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 (2010/31/EU, EPBD)

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

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

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

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

Provisions we support

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

Clarify the scope of application of Art. 12.

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

Ensure charging solutions in existing buildings.

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

Our key recommendations

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

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

Our key recommendations

Reinforce the deployment of smart charging functionalities

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

Our key recommendations

Reinforce the measures to ensure pre-cabling

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

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

Our key recommendations

EPBD: Our support to the proposal

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:

  • Guarantee to the right-to-plug in all buildings and the removal of regulatory barriers (Art. 12. 8)
  • Obligatory pre-cabling of all new and under-renovation buildings.
  • Requirement for smart charging-readiness for all new and renovated chargers, as well as bidirectional chargers (V2G) when appropriate (Art. 12.6)
  • Reinforcement of the charging requirements for new and renovated buildings (Art. 12.1, 12.2 and 12.4)
  • Lowering of the existing parking space thresholds for pre-cabling and installation of charge points for all new and renovated non-residential buildings (Art. 12.1, 12. 4)
  • Requirements for bicycle parking (Art. 12.1 – 12.4)
  • Suppression of the unnecessary exemptions, particularly those applied to SMEs in article 8(4).

EPBD: 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.

Key recommendations:

  • Introduce an explicit definition of pre-cabling, in order to encompass the electrical installation; it should not be limited to ducting infrastructure. To secure efficiency, electrical installations should be considered as ‘technical building system’ (Art. 2.6).
  • Inform on the readiness of any building to safely install an EV charging point into the Energy Performance Certificates (Annex V).
  • Integrate Energy Performance Certificates information about the status (safety and readiness) of electrical installations (Annex V)
  • Set up local or regional one-stop-shop accessible websites and portals that combine various services, including the right to request with streamlined permits and installation procedures.
  • Ensure that requests for installing charging stations in collective properties do not exceed three months. (reinforce ‘right to plug’).
  • Address the administrative hurdles (for example, EV charging as extra-legal benefit for employees) as well as collective action problems (such as split incentives between EV and non-EV drivers, renters vs. owners, employee vs. employer, etc.).
  • Encourage Member States to financially support the installation of EV charging in buildings (including depots and logistic hubs for trucks, light-duty vehicles and buses). The Commission and its co-legislators, including the Member States, should also examine the possibilities of using new and current financial instruments to stimulate investment in private charging infrastructure.

EPBD: 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.[1] 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.[2] 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.

 

Key recommendations:

  • Ensure that all newly installed chargers in buildings are capable of smart charging.
  • Ensure consistency in the definitions and provisions on smart charging set in the revision of the EPBD with those proposed in the new Regulation on the deployment of alternative fuels infrastructure - which is replacing the current AFI Directive 2014/94/EU (in Art. 2 and 5) - and in the revision of the Renewable Energy Directive.
  • Ensure the recognition of mobile storage in the European energy framework.
  • Clarify that bidirectional charging (Art. 12. 6) should be encouraged when demonstrating a positive socioeconomic impact and contributing to system efficiency. Co-legislators should also address any remaining barriers for vehicle-to-grid technologies.

[1] [In French] RTE (2019), Report on the development of electromobility.

[2] AFIR Impact Assessment, Annexes, page 86.


EPBD: Completing the charging requirements for new and under major renovation 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.

Key recommendations:

  • Include depot charging for heavy- and light-duty vehicles, i.e. extending the scope of the EPBD to cover new or renovated private depots, as well as logistic hubs and distribution centres. This would require them to be ready for future battery electric truck charging (350 kW+ chargers), so that trucks can conveniently charge while loading/unloading. This should include pre-equipment, as well as an appropriate grid connection.
  • Charging facilities for e-bikes should match those for e-cars. There are two options:
    • recharging points for electric vehicles would be equipped with a household power socket, allowing for the easy charging of both e-bikes and e-scooters as well as certain types of L-category vehicles such as e-mopeds, or
    • deploy a separate bicycle charging infrastructure, with dedicated bicycle recharging points.
  • The requirements should apply to all buildings that are undergoing a major renovation, regardless of whether the car park is included in the renovation measures.
  • Greater ambition for parking spaces for non-residential buildings; there should be a minimum of 50% of parking spaces with charging points.

EPBD: 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.[1] As a result, the EC should ensure the installation of charging points in existing buildings.

Key recommendations:

  • Extend the scope of Art. 12 to ensure requirements for installing charging points in existing buildings. Incentives or enforcement mechanisms, to make sure that the stakeholders involved comply, should be introduced.
  • Avoid putting a disproportionate burden on building owners and tenants, by addressing the necessary elements to reduce the costs of private charging installation.
  • Introduce per-cabling requirements for existing buildings:
    • 2027: all parking spaces in 15% of all buildings
    • 2030: all parking spaces in 30% of buildings (100% for all publicly owned buildings)
    • 2035: all parking spaces in all buildings.
  • More ambitious charging point requirements for non-residential buildings (15% of parking spaces (2030), 30% (2035) applicable for all buildings with more than ten parking spaces.

[1] EPBD Impact Assessment.


Zoom in on the deployment of charging infrastructure in France

Zoom in
the deployment of charging infrastructure in France

The French government set ambitious objectives for the deployment of charging stations to deploy 100,000 charging points (CPs) by the end of 2021 and to equip all service areas on the highways with fast charging stations by 2023.

To know where to go, we need to understand where we are. This is why, UFE has launched two mapping tools, updated every 3 months, that aim to follow the state of deployment of the public CPs in France.

  • Mapping 1 reflects the deployment of publicly accessible charging infrastructure in the French regions and departments since September 2020.
  • Mapping 2 shows the (ultra-) fast CPs on the French conceded highway network since March 2021.

Methodology[1]

Mapping 1 indicates the number of EVs available for 1 CP per region and department, with reference to the ratio of 1 CP per 10 EVs set by the current Alternative Fuels Infrastructure Directive (2014/94/EU). Mapping 2 assesses the equipment rate of the service stations in at least 50-kVA CPs for all motorways operated under a concession.

Where does France stand at the end of September?

France has acquired around 46,300 CPs and 660,000 electric vehicles in circulation since 2010. Over the past year of monitoring the CPs’ deployment in regions and departments, the number of CPs has increased by 42%, while the EV fleet has grown by 78%. Even if the number of CPs keeps increasing gradually every 3 months, the threshold of 1 per 10 has been exceeded in all regions except Occitanie.

As for CPs on the highway network, (ultra-) fast charging has increased by 9% in France since June 2021 or by 42% in 6 months. 55% of the highways were equipped with at least one fast CP equal to or greater than the 50kVA.

Conclusion

UFE’s mappings show that, while the country is on the right track, more efforts are needed to reach the objectives set by the government for the deployment of public CPs in regions and departments. In this respect, the new AFIR could give France the final boost it needs with the right targets.

[1] AAA Data’s (electric vehicles) and Gireve’s (charging points) figures for UFE


Interview with Amélie Pans, Platform chair 2022

Interview with
Amélie Pans, 2022 chair of the Platform

WG Leaders will make sure to come up with excellent workplan for 2022, but beside the content, what do you think the Platform should focus on in 2022?  

The number of files relevant to the Platform keeps growing but our days weirdly are still 24-hours long. So I would recommend to refocus on key files and ensure we have a strong impact of each of them. I do not have strong recommendations on which to put up the list but that can be discussed within WGs. Secondly, I’d like to look for the Platform to gain efficiency in our internal discussions, reduce the amount of exchanged emails and multiplication of versions of our draft papers. And finally, the Platform should communicate externally more effectively  

How could the Platform communicate more effectively as you say?  

2022 will be a fight for attention among stakeholders and associations like us to talk with policy makers and raise our issues in the public debate. We’ll have to join efforts to talk louder than others. We all spend a lot of time to come up with Platform’s positions, organize events and so on; we don’t do that to put the papers up on the shelf but to communicate them around. An easy step forward would be to share them on our personal social media for example.  

You mentioned the importance of a gender balance governance, it is true that women are still underrepresented in the whole transport industry. What do you want to say  

Although it is outside the scope of the Platform to advocate for gender balance policies, we should make sure to lead by example here. Even before I take the chairwomanship, I must say with Emilia, Claire, Marie-France, Chiara and Sarah leading our working groups and Julia being our vice-chair the Platform was always at the forefront of the fight. What can we do more? There are many of transport and energy female leaders at EU and global – how about a series of interview with them to shine a light and inspire others?  And we should also walk the talk by ensuring that panels at our own events are always balanced. 

Since its birth in 2015, the Platform has been growing covering more parts of the value chain. In which direction would you like to see the Platform grow in 2022? 

Beside growing its impact on social media, I think we should also think about contacting allies outside the box. For example, the Platform could go and meet the navigator providers (Waze, Google…) regarding the mapping of the charging stations. We can also get in relation with builder associations when it comes to the EPBD to show them the added value of the charging infrastructures. 

By the way, I’d like to take some times to meet with members to discuss all those points and more during informal chat. You can plan a meeting here.