Investin circularity for competitive, sustainable, European transport industries
Net Zero Investment Plan
Area 4: Invest to create a circularity value chain (10.0%)
Investing in recycling, urban mining, second-life batteries, and repairability is key for resource sustainability and circular economy in Europe, necessitating coordinated efforts and incentives for efficiency and environmental benefits.
Investment Areas
Circularity Priorities
Recycling
Minin, Remining & Urban miness
Second-Life of batteriest
Repairability
- Recycling
Investing in integrated recycling and repurposing facilities, in order to collect, dismantle and recover valuable metals from these sources, is essential for reducing reliance on primary mining and enhancing resource sustainability. By prioritising development of recycling infrastructure, Europe can establish a robust supply chain for critical metals and promote circular economy principles in the battery industry, ultimately contributing to the continent’s energy transition goals. Developing the EU’s recycling capabilities is paramount to retaining valuable materials within Europe and reducing dependency on imports. Incentivising the colocation of battery manufacturing and recycling facilities can streamline material flows, minimise environmental impact and use resources more efficiently.
- Mining, Remining and Urban Mines
Europe possesses a valuable resource in its so-called ‘urban mines’. These include used batteries and waste materials, which can be effectively leveraged to secure essential metals for battery production.
- Second-Life Batteries and 18. Repairability
Maximising the lifespan of batteries is essential for addressing the limited availability of raw materials within the EU. Embracing second-life battery programmes and implementing robust repairability requirements for both batteries and EVs can extend their usefulness and promote a thriving second-hand market. By incentivising reuse and repair of batteries and vehicles, Europe can reduce waste, lower its environmental footprint and unlock economic opportunities in the circular economy.
Investing in off-road infrastructures to enable the Green Deal
Net Zero Investment Plan
Area 3 : Off-road Infrastructures (14.5%)
Investment in electrifying the rail network, establishing multimodal hubs, enhancing public transport, and upgrading harbors’ electricity infrastructure is vital for advancing Europe’s sustainability goals and improving transportation efficiency, necessitating significant financial commitments and strategic planning.
Investment Areas
Off-road Infrastructures Priorities
Rail Network
Multimodal Hubs
Public Transport
Harbours
- Rail Network & 12. Multimodal Hubs
The electrification of the Trans-European Transport Network (TEN-T) rail network by 2030, 2040 and 2050 presents a significant infrastructure challenge; one that will require substantial investments. Unfortunately, such investment in rail infrastructure has been sorely lacking over the past two decades. To address this, increased investment is imperative, with priority for three key areas. First, maintenance of existing infrastructure is paramount for ensuring optimal track conditions, enabling higher speeds and improving services. Second, upgrading existing network infrastructure – including implementing the European Rail Traffic Management System (ERTMS) signalisation and addressing bottlenecks – are crucial for enhancing efficiency and capacity. As acknowledged by former Italian Prime Minister Enrico Letta in his report “The future of the Single Market”, massive investments are needed to support the establishment of a comprehensive, pan-European high-speed rail network, “seamlessly linking all EU capitals and major urban centres”, with the aim “to significantly elevate rail’s role in long-distance passenger transportation, aiming to capture more than 50% of the market share”. The achievement of this initiative is presented as “a cornerstone in the EU’s journey towards enhanced connectivity, economic growth, and environmental sustainability, underscoring its profound importance for the future of the European Union”. According to the latest analysis by Institut Rousseau, an annual investment of 47 billion euros between 2024 and 2030 is required for the development of rail infrastructures to complete the TEN-T core network.
- Public Transport
Public transport – including urban rail infrastructure such as metros, trams and light rail vehicles – has a pivotal role to play in achieving Europe’s climate objectives. These systems combine high capacity, energy efficiency and safety with minimal land use, making them indispensable components of sustainable mobility. The revised TEN-T Regulation mandates that 430 major cities along the network develop Sustainable Urban Mobility Plans (SUMPs) to promote zero- and low-emission mobility. Accordingly, there must be adequate funding allocated to support alternative fuel infrastructure solutions for urban rail, ensuring that charging infrastructure is also available at key locations such as terminuses and bus stops as well as at depots. In fact, the new TEN-T mandates that airports with an annual passenger traffic volume of more than 12 million passengers shall be connected to the TEN-T railway network, including the high-speed network, allowing for long distance rail services.
- Harbours
Upgrading maritime and inland port grids, along with their connections to the national grid, is essential for powering Shore-Side Electricity (SSE) infrastructure in European ports. Starting with ferry, container and cruise ship terminals by 2025, and extending to all other terminals by 2035, SSE infrastructure will ease the transition to cleaner maritime transportation. By prioritising investments in port electrification, Europe can reduce emissions from the shipping sector and promote sustainable port operations, in alignment with its climate objectives.
Investing in charging infrastructures to enable the Green Deal
Net Zero Investment Plan
Area 2 : Charging Infrastructures (14.5%)
Investment in high-power charging infrastructure for HDVs, depot charging infrastructure for HDVs and buses, LDV charging infrastructure, urban charging networks, and residential charging solutions is essential for enabling the widespread adoption of electric vehicles and reducing greenhouse gas emissions in Europe, requiring significant investment and regulatory support.
Investment Areas
Charging Infrastructures Priorities
High-Power Charging Infrastructure for HDVs
Depot Charging Infrastructures for HDVs and Buses
Charging Infrastructures for LDVs
Charging Infrastructures in Urban Areas
Residential Charging
- High-Power Charging Infrastructure for HDVs
HPC infrastructure along motorway networks is critical for facilitating the transition to electric HDVs. While the available solutions are technically mature, it will require significant investment to kickstart the transformation. By prioritising the installation of HPC stations, Europe can ensure compliance with regulatory requirements (notably AFIR) and substantially reduce GHG emissions from the transport sector. Public money must be directed towards meeting the real needs of drivers and fleets, which is to be able to charge during rest times.
- Depot Charging Infrastructures for HDVs and Buses
Depot charging plays a vital role in electrifying trucks and buses, as a significant portion of these vehicles return to depots at the end of each day. Europe should explore opportunities for local depot-based renewable energy production support sustainable charging solutions. Depot charging infrastructure will both reduce emissions and enhance energy resilience.
- Charging Infrastructures for LDVs
Overcoming barriers, such as high purchase prices and insufficient availability of charging points, is crucial for the widespread adoption of electric LDVs. This will require comprehensive investments to ensure adequate charging infrastructure coverage both nationally and regionally.
- Charging Infrastructures in Urban Areas
Urban areas need a greater density of charging networks to meet the growing demand for electric vehicles, particularly among residents without access to private parking spaces. Public charging points are pivotal in enabling urban dwellers to switch to electric transportation.
- Residential Charging
The residential sector is central to decarbonising the LDV fleet, as a majority of charging events take place at private residences. Furthermore, the installation of a controllable charging station is the most economical solution for the customer, the most energy-efficient for the grid, and promotes off-peak/super-off-peak charging. However, retrofitting existing buildings and electrical installations to accommodate charging points requires significant investment. Europe should assist with the renovations required to ensure widespread access to residential charging infrastructure, and support consumers in purchasing charging points. In addition, financial support for building-related costs – such as electrical upgrades and grid connections – is essential for encouraging the widespread adoption of electric vehicles in residential settings.
A Comprehensive Roadmap for V2X Integration in Europe
Energy & Infrastructures
A Comprehensive Roadmap for V2X Integration in Europe
The paper outlines enablers and barriers concerning bidirectional charging systems, clarifies key barriers, highlights ongoing efforts to mitigate them, and underscores the critical need for concerted and regulatory actions to achieve the transformative potential of V2X integration.
Electric Vehicles (EVs) both pose particular challenges and present promising opportunities for the energy system; they mark a pivotal moment in the evolution of transportation and energy sectors. With the increased adoption of EVs lies the imperative for strategic planning and collaborative action on Vehicle-to-X (V2X), a crucial technology for smartening the road transport sector.[i]
Recently adopted legislation – as part of the European Green Deal – has already paved the way for the roll-out of smart-charging technologies in the electromobility ecosystem.[ii] We welcome these initiatives and will monitor their implementation closely. Smart charging is a fundamental prerequisite for V2X, which will deliver further advantages for people, the climate and European businesses alike.
Recognising this, this document from the Platform for Electromobility seeks to present a comprehensive roadmap on V2X, setting out a series of actionable steps that by Member States (MS) should undertake, along with measures required at the EU level. Stressing the importance of a cross-sectoral approach, our strategy seeks to navigate the complexities of V2X integration in our energy system without delving too deeply into intricate technicalities. The paper outlines enablers and barriers to adopting bidirectional charging systems, clarifies crucial barriers – and highlights ongoing efforts to mitigate them – and underscores the imperative for concerted and regulatory action to realise the transformative potential of V2X integration.
1/ Benefits of bidirectional charging
a/ Benefits for public finances & grid investments
V2X integration offers a multifaceted solution, one with the potential to unlock a wide range of benefits across various domains. Foremost among these, V2X – as with other flexibility resources – complements conventional grid reinforcement measures, helping alleviate the strain on existing infrastructure while enhancing its resilience. We are already starting to see increasing tensions in the grid and the overwhelming need to reinforce it; therefore, the deployment of V2X and the use of EVs as batteries represents a ‘no-brainer’[i] and would effectively smooth the rollout of grid reinforcement, something that usually takes between 5-15 years. V2X integration thus offers access to a realm of ‘low-hanging fruit’ opportunities, allowing the cost-efficient adaptation of the grids to growing electrification.
b/ Benefits for Europe energy autonomy
The integration of V2X will help deploy renewable energy sources (RES), by providing efficient storage solutions. It has the potential to help balance the grid and increase the penetration of renewable electricity (RES-E) into it, thus accelerating the drive to climate neutrality. Indeed, in order to ensure generation adequacy – key for the energy transition – V2X will be pivotal. As intermittent renewable energy becomes increasingly prevalent, maintaining grid stability and meeting demand poses significant challenges. Here, V2X solutions can play a crucial role in balancing supply and demand, enabling dynamic resource adequacy analyses that realise the enormous potential of V2G capabilities.
c/ Benefits for grid operators
From the perspective of the grid operators, there are manifold advantages. For Transmission System Operators (TSOs), V2X is particularly beneficials for Frequency Regulation (FCR) Services, which are pivotal functions for TSOs. In addition to mere savings in battery costs, V2X optimises both standalone and grid-connected storage battery systems. FCR plays a critical role, not only in reducing the necessity for investment in battery storage services but also in minimising the need for grid upgrades. These efficiencies translate into systemic savings, ultimately benefiting electricity consumers. For DSOs, V2X can play a major role in local flexibility markets and congestion solutions providing services to DSOs and representing a valuable flexible resource that can be procured to ease tensions on distribution grids. This requires flexibility mechanisms in which V2X value can be stacked based on related remuneration. To enable even more value of V2X for every DSO, market based procurement of flexibility based on V2X shall be stimulated.
d/ Benefits for users, people and businesses alike
From an end user’s perspective, the benefits of V2X integration will be substantial. Through leveraging V2X capabilities, users will have the opportunity to earn money from feeding energy into the grid, thus enhancing the overall value proposition of electric mobility.[ii] Remuneration mechanisms (such as those based on availability, capacity or time) will trigger further consumers to participate; once they do so, they will naturally generate demand for V2X. V2X integration will not only enhance grid resilience and promote renewable energy uptake but also pave the way for a more sustainable, efficient and adaptive energy ecosystem, one where EVs can equally participate in flex mechanisms.
2. Legislative and Regulatory Principles for V2X Integration
As we call on legislators to begin shaping the regulatory framework for V2X integration, there must be a number of core founding principles that underpin their efforts to foster innovation, interoperability, fairness and trust within the emerging ecosystem.
a/ Consumer trust
Foremost among these principles must be building and maintaining consumer trust. Legislators must prioritise creating a robust system that instils trust among users, system operators and businesses alike. This will entail ensuring transparency and accountability in V2X transactions while also safeguarding consumer rights and interests.
b/ Business models based on use cases
The deployment of V2X infrastructure must be accompanied by corresponding business models, particularly where financed/cofinanced by public entities. As the value of V2X depends on the use case of fleet and chargepoints, there need to be proper business models created that provide an incentive for consumers. Regulators should therefore facilitate mechanisms to support user compensation and fair pricing; these should recognise the pivotal role granular pricing structures play in enabling diverse business models and in incentivising dynamic energy management. The increased volatility in our energy system arising from renewables and negative grid tariffs can further stimulate consumers to engage and participate in V2X initiatives.
c/ Commonly accepted and harmonised standards
The promotion of common standards is paramount for ensuring interoperability and reliability across V2X systems. These should allow the CCS standard to provide smart and bidirectional charging. This should be implemented as early as possible in both charging stations and cars. Any further delay will lead to infrastructure that is not future-proof and will fail to deliver the smart-charging services we will need for the energy transition to succeed. Standardisation bodies should prioritise development and enforcement of standardised protocols for battery efficiency and warranty and for EV charging protocols between both the grid and vehicle. This will bolster consumer confidence and trust in V2X technologies.
d/ Affordability through democratisation
The accessibility and affordability of V2G-capable vehicles must be a priority if access to this transformative technology is to be democratised. By incentivising competition and innovation in the production of V2X-capable chargers and EVs as well as through lowering the barriers detailed below, legislators can drive down costs and promote widespread adoption. This in turn will create economies of scale and lower barriers to entry. With the right regulatory framework in place, recharging costs can theoretically be brought down to zero with bidirectional charging.[i]
e/ Equal treatment for all grid usages
Ensuring equal access, participation, and treatment for all energy usages, including all type of V2X, is fundamental. All grid users should receive equal treatment without discrimination, be they electric vehicles, wind turbines or home appliances. Any exceptions – such as tariff exemptions – should be restricted to emerging user groups, should remain temporary and should be appropriately justified.
f/ Upgradability path
In envisioning the regulatory framework for V2X integration, it is imperative to prioritise establishing future-proof systems capable of evolving alongside advancing technologies and changing needs. Although V2X technology is not as yet fully harmonised across Europe and still faces barriers, its early rollout is needed in order to facilitate improvements. Central to this endeavour is the need for an ‘upgradability path’, embedded within the regulatory framework. Such a path will not only instils trust among consumers and markets but also ensure compliance with future technological advancements and emerging requirements.
g/ Public charging hidden potential
In Europe, a significant proportion of the car fleet lacks access to home charging. As a result, publicly available charging will continue to be necessary in the future. This presents an opportunity to leverage V2X technology at these points also. We therefore encourage public charging points to be V2X-capable; this is provided that the cost-benefit analysis is positive, they are priced similarly, only implemented on slow chargers and do not impede the rollout of charging stations across Europe.
3. Barriers to V2X Deployment
Despite the potential offered by V2X integration, several barriers continue to hinder its widespread deployment. Overcoming regulatory, technical and market hurdles will require concerted efforts.
a/ Implementation of the Electricity Market Design
At the forefront of these challenges are regulatory barriers, most notably the lack of implementation by MS of the 2019 Electricity Market Design, which discriminates and disincentivises the participation of V2X in the electricity markets. To address this, there is an urgent need for MS to accelerate their implementation.
b/ Double Taxation
One of the asks of battery stakeholders (EVs and stationary) is to eliminate double taxation; that is, the taxing again of electricity injected into the grid from a battery. Double taxation[i] remains a persistent concern, particularly in scenarios where energy storage is integrated with other loads. While progress has been made in mitigating double taxation for large-scale storage, challenges persist for small-scale storage assets such as V2X. For example, in Germany, double taxation for stationary storage has been removed, yet remains in place for mobile storage.
c/ Uncoordinated grid requirements
The absence of the anticipated regulations, coupled with limited access to organised markets and revenue streams, poses significant challenges to V2X deployment. Uncoordinated grid requirements and standards between countries are exacerbating these challenges, hindering interoperability and complicating cross-border deployment efforts. Divergent communication standards and disparate smart meter adoption rates – something that is particularly evident in countries such as Germany, which has low penetration rates – underscore the urgent need for harmonisation and standardisation initiatives to realise the full potential of V2X integration.
4. Call for coherence, actions and political ownership at EU level
a/ Coherence across Member States
As the EU navigates the complexities of V2X integration, it is vital to address the prevailing divergences among MS and to foster a cohesive regulatory framework that promotes innovation and harmonisation. Despite incremental progress, no MS has successfully removed all barriers to V2X deployment, underscoring the imperative for EU-level intervention. For V2X for slow public charging, we therefore call for national capacity targets – rather an EU-wide one – because the share of cars without access to off-street parking at home differs significantly between MS.
b/ Coherence across EU legislations and regulations
To advance implementation of V2X and harness its manifold advantages within Europe, it is crucial that the newly installed European institutions adopt a holistic approach to this challenge. All V2X-relevant measures should be in the form a comprehensive regulatory framework, rather than addressing them in isolated discussions, or rather than discussion technologies (AC vs DC). One way of ensuring this seamless integration across diverse legislative frameworks – and avoiding a fragmented approach – is to establish political ownership.
c/ Multilevel coherence on V2X
Cities will, in general, be the key enablers and accelerators of V2X due to the alignment between clean air and decarbonisation strategies (such as growing adoption of zero-emission zones, electrification of heating as an alternative to petrol/gas/wood). V2X should therefore be part of an integrated mobility and energy strategy at all territorial levels. We therefore call upon the EU to adapt the proposed SUMPs/SULPs into SUMEPs/SULEPs (Sustainable Urban Logistics/Mobility and Energy Plan). This will ensure coordinated and integrated planning, helping couple mobility/logistics with energy aspects
d/ Double mandate to jumpstart the market.
Mandating V2X interoperability for all bidirectional-capable vehicles, while at the same time requiring V2X capability for public fleets and buildings would be decisive in kickstarting the market and boosting widespread adoption. It would also ensure flexibility for independent aggregators and promote the use of submeters. Requiring interoperability and encouraging public fleets to lead by example will help jumpstart the market.
Conclusion
Additional measures, including addressing communication standards and issuing non-binding guidelines for MS, will be essential for fostering coherence and facilitating the transition towards a sustainable, interoperable V2X ecosystem. With upcoming revisions to key pieces of legislation now on the horizon, it is an opportune moment for the European Commission to demonstrate leadership and to spearhead concerted action to achieving V2X integration goals. By embracing coherence at an EU level, policymakers can unlock the full potential of V2X technologies and accelerate the shift to a smarter, greener future.
Introduction [i] V2X is an EV bidirectional charging technology encompassing several sub technologies: When the vehicle is plugged and electricity automatically flows from the car back to the grid, this is known as Vehicle-to-Grid (V2G). If the charging and discharging of electricity stored in electric vehicles takes place in buildings, this technology is known as Vehicle-to-Building or Vehicle-to-Home (V2B or V2H). [ii] Notably in the Energy Performance of Buildings Directive, the Renewable Energy Directive and the Alternative Fuels Infrastructures Regulation The benefits of bidirectional charging [i] It has been calculated that V2G can offer 21TWh of upward flexibility, and 24TWh of downward flexibility by 2030, considering 30% of the EVs are charged bidirectionally. Together with other flexibility resources, €11 to €29 billion could be saved in annual savings in distribution grid investments. Source : https ://smarten.eu/wp-content/uploads/2022/09/SmartEN-DSF-benefits-2030-Report_DIGITAL.pdf [ii] In a fleet demo in Denmark, a 10-EV fleet engaging in frequency regulation (FCR) services recorded an average revenue of € 1,860 per car per year[ii]. In a residential V2G project connecting 320 homes in the UK, the V2G units were able to create ‘between £230 and £300 of value per year through the spot electricity market’ and the project team expects that ‘when combined with flexibility services this could grow to £500 per year[ii].’ In the UK, a solution already commercialized proposes the first V2G tariff in the UK where EV drivers would get free charging thanks to their V2G charger and vehicle[ii], providing clear incentives and enhancing the social acceptance of the consumer to opt for bidirectional charging. Source: https://www.ofgem.gov.uk/publications/case-study-uk-electric-vehicle-grid-v2g-charging Legislative and Regulatory Principles for V2X Integration [i] Source: https://smarten.eu/position-paper-why-flexible-consumers-matter-a-contribution-to-eu-elections-2024/, p 9 Barriers to V2X deployment [i] In fact, battery stakeholders face a triple taxation. Once when the energy is taken from the grid, twice when part of the energy is injected into the grid, and a third time when that electricity is used somewhere else. The electricity injected to the grid should not be taxed when taken by the battery nor when injected back into the grid.
Platform's statement: PFAS in sustainable e-mobility
Supply chain
PFAS in sustainable e-mobility
In the pursuit of the electrification of the mobility sector for the years to come, it is essential to recognise concerns surrounding certain PFAS use cases and their production, use and disposal.
The Platform for Electromobility acknowledges the significance and broad presence of Per- and Polyfluoroalkyl Substances (PFAS) in the electromobility ecosystem. PFAS represent a group of artificial/ anthropogenic chemicals with different physical, chemical, and biological properties[1]. PFAS have been widely utilised in most industries for their valuable properties (including resistance to heat, water, and oil) that enhance product performance and safety. However, their production and disposal raise concerns about environment and human exposure[2].
In the context of clean mobility manufacturing, e.g components of electric vehicles of all modes to renewable energy infrastructures, PFAS have played an enabling role. They are used in sustainable transportation, energy systems and components, such as batteries, wiring, and battery thermal management systems.
In the pursuit of the electrification of the mobility sector for the years to come, it is essential to recognise concerns surrounding certain PFAS use cases and their production, use and disposal. Considering that environmental and human health protection are critical, we are committed to supporting the transition to PFAS-free solutions in the sustainable mobility sector, and would support measures to eliminate all emissions released during the life cycle as soon as viable industrial alternatives[3] are available[4]. Our primary collective objective is to reduce, and where possible, phase out the use of PFAS following the REACH risk management approach across all mobility industries. We advocate for continuous innovation to replace such PFAS application in sustainable mobility.
We outline below crucial points for consideration to the Regulators during the whole restriction proposal negotiation process:
1. Minimize uncertainties for investors
While Europe has shown its intention to take a global leading role in environmentally conscious battery production, ongoing uncertainties around PFAS use in the battery industry represents a real threat to this nascent and needed industry for the coming years. The PFAS restriction proposal presented by the four Member States and Norway to ECHA is putting investments in Europe into the mobility sector today at risk, while other parts of the world are actively promoting the development of a domestic e-mobility value chain. Uncertainties regarding the duration of the derogation period pose a potential risk of exposing the sectors to a phase-out without adequate alternatives.
We call upon legislators to take a detailed approach ensuring predictability for battery value chain operators while future-proofing the industry from further restrictions.
2. Allow appropriate, open-ended derogation periods
The proposed phase-out of PFAS, which does not take into account the long lead times for developing alternatives will likely hinder the deployment of ‘made-in-Europe’ essential sustainable mobility solutions, particularly in uses when no viable substitutes exist. Legislators must recognise that, up to date, some components of e-mobility applications cannot work without PFAS[5], because no viable alternative solutions exist on the market or possible alternatives have been ruled as unviable. In order to avoid disastrous consequences for the battery industry and therefore the e-mobility roll-out, the proposed PFAS restriction requires careful and specific consideration:
We call on legislators to grant appropriate derogation periods for as long as necessary for testing alternatives and bringing them to the market[6] and allow for the use of PFAS where no alternative is available.
Encourage continuous and increased research and development to accelerate the testing and research around possible alternatives.
We also support reducing the scope of the current restriction proposal to exclude applications where no significant emissions happen during the whole life cycle, such as for batteries.[7]
3. Consider appropriate tools to increase transparency along the e-mobility supply chain:
Transparency and monitoring requirements could help improve the appropriate capture and destruction of PFAS using complementary abatement technologies and improve depollution standards.
4. Ensure consistent and future-proof legislation
Consistency across various EU legislations is key. Upstream, the issue of PFAS should be addressed within the context of Article 6, which pertains to Substances of Concern in the EU Batteries Regulation. Downstream, matters related to the disposal of materials containing PFAS in electric vehicles are currently under discussion in the End-of-Life Vehicle Regulation proposal.
We urge legislators to pay special attention to the issue of legacy substances under the revision of the EU End-of-Life Vehicles Directive.
Any ban on substances must be applied only on new types of vehicles.
Subsequent set of policies
Following the above-mentioned principles, we call for adopting the following balanced set of policies, which support reducing PFAS use where possible, mitigate their impact on the environment and human health, while supporting the energy transition and path towards climate-neutrality:
Encourage and invest in research and development to identify and promote viable alternatives to currently used PFAS in the electromobility sectors
The derogations which will be defined in the European Commission’s restriction for the use of PFAS substances in MAC (Mobile Air Conditioning) should be the same for all vehicles including EVs and combustion engine vehicles with mechanical compressors;
Ensure legislative predictability and science-based principle in chemicals management so that PFAS restrictions do not unintentionally increase the risk of investment diversion in battery manufacturing, potentially shifting operations from Europe to third countries.
Increase transparency and traceability on PFAS presence across the EV value chain, beyond battery production, notably by merging requested information of the Vehicle passport as proposed in the ELVR and the Battery passport behind a single QR Code.
It is imperative to foster sustainable and viable alternatives to PFAS in a balanced approach to align with the EU’s wider objective of accelerating a sustainable and resilient clean mobility sector.
[1] https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/terminology-per-and-polyfluoroalkyl-substances.pdf [2] The PFOA, a sub-group of PFAS, have notably been included in recent WHO classification as group one carcinogen (IARC Monographs evaluate the carcinogenicity of perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) – IARC (who.int)). Resulting from this, PFOA have been already globally regulated and phased out. They are not in the scope of this document. [3] Industrial viable alternatives are defined as innovations that have been tested, approved and scalable, ready for mass-market applications. [4] Regarding vehicles, only new types should be concerned by the upcoming restrictions. [5] https://rechargebatteries.org/wp-content/uploads/2023/09/FINAL-SECOND-SUBMISSION-.pdf [6] ready for mass-market applications [7] ECOS have decided to dissociate from other members of the Platform for Electromobility and not to support this last specification.
Five steps towards a 360° e-mobility industry strategy
EU Industrial Strategy
Our recommendations for a “Green Deal Industrial Plan”
Any “Green Deal Industrial Plan” would not be complete without a strong chapter on the electromobilities manufacturing ecosystem.
In the context of the forthcoming EU legislative mandate, the Platform for electromobility endorses the overall shift in European policy priorities set by the European Green Deal as a welcome long-term compass. Recent institutional declarations[1] aligned with Platform’s EU Election Manifesto[2] support the development of a robust industrial policy. This is essential to ensure Europe’s competitiveness, resilience in a rapidly evolving global landscape, and maintain its leadership in climate change mitigation. Any “Green Deal Industrial Plan” would not be complete without a strong chapter on the electromobilities manufacturing ecosystem. To achieve these goals, we propose a multifaceted approach that considers the entire value chain’s competitiveness in green transport solutions while revitalizing their financial support. Such policies must be implemented within a framework of regulatory stability and close international cooperation with other regions.
We will set out these proposals below under 5 headings:
- Ensuring regulatory stability for industries and investors
- Enhancing value chain competitiveness and resilience
- Financing the transition in the short term: the “low hanging fruits”
- Financing the transition in the long term: Net Zero Investment Plan
- Strengthening international cooperation
We welcome questions and cooperation with the Platform for Electromobility on our proposals.
1. Ensuring regulatory stability for industries and investors
A stable regulatory system is crucial. Attracting investment to create the net-zero industrial ecosystem for electromobility will be facilitated by maintaining a consistent, clear regulatory framework and climate objectives. This means first and foremost ensuring that the European Green Deal legislations as voted in the 2019-2024 mandate remain steady over time. We strongly warn against disruption of the Green Deal and their long-term planning notably by limiting the scope of major reviews. At a more granular level, we call for stability in the regulatory frameworks of all transport modes. It is a key element for successful risk management. A consistent, clear regulatory framework secondly means performing sound impact assessments before proposing new legislation. Potential legislations should be in line with the direction taken by the Green Deal as voted during this mandate. Thirdly, regulatory stability means focus on proper implementation through the swift adoption of all necessary complementary acts In a nutshell, implementing before reviewing.
2. Enhancing value chain competitiveness and resilience
a. A 360° e-mobility industry strategy
While recent European industrial policy initiatives, such as the Net Zero Industry Act (NZIA), have focused on key components and sub-systems[1], we have observed that an emphasis and consideration of full value chain competitiveness is lacking. It is crucial that these policies take into account the comprehensive nature of mobility industry value chains across sectors and support their global competitiveness as they navigate the green transitions. We call for a 360° e-mobility industry strategy, widening the focus from specific components to a more comprehensive approach, spanning from raw materials to end products and from individual to all modes of sustainable transportation.
B. Upstream and downstream
While the presence of gigafactories is fundamental for the development of green industries in Europe, with production capacity on some parts of the value chain (so far mostly focused on end products), it is important to highlight that they alone do not guarantee a competitive and non-dependant industry[2]. Indeed future industrial policy should go beyond the end-product and also consider upstream (refining) and downstream (recycling), both sectors being, so far, not located in Europe. A European industrial network of innovative companies from all sizes would help securing all stages of e-mobility value chains for the manufacturing and recycling of key components. The EU should channel purchases toward “made in Europe” products and increase production chains within Europe. Given the high demand for strategic raw material to manufacture electric vehicles, securing the value chains also includes a strong focus on security of supply of such materials and other available alternative technologies, as well as the recyclability of engines and batteries. The creation of new industrial hubs in Europe should go hand-in-hand with this strategy.
c. Energy-cost efficient strategy
Energy costs play an integral part of manufacturing competitive transport solutions. The availability of affordable, decarbonised energy is paramount to maintaining Europe’s competitiveness in the global low-carbon technology competition. We ask policymakers to work urgently on mitigating electricity prices disparities between the Union, China and the US, which are severely disadvantaging EU manufacturers. We endorse other calls[3] for the introduction of incentives that reward low-carbon technology producers favouring local materials and components.
d. Public procurement driven sectors
Similarly, for mobility sectors where investment decisions are predominantly the responsibility of public authorities, such as rail, the relevant EU legal framework must be properly enforced. That starts with public procurement, ensuring that tender evaluation criteria set the right focus on the sustainability of the selected solutions but also include all available tools to ensure fair competition, such as the foreign subsidy regulation. We strongly support the NZIA’s non-price criteria proposal in public procurement supporting sustainable development and resilient European industries. Those criteria will help favour European industries in public auctions and ultimately promote technologies produced in Europe.
e. Accompany workers and employers in skills transition
Industrial sectors must be supported in their skills development and employment policies for a successful decarbonisation of its values chains. For this purpose, EU institutions and Member States should undertake a mapping of skills shortages. This should consider both traditional and new skills. That way, we can assess the needs for jobs and skills in each sector, developing tools to identify and publicise available training, and highlight those that need to be created. Based on the identified needs, measures should be undertaken by the EU – such as NZIA’s initiative for “Net-Zero Academy” – and the Member States to support existing training structures in Member States as well as to ensure that the trainings are conducted by practitioners from companies.
3. Financing the transition in the short term: The “low hanging fruits”
Existing EU funds can already serve as valuable assets if they are distributed efficiently and intelligently, notably by streamlining access to finance, particularly for net-zero industries, through instruments such as the Innovation Fund and InvestEU. To do so, we have identified five “low-hanging fruits” measures that can be taken without further delay:
- Low hanging fruit 1: Guarantees. As a matter of priority, public investment tools should crowd in private investments by increasingly making use of instruments like guarantees. Firstly, the InvestEU Fund should be further mobilised in support of a 360° e-mobility industry strategy. Secondly, the European Investment Bank (EIB) Group should strengthen the provision of commercial bank guarantees for investments by companies across the EV value chain, replicating the recently announced €5 billion guarantee facility for the wind sector[1].
- Low hanging fruit 2: Innovation Fund. We welcome the recent initiative under the Innovation Fund to dedicate €3 billion to the EV battery value chain. This new mechanism needs to focus on the most sustainable EU battery and components manufacturers[2]. A robust mechanism needs to be built, including for channelling increased funding from Member States to match EU funding.
- Low hanging fruit 3: Capacity building. To enhance accessibility, we propose that EU or national administrations train and appoints specific staff to provide advisory services to both applicants and national authorities responsible for distributing EU funds. A substantial portion of these funds, especially in the case of Recovery funding, may remain unallocated due to the constrained administrative capacity of Member States[3] to prepare projects or process applications. Supporting project preparation and speeding up authorization procedures at the national level would thus benefit both the applicants and the authorities involved.
- Low hanging fruit 4: Mid-term MFF revision. The mid-term revision of the MFF is the opportunity for European institutions and Member States to significantly raise funds of strategic programmes (STEP but also CEF) to provide appropriate financing instruments to support a competitive decarbonisation of the EU industry and support investments in clean, sustainable mobility solutions.
3. Financing the transition in the long term: Net Zero Investment Plan
a. Why a Net Zero Investment Plan now?
The climate investment gap is deepening by the day and the way to fill the gap will be a major challenge for decision-makers in the coming years. European elections are the democratic the window of opportunity to set priorities about where EU funds should flow and the level of support that EU will provide to shift the continent to clean mobility. 2024 is thus a milestone year for the green transition. The STEP platform is, although welcomed, unfortunately far from the pan-European response to global competition on cleantech that the EU needs. Therefore, we support the creation of a major Net-Zero Investment Plan after the EU elections.
b. Predictable and upfront support for op-ex
The EU should ensure that financial instruments do not exclusively prioritise innovation but also consider the importance of providing strategic support for operating expenses and production, for a limited duration. We highlight the fact that operational expenses (op-ex) are not covered by the current InvestEU funding framework. This means that in addition to promoting innovation, financial support should be directed towards sustaining and optimizing day-to-day operations and the production processes of net-zero industries, thereby creating a more balanced approach to funding allocation. Beyond deciding the level of support that will be provided to the green and digital transition of the transport sectors, upfront predictability and certainty about possible funding should also be provided. A rulebook for financing should make sure op-ex support is both predictable and upfront.
c. Consider ventures with higher risk profiles
To complement this new approach and move closer to a truly comprehensive funding allocation, it’s essential to also consider ventures with higher risk profiles. For instance, when it comes to the Alternative Fuels Infrastructure Fund, the current financing terms are notably stringent. These terms often exclude high-risk endeavours, as they require a minimum of 50% funding from national banks or partners, effectively limiting opportunities for investment in riskier projects. This, in turn, disproportionately affects emerging industries and initiatives in Central and Eastern Europe. To address this issue, the European Investment Bank (EIB) should explore investments in riskier ventures, and InvestEU should be equipped to provide loans and equity for such undertakings. The InvestEU Program, designed to offer guarantees to both public and private banks, can play a pivotal role in enabling them to take more substantial risks in their lending and equity operations. This approach can facilitate the inclusion of ‘investments in riskier ventures’ and contribute to a more diverse and dynamic investment landscape.
d. How to finance a Net Zero Investment Plan?
This Net-Zero Investment Plan should be structured under the EU Multi Financial Framework on the one hand, and via new bond issuance programme replacing the Next Generation EU programme on the other hand. In addition, this broader investment plan should ensure that sufficient European and national funding resources, leveraging private sector investment, are available to achieve Europe’s objectives as set in the Climate Law and in the Smart and Sustainable Mobility Strategy. On top of the achievement of dedicated programs such as the TEN-T, it should include a dedicated Green Industry fund. State Aid measures should be re-designed and local supports coordinated at EU level to ensure a level playing field at European level,. The future State Aid regime should mandate EU governments to integrate environmental and social considerations to their support schemes, so that only best-in-class projects benefit from public support at regional and national level.
5. Strengthening international cooperation
Stability also requires robust international cooperation. Strengthening ties with diverse regions would diversify sources, reduce geopolitical risks and uncertainties, ensure a secure supply chain, enhance global industrial collaborations, and uphold a fair competitive environment for all clean transport industries.
- Proactively setting a Level Playing Field
The EU response to other regions’ recent green industry support program should be prepared with care, to avoid provoking a global subsidy race. The goal should be to create an international level playing field between all economies, aimed at reaching Paris Agreement climate targets (COP21) together and aligned on WTO rules. For certain industries, level playing field can only be reached by matching competitors’ support: for examples, for battery manufacturing, the US IRA provides a significant op-ex support per kWh produced; for reskilling workers, massive support for training automotive workers is proposed. We call for EU policymakers to match such support in some manner to help its European battery industry compete on more equal terms. Without such matching, there can be no global level-playing-field for e-mobility related manufacturing.
- Cooperation to avoid trade disruption
With several studies by the OECD[1] highlighting the challenges faced by European railway producers in the Chinese market, as well as the public assistance received by their companies, the question of China’s undisclosed subsidies benefiting its products is not new for the railway industry. Cooperations should be reinforced to ensure there are no such practices risking unbalancing global competition.
- Cooperation to diversify sources
Dependence on one single third country for green transport technologies is tangible[2] and should also be mitigated. China dominates the production of solar panels, batteries for EVs and part of the world trade in wind turbines. To diversify sources, we support proposals to form a green technology partnership between governments and businesses of the major economic powers to reduce strategic dependencies. Such partnership would be intended to complement, not replace, existing supply chain. Beyond cooperation with third countries, cooperation should also be within European countries and industrial partnerships to multiply joint purchases and thus secure supply of strategic raw materials at advantageous prices.
[1] President von der Leyen’s State of the Union, European Commission’s Work Programme. Executive Vice President Sefcovic’s speech at Environment Council. [2] “2024-2029: Five years to make e-mobility transition a success”, Platform for electromobility, September 2023. --- [1] A "sub-system" refers to a specialized and interconnected set of components that collectively perform a specific function within the overall system. [2] “How to Meet the Industrial Challenge of Electric Mobility in France and in Europe?”, Notes de l’Ifri, Ifri, November 2023. [3] “Call for EU Clean Industrial Deal and urgent actions to keep Europe in the world’s clean technology race”, Eurofer, October 2023. --- [1] Press Release, EIB, December 2023 [2] Press Release, European Commission, December 2023 [3] “How Europe should answer the US Inflation Reduction Act”, Bruegel, February 2023 --- [1] “Measuring distortions in international markets: The rolling-stock value chain”, OECD, February 2023 [2] “De-risking and decarbonising: a green tech partnership to reduce reliance on China”, Bruegel, October 2023.
Our five recommendations to CO2 Standards for trucks and buses trilogue negotiators
CO2 Standards for HDVs
Our recommendations to trilogue negotiators
The members of the Platform for Electromobility welcome the position adopted in November by the European Parliament on the revision of the CO2 Standards for trucks and buses Regulation. Welcomed overall, the text provides a robust and ambitious yet realistic and business-friendly path toward decarbonisation of road transport in Europe. Ahead of trilogue negotiations, we hereby highlight key elements that negotiators should keep in mind to safeguard the Regulation’s added value
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First and foremost, we urge negotiators to reach a conclusion before March 2024 to avoid losing one year in our collective fight against climate change. Considering the deadline of the text, a late agreement would delay its application by a full year, hence jeopardising our joint effort to reduce CO2 emissions and reach net-zero society in 2050. A timely resolution is paramount to providing certainty to the truck and bus industries, its customers as well as adjacent infrastructures and energy industries, enabling them to plan and invest in the necessary innovations for compliance.
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Industrial certainty and environmental progress are also jeopardised by a potential loophole that could open the way for unrealistic use and expectation of e-fuels and biofuels. Both alternative fuels solutions are inherently inefficient[1] and should remain out of the CO2 standards. Renewable and low carbon fuels and, most notably, e-fuels will not be carbon-neutral in time to decarbonize the road transport sector and meet our climate targets, and as a result should be limited where direct electrification is not feasible, namely in maritime and aviation sectors. These fuels are scarce resources sorely needed to reduce greenhouse gas emissions in the aviation and shipping sectors, whereas the road transport sector is well-suited for electrification. They do not provide a viable alternative to existing zero-emission solutions. In addition, e-fuels aren’t currently produced at commercial volumes. Scaling up additional renewables, electrolysers, direct air capture (DAC) and e-fuel production facilities would take time and larger e-fuel quantities would likely not be available before 2040.
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Thirdly, considering that in 2022 30% of new buses in Europe were already zero emission, an urged confirmation of the 100% Zero Emission mandate target at 2030 for urban buses, with no postponements, is an optimal option, notably with the move of the two subcategories of urban buses, namely class II low-entry (i.e. 31L2 and 33L2) into the coach segment, as they are often used by local and regional authorities for longer distance public transportation. While reducing the CO2 emissions of those groups of vehicles, this choice would also bring substantial public health benefits by lowering the amount of particulate matters (PM) emitted.
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Fourthly, we praise the European Parliament’s extension of the emission debts and crediting system from 2030 to 2040 gives additional flexibility to manufacturers to earn credits (when reducing emissions more than required) and use them to offset debts (if emissions are above what is required). Credits now can be used for 15 years to offset debts. Credit’s lifetime should have a maximum of 5 years as do the debts. This would force manufacturers to continuously invest in reducing their CO2 emissions. This mechanism is pivotal in encouraging industry players to adopt sustainable practices and contribute meaningfully to the reduction of greenhouse gas emissions.
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Platform members also recognise the positive impact a fleet mandate mechanism would have on the decarbonation of heavy-duty vehicles. On this point, Platform members equally stress the importance of support mechanisms for the rollout of office-based charging, from subsidies to tax discounts.
With a timely conclusion, unequivocal standards without place for questionable alternative fuels, the strongest ambition on decarbonization of urban buses, an ambitious definition of zero-emission heavy-duty vehicles and fit-for-purpose emission debts and crediting system, the CO2 Standards for trucks and buses would truly be the regulatory framework that promotes sustainability, innovation, and the accelerated adoption of zero-emissions road transport.
[1] Estimates indicate that the electricity requirements for the production, transportation, and distribution of various e-fuel types are significantly higher, ranging from approximately 1.6-1.8 times greater for compressed gaseous hydrogen to between 2.2 and 6.7 times higher for liquid e-fuels, in comparison to the direct use of electricity, depending on the specific fuel type. When we account for not just the fuel production phase but also the efficiency losses within the vehicle powertrain during e-fuel usage, the overall efficiency diminishes even further.
Our reaction to the revision of the End-of-Life Vehicles Regulation proposal
ELVR: Our reaction to the revision of the End-of-Life Vehicles Regulation proposal
We express our support to revise the ELVD and to combine it with that of the Directive. As a pivotal legislative tool to enhance the lifelong sustainability of EVs, this revision is key for the e-mobility transition and can accelerate the growth of a robust recycling value chain within the EU.
While our primary focus is on elements of the ELVR directly relevant to ZEVs, we welcome the overall text and notably the decision to turn the directive into a regulation, setting a comprehensive, harmonised regulatory framework across Europe.
We welcome Chapter 5, introducing provisions on the export of used vehicles. The export ban on non-roadworthy vehicles must remain a key point. We welcome the circular economy provisions addressing the design, production and end-of-life treatment of vehicles, effective dismantling, recycled content rate and the recoverability of raw materials. Measures have been forecasted to support the market for reuse, remanufacturing and refurbishment of parts and components of a vehicle
Binding targets for the reuse, recycling and recovery of ELVs must be preserved and their practical achievability ensured. Certain aspects of the proposal require clarification:
- Potential overlaps with other existing legislations, e.g. the Batteries Regulation (BR) and the Ecodesign for Sustainable Products Regulation. To reduce excessive administrative burden it t is imperative to clearly define the interlink between the ELV passport and the Battery passport – i.e. how the information is communicated between these platforms and who has access to what information, with the aim of avoiding any redundancy, and if feasible, merging requested information behind a single QR Code. Such a tool has to take into account confidentiality of information and also differentiate on levels of data accessibility depending on stakeholder type, considering the information sharing requirements in the BR.
- The annex on roadworthiness needs refinement to ensure that non-functioning batteries will not be exported, and aligning the provisions with the BR’s article on the export of waste batteries.
- A close examination of Article 7, on the design of the removability of certain parts of the vehicle, particularly in the context of EV batteries and drive modes (7.2), is needed. Consistency between the BR and the ELVR needs to be ensured with clear roles and responsibilities between the different actors of the value chain (battery and vehicle manufacturers, second-life manufacturers, end-of-life operators).
- When regulating the removability and replaceability of EV batteries, safety and appropriate qualification considerations is a priority. Batteries removed from vehicles need to be directed to the right recycling channels to be treated in line with the BR.
We would also encourage co-legislators to consider:
Legacy substances dilemma: The question of whether legacy substances can be used as recycled content must be addressed in a future-proof manner. The regulation needs to anticipate the potential time gap and regulatory changes between the production of EVs and their end-of-life phase. This will help mitigate contradictions between what automakers are required to do and what must be accomplished when permitted recycling facilities receive ELVs.
Beyond the proposed regulation, we would also welcome incentives for consumers to further drive the market to ever more sustainable EVs.
Incentives for low-carbon materials: Similarly to the BR, the revision should be leveraged to incentivise the use of low-carbon materials and processes. While we support the introduction of targets for producers and public procurement provisions to increase the use of low-carbon materials such as steel and plastics to drive ever more sustainable EVs, those targets should be accompanied with incentives for producers. Beyond the proposed regulation, we would also welcome incentives for consumers to further drive the market to ever more sustainable EVs.
[1] Reusability, Recoverability, and Recyclability
Solutions for a smooth integration of e-mobility into the grid
Energy & Infrastructures
Solutions for a smooth integration of e-mobility into the grid
Fifteen policy recommendations for sustainable governance and development of the power grid in front of the electric vehicles uptake.
As the adoption of electric vehicles (EVs) increases, it becomes imperative to step up our efforts to achieve their seamless integration – and related charging infrastructure – into the existing power grid. While the development of electric mobility is a significant asset to a clean energy system, it nevertheless raises questions over the management of power grids and connected charging infrastructure.
Some 60% of the EU car fleet has access to off-street parking space at home, and ‘unmanaged charging’ can create substantial peak loads. To a greater extent than passenger cars – which would only require a manageable 40kWh/week on average – the electrification of heavy-duty vehicles is a modality that requires specific attention. We have therefore dedicated a specific paper to this topic This current position paper aims to offer recommendations and potential solutions for ensuring that the development of the power grid is consistent and aligned with the growth of electric transportations of all modes.
There are many topics to consider under the heading of ‘e-mobility and the grid’, and this paper will present a succinct overview of a number of them. This will be followed by more in-depth papers on selected topics.
I. Communication, Coordination and Collaboration
1. Collaboration to reduce uncertainties
One of the main challenges in planning the electrical grid in a way that can absorb EV charging infrastructure lies in the uncertainty that surrounds how different types of EVs will recharge in different places. This also makes it difficult to assess needed investments. These uncertainties can be addressed through cooperation, knowledge-sharing, and effective planning.
Early coordination between stakeholders is key to success. Coordination around how charging infrastructure is deployed will ensure convenience and cost-effectiveness for users. We therefore recommend close cooperation between policymakers, regulatory authorities, energy companies, flexibility service providers, fleet managers, charge point operators (CPOs) and – most importantly – Distribution System Operators (DSOs). Such collaboration will benefit all parties.
In practise, this collaboration should:
- Be initiated and moderated by public and regulatory authorities
- Assess the grid in advance – even before any connection requests – and prioritise the flexible use of the grid
- Recommend reinforcing network components, should any overload be anticipated;
- Foster communication with municipalities to address network construction requirements when connecting charging stations
- Streamline the permitting and connection process.
2. Formalising this collaboration through ‘EV charging Blueprints’
It is important that this stakeholder cooperation also produce a state of play in the form of ‘Blueprint for recharging infrastructure’.
Adopting a ‘Blueprints for recharging infrastructure’ approach would help local authorities ensure an organised, planned and coordinated deployment of charging stations. This document – defined by local authorities and designed in consultation with the relevant stakeholders (in particular DSOs) – will comprise the local planning rules for implementing recharging infrastructure in main highways, national roads, and urban areas, including suburbs, could offer a solution. The ‘Blueprint’ would assess charging infrastructure required (such as the number of points to be installed, their location, their power and the types of socket), taking into account both the existing publicly accessible infrastructure and the existing and expected private charging infrastructure.
From the public authorities’ side, local authorities can leverage these ‘Blueprints’ in their Sustainable Urban Mobility Plans (SUMPs) as relevant tools for promoting cooperation and engagement with DSOs and CPOs in the short term. When fully deployed, SUMPs enable an iterative approach with DSOs and other economic actors from the outset, allowing for proactive planning and network development in the short, medium and long term.
3. Coordination & system governance changes needed at all levels
In order for the European regulatory framework to evolve in a way capable of supporting grid optimisation and investment in a coordinated manner, there should be discussions between all regulators at EU level, as well as between the Council of European Energy Regulators (CEER) and the Agency for the Cooperation of Energy Regulators (ACER). The former should be encouraged to act, and the latter to update network codes as needed (see further details below).
4. Implementing existing EU legislations
However, until EU coordination can be established, the work required should be undertaken at national level. This national level work includes the proper implementation of existing articles of legislations, such as the Electricity Directive of 2019 (notably its Article 32, which incentivises flexibility procurement by DSOs), the recently adopted Renewable Energy Directive and the reform of the Electricity Market Design, which should be adopted soon and strengthen the existing legislation.
II. Support for Network Operators and grid infrastructure
5. Improve effectiveness of Network Development Plans for EV integration
With the aforementioned coordination and advance information sharing, network development plans – which not least for charging infrastructure for battery trucks are ineffective – can be vastly improved. National governments must be reminded of their responsibilities – most notably those set out in the Alternative Fuels Infrastructure Regulation (AFIR) – to enforce these regulations effectively.
Member States, via their National Regulatory Authorities (NRAs) and involving market parties, should make sure – and even encourage – DSOs and TSOs to plan and invest in anticipation. This should be under the supervision of the energy regulator, prior to connection requests for charging infrastructure and should also take into account flexibility options into account.
6. Resources and digital solutions to support DSOs
Many DSOs lack the digital infrastructure to implement solutions that would facilitate and simplify the EV charging connection process. The gaps include:
Digital connectivity between DSOs and CPOs, for the purpose of transparently sharing available grid capacity (for charging). Enhancing transparency offers a crucial advance that could optimise the charge point deployment procedure. A substantial number of charge points are still awaiting installation in a number of countries, as a result of a lack of available information to CPOs on existing capacity. While some DSOs do provide heat/capacity maps, which enable CPOs to plan their deployments accordingly, the majority do not. Generating such maps would significantly enhance the overall process. In addition, there should be:
Digital Ticketing Systems, so that applicants can know the status of their grid connection request and timeframe for replies. Digital and automatic tools, which could give historic information on the connection of charging stations in different locations (map-based).
7. Establish cross-functional working group within the DSOs
Coordination and knowledge sharing is also essential within the network operators, in order to share expertise and project information across departments, for example. Therefore, DSOs should establish a cross-functional working group within the DSO to address any issues relating to charging station connections.
8. Proactive, anticipatory grid investments required
While private EVs will represent only a fraction of the total grid investment required by 2030, European distribution grids will still require substantial investments[1] to be able to support e-mobility and to integrate EV charging infrastructure. As DSOs are regulated entities, there must be an adequate regulatory framework established in each country that would allow proactive, anticipatory investments in the grid. This could be on the basis of a small fee approach.
Inspired by the UK’s Green Recovery Scheme managed by Ofgem, there should be European funding mechanisms established to enable DSOs to apply for funds specifically for grid reinforcements for EV charging. Moreover, investments should be made not just in grid expansion but also reinforcement, modernisation, efficiency and flexibility.
DSOs should be empowered to initiate initial investments that follow with incentives and proper business model to plan ahead. The market needs to develop incentives for the timing of necessary upgrades.
9. Promote local energy hubs through smart regulation
The impact of local electricity consumption for clean mobility can be mitigated, if it is matched with the local energy generation connected and delivered through the grid through smart management of consumption and generation. Building on the energy-sharing Article 15a in the revised Electricity Market Design, this has the dual potential to facilitate grid integration, while increasing direct consumption of clean energy. Realising this dual potential would require valuing ‘energy hubs’, where local consumption is matched with local generation.
10. Invest in and implement smart and flexible solutions
Smart and bidirectional charging can play an important role in optimising the grid integration of EVs, as well as alleviating their impact during peak hours. Thanks to smart meters – in synergy with dedicated measurement devices – the needs for, and costs of, network capacity reinforcement can be minimised and the deployment of new charging points optimised, by providing information of the relevant distribution network parameters. Likewise, it would help flattening load peaks. This would ultimately reduce the carbon intensity of the energy system and alleviating the impact on the distribution network.
As non-wire technologies[2], smart and bidirectional charging enable the application of the Energy Efficiency First Principle. Indeed, by using already existing technologies, whose initial purpose lies somewhere else, we avoid expensive investment in new capacity.
The benefits of such service are even more striking when EVs are turned into energy storage assets that can return power to the grid through bidirectional charging. This allows for grid balancing, thus boosting grid reliability and stability while lowering the charging cost for consumers. EV charging can also be aligned with local renewable energy production and electrical solutions, such as heat pumps in buildings. Last, much greater amounts of electricity can be moved via existing cables by deploying optimisation tools such as dynamic line rating.
11. Reform of grid connection agreements between (D)SOs and CPOs
To enable flexibility, smart charging and bidirectional power transfer at scale will require smarter grid connection agreements between DSO and CPOs. In particular, in those cases where market-based alternatives for congestion have been shown by the NRA to provide insufficient volumes (in line with article 32 of the Electricity Directive), flexible grid connections should be considered. This will allow for flexible and time-bound contracts or for capacity contracts where the contracted transport capacity is partially or not guaranteed. Such an approach can be implemented in various ways, for example through a so-called ‘non-firm Connection and Transport Agreement’ or via other flexible agreements.
Clear conditions, to guide consumers, operators and system operators on their rights and responsibilities, are required.
Alongside grid connection agreements, dynamic network charges can assist the adoption of flexibility. These would allow flexible solutions, such as smart vehicle charging and other demand-side measures, to play their part in solving grid congestion.
[1] 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
[2] Technologies which do not need any grid, Capex investments or more material to install.
III. Market models and rules to foster smart & flexible EV charging
12. Market models to incentivise consumers and Charge Point Operators
To provide the required flexibility for the energy system, proper market models and regulatory frameworks are needed. Flexibility first requires a regulatory-friendly business model, given the scale of the deployment. While the technology of smart charging is already being developed and recognised within the EU legislative framework, bidirectional charging – despite its considerable potential – still encounters many hurdles hampering its proper development.
Governments, system operators and market regulators must recognise both technologies as beneficial for grid stability, instead of seeing them as beneficials for consumer and as a generator. Fostering a functioning market model will incentivise operators/aggregators to ensure that flexibility is offered on a large scale. Flexibility market demands should be driven by the value they bring both to the consumer and the energy system as a whole, not by technology or capabilities. Adopting market models where flexibility plays an important role will only become a reality if consumers see clear benefits or receive incentives to participate. Without clear rights and conditions for both CPOs, System Operators (SOs), FSPs and consumers, market models will not develop at scale, and consumers will not feel incentivised to participate in flexibility. This results in a small market where flexibility, V2G and grid support will not be adopted, and grid integrations would remain local initiatives without perspectives at scale and harmonised roll out. In this sense, as already mentioned, it is paramount that Member States swiftly implement the 2019 Electricity Market Design and to already prepare the new changes brought by the current revision of the EMD, which will further strengthen such friendly business models.
IV. Standards to ensure proper functioning of the grids systems
13. Standardise and integrate technologies
Smart metering[1], or at minimum dedicated measurement devices, are necessary at the DSO side for grid state information and to measure levels of flexibility delivered. Meanwhile, smart charging technology is required at the CPO side for adapting the charging power and the digital connection between DSO and charging infrastructure. The development of both technologies – smart metering and smart charging – requires standardised and transparent procedures to facilitate connections for CPOs. In addition, it needs future-proof communication standards in EVs and in energy management systems, charging infrastructure and building energy management systems.
This requires simplified conformance testing and compatibility checks, by means of a harmonised certification on the side both of EVs and charge points. The existing regulatory connection requirements from the ACER may require readjustment to align with current technology. It is important to acknowledge and address obstacles arising from technological limitations.
14. Update network codes
To ensure that EVs and their flexible capacity are able to be integrated into grids, it is important to adopt EVs in EU based grid codes, starting with the amendments to the Grid Codes RfG (requirements for Generators) and the new Grid Code Demand Response. It is also important to adopt them in EU grid codes so that SOs and Member States adopt and embrace EVs and corresponding charging point in harmonised rules and regulations.
We also call on legislators to pay particular attention to the revision of the Network Code RfG and the new grid code on Demand Response, taking into account the requirements for V1G and V2G in the grid codes.
15. Workforce development
To guarantee that these measures are truly effective, energy companies and relevant stakeholders must be supported in their efforts to develop jobs and skills required to manage the grid and the install charging points. Thus, a comprehensive framework also requires addressing this shortage of skilled and certified workers.
To improve the attractiveness of these jobs and to promote the available training and retraining offers, the EU institutions and Member States should undertake a mapping of skills shortages. This should consider both traditional and new skills. That way, we can assess the needs for jobs and skills in each sector, developing tools to identify and publicise available training, and highlight those that need to be created. Practitioners from CPOs and DSOs should be involved in organising training programmes funded by national and regional funds. Last, national and regional communication campaigns should be highlighting attractiveness of these sectors.
[1] Smart meters in particular, as one of the solutions allowing smart charging, play an important role in grid management optimisation and flexibility services promotion. The combination of both technologies could provide the system with the necessary data to manage more efficiently the charging process and, thus, reducing the impact on distribution network. Dedicated measurement devices can complement smart meters by providing more data granularity for demand response and flexibility purposes, or substitute them in the situation where a consumer does not have one.