Ou response to the consultation on the Transeuropean Network of Transport (TEN-T)

Transeuropean Networks - Transport
Our response to the consultation

The Platform for electromobility welcomes the EC proposal for a revision of the TEN-T guidelines as a necessary instrument to make transport modes more sustainable by setting firm incentives and requirements for transport infrastructure development.

In particular, we welcome:

  • The introduction of “The promotion of zero emission mobility in line with the relevant EU CO2 reduction targets” as first point in the Sustainability’s objective of TEN-T.
  • The direct link to AFIR provisions on the deployment targets of charging infrastructure for LDV & HDV as well as for the onshore power supply infrastructure.
  • The extended core network to be completed by 2040.

However, some adjustments to the proposal are deemed necessary:

Promotion of the transition towards a clean and zero-emission transport system and fostering its charging infrastructure. The “energy efficiency first” principle should be reflected in planning and investment decisions related to the deployment of recharging and refueling infrastructure. The “zero-emission” solutions and deployment of related infrastructure should be explicitly identified within the additional priorities in the promotion of projects of common interest (PCI) for all transport modes.  The TEN-T is closely linked to the TEN-E, hence it is paramount to reinforce and support the seamless integration of EV and charging infrastructure with the energy system stimulating solutions such as “energy storage” and “vehicle grid integration”.

Covering regions beyond the Core Network. The deployment targets of charging infrastructure along with the comprehensive TEN-T network as foreseen in the AFIR proposal for LDV should be brought forward as per the Core network. It will fill the gap in terms of social and economic disparity.

Consistency with the AFIR revision. The proposed TEN-T regulation includes clear provisions on indicators for the provision of alternative fuel recharging/refueling infrastructure for the different modes of transport. Its successful implementation will strictly depend on the synergies between the TEN-T and the AFIR, as both are intrinsically dependent on each other. For example, the AFIR proposal regulates the provision of charging/refueling points on the TEN-T network, while the TEN-T Regulation provides the infrastructural basis for their wide deployment from an EU network perspective.

Introduction of the reference to alternative fuels for rail. There is potential for alternative fuels as a complement, particularly where direct electrification is not a viable option. In particular, Art. 14 extends the list of rail infrastructure components including rail services facilities, rail access routes and last mile connections. However, it is sometimes not feasible or economically relevant to mandate direct electrification for some of these segments of the network. In these specific cases, possibility should be opened to offer zero-emission solutions based on alternative propulsion systems (e.g., battery trains). A more flexible derogation process under Art. 15 should also be considered to allow for the deployment of such technologies.

Guarantee of an appropriate level of funding. In this sense, the EC considers that the largest part of investments is estimated to originate from public funding (national public funds, EU funds) and would amount to €244.2 billion over 2021-2050. As possible and suitable additional funding support, the budget for Connecting Europe Facility (CEF) transport could be increased. In addition, given the significant funding allocated to mobility infrastructure including the TEN-T Network within Member States’ National Recovery Plans (NRPs), the tight deadline for the commitment of funds (2023) and its subsequent implementation (2026), the Platform supports the Commission to increase and facilitate further synergies between CEF and funding from the NRP and the Cohesion Policy Programs.


Reaction Paper to the new Article 12 “Infrastructure for sustainable mobility” (EPBD)

Reaction Paper to the new Article 12 “Infrastructure for sustainable mobility” of the Revision of the Energy Performance of Buildings Directive

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Last year, 2021, set a record for the battery electric vehicle (EV) sales, which achieved 10%[1] of total sales in the European automotive market. This trend is expected to continue to rise, driven by the new ambitious objectives set by the EU along with the national recovery plans implemented by Member States. However, the challenge remains immense. Indeed, the number of EVs is set to increase throughout the EU as a result of the proposed ban of internal combustion engines (ICE) sales by 2035, set out in the revision of the Regulation on the CO2 standards for cars and vans as part of the Fit for 55. Consumer demand for electric bicycles is also increasing strongly, with more than 4.5 million units sold in 2020, representing more than 20% of total sales.

If Europe is to succeed in its transition towards zero-emission mobility, the correct charging infrastructure needs to be put in place to push the EV market into achieving the required growth and ensuring a positive customer experience. Here, the deployment of private charging is of the utmost importance for encouraging the growth of electromobility, as 90% of all charging takes place at home or in the workplace. However, the current electromobility provisions of the Directive on the energy performance of buildings (EPBD) will fall significantly short in establishing the right conditions for the widespread adoption of EVs.

The Platform for electromobility therefore fully supports the revision of the EPBD

The Platform for electromobility therefore fully supports the revision of the EPBD presented in December 2021, as it is the main EU legislation for addressing private charging. The introduction of Art. 12 in the Commission’s proposal, which relates to electromobility in buildings, is therefore central to supporting zero-emission mobility in the EU. In particular, the Platform welcomes the:

Provisions we support

However, the Platform believes that further improvements are needed, and has therefore set out five recommendations:

Clarify the scope of application of Art. 12.

The way Art. 12 is currently drafted could be interpreted as meaning that requirements only apply to parking spaces if ‘the car park is physically adjacent to the building’ but not if it is ‘located inside the building’. We believe this is not the Commission's intention and therefore ask for further clarification.

Ensure charging solutions in existing buildings.

Some 80% of the EU’s current building stock will still be in use by 2050, with the average annual major renovation rate just 2.7% for non-residential buildings and 1.5% for residential buildings. As a result, the EC should ensure the installation of charging points in existing buildings.

Our key recommendations

Completing the charging requirements for new and under major renovation buildings.

The Platform asks to complete the charging requirements for new buildings and buildings undergoing renovation in order to mandate the deployment of smart-charging ready recharging points in all new and existing buildings.

Our key recommendations

Reinforce the deployment of smart charging functionalities

The development of smart charging and bidirectional charging (V2G) in buildings is an opportunity for EV users. It provides a superior charging experience and reduces the consumers’ electricity bill. Indeed, in France, on average with V2G, the annual cost of recharging an electric vehicle is 240€/year, compared to 420€/year without smart charging functionalities. The Commission has recognised, in its AFIR Impact Assessment, that every smart recharging point could on average create a system benefit of more than 100€/year by 2030. Smart charging also reintegrates electricity surpluses into the grids (V2G) and/or reuse it in the buildings (V2B) and homes (V2H), as well as supporting the uptake of electromobility. It can also create synergies with renewable energies, by integrating them into the electricity grids and providing flexibility services to the system. Furthermore, smart charging complements the right-to-plug by ensuring that charging points optimise the use of the grid capacity of a building and removes the argument that grid connections need to be reinforced.

Our key recommendations

Reinforce the measures to ensure pre-cabling

Pre-cabling of buildings should refer to both the technical cabling (cable path, technical sheaths, drilling) and the electrical pre-equipment in collective electrical installations (switchboard, horizontal electrical column, bus cable).

The comprehensive pre-cabling of buildings will enable the subsequent connection of individual charging points, at minimum cost, by simply installing a home charger. Furthermore, the pre-cabling of renovated buildings is a low hanging fruit, with little cost involved when done during the construction phase – which is the most efficient way to do it. Cabling after construction is completed is not cost-efficient and would lead to highly cumbersome discussions with project developers. Ducting infrastructure is a future-proof and cost-effective solution, the installation cost of which is minimal when compared to the total cost of constructing or renovating a building. By way of comparison, failure to ensure ducting infrastructure would entail costs that could be up to nine times higher if a building needs to be retrofitted.

Our key recommendations

Platform general comments for the trilogue negotiation on Battery Regulation

Battery Regulation
Our recommendations for trilogue

During current trilogue negotiation on the Battery Regulation between institutions, we welcome several changes introduced by the European Parliament (EP) and Council. Notably, we support:

✓ The change of scope for the carbon footprint declaration per battery model and plant, rather than per batch, as initially proposed by the Commission.
✓ In the EP text, ambitious deadlines for recycling and material recovery conditions for batteries on the European market whether they are imported or not.
✓ We welcome the emphasis on the waste hierarchy and the clarification on reuse of batteries when available on the market, notably the explicit transfer of Extended Producer Responsibility from producer to second user.
✓ Both texts base due diligence obligations on the UN Guiding Principles on Business and Human Rights and OECD Guidelines for Multinational Enterprises, and that both EP and Council have strengthened the environmental risk categories in Annex X.
✓ The Grandfathering clause for spare parts proposed in the EP text.

We have however reservations and will remain vigilant on the following points:

Timeline & targets
The innovative approach of this regulation requiring multiple new sustainability criteria declaration and control, accompanied by close to 40 currently unknown secondary acts, is a first in terms of implementation.
Recommendation: ample resources should be dedicated by lawmakers to ensure that the proposed targets and timelines for the implementation of the new sustainability criteria can be met.

Guarantee of origins
Concerns over the explicit possibility in the Council text to use guarantees of origin alone as proof of clean and renewable energy for the purposes of the battery carbon footprint calculations.

Recycling and end of life
Binding recycling content should always go hand in hand with a careful assessment of the environmental costs and benefits, and compatible with the real technological state of the art and availability of recycled materials.
Further, availability of batteries for second life must be considered. We would like to stress that EV batteries should always be handled by professionals with a certain level of qualification, and that the same goes for potential EV battery waste. Minimum conditions for battery recycling outside Europe should be ensured, accompanied by a deadline for when such conditions must be established. This can help to get extra-EU battery recycling industry ready for incoming EOL battery volumes.
Recommendation: Recycling targets in Article 57, Annex XII must be brought forward in the Council text (in line with the timelines proposes by the Commission) to reflect the vital need for a domestic supply of raw materials. At the same time, the possibilities for reuse must be clarified as more EV batteries are available for second life.
The substances needed for EV batteries should always remain in a waste loop. Future potential restrictions of substances must take into consideration the strategic autonomy objective of the EU battery sector, the performance of EV batteries and the closed loop of the substances needed for batteries. In addition, second-life batteries should not be exempted from obligations on performances and durability.

Removability
We want to highlight the significant technical difficulties, safety and performance challenges coming with the EP’s proposed removability and replaceability requirements for EV and industrial batteries at cell level. Such requirements would remove any incentive or space to innovate and contradicts the idea of longer lasting and better performing batteries if battery pack designs are not allowed to change over time.
Recommendation: we do not support the extension of the removability and replaceability requirements to all batteries at cell level, as they would threaten the performance, safety, and technical integrity of the whole battery. We therefore call on maintaining the Commission’s current article 11 setting removability and replaceability requirements for portable batteries only.


PV – EV : A powerful duo to make Europe drive clean

The three keys for a join deployment of

solar power and electric vehicles

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Electric vehicles (EVs) deployment needs to significantly accelerate in the coming years. However, challenges to its deployment (lack of distribution grid availability, low consumer engagement, challenges to the deployment of the infrastructure during renovation, etc.) show very close similarities with those posed by the deployment of distributed photovoltaic solar power plants (PVs). Therefore any successful solutions should benefit both EV and PV deployment.

The uptake of EVs, together with PVs deployment (mainly via rooftop solutions), opens an important opportunity for unlocking a European ‘prosumer’ potential. ‘Prosumer’ refers to a model where individuals manage their own energy supply and consumption. Prosumer models can become a powerful enabler of Renewable Energy Sources (RES) integration, including photovoltaic solar power plants (PV). The joint integration of PV and EV will also have a significant impact on citizen carbon footprint (for their home energy and transport), by ensuring EV charging take place during periods of highest renewable content.

The rapid, massive uptake of EVs has the potential to become both a flexible asset for grid management and an opportunity for prosumer business models. EVs will also provide a boost to increasing the cost-effective penetration of renewable energy – like PV – within the electricity system. The combination of EVs, their batteries and smart-charging functionalities as sources of ancillary services for the distribution grid will bring clear benefits, in terms of RES integration, for both individual and collective projects. Electromobility and renewable energy therefore offer a win-win partnership. The benefits of smart and bidirectional charging in regions with high solar capacities are clear: when sun sets and falls, EVs can optimise consumption and grid constraint and avoid polluting at peak times.[1]

Recent European legislation, through the ‘Fit for 55’ package, leverages these opportunities, notably in the revision of the Renewable Energy Directive (see our full position here and here), but there is still more that can be done to increasingly make cars in Europe run on renewable energy.

Signed by both renewable energy suppliers, charge points operators (CPOs) and other relevant stakeholders, this joint call shows the enthusiasm within the whole industry to explore the synergies between solar electricity and EV charging solutions. To enhance these synergies and solve common challenges between EVs and PV, we recommend:

1. Developing an enabling framework for EV drivers to become prosumers

A significant share of EV drivers (30-50%) charging at home are usually interested in installing PV panels as part of their broad decarbonation objectives and to maximise their contribution to climate change objectives.

This offer considerable potential for encouraging prosumer behaviour, but in order to realise this potential, an appropriate regulatory and technological framework is needed. To make this a reality, the EU should develop a distributed energy strategy capable of empowering and boosting prosumers with solar PV, battery and EV, and, at the same time, ensure that the electricity distribution grid can connect distributed RES. It should be noted here that the adoption of these distributed loads does not pose a problem for the distribution grids in the short- and medium-term, since the most significant impact will occur principally in very specific areas and at a later stage, when greater investment will be needed.[2]

Rooftop solar, EVs and other local flexibility resources will only realise their full potential once they are able to also provide grid services via flexibility markets. This will require the full implementation of the Clean Energy Package across Europe. However, because this is not yet the case – despite the deadline expiring – the EU should look into options for applying greater pressure on Member States. A full implementation would allow entry into the next phase, which will see the designing of local flexibility markets, together with the European DSOs, to find appropriate flexibility signals for EV users.

2. Ensuring an enabling framework for solar PV deployment

To support the use of renewable energy in electric mobility, an enabling framework must be build. PPAs contracts must be facilitated, through clear frameworks and financing support – the guidelines on PPAs will be critical here. In addition, the stability of investment signals and market rules will be key.

In addition, permitting still pose significant barriers to solar PV project development. Here, the RED II provisions must be implemented, and the Commission should support the exchange of best practices.

3. Helping transition to needed new skills

With the development of new economic sectors, boosted by EV uptake such as PV industry, the transition to electromobility does not pose a threat but rather an upskilling opportunity for workers. New skills will indeed be needed, both to adapt the manufacturing of vehicles and to install the required infrastructure across Europe. We recommend the launch of a Skills Initiative on Solar installers, in synergy with CP operators and installers, as well as a Distributed Energy Installers Skills Initiative.

From a forward-looking perspective, it will be possible to identify specific initiatives for integrated retrofits.

In highly specific use cases, new approaches could be explored to reduce the installation and integration cost related for the combined installation of Solar PV, Home Storage and V2X charging. Early-stage experience has shown that the integration of AC-DC conversion technologies across the different voltage levels could be a solution for reducing PV and EV integration costs in certain use cases, such as isolated houses or rural areas (up to 30%-50%[3]). From that perspective, we would suggest identifying how the application cases can be addressed through Horizon Europe or similar calls in the areas of R&I identified above.

[1] For example, in California, a study has shown that “the real strength of grid-integrated vehicles in mitigating the duck curve is in avoiding large system-wide ramping, as seen in figures 3(c) and (d). In the V1G-only case, down-ramping and up-ramping are both mitigated by more than 2 GW/h by 2025. In the case with a mix of V1G and V2G vehicles, however, substantially larger gains are seen. Both down-ramping and up-ramping are substantially mitigated, by almost 7 GW/h, equivalent to avoiding construction of 35 natural gas 600 MW plants for ramping mitigation”. “Clean vehicles as an enabler for a clean electricity grid”, Jonathan Coignard, Samveg Saxena, Jeffery Greenblatt, Dai Wang, 2018

[2] Debunking the myth of the grid as a barrier to e-mobility, Eurelectric 2021 https://cdn.eurelectric.org/media/5275/debunking_the_myth_of_the_grid_as_a_barrier_to_e-mobility_-_final-2021-030-0145-01-e-h-2DEE801C.pdf

[3] Calculations made by Dcbel on real pilot home data in England


First feedbacks to the revision of the CO2 emission performance standards for new heavy-duty vehicles

CO2 Standards for HDVs
Our first feedbacks to the Commission

The Platform for electromobility very much welcomes the Commission’s willingness to revise the HDV CO2 standards. The standards are a fundamental tool to advance the zero emission transition, as outlined in the European Green Deal and advance the transport sector. More ambitious standards set the right pace and a clear trajectory  for manufacturers and logistics operators. Hence, the revision of the Directive (EC) 2019/1242 is a needed and welcome step of the Commission to lower emissions from trucks and other heavy-duty vehicles. The revision should align the CO2 targets for the transport sector with the EU’s overall -55% GHG reduction target in 2030 and the climate neutrality target of 2050. Importantly the HDV CO2 standards are the single most effective tool to achieve scaling effects in production and technology development, which contributes to making electric HDVs more competitive and widespread.

In particular, the Platform calls the European Commission to prioritise the following:

  • Almost all newly registered heavy duty vehicles (including long haul) should be zero emission at the latest by 2035, whilst an exemption can be considered for some niche vocational vehicles (such as construction trucks) with a 100% ZEV target by 2040.
  • The introduction of an intermediary target in 2027 is necessary to accelerate the transition to electric trucks already in the 2020s
  • Strengthening the ambition in 2030 is crucial to spur the momentum and further scale up production and sales of ZETs.
  • Crucially, no mechanism for renewable and low-carbon fuels should be included under this regulation

The Platform wants to stress that with regards to urban buses the revision of the CO2 standards should also take into account the demand-side targets from the Clean Vehicle Directive (Directive 2019/1161), especially when taking into account the purchasing of heavy-duty ZEVs for public authorities. The standards are an important tool to drive down the prices of buses of publicly procured vehicles, making them affordable for public institutions.

Lastly, the Platform highlights that the transition to electric trucks and buses is a considerable opportunity for the European electromobility value chain and the competitiveness of the economy. Ambitious targets would make Europe a leader in zero emission HDVs and thus further unlock the potential of the electromobility value chain.

Electrifying heavy trucks is particularly crucial in the wider context of reducing Europe’s GHG emissions as it makes up the largest part of the HDV emissions and allows to drastically improve noise and air pollution.

Investments need to be made for higher grid capacity to serve truck charging demand.


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.


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).


Our recommendations on due diligence initiative for a sustainable transition to electric mobility.

Due Diligence
for a sustainable transition to electromobility

The Platform for electromobility advocates for a sustainable mobility approach that protects the environment and human rights. To achieve this, coherence between legislative files will be key. The following steps should be taken on the Battery Regulation and the upcoming horizontal initiative on mandatory Human Rights and Environmental Due Diligence (mHREDD), while bearing in mind the difficulties encountered in implementing similar legislation, as was seen with the Conflict Minerals Regulation (CMR).

Strengthen and mirror the Battery Regulation’s provisions on due diligence

The Platform strongly supports the introduction of binding corporate responsibility rules within the Battery Regulation for due diligence throughout the battery supply chain. As this Regulation is likely to act as a framework for regulating other complex products arising from the mobility industries, the Platform therefore invites the Commission to strengthen the due diligence requirements.

Europe’s new level of ambition for due diligence on batteries should be mirrored in any upcoming legislation that impacts other transportation industrial sectors and their supply chains. Both zero emission and traditional combustion transportations should face equivalent strict requirements. Those common or equal obligations should cover the entire supply chain of an economic operator, including its business relationships and subsidiaries. Economic operators should have clear environmental responsibilities, addressing risks such as water contamination, air pollution, biodiversity. This should also be the case for human rights, addressing risks such as child labour, forced or unpaid labour and the freedom of association of workers and so on.

Horizontal initiative on mandatory Human Rights and Environmental Due Diligence (mHREDD)

The Platform supports the overall objective of the mHREDD Directive, as well as the opportunity to boost investment crucial for the electromobility transition: productions sites, innovation as well as employee retraining, upskilling and reskilling.

However, it is important the European Commission proposes an ambitious horizontal mHREDD, to match – at minimum – the Battery Regulation on the due diligence requirements included in Art. 39 and Annex X. If the due diligence requirements in the Battery Regulation are strengthened by the co-legislators – a step we are calling for – the gap between the new battery industries and traditional ICE producers would keep growing, undermining the growth potential of the former.

The mHREDD requirements should therefore be extended to those sectors that compete with electric transport. In particular, due diligence requirements must apply equally to the fossil fuel sector. This would provide consumers and authorities with full transparency on the diverse mobility options available on the market. In addition to the excessive complexity created by double standards, an unambitious mHREDD would not deliver the level playing field between competing industries, consequently slowing down the transition to electric mobility.

Companies falling within the scope of the mHREDD should be liable for human rights and environmental harm they – or a company they control or have the ability to control – have caused or contributed to. This range of control should be clearly defined.

On the impact on prices, costs may increase due to new requirements on suppliers. They will either adapt their production accordingly or will pull out of the EU market, thus restricting the sourcing possibilities for European manufacturers to more costly suppliers. Establishing ambitious environmental and social standards via supply chain due diligence rules will, however, enable batteries and vehicles manufacturers in the EU to compete globally on elements other than price alone.

Finally, implementation of the mHREDD should be harmonised throughout EU to avoid double standards and divergence between Member States. A Regulation is necessary to create unambiguous guidance for transnational companies on the methodologies. Any uncertainties – particularly on implementation, scope, certification and auditing – should be avoided.

Word of Warnings from the implementation of Conflict Minerals Regulation

Reflecting on the experience of the implementation of CMR – which legislates on a very specific set of minerals – is essential for ensuring the effective implementation of the horizontal mHREDD and of the Battery Regulation. We urge legislators to take all steps necessary to tackle the difficulties of implementing and enforcing all EU due diligence policies in all sectors, particularly for other critical materials for the transition of electromobility.

 Considering that the basic components of the CMR are taking a significant time to implement, the Platform is concerned by the feasibility for the European Commission to enforce Art. 39 of the Batteries Regulation and upcoming mHREDD. The Platform for electromobility underlines the following challenges to ensure provisions can genuinely be enforced. New measures should:

  • Address delays in recognising industry schemes, which are at the core of the CMR, without compromising a thorough auditing process of the applying scheme.
  • Rely on concrete outcomes rather than on reporting, as is the case for the CMR.
  • Ensure responsibility falls on the user placing the minerals on the market (i.e. OEMs in the case of transport industry), rather than on their Tier 1 or 2 suppliers, in order to get closer to the end users.