Position paper on CO2 standards for cars and vans

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The Platform for Electromobility supports the overall greenhouse gas emissions reduction target of 55% by 2030 and the climate neutrality objective by 2050. Reducing – and ultimately eliminating – emissions from cars, vans and trucks will be key to achieving these objectives.

The Platform for Electromobility would like to emphasise that the EU CO2 standards regulation delivers genuine benefits for transport, setting clear signals to both car makers and consumers on the required pace for the transition to zero-emission mobility. This regulation is the most effective way to do so, when compared to the extension of the ETS system to road transport.

The future cars and vans CO2 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 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.

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. After 2035 looking at the overall life cycle carbon footprint of vehicles could be a relevant factor to consider.

Setting binding annual CO2 targets would be optimal from a climate perspective and would ensure a continuous CO2 emissions reduction trajectory. Such targets should follow a long-term emission reduction trajectory to ensure sufficient visibility for industry (ensuring annual targets are set sufficiently in advance, and minimum of 5 years). The current design of the car and vans CO2 regulation targets – whereby targets kick-in in five years intervals with no emission reductions required in between – is suboptimal from a climate perspective and means CO2 emissions actually increase in between, as was seen between 2016 and 2019 from new car sales.

The revised regulation should set significantly higher targets for CO2 emissions from 2030 and adding a binding interim target in 2027 of at least 37,5% CO2 emissions reduction (a date consistent with the technology reset required by the Euro 7 emission standard) to secure a more linear CO2 emission target trajectory and ensure new vehicles can fairly contribute to the higher overall GHG reduction target for 2030.

In addition to the CO2 targets, a mechanism incentivising zero-and low-emissions vehicles (ZLEV) should be maintained in the period up to 2030. Only zero-emissions vehicles should be eligible for the incentive system, as well as vehicles with emissions below a threshold lower than 40 g CO2/km. Ultimately, the ZLEV benchmark/mandate level should be adapted from 2030 onwards, and only zero-emission vehicles should be eligible for any incentive system. The Platform for Electromobility considers that another incentive type could be envisaged – based on an accurate impact assessment and analysis – in the form of a bonus-malus for the period up to 2030 with a realistic threshold. After 2030, the bonus would be removed to be replaced by a unique malus.

In addition, regarding specificities of vans (professional purposes, goods & persons transport) it should be considered to differentiate between the target levels for cars and vans until 2035.

The Platform is opposed to any 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.
We would like to underline that new skills and qualifications for workers in the automotive value chain will be needed. Excess emission premiums, which are paid by OEMs whose average specific emissions of CO2 exceeded their specific targets and whose amounts are considered as a revenue for the general budget of the EU, should be allocated to a new or existing fund or relevant programme with the objective of ensuring a just transition towards a climate-neutral economy, in particular to support re-skilling, up-skilling and other skills training and reallocation of workers in the automotive sector and ecosystem.

Data collected from fuel consumption meters (FCMs) – fitted as standard on all new cars from 2021 onwards – should be used for consumer information and vehicle labelling purposes, either via a review of the car labelling directive, or via direct amendments to the cars CO2 regulation, and from 2025 onwards be used for compliance with CO2 targets.

The Platform supports removing the target mass adjustment mechanism. Removing the target mass-adjustment mechanism has many benefits: it removes a structural weakening of the regulation; ensures that all carmakers have the same target therefore pushing the larger and more polluting segments to electrify more rapidly, in line with their heavier climate impact; and it simplifies the regulation.

The decarbonisation of the transport sector needs a holistic approach. The planned revision of the Alternative Fuels Infrastructure Directive (AFID) needs to support the harmonised roll-out of a high-quality charging infrastructure for BEVs. It should be turned into a regulation for road transport infrastructure and set minimum mandatory targets per Member States for the deployment of publicly accessible charging points with a minimum quality service requirement that are accessible for every consumer.

The Platform for Electromobility urges the Commission to seize the unique opportunity of the Fit for 55 package and of the Green Recovery Fund to achieve the EU Green Deal’s goal to fully decarbonise road transport by 2050 and make electromobility a lifelong reality.


Platform’s proposals to boost zero-emission vehicles in corporate and urban fleets

With the European Union agreement on -55% greenhouse gas emissions (GHG) by 2030, all economic sectors will have to pull their weight towards this goal. Unfortunately, the transport sector has a poor decarbonization track-record with emissions steadily growing since 1990.

Looking at all transport modes, road transport is still the largest emitter (71%) and will remain so in the near future[1]. Recently adopted CO2 emission performance standards, investment in charging infrastructure, etc. will eventually drive down emissions, but new initiatives aimed at “quick wins” are needed to fast-track decarbonization.

These initiatives should be based on the idea that when fighting against climate change and local pollution, not all vehicles are equal. Fleet vehicles (i.e. corporate fleets) drive on average 2.25 times[2] more than private cars. Public fleets, such as urban buses which account for 8%[3] (per passenger per km) of greenhouse gases (GHG) emitted by the transport sector, are also big players. Last but not least, as fleet vehicles are often parked in depots and large parking lots, their batteries could be used to optimise the RES integration and the use of smart charging could provide benefits to local utilities and to the whole power system[4].

Against that background, the Platform for electromobility welcomes the European Commission’s ambition to electrify public and corporate fleets recently introduced in the Smart and Sustainable Mobility Strategy.

In this paper, we share our insight and expertise to make this a reality. We first recommend ensuring an ambitious implementation of the Clean Vehicle Directive (CVD) for public fleets in all Member States (MS). Second, new legislation dedicated to the electrification of corporate fleets should be envisaged.

Implementing the Clean Vehicle Directive

While at its adoption in 2019, we expressed our enthusiasm that the CVD would pave the way for a broad deployment of clean vehicles across Europe – electric buses in particular – it seems likely that few MS will transpose the directive in time.

As of April 2021, only France has implemented the directive, and only a few more MS have started the transposition process which is due to be completed by 2nd August 2021. There is a risk that an unequal transposition of the directive will lead to fragmentated and non-harmonized access to clean transportation and its benefits for citizens between MS.

Recent bus registration figures also show that while the sales of electric buses are progressing, most countries are still nowhere near the CVD targets [6]. Therefore, we call the legislators to push for a better and faster implementation of the CVD in most MS. National governments should make the best use of available funds, including national and European recovery plans, to achieve the targets of the directive.

Electrification of public fleets covered by the CVD is only one step on the road to a 90% cut in transport emissions by 2050. Electrifying corporate fleets[7] constitute another powerful leverage towards the decarbonation of transportation in Europe.

Leveraging corporate fleets to curb emissions

Corporate cars represent millions of high-mileage vehicles circulating in Europe with a high turnover. They now also represent the main part of the car market in Western Europe. According to a recent Deloitte[8] report, in 2010 the private and corporate market segments were almost equally large in Western Europe (respectively 7.3 million vs. 7.2 million car registrations). In 2016, the balance had already tilted in favour of corporate cars (58%), and by 2021, Deloitte forecasts a share of new car registrations of 37% for the private and 63% for the corporate channel. In countries not covered by the study like Poland, corporate cars share in a new passenger car market is even larger, reaching 75% in 2020[9].

Corporate cars quickly become private cars via the second-hand market after an average ownership of 36 to 48 months. Most Europeans indeed purchase private cars after they used corporate functions[10]. The electrification of corporate fleets is therefore key to also electrify the whole stock (owned by individuals) with a reasonable time gap.

Corporate fleets represent 20% of the total vehicle park in Europe, 40% of total driven kilometers but is responsible for half of total emissions from road transport. Starting with corporate fleets is the quickest way to reach emission cuts.[11]

Additionally, corporate cars are highly visible in our cities. By leading by example and supplying the second-hand market, electrified corporate vehicles will increase acceptability and accessibility of electric cars for European households. The electrification of this market therefore is not only a ‘low hanging fruit’, it has significant indirect impacts on other markets. As such, it is a major element for the electric vehicles (EVs) market to reach a critical mass.

Additionally, corporate cars are highly visible in our cities. By leading by example and supplying the second-hand market, electrified corporate vehicles will increase acceptability and accessibility of electric cars for European households. The electrification of this market therefore is not only a ‘low hanging fruit’, it has significant indirect impacts on other markets. As such, it is a major element for the electric vehicles (EVs) market to reach a critical mass.

Yet, the electrification potential of corporate vehicles remains largely untapped, due to a lack of clear rules and incentives. Indeed, along with main files such the Eurovignette Directive currently under negotiation, and which would be an important incentive for greening fleets, a whole patchwork of initiatives is included in existing and upcoming legislations. We remind that a successful electrification of corporate fleet shall be linked with a strong roll-out of public and private of charging infrastructures. Annex 1 below outlines our positions on these legislative files and why they will suffice to yield the way to a full decarbonisation of corporate fleets.

With no legislative instrument at hand today, the European policy lacks teeth when it comes to electrification of corporate fleets. We invite policy makers to require more and more fleets such as company cars, taxis, leasing and renting companies and delivery vehicles to electrify, and support companies towards this goal.

To do so, we call for the establishment of a new single regulation dedicated to the electrification of corporate fleets.

Call for a new proposal on the electrification of corporate fleets

A new legislation on the electrification of corporate fleets would set a clear path and objective. This new legislation should include the following provisions:

For a start, such a legislation should equally apply across the European internal market. Therefore, we believe a regulation would be the most suitable legislative instrument to accelerate fleet electrification.  The regulation would harmonize the European market by preventing risks of increased gaps between MS during the implementation. This is particularly important for internal market cohesion and regulatory clarity for businesses owning fleet across the EU. A regulation would have the final benefit of having a direct effect.

A realistic yet ambitious mandate should be put on companies to decarbonise their vehicle fleets in accordance with the European Green Deal’s objectives. Fleet electrification is a journey that requires following a roadmap and trials before scaling up in largest companies. Considering the timing of application of the regulation and the ability of companies that recently purchased vehicles or have larger fleets to react a stepwise approach is with interim targets therefore required.

We recommend setting a gradual approach to progressively but eventually reach the objective of 100% of new vehicle purchase in corporate fleets to be electrified by 2030.

To avoid imposing a heavy burden on the smallest companies, the regulation should apply to fleets above a certain size. Thresholds should be based on a robust methodology to consider the different segments, industries and MS characteristics while keeping in mind the lower the threshold, the higher the incentives should be for smaller fleets. Next to the electrification of the corporate fleets, companies should consider multimodal packages where a Zero-emission vehicle is combined with other sustainable transport solutions.

The Regulation’s provisions should differentiate between fleets in their capacity to make the change based on their usual turnover and nature of the transport they perform. Some fleets should face stricter and faster pace to electrification while other could be given more time to electrify. For example, new taxis and private hire vehicles (PHV) committed to drive fully electric vehicles should be issued licences in priority over ICE drivers while fleets in specific industries with technological obstacles (e.g. logging/lumbering industry) may be given derogations.

Along with mandatory targets and compliance mechanisms, incentives for fleet owners will also be needed at European and national levels to accompany the shift. Inspiration for positive incentives should be drawn from lessons learnt from well-designed benefit in kind systems for corporate cars across MS. The Platform for electromobility will soon propose a document outlining such best practices.

[1]https://www.eea.europa.eu/data-and-maps/indicators/transport-emissions-of-greenhouse-gases-7/assessment

[2]https://www.transportenvironment.org/sites/te/files/publications/2020_10_Dataforce_company_car_report.pdf

[3] EU Commission Expert Group on Clean Bus Deployment; D2 Procurement and Operations.

[4] Flagship 1 – Boosting the uptake of zero-emission vehicles, renewable & low-carbon fuels and related infrastructure

[6] https://www.acea.be/uploads/press_releases_files/ACEA_buses_by_fuel_type_full-year_2020.pdf

[7] In this paper, we include into corporate fleets all “Vehicle owned or leased by a private a company, and used for business purposes.”

[8] https://www2.deloitte.com/content/dam/Deloitte/cz/Documents/consumer-and-industrial/cz-fleet-management-in-europe.pdf.

[9] https://fppe.pl/

[10] DG Climate Action, European Commission. https://ec.europa.eu/clima/sites/clima/files/transport/vehicles/docs/2nd_hand_cars_en.pdf

[11] “Accelerating fleet electrification in Europe”, Eurelectric, 2021 (www.evision.eurelectric.org)

[12] Infographic on assessing the feasibility (https://evision.eurelectric.org/infographics/) – with examples of several fleet use-cases / Eurelectric


Our response to the consultation on the revision of the TEN-T regulation


Platform's reply on the revision of EPBD

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The Platform for Electromobility warmly welcomes the EC’s willingness to revise the Directive on the energy performance of buildings (2010/31/EU, EPBD).

In light of the roadmap and scenarios proposed by the EC, the Platform does not only take a stand for the option 3 but points out that electromobility needs to be addressed as one of the key elements of the EPBD revision if the EU wishes to deliver the objectives set in the Smart and Sustainable Mobility Strategy, the Energy System Integration Strategy and the Renovation Wave Strategy. The deployment of private charging is as important for the growth of electromobility and the decarbonisation of transport as that of charging accessible to the public. The Platform also thinks that the electric bicycles (incl. e-cargo bikes, e-two-wheelers, e-moped and e-cars) should be considered when revising the EPBD.

Given that 90% of EV charging happens at home or in the workplace and that 80% of the EU’s current building stock will still be in used by 2050, the EC must tackle the outstanding barriers to the installation of EV chargers and collective charging infrastructure in all (non-) residential buildings to ensure that all EV users have a “right to plug”. In this regard, art. 8 of the EPBD should be revised.

To that end, the Platform shares its key recommendations.

Set minimum infrastructure requirements for all types of buildings (new and existing)

The EPBD should encourage Member States to implement measures to pre-equip all buildings. The Platform recommends putting in place minimum requirements for the pre-cabling of the installation of EV chargers and ensuring that all buildings will be pre-equipped by 2035.

Guarantee the right-to-plug to all EV users

The revision of the art. 8 of the 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 aligned with Spanish, Dutch and Norwegian legislations and the current EPBD recommendations. In France for instance, condominiums still face barriers when wishing to implement charging solutions due to non-adapted standards.

The EC needs to tackle the remaining obstacles for the installation of charging points in buildings by removing the unnecessary exemptions applied to SMEs and addressing the administrative hurdles (e.g. EV charging as extralegal benefit for employees) as well as collective action problems (e.g. split incentives between EV and non-EV drivers, renters vs. owners, employee vs. employer, etc.). The EC should ensure that the right to plug is as simple as a subscription to other services like internet, phone provider, etc. The request for the installation of charging stations in collective properties should not exceed 3 months. EV users without charging station at home should have a right to plug at work.

Introduce requirements for smart charging

The development of smart charging in buildings is an opportunity for EV users: it ensures a better charging experience, reduces the consumers’ electricity bill1 and could reintegrate the surplus of electricity into the grids (V2G) and/or reuse it in the buildings (V2B). It could also support the uptake of electromobility and can create synergies with renewable energies by integrating them into the electricity grids and providing flexibility services to the system.

Aligned with a definition on smart charging that the Platform urges to be introduced in the revision of the Alternative Fuels Infrastructure Directive (AFID), the existing requirements set in art.8 of the EPBD should be strengthened to support the deployment of smart charging in multi-family and nonresidential buildings in order to provide flexibility services to the power system via EV connection to the grid and to buildings.

The EPBD must be revised in coherence with the AFID to ensure the same level of ambitions in both texts and a coherent framework for the deployment of charging infrastructure across Europe. In line with the Renovation Wave, the EC also needs to ensure that funding and recovery plans tackle the rollout of smart charging infrastructure in the building renovations. A long-term funding programme (about 10 to 15 years) for local authorities and governments could be developed for example and channelled through the Member States to support the cabling of residential and office buildings’ in all parking spots.


Our vision on the future of Eurovignette

  1. General Comments

Establishing a level playing field between all modes of land transport requires an ambitious revision of the Eurovignette directive. A level playing field across single market will then allow the development of a clean transportation system in Europe. Both rail and Zero Emission heavy duty vehicles ZE HDVs) will benefit from it, therefore reducing the impact of land transport on the environment. Revising the Eurovignette directive is therefore a necessary step towards 2050 climate objectives.

Two aspects of the new Eurovignette directive can have a true and significant impact on the deployment of ZE HDVs: external cost charges for air and noise pollution on the one hand, and improving the CO2-based tolling system on the other. Internalization of cost and an improved tolling system will significantly reduce CO2 emissions. The distance-based infrastructure charging coupled with CO2 differentiation is the ideal for incentivizing cleaner vehicles. Here external cost charging is crucial as well as the application of the “polluter pays” principle.

This reaction paper presents the Platform for electromobility’s point of view vis-à-vis the positions adopted by the European Parliament and the Council. Although ideally the “polluter pays” principle will be applied in all modes, the paper provides the realistic expectations of the electromobility sector to actors in the trialogue negotiations. This paper complements a precedent paper issued after the Commission’s proposal in 2017.


Platform’s feedback to the consultation Batteries – modernizing EU rules

The Platform welcomes the proposal for a Battery Regulation and strongly supports the need for modernisation of the existing batteries legislation. It must ensure harmonisation in the internal market and facilitate an accelerated shift to electrified mobility by engaging all parts of the battery supply chain. The regulation must establish proportional and well-designed provisions to enable sustainable battery production, use, and end-of-life management.

Generally, the timeline for the provisions should be well-thought through to ensure robust and harmonised application and enforcement. We need to strike a balance between the need for a quick implementation of the Regulation while ensuring a robust methodologies. Overall, the proposed measures shall promote cleaner, more competitive and more efficient battery manufacturing.

To avoid duplication or overlaps with existing legislation and requirements and limit excessive administrative burden on the nascent battery industry, the Platform sees a need to streamline and align provisions.

Read the PDF version here

While the Platform believes that the proposed requirement for carbon footprint declarations goes in a positive direction, we are concerned about the measure’s enforceability at the Member State level. Provisions should apply per battery model and manufacturing plant instead of “for each battery model and batch per manufacturing plant.” Rules on enforcement, methodology, and electricity accountability should also be clarified, to ensure:

1. Harmonised enforcement at Member State level and for imported batteries;

2. The use of representative data and supply-chain configurations to ensure comparability of declarations. E.g certification of energy use should reflect real world use of renewable energy and must not rely on purchase of green certificates (Guarantees of Origin).

3. The confidentiality of the declared primary data is respected.

The Platform strongly supports the introduction of rules for the responsible sourcing of raw materials for batteries. Similar due diligence requirements must also be applied as soon as possible to the fossil fuel sector as part of the upcoming horizontal due diligence legislation.

The Platform highlights that economic operators must have sufficient time to adapt to new data sharing requirements. The chosen method, be it battery passport or QR Code, should be streamlined with a focus on a single, innovative, and digital approach. The Commission must identify which data sets are essential to boost the data-sharing economy while ensuring confidentiality.

The Platform welcomes the Regulation’s intention to provide a regulatory framework for the transfer of liability and safety requirements for second-life EV batteries. The current provisions, however, require clarifications as regards access to BMS, conditions for the safe treatment of batteries, property rights protection, as well as ownership of data created by EVs. Moreover, the waste status of batteries is vital: the collection of waste batteries potentially suitable for repurposing should be designed in such a way that a second life business model can develop without creating a free pass for illegal waste transport. In particular, a clear-cut transfer of extended producer responsibility is pivotal to avoiding the risk of illegal export.

On end-of-life management, we welcome the recognition of batteries within a circular economy. Also, the Batteries Regulation now better differentiates between battery chemistries. However, the future regulatory framework should be aligned and consistent with EC 1907/2006 (REACH). To work towards a level playing field, we propose including a deadline for the adoption of equivalent conditions criteria for export of waste batteries to third countries. Minimum recycling conditions outside Europe must be set, including environmental and social criteria.


Guidance Note on "Recharge and Refuel" Flagship un the Member States recovery plans

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Introduction

Last year, the electric car market reached a tipping point in the EU with sales surging to 10,5% on average. However, to meet the EU climate goals and achieve the target of 30 million zero emission vehicles on the road in 2030 set by the EU Smart and Sustainable Mobility Strategy, steep the acceleration in the sales of electric vehicles (EV), the deployment of EV charging infrastructure and the extension of public transport is necessary. The European Commission has set the objective to reach one million public chargers in 2025 and three million in 2030 and thus the fair contribution of each Member State (MS) towards reaching that target is key.

As part of the Recovery and Resilience Facility (RRF), the EC strongly encourages Member States to put forward investment and reform plans on the so-called ‘Recharge and Refuel’ flagship. This flagship is identified as one of the areas for investments and reforms with tangible benefits for economy and citizens across the EU[1].

 

In order to make climate objectives and tap on the benefits of clean and cheap electromobility, it is essential that Member States place a strong focus on the ‘Recharge and Refuel’ flagship in their recovery plans. Both private, commercial and public charging infrastructure for cars and vans as well as public transport infrastructure should absolutely be on top of the agenda, while charging infrastructure for heavy commercial vehicles should also be clearly targeted. The electric truck market, from commercial urban vehicles to long-haul trucks, is expected to ramp up quickly in the next years which means that financing and funding support are necessary to support the rollout of the dedicated charging infrastructure: at the depot, at the distribution centre and at public locations, being it urban areas or along highways.

Given that charging infrastructure is disproportionately concentrated in 4 countries, special attention should be paid to ensure that new stations funded under the NextGenerationEU program are more distributed and that the proper ambitions are expressed in all MS proposals. That is the only way to reach the 3 million target in 2030 and ensure there is a truly pan-European network for all EU citizens.

Overall, the principle of cost-effectiveness should steer the support towards increased electrification of road transport across all vehicle segments. From small vehicles to heavy-duty trucks with long-range transport applications, the battery technology is proven to be the cleanest, most energy-efficient and competitive alternative for the long-term and should therefore be prioritised in the road transport decarbonisation plans of the Member States.

This Guidance Paper provides some recommended elements that Member States should prioritise in their recovery plans and that the EU evaluators should look for in evaluating MS plans. The Platform for Electromobility strongly feels that these elements are key to ensure that the deployments under the RFF meet the needs of EV drivers and public transport users across the EU and to form the necessary trigger for accelerated private investment. It is essential that Member States place a strong focus on the Recharge and Refuel Flagship in their recovery plans and prioritise RRF funds towards charging infrastructure.

To make sure public funds are allocated in the most targeted way, the Platform believes Member States should develop national e-mobility and related infrastructure masterplans, which include ambitious deployment targets for both vehicles and infrastructure and form the basis of the allocation of the public investments. These plans and targets will provide the necessary trigger for private investment.

  1. All types of locations and all use cases should be targeted

In order to ensure that the Recharge and Refuel Flagship proposals in the Recovery and Resilience Plans submitted by MS achieve the goals laid out by the EC, it is critical that they look broadly at all the opportunities and locations where charging infrastructure and electric road system can be deployed. Investments should also target national EV charging networks for long distance travel. Specific support should also be considered for operators looking to invest in charging deserts. We elaborate on some specifics in the next two points:

  • Private, semi-public and public charging

The major growth areas for EV charging are workplace and community locations, including multi-unit buildings and (semi-)public charging in residential neighbourhoods. In many cases, especially shared private facilities, private charging infrastructure performs the same function as public infrastructure, being accessible to multiple users. MS plans must prioritise significant EV infrastructure deployment at these types of locations, based on their national needs’ assessment and ambitions. In this regard, a close collaboration between national and local authorities in developing such plans is key to steer recovery funds towards relevant investments needs for charging infrastructure.

  • Develop and modify local building codes to provide specific rules and guidance around the deployment of EV charging infrastructure in new and existing buildings.
  • Set a pre-installation requirement of EV charging infrastructures in the design of new buildings and a specific requirement for community infrastructures which enable smart charging.
  • Support the “right to plug” so that interested tenants in a building have the standing to request an EV charging station in their building/at their parking space and simplify the administrative procedure for the installation burden is on the municipality or other responsible parties to object, and planning funds are available.
  • Address the “first mover” problem by earmarking funds to support the wiring and cabling of the shared/communal portions of new and existing buildings.
  • Make public funds available for some private and semi-public charging infrastructure, where it supports a whole group of users (such as employees of a company, vehicles in a depot, tenants of a building, visitors to a building, etc) – i.e. more than just the single owner of the vehicle.
  • Destination charging at public parking facilities (e.g. shopping malls, sports facilities, restaurants, hotels, etc.) are essential and should also be supported.
  • Do tendering processes in a way to support open markets and optimal service delivery and ensure the best companies for installing and operating EV charging infrastructure are selected through a fair and competitive process.
  • Take into account the extension of public transport infrastructure (e.g. for electric buses) in MS plans.
  • Dedicated focus on electric trucks, which yield the greatest synergies

Fully electric heavy-duty vehicles (HDVs) are very much a reality and already driving on European roads. The number of these will rise quickly in the years to come. Member States must plan for this by deploying the proper infrastructure.

By planning for the growth of the battery electric vehicles (BEV) HDV’s, Member States can also generate the greatest infrastructure synergies, as in some cases these hubs can support a range of high and lower power users.

  • Funds should be used to encourage the creation of high-powered charging hubs to support HDVs and other users should be planned and developed on main roads and highways, at rest areas, near off/on ramps around logistics hubs, and at depots
  • Funds and plans must consider the state of the electricity grid and the need to either extend or upgrade it or provide options for local onsite generation from renewable energy sources coupled with onsite storage.
  • Grid capacity should be factored in decisions to build or upgrade a truck resting area to facilitate such high-power charging (e.g. megawatt chargers). This could help lower deployment costs and accelerate grid readiness for e-trucks to come.
  1. Deployment and investment decisions should be based on data and real conditions

Proper planning for charger deployment and (possible) grid improvements require data to inform those decisions. Data on existing charging stations and grid conditions should be made promptly available (to municipal, regional authorities and relevant industry actors).

  • To prepare such a plan properly, data is needed to understand the situation now, needs and gaps
    • Funds must be made available to support MS in gathering this data.
    • The capacity building of grid operators to be part of local infrastructure planning should be enlarged. The process of involving DSOs could include municipal, regional and highway charging infrastructure planning, the development of best location-plans with information on grid capacity and reinforcement needs, with information on costs being made available to all relevant industry actors directly involved in establishing the business case of the operation of the infrastructure, while respecting all data privacy requirements.
  • For proper infrastructure deployment planning purposes, data is needed to map:
    • Current infrastructure (in Charge Point Equivalent terms)
    • Geographic coverage and gaps
    • Available power levels
    • Accessibility of stations
    • Grid capacity (overall and at precise locations)
  1. The grids should be prepared for increased EV integration

 

The MS plans should require distribution grid connections and available capacity to be future proof, by defining minimum standards which will be necessary for the upgrading and the extension of the infrastructure network, both in urban and rural areas.

  • Grid capacity upgrade support should be factored into decisions to build hub areas, commercial parking spots, or resting areas to facilitate high power charging. This could help lower deployment costs and accelerate grid readiness for different types of vehicles, from ride-hailing vehicles to e-trucks.
  • Sufficient tools should be given to distribution network operators to operate the grid in the smartest way possible; time-varying network tariffs aimed at shifting EV network use away from peak hours in order to reduce the need for grid reinforcement for example can help to address grid capacity or congestion challenges at particular locations.
  1. Interoperable infrastructure should be embedded and roaming enabled

The adoption of open, non-discriminatory and interoperable communication standards in EV charging infrastructure as a key requirement is fundamental to facilitating a seamless charging experience for the driver across national EV charging networks, but also across borders.

Publicly accessible charging infrastructure at commercial or public locations should never be locked into an equipment or network provider, either commercially or technically. Any publicly financed charging stations under the RRF should therefore require open protocols and standards for the backend communications and for enabling smooth roaming. This will help to encourage and accelerate the uptake of EVs and address availability concerns by EV drivers.

At the same time supporting infrastructure that enables roaming on publicly accessible charging stations will allow drivers to charge at stations belonging to the network of another operator (not their “home” operator) with a single subscription provided by a mobility service provider. This applies both within and across national borders. The MS recovery plans should therefore steer eligible publicly accessible charging stations to require the use of the open, roaming communication protocols to facilitate roaming agreements.

  1. Smart-charging should be future-proof

EVs could help realising the EU’s renewable energy objectives by increasing the share of RES in the network through smart charging. Future charging stations should be prepared to deliver a basic level of smart charging services, e.g through load balancing and time of use, in particular in regard to private charging at home and/or in residential areas when there is not possibility for EV users to install a charger in the building. It will be important to work towards a situation in which smart and bi-directional charging are standards applied in practice in the coming years. The plans should therefore include smart charging incentives:

  • Incentives should focus on supporting the business case for smart charging, for instance by facilitating variable time-based pricing policy, but not prescribe technical means to achieve this additional capability. These facilitating measures should focus on increasing the willingness of consumers and their ability to participate in smart charging.
  • Support could also cover the risks in business cases of market parties in the roll-out and/or the operation of smart- or bi-directional charging infrastructure.
  • Support should be steered towards future innovations, such as smart charging and state of the art system integration technologies, including vehicle-to-grid (V2G) capability.

[1] European Commission (2020), EU Recovery and Resilience Facility: https://ec.europa.eu/info/business-economy-euro/recovery-coronavirus/recovery-and-resilience-facility_en


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

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).

It should also be assessed how future credit mechanisms could account for the renewable kWhs charged at home or in the workplace

 

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.