An ambitious revision of the AFID consistent with the EU Green Deal
Key recommendations
The Platform for Electromobility calls for an ambitious revision of the Alternative Fuels Infrastructure Directive (2014/94/EU, AFI) consistent with the EU Green Deal
February 2021
An ambitious revision of the AFID is vital to accompany and boost the electrification of transport and reduce GHG emissions as requested by the EU Green Deal and the EU Smart and Sustainable Mobility Strategy. The current AFI Directive was adopted at a time the market for alternative fuels was still an emerging market. Europe must now equip itself with the right public and private charging infrastructure to support the surge of electric vehicles (EVs) and the transition to a zero-emission mobility.
In this context, the Platform for Electromobility calls for:
EXTENDING THE SCOPE OF THE DIRECTIVE
Given the EC’s goal to reduce EU GHG emissions by 55% by 2030, the revised AFID must incentivise the uptake of low and zero emission vehicles.
Key actions:
• Prioritise the electrification of transport as the most effective and efficient pathway compatible with the objectives of the EU Green Deal and the decarbonisation of mobility. In particular, the Platform underlines that the decarbonisation of the transport sector cannot be achieved with the fossil fuels still supported in the current AFID.
• Set minimum mandatory targets for the availability of recharging points in all public parking facilities from 2025 (e.g. supermarkets, shopping malls, car park operators etc.).
• Introduce an updated definition of charging points based on their power levels to the existing one, i.e. ultra-fast (≥150 kW) and fast charging (22-150 kW). Criteria for minimal requirements should embrace the number of points, charging power, ratio to the number of EVs. The market should decide the most useful power level to apply.
• Apply the revised directive also to charging infrastructure for Heavy Duty Vehicles (HDVs) (trucks and buses), electric charging for two wheelers and rail infrastructure. For HDVs, the specific charging needs of electric trucks should be addressed by introducing requirements for the roll-out of public charging infrastructure and electric road system for electric heavy-duty commercial vehicles (vans and trucks) in medium and large urban areas by 2025, as well as along the TEN-T Core Network.
• Require Member States to propose to the EC a decarbonisation strategy for their rail system, identifying the alternative fuels that they intend to make available on the parts of their network that are neither electrified nor mandated to be electrified under an existing EU regulation. In particular, MS should include in their strategy a plan to replace current refueling facilities as defined in point 2.(i) of Annex II of the Directive 2012/34/UE “Recast”.
• Revise consistently the AFID and the Energy Performance of Buildings Directive (2010/31/EU, EPBD) to ensure the same level of ambitions in both texts. The way article 8 of the EPBD imposes an obligation for the deployment of charging infrastructures in non-residential buildings may have an impact on publicly accessible charging infrastructure since some non-residential buildings are open to the public such as malls. Besides, the EPBD should address the issue of private charging in all types of buildings as it is also important for the development of electromobility.
SETTING MINIMUM BINDING TARGETS for the deployment of publicly accessible charging infrastructure
Key actions:
• Introduce minimum binding targets per Member States on the number of public chargers deployed per type of transport (Light Duty Vehicles, Heavy Duty Vehicles) starting in 2025. Minimum binding targets should also be set for the deployment of charging infrastructure for airport infrastructure for ground movements and onshore power supply or boat ‘refuelling’ in maritime and inland ports.
• Develop an EU methodology to set the binding targets introducing penalties in case targets are not satisfied. These targets should ensure that – at the minimum – the EU objective of 1 million public chargers in 2025 and 3 million in 2030 are reached. The penalties of each MS should be reinvested at national level for zero-emission mobility measures (like funds for electric infrastructures, public subsidies for EV uptake in favour of citizens or businesses like purchasing aid or fiscal measures etc.).
• Establish a new bottom-up EU metric considering the charger power level of charging points, the number of EVs, assessing locally the right geographical coverage of infrastructure (via geographic, traffic and density criteria) and including the level of access to a private charging infrastructure. Given that two thirds of cars are parked overnight on the street (or public car parks), EV users living in condominiums, in particular, should be able to benefit from a public charging point in their residential area when it is not possible to install a charger in their building.
• Empower local authorities to take clearer and simpler administrative procedures to install public charging infrastructure.
• Request Member States to decarbonise the non-TEN-T part of the rail network, through further electrification, where economically feasible, or through battery and hydrogen powered trains.
ENSURING CONSISTENCY between the AFID and the TEN-T Core and Comprehensive Networks
The EC should revise the TEN-T guidelines in line with the requirements of the revised AFID.
Key actions:
• Make the minimum target of one charging point/60 km mandatory, as defined in the TEN-T Core Network for both TEN-T Core and Comprehensive Networks by 2025 to make the EVs convenient for long road journeys and ensure the coverage of the TEN-T Networks with ultra-fast chargers, including urban fast charging hubs.
• Align the TEN-T high-power recharging infrastructure requirements with the electricity development plans.
• Focus on the part of the main line rail network which is not part of the TEN-T as well as nodes on the Core and Comprehensive networks (ports, multimodal terminals for example).
DEVELOPING SMART CHARGING
The Platform emphasises the capacity, in general, of electricity system operators to integrate EVs even with an ambitious target for 20301. However, in some places of Europe this would require the adoption of smart-charging
1 In France, the French DSO Enedis has concluded in a report that the needed investment to integrate EVs into their grids will only represent 10% of their total investment by 2030 (cf. Enedis, Report on the integration of electric mobility in the public electricity distribution network, November 2019)
strategies to optimise network investment and, potentially, reduce the need for grid reinforcement. The Platform underlines that smart charging should be developed in accordance with the evolution of mobility needs of EV users and with their consent.
Key actions:
• Introduce a definition of “smart charging” as charging of an EV which facilitates the security (reliability) of electricity supply while meeting the mobility needs of the user. The definition should serve as basis and be referred to in other legislations. It should be coherent with already existing legislations supporting the integration of EVs in the power system (e.g. electricity regulations on the role of DSOs).
• Ensure that publicly accessible normal charging points (<22 kW) installed from now on are smart and future proof. This requirement should specifically apply in residential areas and cities where people may have limited access to private charging points.
GUARANTEEING INTEROPERABILITY via a user-centric approach
The electricity charging infrastructure should be interoperable to provide seamless EV charging experience to the users through the use of open and compatible standards and open and shared data on information, location and availability of chargers as well as price transparency to deliver more intelligent services such as smart charging, roaming of service and common ad-hoc payments (at least at national level). The EC should provide a harmonised framework for product and security requirements for charging and data exchange at the different interfaces without excluding technology already in the market.
Key actions:
• Put in place interoperability principles for the operation of various technical standards and protocols on the market to promote a competitive market environment and improve user experience.
ENSURING A STRONG IMPLEMENTATION OF THE DIRECTIVE
To ensure the rapid and strict implementation of the binding targets and provisions set in the revised AFID, the EC should tighten the EU monitoring and further involve the local level.
Key actions:
Consult with local authorities and distribution system operators when developing National Policy Frameworks or strategies to implement them.
• Create independent national reporting authorities within Member States (such as National Energy Agencies) in order to strengthen EU monitoring of the implementation Member States’ target.
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• Turn the AFI Directive into an ad-hoc EU Regulation for road transport infrastructure to ensure a strong, rapid and more uniform implementation in all Member States. However, considering other modes of transport (inland waterways, maritime transport) for which alternative fuels are less mature, the directive should remain the preferred regulatory tool.
Platform for Electromobility reaction to the revision of the European Batteries Directive
10 December 2020
Read our full paper here:
Platform for Electromobility reaction to the revision of the European Batteries Directive_v1_Final
The Platform for Electromobility – representing 39 industrial, urban and environmental stakeholders from across Europe’s e-mobility value chain – welcomes the Commission’s long-awaited publication of their proposal for new European rules for batteries as presented today.
This comprehensive legislation will be key to ensuring batteries on the European market are both produced in a socially and environmentally sustainable manner, while at the same time, putting the EU firmly on track to meet to achieving its 2050 climate-neutrality and industrial leadership ambitions as set out by the Strategic Action Plan on Batteries. The revision of the current legislative framework has the potential to provide further regulatory support and clarity for the European battery manufacturing and recycling industries by establishing legislative measures capable of increasing the continent’s competitiveness in the booming e-mobility sector. Specifically, the the whole objective of the proposal should create the legal conditions and incentives for a domestic, competitive, high-quality battery market to emerge in Europe, with true business cases for battery end of life management and environmentally sound recycling, which can help accelerate the EU’s transition to zero emissions.
Batteries will underpin Europe’s drive to climate neutral economy and zero-emission transport. In this context, we urge policymakers to keep the following in mind as the Commission proposal is debated in the European Parliament and Council:
1. Ensure comprehensive due diligence requirements – from sourcing, to refining and manufacturing – are supported at EU level so that the battery industry can bring social and environmental value along the entire value chain;
2. Develop a robust EU carbon footprint methodology addressing all batteries chemistries and covering all key emission hotspots/phases;
3. Pave the way for an effective, net-value circular economy strategy capable of treating developing waste volumes and meeting the needs of a fast-paced, innovative industry such as e-mobility.
4. Avoid batteries are not lost once they hit the market via an improved (end-of-life) declaration system;
5. Provide a consistent regulatory framework for 2nd life options of EV batteries.
As EV sales begin to take off in Europe, the future success of the EU’s ability to remain competitive with the rest of the world will be heavily dependent on the ability to domestically develop batteries at larger scale in order to meet EV demand and help accelerate the transition to e-mobility. Only with clear rules and high standards can Europe fully reap the benefits of a home-grown battery industry, bringing economic value, jobs and long-term growth as a part of the e-mobility transition.
Jayson Dong, Chair of the Batteries Working Group in the Platform for Electromobility, added that “this piece of legislation will be key to supporting a thriving European e-mobility ecosystem. It will play a key role in delivering on the innovation, sustainability and competitiveness ambitions of the 2017 launched European Battery Alliance and working towards the EU’s Green Deal roadmap. The Platform for Electromobility looks forward to engaging with all relevant EU decisionmakers on this file and sharing our wealth of expertise to ensure the EU becomes a leader in the manufacturing of innovative and sustainable EV batteries.”
For more information about the Platform and our detailed position on the revision of the Batteries Directive, please find our paper on our website here.
Input to Smart and Sustainable Mobility Strategy
Electromobility is the best solution to achieve the climate and industrial ambition of the European Green Deal for transport. The Sustainable and Smart Mobility Strategy will present the European Commission’s new vision on mobility for the upcoming years and must thus set a long-term and ambitious policy framework and support the further electrification of all modes of transport. It needs particularly to support the roll-out of an accessible charging infrastructure network for all modes of transport. The urgent revision of the TEN-T guidelines and AFI Directive for road and rail must occur without any delay and will ensure the decarbonisation of both modes of transports. The revision of the AFI Directive must be ambitious and should clearly set minimum binding targets per the Member States and type of vehicles (LDVs and HDVs) for the deployment of charging infrastructure for low- and zero emission transport technologies in order to reach the 2050 climate neutrality objective.
Smart charging, and demand-side resources (i.e. vehicle to grid) will therefore constitute a key enabler to strengthen future synergies between transport, digital, and energy sectors, supporting Europe’s energy transition and fostering technological innovation. In line with the Energy System Integration Strategy, the Platform for Electro-Mobility recommends that EU and Member States’ policy-makers encourage and develop policies in support of these innovative system integration technologies to unlock all the benefits it can deliver to the electricity system and to society at large. The European Commission must also make sure that the synergies between energy and mobility are maximised with adequate financial cross-sectoral schemes. Funding and support for electrical upgrades (within buildings as well as grid connections) necessary to install charging equipment should also be made available to consumers, for instance through the upcoming Renovation Wave initiative, and namely through the revision of European Performance of Buildings Directive. Support for zero emission mobility will address the behavioural changes and answer the growing demand. Therefore, it would be important for the Commission to shape regulations to drive affordable supply of EV models and design mechanisms to enhance the consumers’ uptake of electro-mobility innovations and ensure social inclusion of lower income households. The corporate market is a clear lead market for electrification and the strategy should include mechanisms to require more and more fleets such as company cars, taxis and delivery vehicles to electrify and support companies towards this goal. It is also key to rebalance the modal shares with a view to encouraging a greater use of energy-efficient modes with the highest electrification rates such as rail as well as measures to ensure the modal shift to rail.
The Battery Directive will be key to create a sustainable environment and should provide conditions for the EU to become more competitive. The new strategy should also support innovative and competitive business models for the second life and recycling of EV batteries. The Smart and Sustainable Mobility Strategy should recognise the vital role of businesses in stimulating the EV market and providing EV charging to help make e-mobility a more affordable and viable option for citizens across the EU.
New mobility zero emission shared services alongside public transport (bus, rail, tram and metros) have a key part to play in the electrification of urban transport. In cities, the development of a sustainable and efficient urban freight, with a focus on zero emissions trucks as well as last-mile delivery services, are long-term solutions which need to be stimulated. Furthermore, taxation is a central driver for the decarbonisation of transport, and it is essential that the EU’s taxation rules are aligned with its decarbonisation commitment. Specifically, the revision of the Eurovignette and the Energy Taxation Directivesis a chance to build a future-proof taxation policy, adapting to a modern and decarbonised economy while accompanying the uptake of electromobility by integrating a CO2 component.
The Platform for Electro-mobility unites organisations from across civil society, industries, cities and transport modes. Its members are committed to promote electro-mobility and strive to collectively develop solutions to electrify European transport, and to promote those solutions to the EU institutions and Member States. The Platform is working to create a sustainable, multimodal transport system in which people and goods are predominantly moved across land in Europe using sustainable electricity. The aim of the Platform is to drive the development and implementation of sustainable European Union policies, programmes and initiatives to move people and goods by electricity https://www.platformelectromobility.eu.
