment of charging infrastructure for airport infrastructure for ground movements and onshore power supply or boat ‘refuelling’ in maritime and inland ports.
• Develop an EU methodology to set the binding targets introducing penalties in case targets are not satisfied. These targets should ensure that – at the minimum – the EU objective of 1 million public chargers in 2025 and 3 million in 2030 are reached. The penalties of each MS should be reinvested at national level for zero-emission mobility measures (like funds for electric infrastructures, public subsidies for EV uptake in favour of citizens or businesses like purchasing aid or fiscal measures etc.).
• Establish a new bottom-up EU metric considering the charger power level of charging points, the number of EVs, assessing locally the right geographical coverage of infrastructure (via geographic, traffic and density criteria) and including the level of access to a private charging infrastructure. Given that two thirds of cars are parked overnight on the street (or public car parks), EV users living in condominiums, in particular, should be able to benefit from a public charging point in their residential area when it is not possible to install a charger in their building.
• Empower local authorities to take clearer and simpler administrative procedures to install public charging infrastructure.
• Request Member States to decarbonise the non-TEN-T part of the rail network, through further electrification, where economically feasible, or through battery and hydrogen powered trains.
ENSURING CONSISTENCY between the AFID and the TEN-T Core and Comprehensive Networks
The EC should revise the TEN-T guidelines in line with the requirements of the revised AFID.
Key actions:
• Make the minimum target of one charging point/60 km mandatory, as defined in the TEN-T Core Network for both TEN-T Core and Comprehensive Networks by 2025 to make the EVs convenient for long road journeys and ensure the coverage of the TEN-T Networks with ultra-fast chargers, including urban fast charging hubs.
• Align the TEN-T high-power recharging infrastructure requirements with the electricity development plans.
• Focus on the part of the main line rail network which is not part of the TEN-T as well as nodes on the Core and Comprehensive networks (ports, multimodal terminals for example).
DEVELOPING SMART CHARGING
The Platform emphasises the capacity, in general, of electricity system operators to integrate EVs even with an ambitious target for 20301. However, in some places of Europe this would require the adoption of smart-charging
1 In France, the French DSO Enedis has concluded in a report that the needed investment to integrate EVs into their grids will only represent 10% of their total investment by 2030 (cf. Enedis, Report on the integration of electric mobility in the public electricity distribution network, November 2019)
strategies to optimise network investment and, potentially, reduce the need for grid reinforcement. The Platform underlines that smart charging should be developed in accordance with the evolution of mobility needs of EV users and with their consent.
Key actions:
• Introduce a definition of “smart charging” as charging of an EV which facilitates the security (reliability) of electricity supply while meeting the mobility needs of the user. The definition should serve as basis and be referred to in other legislations. It should be coherent with already existing legislations supporting the integration of EVs in the power system (e.g. electricity regulations on the role of DSOs).
• Ensure that publicly accessible normal charging points (<22 kW) installed from now on are smart and future proof. This requirement should specifically apply in residential areas and cities where people may have limited access to private charging points.
GUARANTEEING INTEROPERABILITY via a user-centric approach
The electricity charging infrastructure should be interoperable to provide seamless EV charging experience to the users through the use of open and compatible standards and open and shared data on information, location and availability of chargers as well as price transparency to deliver more intelligent services such as smart charging, roaming of service and common ad-hoc payments (at least at national level). The EC should provide a harmonised framework for product and security requirements for charging and data exchange at the different interfaces without excluding technology already in the market.
Key actions:
• Put in place interoperability principles for the operation of various technical standards and protocols on the market to promote a competitive market environment and improve user experience.
ENSURING A STRONG IMPLEMENTATION OF THE DIRECTIVE
To ensure the rapid and strict implementation of the binding targets and provisions set in the revised AFID, the EC should tighten the EU monitoring and further involve the local level.
Key actions:
Consult with local authorities and distribution system operators when developing National Policy Frameworks or strategies to implement them.
• Create independent national reporting authorities within Member States (such as National Energy Agencies) in order to strengthen EU monitoring of the implementation Member States’ target.
,
• Turn the AFI Directive into an ad-hoc EU Regulation for road transport infrastructure to ensure a strong, rapid and more uniform implementation in all Member States. However, considering other modes of transport (inland waterways, maritime transport) for which alternative fuels are less mature, the directive should remain the preferred regulatory tool.


Platform for Electromobility reaction to the revision of the European Batteries Directive

The Platform for Electromobility – representing 39 industrial, urban and environmental stakeholders from across Europe’s e-mobility value chain – welcomes the Commission’s long-awaited publication of their proposal for new European rules for batteries as presented today.

This comprehensive legislation will be key to ensuring batteries on the European market are both produced in a socially and environmentally sustainable manner, while at the same time, putting the EU firmly on track to meet to achieving its 2050 climate-neutrality and industrial leadership ambitions as set out by the Strategic Action Plan on Batteries. The revision of the current legislative framework has the potential to provide further regulatory support and clarity for the European battery manufacturing and recycling industries by establishing legislative measures capable of increasing the continent’s competitiveness in the booming e-mobility sector. Specifically, the the whole objective of the proposal should create the legal conditions and incentives for a domestic, competitive, high-quality battery market to emerge in Europe, with true business cases for battery end of life management and environmentally sound recycling, which can help accelerate the EU’s transition to zero emissions.

Batteries will underpin Europe’s drive to climate neutral economy and zero-emission transport. In this context, we urge policymakers to keep the following in mind as the Commission proposal is debated in the European Parliament and Council:
1. Ensure comprehensive due diligence requirements – from sourcing, to refining and manufacturing – are supported at EU level so that the battery industry can bring social and environmental value along the entire value chain;
2. Develop a robust EU carbon footprint methodology addressing all batteries chemistries and covering all key emission hotspots/phases;
3. Pave the way for an effective, net-value circular economy strategy capable of treating developing waste volumes and meeting the needs of a fast-paced, innovative industry such as e-mobility.
4. Avoid batteries are not lost once they hit the market via an improved (end-of-life) declaration system;
5. Provide a consistent regulatory framework for 2nd life options of EV batteries.

As EV sales begin to take off in Europe, the future success of the EU’s ability to remain competitive with the rest of the world will be heavily dependent on the ability to domestically develop batteries at larger scale in order to meet EV demand and help accelerate the transition to e-mobility. Only with clear rules and high standards can Europe fully reap the benefits of a home-grown battery industry, bringing economic value, jobs and long-term growth as a part of the e-mobility transition.

Jayson Dong, Chair of the Batteries Working Group in the Platform for Electromobility, added that “this piece of legislation will be key to supporting a thriving European e-mobility ecosystem. It will play a key role in delivering on the innovation, sustainability and competitiveness ambitions of the 2017 launched European Battery Alliance and working towards the EU’s Green Deal roadmap. The Platform for Electromobility looks forward to engaging with all relevant EU decisionmakers on this file and sharing our wealth of expertise to ensure the EU becomes a leader in the manufacturing of innovative and sustainable EV batteries.”

For more information about the Platform and our detailed position on the revision of the Batteries Directive, please find our paper on our website here.


Input to Smart and Sustainable Mobility Strategy

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Electromobility is the best solution to achieve the climate and industrial ambition of the European Green Deal for transport. The Sustainable and Smart Mobility Strategy will present the European Commission’s new vision on mobility for the upcoming years and must thus set a long-term and ambitious policy framework and support the further electrification of all modes of transport. It needs particularly to support the roll-out of an accessible charging infrastructure network for all modes of transport. The urgent revision of the TEN-T guidelines and AFI Directive for road and rail must occur without any delay and will ensure the decarbonisation of both modes of transports. The revision of the AFI Directive must be ambitious and should clearly set minimum binding targets per the Member States and type of vehicles (LDVs and HDVs) for the deployment of charging infrastructure for low- and zero emission transport technologies in order to reach the 2050 climate neutrality objective.

Smart charging, and demand-side resources (i.e. vehicle to grid) will therefore constitute a key enabler to strengthen future synergies between transport, digital, and energy sectors, supporting Europe’s energy transition and fostering technological innovation. In line with the Energy System Integration Strategy, the Platform for Electro-Mobility recommends that EU and Member States’ policy-makers encourage and develop policies in support of these innovative system integration technologies to unlock all the benefits it can deliver to the electricity system and to society at large. The European Commission must also make sure that the synergies between energy and mobility are maximised with adequate financial cross-sectoral schemes. Funding and support for electrical upgrades (within buildings as well as grid connections) necessary to install charging equipment should also be made available to consumers, for instance through the upcoming Renovation Wave initiative, and namely through the revision of European Performance of Buildings Directive. Support for zero emission mobility will address the behavioural changes and answer the growing demand. Therefore, it would be important for the Commission to shape regulations to drive affordable supply of EV models and design mechanisms to enhance the consumers’ uptake of electro-mobility innovations and ensure social inclusion of lower income households. The corporate market is a clear lead market for electrification and the strategy should include mechanisms to require more and more fleets such as company cars, taxis and delivery vehicles to electrify and support companies towards this goal. It is also key to rebalance the modal shares with a view to encouraging a greater use of energy-efficient modes with the highest electrification rates such as rail as well as measures to ensure the modal shift to rail.

The Battery Directive will be key to create a sustainable environment and should provide conditions for the EU to become more competitive. The new strategy should also support innovative and competitive business models for the second life and recycling of EV batteries. The Smart and Sustainable Mobility Strategy should recognise the vital role of businesses in stimulating the EV market and providing EV charging to help make e-mobility a more affordable and viable option for citizens across the EU.

New mobility zero emission shared services alongside public transport (bus, rail, tram and metros) have a key part to play in the electrification of urban transport. In cities, the development of a sustainable and efficient urban freight, with a focus on zero emissions trucks as well as last-mile delivery services, are long-term solutions which need to be stimulated. Furthermore, taxation is a central driver for the decarbonisation of transport, and it is essential that the EU’s taxation rules are aligned with its decarbonisation commitment. Specifically, the revision of the Eurovignette and the Energy Taxation Directivesis a chance to build a future-proof taxation policy, adapting to a modern and decarbonised economy while accompanying the uptake of electromobility by integrating a CO2 component.

The Platform for Electro-mobility unites organisations from across civil society, industries, cities and transport modes. Its members are committed to promote electro-mobility and strive to collectively develop solutions to electrify European transport, and to promote those solutions to the EU institutions and Member States. The Platform is working to create a sustainable, multimodal transport system in which people and goods are predominantly moved across land in Europe using sustainable electricity. The aim of the Platform is to drive the development and implementation of sustainable European Union policies, programmes and initiatives to move people and goods by electricity https://www.platformelectromobility.eu.


On 11 December 2019, the European Commission unveiled the EU strategy on climate neutral Europe, or the European Green Deal. The strategy promises to ensure that there are no net greenhouse gas (GHG) emissions by 2050, including increasing the EU’s 2030 GHG reduction target to at least 50%, and towards 55% in a responsible way. This clear shift towards sustainable and zero emissions technologies and economy-wide change is urgently needed if the EU is to meet the ambition of the Paris Agreement. Electro-mobility is already ubiquitous in our lives, from road vehicles to rail, as it is key to clean cities, affordable mobility of all Europeans and our industrial competitiveness.

In March 2020 the COVID-19 pandemic swept across Europe and confined Europeans to their homes, halting business activity and closing factories for months. As Europe slowly goes back to life, the deepest economic recession since the 1930s heralds a new normal. But the relevance of the Green Deal or the urgency of climate action have not disappeared – the twin challenges of economic and climate crises must be tackled together. Electrification is the strong basis to relaunch the economy and create futureproof jobs fast.

The Green Deal should be the basis of the economic recovery, starting with today. This policy paper outlines the Green Deal vision and green recovery recommendations of the European
Platform for Electro-mobility, representing almost 40 companies, associations and civil society across the electro-mobility ecosystem.

Notably:

  • Electromobility remains the best solution to achieve the climate and industrial ambition of the European Green Deal for transport. This ecosystem is crucial to Europe’s economic
    relaunch in the aftermath of COVID-19 and will create over 1 million jobs in vehicle and rail manufacturing, charging infrastructure deployment and supply chains such as batteries by
    2030.
  • The EU Recovery Package must support the e-mobility ecosystem, including the continued demand for zero emission vehicles, green investments into e-mobility supply chains and
    stimulus to accelerate the roll-out of charging infrastructure across Europe, notably workplace & residential schemes.
  • The Commission should not delay the enabling policies key to e-mobility’s success, including the urgently needed review of the Alternative Fuels Infrastructure law, the Sustainable Battery
    package and the revision of the Energy Taxation Directive.

Batteries will underpin Europe’s efforts to achieve a climate neutral economy and transport electrification. In the European Green Deal, the European Commission stated that a ‘90% reduction in transport emissions is needed by 2050 (compared to 1990)’ and that road transport needs to move to zero emissions beyond 2025 . In order to reach this objective, Europe will have to significantly increase the uptake of zero emission technologies, with a strong emphasis on battery electric vehicles.

This will require large amounts of batteries on the European market required to power the mass expected number of zero emission vehicles. Within this context, the Commission should therefore take stronger action and prioritise these zero emission technologies in the upcoming EU Industrial Strategy and the Circular Economy Action Plan planned for March 2020 to support the domestic production of sustainable batteries.

In preparation for the upcoming EU Battery Strategy expected for October 2020, the Commission must prioritise a circular economy approach when it comes to addressing the recycling of batteries. This includes ensuring the security of supply of raw materials, the reuse (where adequate) and recycling of batteries, as well as the high  environmental and social values in the manufacturing process as ways to promote a sustainable EU battery industry. Moreover, it will be extremely important to take note of the emerging new jobs related to the dismantling and recycling sector overall, as well as the processing and the reincorporation of used active materials within new batteries (i.e. when repurposing is economically proven to be better than recycling).

This is the only path to build a strong and competitive sustainable battery industry in Europe. Success in the European EV revolution is heavily  dependent on the success of Europe’s up and coming battery industry. Only with clear focus and political will, can Europe fully enhance the benefits of a home-grown industry, bringing economic value, jobs and growth as a part of the energy transition.