Bidirectional charging : let's avoid double taxation for EV owners
Energy Taxation Directive
Ensuring fair taxtion for EV owners providing flexibility to the grid
By purchasing more and more electrified assets, which can produce, store, or send electricity to the grid, consumers are actively participating in the energy transition. In the transport sector, Electric Vehicles (EVs) is the mean to decarbonise the sector. However, more than mere transport assets, EVs can become energy assets, ‘battery on wheels’, if they unleash their flexibility, providing benefits to the consumers and to the grid.
How? With smart and bidirectional charging. Smart charging goes in one direction and enables adjustment to the charging process depending on external signals. Bidirectional charging – also known as V2X (‘vehicle-to-everything’) goes a step further and allows the vehicle to exchange energy with the connected asset (grid, home, building) in both directions, as well as charging or discharging for as long as it is plugged in. This means that the vehicle can offer services for a longer timeframe, as unidirectional charging stops once the battery is full.
One barrier which deter the uptake of bidirectional charging schemes and similar flexibility services in the Member States is the possibility of double taxation in the current version and under the proposed revision of the Energy Taxation Directive (ETD). On the EV owner side, such double taxation disincentivises the use of bidirectional charging because it costs the driver twice as much to essentially not use the energy that is back-fed to the grid. It also hampers the development of prosumer business models supporting the active contribution of consumers in providing flexibility services to the system. On the energy supplier side, this creates unnecessary administrative burden.
Thanks to bidirectional charging capabilities, the electricity can flow between the EV battery and the grid multiple times between the moment the EV is plugged and the one when the electricity is consumed for driving. Having to track the amount of energy transferred and calculate the tax on each transaction must be avoided to prevent hindering V2G services: taxes and tariffs should be applied exclusively on the amount of energy actually exploited by the final user, by means of proper metering.
We therefore propose the following change to the current ETD proposal, to ensure these ambiguities are addressed directly in the legislation:
Proposed amendment:
Art. 22.4: …For the purposes of the first subparagraph, electricity storage facilities and transformers of electricity may be considered as redistributors when they supply electricity. Active customers (as defined in Directive (EU) 2019/944 Art. 2(8)), including electric vehicle or battery owners participating in bidirectional charging schemes and other customers providing flexibility services to the grid, shall be exempt from taxation on unused energy which they reinject into the grid.
Current proposal text:
Art. 22.4: …For the purposes of the first subparagraph, electricity storage facilities and transformers of electricity may be considered as redistributors when they supply electricity.
Our Contribution for an e-mobility friendly taxonomy
EU TaxonomyRecommendations for an e-mobility friendly Taxonomy
The members of the Platform for electromobility, which brings together more than 40 members from across all transport modes, are fully committed to promote sustainable mobility solutions and contribute to the on-going European green transition.
The Platform welcomes the EU’s initiative to establish a European Taxonomy to classify economic activities and direct public and private funding towards sustainable investments. This will be essential to achieve the ambitious climate targets of 2030 and 2050 set by the European Green Deal and the Sustainable and Smart Mobility Strategy . As transport is responsible for 27% of emissions at EU level, the European Taxonomy will play a key role in informing investors on sustainable transport activities and guiding decisions towards green investments.
Following the first reporting exercise of 2022 and the Commission’s intention to focus on the “usability” of the published Taxonomy delegated acts, the Platform would like to relay a number of observations commonly shared by its members representing the whole electromobility value chain.
- Some of the key players in the e-mobility value chain, such as the main suppliers, do not necessarily have all their economic activities covered by the taxonomy categories included in the climate delegated act, despite their significant contribution to the manufacturing of more sustainable products (BEVs, trains, etc.). This is mainly due to the fact that the taxonomy categories mainly focus on the activities of the OEMs and not necessarily on the activities of upstream suppliers[1].
- The Platform’s proposal would be to allow suppliers and subcontractors to disclose their activities in the same category as the corresponding OEM activity, particularly where these upstream activities supply single purpose technologies to be used exclusively in taxonomy-aligned assets. This would better reflect their real contribution to sustainable products, while encouraging sustainable financing of the entire electromobility value chain segments
Most of the transport activities are largely covered by the first Climate Delegated Act. Therefore, a number of companies are already preparing to report on the Taxonomy-alignment from 2023. In order to carry out this exercise, the Platform would welcome clarification on the interpretation of the Do No Significant Harm principle (DNSH) criteria on pollution and in particular on the use of substances (listed in Appendix C). These raise usability concerns, because of the difference in scope of the pieces of legislation referred to in Appendix C (notably REACH and RoHS) and the requirements of that appendix. In particular, the concept of essential use not defined in EU legislation may lead to differences in appreciations by economic operators. As a result, the information available to taxonomy users may be lacking.
- In order to avoid difficulties in proving alignment with the DNSH criteria and differences in the implementation thereof, the Platform calls for the Commission to ensure that the information gap is bridged.
- A number of delegated acts and derived documents (e.g. FAQs,) were published well after the adoption of the taxonomy regulation, even though the first eligibility reporting exercise for activities covered by the climate delegated act was required in 2022.
- The Electromobility Platform requests the stakeholders to be given appropriate time to prepare for the reporting and to have all the necessary clarifications and interpretations to fully implement all three sets of alignment criteria (substantial contribution, DNSH and minimum safeguards).
- The EC considers that the largest part of investments to complete the Trans-European Transport Network (TEN-T) is estimated to originate from public funding (national public funds, EU funds) and would amount to €244.2 billion over 2021-2050. However, to complete the core infrastructure of the TEN-T for all modes of transport, €750 billion between 2016 and 2030[2] is required. Considering the public funding contribution will cover only a limited part, a massive private investment injection will still be needed to complete the TEN-T infrastructure and achieve decarbonization objectives in the coming years.
- The Platform’s calls the European Commission to ensure a full taxonomy eligibility of electromobility members’ economic activities in order to preserve the future required investments for the e-mobility sector.
All these elements should be taken into account when amending the existing delegated acts and adopting future delegated acts & FAQs. In particular, these considerations should enhance the positive signal of the Taxonomy for electromobility technologies, which will contribute to decarbonising transport, at a time when the Green Deal objectives need more than ever to be accompanied by a coherent Taxonomy framework to finance the transition.
[1] Sometimes the NACE codes included in the Climate Delegated Act appear to be not entirely exhaustive and sometimes even misleading. [2] According to the latest Core Network Corridor Work Plans,
The added-value of electricity for mobility
The added-value of electric mobility
Platform for electromobility Statement on the Plenary vote on AFIR
As the AFIR prepares a solid legislative basis for the decarbonisation of transport in the next years, it is important to support only clean solutions and to refuse the usage of fossil fuels. An increasing penetration of e-mobility also implies a demand-reduction for fossil-fuel, that are mostly imported from instable regions, and thus higher security of supply. The European Union should be very cautious with the list of alternative fuels. Fossil fuels cannot be alternative fuels and must remain transitional with a concrete specification of their end date.
Thus, electric mobility is the most satisfactory option and should be supported in the AFIR by a strong set of targets for charging infrastructure. Here are the 4 main reasons:
Ensure energy efficiency
BEVs are the cleanest and most efficient types of powertrains for individual vehicles (T&E, 2022). Electric cars for road transport are far more energy efficient (85-90% efficient) than ICE cars (17-21%). Regarding natural gas for vehicles (NGV), 30m3 of natural gas, converted to electricity, yields 735km in an EV but 580 km in an NGV vehicle (MIT, 2010). In terms of the rail sector, it accounts for just 2% of total EU energy consumption in transport (Commission, 2021), being the most energy efficient transport mode (T&E, 2022).
Improve air quality
Road transport is a major source of air pollution in European cities. In 2019, 307,000 premature deaths were attributed to chronic exposure to fine particulate matter (PM). 40,400 premature deaths were attributed to NO2 exposure (European Energy Agency, 2021). In comparison to other technologies, electric vehicles produce no exhaust emissions. EVs are estimated to emit 20% less PM10 from non-exhaust sources per kilometre than internal combustion engine vehicles (ICEVs) (OECD, 2020) . Modal shift and the use of urban electric rail can improve air quality. In Europe, the rail sector’s share of total Nitrogen Oxide (NOx) and PM emissions of transport is respectively 3% and 4,5% (UCI, 2018).
Integrate renewable energy into the grid
Battery-on-wheel solutions, like bidirectional charging, can facilitate the integration of renewable energy to the electricity system. The combination of EVs, their batteries and smart charging functionalities as sources of ancillary services for the electricity grid will clearly bring benefits in terms of RES (Renewable Energy Sources) integration.
Reach climate neutrality
Electric cars and trains are the only available technology to reach climate neutrality. Full life cycle emissions of electric cars in Europe emit, on average, more than three times less CO2 than equivalent fossil fuel cars (Transport & Environment, 2022). Rail accounts for less than 0,4% of transport related greenhouse gas emissions in the EU (Commission, 2021).
Our Position Paper on the revision of the HDV CO2 emission standards
CO2 Standards for HDV
Our position ahead of Commission's proposal
The Platform for Electromobility strongly welcomes the revision of the CO2 standards for heavy-duty vehicles (HDV). The Platform sees the Regulation as a fundamental tool for electrifying trucks and thus advancing the zero emission transition within the road freight sector. Currently, this sector is responsible for 24% of the EU’s transport emissions, with trucks making up the largest part. The revision of HDV CO2 standards should align the CO2 targets for the sector with those of the EU’s overall 55% GHG reduction target in 2030 and the climate neutrality target of 2050.
In order to transition the road freight sector to zero emissions, more ambitious standards are needed to set the correct pace and a clear trajectory for manufacturers, logistics operators and for the supply chains in the electromobility and automotive industry. Scaling effects in production and technology development in the e-mobility and transport sector all contribute to making electric HDVs more competitive and widespread.
The Platform calls upon the European Commission to adopt the following recommendations as part of the revision of the HDV CO2 standards:
Strengthening the emission reduction targets to fully decarbonize the sector by 2050.
- Almost all newly registered HDVs (including long-haul) should be 100% zero emission by 2035 at the latest, given the average lifespan of a truck of approximately 15 years.
- An exemption should be considered for some niche vocational vehicles (such as those operating in remote areas or of abnormal weight) with a 100% Zero Emission Vehicle (ZEV) target by 2040, due to their more complex operational requirements and usually significantly lower mileage, which postpones the year of cost parity for the total cost-of-ownership for those vocational vehicles.
- The introduction of an intermediary CO2 target in 2027 of 30% for medium and heavy lorries is necessary to accelerate the transition to electric trucks during the 2020s.
- Strengthening the ambition of the 2030 CO2 target is crucial in providing momentum to, and further scaling up, the production and sales of ZETs. The 2030 target should be increased to an emission reduction level of at least 65%.
Extend the scope of the regulated HDV categories.
- Medium-sized lorries should be regulated through CO2 reduction targets, with the interim target of 30% in 2027 and the 2030 target of 65%.
- Small lorries – as well as urban buses and coaches – should have a mandated ZEV target, as they are not included in either the VECTO monitoring, or the datasets are deficient and hence have no CO2 reduction targets.
- The Platform recommends including small lorries with a ZEV target of 35% in 2027 and of 70% by 2030.
- Urban buses can decarbonise faster, and hence 100% of these should be ZEV by 2027. [1]
- Finally, coaches will transition a bit slower – due to the different vehicle design – with 20% ZEVs by 2027, 60% by 2030 and 100% by 2035.
- Trailers and semi-trailers will benefit from the introduction of energy efficiency targets, as this will unlock the deployment of zero-emission long-haul tractor-trailer combinations. The targets should be set where technically and practically feasible and as early as 2027. The full energy-efficiency potential of 12% for long-haul and 8% for regional delivery should be reached by 2030.
Other regulatory elements.
- The zero or low emissions vehicles (ZLEV) mechanism should be transformed into a ZEV-only mechanism with an enhanced benchmark of 15% by 2027. After 2030, the benchmark mechanism should be removed.
- The possibility of pooling of resources should be explored in the impact assessment, next to the introduction of a straight credit-trading scheme, which might allow for greater flexibility and less regulatory barriers.
- There should not be an exemption for small-volume manufacturers, as it risks creating a loophole for continuing to produce ICE-powered trucks.
- There should be no mechanism for renewable and low-carbon fuels to be included under this Regulation. Under such a mechanism, manufacturers could continue to produce ICE-powered trucks and delay the transition to ZEVs whilst not actually being able to control how fuels are ultimately being used (yet still being rewarded for it).
Ambitious charging infrastructure targets, as discussed in the Alternative Fuels Infrastructure Regulation (AFIR), are elementary for a successful rollout of ZETs. In addition, private as well as public investments will be needed to ensure higher grid capacity to serve the growing truck-charging demand. The revenues from excess emission premiums should be channelled back into the sector for the rollout of the infrastructure network. Related files, such as the Energy Performance of Buildings Directive (EPBD) can act an enabler for a smooth deployment of electric trucks. The platform therefore recommends including infrastructure requirements for charging at depots and logistic hubs.
Investing in the reskilling of workers is essential, both for those currently employed in HDV manufacturing and therefore see a conversion of current skills, and new ones who will be increasingly specialised in the new production value-chain. It can reduce social risk and increase workforce resiliency. Other measures such as job-search assistance for jobseekers and income and early retirement support could make the transition more just and fair.
The positive effects of electrifying heavy trucks are far-reaching, and go beyond reducing Europe’s GHG emissions; accelerating the zero-emission truck roll out also allows for drastic improvements to noise and air pollution. The high increase of energy efficiency in the case of battery-electric trucks is particularly beneficial when road transport accounts for 29% of the EU’s final energy consumption. The Platform for Electromobility also wishes to highlight that the transition to electric trucks and buses provides a considerable opportunity for the European e-mobility value chain and the competitiveness of the economy. Ambitious targets would make Europe a leader in zero emission HDVs and thus accelerate the unlocking of the potential of the e-mobility value chain.
[1] UITP is currently still considering its alignment with this objective.
Statement on EP ITRE Committee on RED ahead of Plenary vote
Renewable Energy Directive
Our statement ahead of Plenary vote
The Platform for electromobility is pleased to see the progress established by EP ITRE Committee on the recast Renewable Energy Directive (RED). This revision represents an unmissable opportunity to achieve two strongly related public policy objectives: accelerate the transport sector’s transition towards zero emissions and modernize the current legislative framework for renewable energy as a whole, and more specifically for Europe’s transport system.
With the European Parliament scheduled to formalize its position on the file in mid-September, the Platform would like to shed the light on some elements that could improve the EP’s position:
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Include private charging in fuel neutral credit trading mechanisms
The Commission’s proposed EU-wide requirement for Member States to set up a fuel neutral credit trading mechanisms is highly welcome. However, the mandated credit system, as established by art 25(2), should not, as it would as the text stands, limit the scope of this new system to public charging points only. Any charging points should be allowed for inclusion under national credit mechanisms. Limiting the scope of the credit mechanism at EU level to public recharging stations will lead to inefficiencies and distortions, and affect the deployment of charging infrastructure. The ITRE Committee has gone in the right direction, leaving the option for Member States to set up their system in the way they see best fit, including a voluntary inclusion of private charging.
Given that the vast majority of EVs in the EU (>70%) will be charged at home or at the workplace, the Platform believes a stronger wording is needed, namely expressly including private recharging stations in the mechanism.
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Ensure appropriate energy efficiency ratios regardless of accounting methodology
The current RED allows countries to choose between setting transport targets based on energy volumes/content or GHG emission reductions. Contrarily, both the Commission’s proposal and the ITRE Committee Report call Member States to set targets based on GHG reductions only, in clear countertrend compared with the 24 out of 27 Member States currently using an energy-based system. With this new proposed accounting methodology comes the deletion of the existing “multiplier system” or ‘Energy Efficiency Ratio (EER)’. The multiplier or EER accounts for the superior energy efficiency of renewable electricity, and is currently set at 4 for electricity. The mandate for the new transport targets does contain an “implicit” EER, i.e. a different fossil fuel baseline.
Nonetheless, as Member States are expected to push for maintaining the flexibility to choose between GHG- or energy-based targets, it is crucial to maintain an Energy Efficiency Ratio (EER) of at least 4 regardless of the accounting methodology used (in case a member states chose to keep an energy-based system or the current proposed implicit multiplier in case of GHG emission reductions system), reflecting the fact that EVs are between 4-5 times more efficient than internal combustion engine cars (“well to wheel” efficiency) powered by any renewable fuels.
Hence, the Platform believes that, while it would be welcomed to maintain flexibility for countries to choose their accounting system, appropriate EERs should be kept ensuring that direct electrification is able to compete on a level playing field.
Let’s not let 40% of EV batteries go missing!
End-of-Life Vehicle DirectiveOn how the End-of-Life of Vehicles Directive revision can make the uptake of EVs faster and more sustainable.
For Europe to become carbon neutral by 2050, road transport needs to be entirely decarbonised by this date. Considering the average retirement age of petrol and diesel vehicles in Europe (around 15 years), the Platform for Electromobility believes that an EU-wide phase-out date for sales of new pure internal combustion engine passenger cars and vans no later than 2035 is necessary to achieve this objective with a clear emissions reductions trajectory.
Last year, the sales of new BEV accounted for 5.3% of the total (1). In other words, European market will need to grow from 530.000 battery cars today to around 16 million in less than 15 years.
Considering that to produce the corresponding amount of battery cells will require huge quantity of critical raw materials. There are several critical raw materials for which these market requirements mean a significant challenge. For example, major manufacturers (2) have already announced they will not use Ni in their entry level models. On average, it takes 10 years from taking the internal decision to have a new mine in operation. Accelerating the recycling capacities is therefore key for the deployment of accessible and sustainable electric vehicles (LDVs and HDVs alike).
Yet, in 2014, 4.66 million end-of-life vehicles (ELV), representing 39% of the total vehicles being decommissioned, were at ‘unknown whereabouts’ (3). From 2007 at least, the ‘unknown whereabouts’ share has remained at a constant level4. The two main elements that explain most of the issue with ELVs at ‘unknown whereabouts’ are vehicle dismantling at illegal sites, and exporting of ELVs outside of Europe as used cars.
Consequently, it’s of key relevance for the deployment of electromobility and to reach 2030 and 2050 EU climate goals not to spoil 39% of used batteries from future EU battery ELVs. Reinserting those ELV into the recycling system will reduce the stress of primary production as well as cost impact and a potential slowdown of the BEV uptake by lack of affordable materials.
While it is true that vehicle registration procedures are the national competence of the Member States, each EU legal act has to comply with two fundamental principles laid down in the Treaty on European Union, proportionality and subsidiarity. The content and scope of EU action may not go beyond what is necessary to achieve the objectives of the Treaties. Also, given that transport is a shared competence, the EU may act only if — and in so far as — the objective of a proposed action cannot be sufficiently achieved by the EU countries, but could be better achieved at EU level.
As Member States have not been able to reduce since 2007 the number of ELVs at unknown whereabouts, the Platform for electromobility proposes to introduce the following dispositions in the revised ELVD:
- Registering any road transport vehicle – including heavy-duty – when the owner is a resident (or registered company) in that Member State will have a large and cost effective impact on reducing the amount ‘unknown whereabouts’. By doing so, vehicle owners will face at least two payment obligations (i.e. insurance and Periodical Technical Inspection – PTI). Owners will therefore be incentivised financially to send the vehicle to an authorised treatment facility (ATF) when it reaches its end of life and therefore avoid those costs.
- Provide necessary safeguards to avoid as much as possible temporary deregistration that currently causes loopholes and increase the amount of ‘unknown whereabouts’
- In case of sale in the same Member State, or change of ownership (typically to its insurance company), the new owner will have to be updated in the vehicle registration system.
- It will only be possible to deregister a vehicle under one of the following circumstances:
- Destruction, after presenting a certification of destruction (CoD) issued by an ATF.
- Export within the EU, after presenting the certificate of having been registered in the second Member State.
- Export outside the EU, after presenting the customs declaration for export.
- Theft, after presenting the police report. If the vehicle was recovered, the vehicle will beregistered again to its legitimate owner.
- Additionally, it should be made compulsory to have a valid roadworthiness certificate for a vehicle to be exported outside EU as used car.
To achieve the ambitious but necessary objective of decarbonizing road transport by 2050, transport must be seen holistically and therefore all upcoming legislations should, like the End-of-Life of Vehicles Directive revision, should consider needs that a fast and sustainable uptake of electromobility requires.
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1 https://www.eafo.eu/vehicles-and-fleet/m1
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2 VW Power Day and Tesla Battery Day
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3 https://ec.europa.eu/environment/waste/elv/pdf/ELV_report.pdf. In the Assessment of the implementation of Directive 2000/53/EU on end-of-life vehicles, is defined the term “ vehicles of unknown whereabouts”: vehicles that are deregistered but without a Certificate of Destruction (CoD) issued or available to the authorities and also with no information available indicating that the vehicle has been treated in an Authorized Treatment Facility (ATF) or has been exported.
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4 http://ec.europa.eu/environment/waste/pdf/target_review/Final Report Ex-Post.pdf
EV Charging: how to tap in the grid smartly?
EV Charging :
How to tap in the grid smartly?
With a market penetration of 10% in Europe in 2021[1], and with a purchase price and total cost of ownership outperforming that of the internal combustion engine (ICE) before the end of 2027[2], the take-up of electric vehicles (EVs) is expected to accelerate significantly in the coming years. The widespread electrification of transport is the most efficient way to reach Europe’s climate objectives for the sector. Challenges may lie ahead, but smart charging must not be overlooked as the main asset for overcoming these hurdles.
A critical mass of EVs on the market will impact electricity consumption patterns and create an overall increase in electricity demand, particularly during peak-time periods. Smart charging can be a crucial tool for increasing the adoption rate of EVs, by mitigating the stress on the grid and supporting the transition towards sustainable electricity; each connected EV helps reduce CO2 emissions further. Smart charging can reduce CO2 by an estimated annual 600,000 tons by 2030, through the greater integration of renewables in the grid.[1]
With the electrification of usages, a rapid increase in decentralised and local loads could – if not managed correctly – overstretch the current low-voltage distribution grids, particularly in residential or commercial areas[2]; smart-charged EVs provide a solution. Bidirectional charging and other flexible services – where appropriate – can also provide solutions and benefits, both to the grid and to the end-user (of the grid and of the vehicles), and should not be overlooked.
The Platform for electromobility therefore welcomes that the ‘Fit for 55’ package recognises the importance of smart charging for integrating transport in the energy system but we encourage more robust and consistent support for smart charging throughout the package. In order to unlock all the benefits smart charging can deliver to the electricity system, to EV users, to the environment and to society at large, the following considerations should be respected in a coherent manner throughout all relevant legislative files.
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What should be classified as smart charging?
Definitions of smart charging differ between legislations. Indeed, different levels of ‘smartness’ are possible, depending on the business solution deployed and the level of involvement of the consumers. The Platform for electromobility believes that charging installation should be considered smart if:
- it provides real-time adjustment
- it adjusts charging in response to external signals
- the adjustments give additional clear benefits to the EV driving consumers, providing flexibility to the grid.
Bidirectional charging comes to complement smart charging services. While unidirectional charging enables adjustment to the charging process depending on external signals, bidirectional charging – also known as V2X (‘vehicle-to-everything’) goes a step further. It allows the vehicle to exchange energy with the connected asset (grid, home, building) in both directions, as well as charging or discharging for as long as it is plugged in. This means that the vehicle can offer services for a longer timeframe, as unidirectional charging stops once the battery is full.
What are the benefits of smart and bidirectional charging?
Flexibility services are a vital enabler for grid management in the energy system of a carbon neutral Europe, and smart charging can play a crucial role in delivering this flexibility. New and refurbished charging installations (public and private) should therefore be smart.[1] The timeframe for a potential eventual retrofit of existing stations should be defined through a comprehensive impact assessment, coordinated with the stakeholders of all affected sectors and Member States. Such an impact assessment will allow a comprehensive overview of the requirements for retrofitting, and will therefore optimise both the cost and the deployment of smart charging points.
- Smart charging will have a key role for the user in:
- Empowering consumers in the energy transition, by transforming electric vehicles into an energy asset.
- Taking full advantage of low electricity prices in the system for consumers and reduce the consumer’s bill of electricity (savings are estimated between €60 and €170 per year[2]).
- In the heavy-duty vehicle (HDV) segment such as e-buses, smart charger capability offers the possibility to optimise the charging process according to the e-bus’s schedule, managing the allocation of the available power at charging depots (e.g. identifying and setting different priorities and criteria for charging the vehicle based, for example, on the order of arrival, departure-time priority, etc.).
- Smart charging will have a key role for the grid in:
- Increasing system efficiency, by integrating the road transport sector into the energy system. This will optimise the use of the electricity grid and reduce the investments required in the power grid (which could reach €375-€425 billion by 2030[3]) compared to those of unmanaged charging.
- Avoiding grid congestion, by lowering the load pressure and consequently enabling the more efficient integration of EVs into the power system.
- Taking full advantage of the availability of renewable electricity, therefore increasing the penetration of variable renewable energy within our energy system.
- Bidirectional charging could also have a key role for the user in:
- Empowering the consumer in the energy transition to an even greater extent, by transforming the electric vehicle into a ‘battery on wheels’.
- Taking full advantage, and in particular Vehicle-to-Home (V2H), of self-consumption while mitigating their exposure to high prices for customer exposed to dynamic tariffs.
- Selling back electricity to the grid to bring further significant financial benefits for the consumer.
- Generating further revenue streams for public transport operators and/or fleet managers, in particular in the case of depot charging, allowing reductions to the total cost of ownership and thus offsetting the cost of charging infrastructure while generating additional revenues.[4]
In addition, other technological innovations capable of bringing flexibility to the system in the future – as well as a proper determination of the correct balance between charging modes using a case-based approach – should not be ignored but rather be carefully considered.
How to make smart charging work?
An enabling policy framework is needed to unlock these benefits and deliver them to both the electricity system and to society at large. The legal framework should be consumer-focused, consistent, future-oriented, and should allow appropriate reactivity, coordination and data sharing:
- Consumer focused: Any legal framework should create provisions that ensure that those EV drivers who provide flexibility by adopting smart charging solutions receive net positive effect for so doing. Consumer adoption is key to a successful implementation of smart charging technologies, and therefore should be made the central stakeholder.
- Consistent: Any definition and provisions set out in the AFIR, the REDIII and in the revision of the EPBD, should be both mutually consistent and consistent with energy directives in general, in line with the definition of storage. In particular, it will be essential to maintain consistency between the different definitions for smart and bidirectional charging. Furthermore, it will be vital that regulations consistently pursue a level playing field for smart charging and other technologies that provide flexibility to the grid. Consistency between legal definitions should also be ensured by avoiding overlap with the definition of ‘digitally connected stations’. To run the smart charging system in a coherent way, regulatory framework must also support the different actors of the eco-system to cooperate together, including OEMs, to optimize the benefits while ensuring that batteries are preserved.
- Future-oriented: A legal definition of smart charging should be sufficiently broad, and mention benefits without mentioning technicalities, so as to include future technologies.
- Reactivity: Smart charging should allow adjustments that are rapid enough to deal with grid disturbances and emergencies.
- Data: To ensure this necessary level of reactivity, smart charging requires access to information from the battery management system. On the basis of a contractual agreement, relevant and necessary data should be made available to vehicle owners and users, as well as third parties acting on their behalf.
- Cooperation: Smart charging needs the different actors of the eco-system to work together, including OEMs, to optimize the benefits while ensuring that batteries are preserved.
Our specific policy recommendations for smart and bidirectional charging
Incentives and support for the uptake of smart charging should be proposed, as it can offer a full range of additional services compared to regular charging. Bidirectional charging should also be encouraged when demonstrating the positive socioeconomic impact and creating a net benefit for the EV driving consumer who is contributing to the energy efficiency of the entire system.
The Platform calls for ensuring the consistency of the RED III with both the new Regulation on the deployment of alternative fuels infrastructure and with the energy performance of buildings directive (EPBD). The current definition of smart charging and bidirectional recharging should be aligned, and any changes to the related definitions and provisions in one text should also be made in the other.
The Platform welcomes the Commission’s recognition of the role of smart charging in the AFIR for enabling system integration. Improvements should also be made to support smart charging deployment. We therefore call for improvements to the requirements on smart charging (art. 2 and 5.8). You can read more details in our paper dedicated to AFIR here.
Time with the vehicle plugged: as important as using a smart charger: To realise the full potential of smart charging, the recharging points should be deployed at locations where vehicles park for extended periods of time. This allows the flexibility of choosing when to start and stop charging. At or near home is the main one, followed by the workplace. On average in EU, 60% of passenger cars have access to off-street parking at home, where is relatively easy to install a small charger. The other 40% of the car fleet will depend on the urban public infrastructure to recharge their batteries, as most of them won’t have access to a parking space at work.
On average, a battery passenger car in the EU consumes around 50 kWh/week. Three main prototypes of public recharging exist: high-power charge stations (equivalent to a petrol station), chargers in commercial areas (typically 22-90 kW) or chargers in residential areas (3.7-11 kW). High power chargers have limited flexibility. Here drivers usually seek the maximum power in the shortest amount of time possible In a commercial area, the vehicle will need between one to two hours a week, while in a residential area, the car can be plugged in for more than 12 hours a day (even more during weekends) replicating the use case of people with off-street parking at home. In other words, in residential areas, the vehicle can be plugged in for 64-times longer than in a commercial location.
[1] https://insideevs.com/news/564628/europe-plugin-car-sales-2021/#:~:text=Thanks%20to%20the%20strong%20second,in%20ten%20was%20all%2Delectric. [2] https://www.transportenvironment.org/discover/evs-will-be-cheaper-than-petrol-cars-in-all-segments-by-2027-bnef-analysis-finds/ [3] Elia Group “Accelerating to net-zero: redefining energy and mobility” [4] Smart charging: integrating a large widespread of electric cars in electricity distribution grids – EDSO, 2018 [5] Exceptions such as underground parking lot, where Wi-Fi to is impossible may exist or through location management system. [6] https://www.concerte.fr/system/files/concertation/Electromobilite%CC%81%20-%20Synth%C3%A8se%20vFinale.pdf [7] “Connecting the dots: Distribution grid investment to power the energy transition”, Monitor Deloitte, E.DSO & Eurelectric, January 2021 [8] Currently, and assuming that the availability band made available by the e-buses in depot is 50 KW, it is expected that “Bus 2 Grid” will reduce the costs of the infrastructure to zero and generate additional annual revenues of €1000 per bus. Enel Foundation 2021 “Scenari E Prospettive Dell’elettrificazione Del Trasporto Pubblico Su Strada”.
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
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:
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.
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.
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.
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.
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.