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.

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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.

  1. 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.

  1. 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.

  1. 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.

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[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.

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[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.

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[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

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[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.


[Video] Charging Infrastructures: A perspective on 2024 by Jayson Dong


Our five recommendations to CO2 Standards for trucks and buses trilogue negotiators

CO2 Standards for HDVs
Our recommendations to trilogue negotiators

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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

1

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.

2

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.

3

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.

4

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.

5

 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

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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

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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.

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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:

  1. Be initiated and moderated by public and regulatory authorities
  2. Assess the grid in advance – even before any connection requests – and prioritise the flexible use of the grid
  3. Recommend reinforcing network components, should any overload be anticipated;
  4. Foster communication with municipalities to address network construction requirements when connecting charging stations
  5. 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.

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Recommendations for the deployment of sustainable infrastructure of BE HDVs

Logistics & Infrastructures

Driving the adoption of Battery Electric Heavy-Duty Vehicles

General policy recommendations for the deployment of sustainable infrastructure

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The members of the Platform for electromobility recognise the importance of driving uptake of the required infrastructures for Battery Electric Trucks and buses (BEHDVs). They also recognise the need for policy recommendations that complement the Alternative Fuels Infrastructure Regulation (AFIR) and Energy Performance of Buildings Directive (EPBD).

The challenges in this area span multiple sectors, from energy, through land management and on to data security. We therefore emphasise the importance of cooperation between all sectors of the electric road transport system, resulting in this paper, which outlines the key elements that legislators should keep in mind when addressing this topic.

In this position paper, we identify three areas that require attention and provide policy recommendations to ensure the successful roll out of infrastructures for BEHDVs: the grid, the data framework and the land.

Beyond infrastructure (which this paper is dedicated to), we stress the importance of ambitious, clear and timely revision of both the CO2 Standards for trucks and buses Regulation and the Weights and Dimensions Directive. We have discussed both of these in previous publications (respectively here and here).

The grid

A. Assessments: per country and per usage

While strong CO2 Standards would prove useful for anticipating actual and future demand, a situation where a grid connection may not be available can potentially undermine the trajectory defined by those new CO2 Standards. It therefore becomes urgent to immediately and proactively assess whether there is sufficient potential grid-capacity to allow for sufficient connection for the charging infrastructure needed for BEHDVs. Assessment becomes all the more pressing when considering the lengthy lead times, the need for grid reinforcement, the likely demand for BEHDVs and the number of actors involved.

Grid infrastructure varies between countries. Some may need important investments in order to prepare for the integration of BEHDVs, with the development of megafast chargers where required. In the Netherlands – a European Member State at the forefront of road transport electrification (along with other such as Germany and, to a lesser extent, Belgium) – it appears to be extremely difficult for transport operators to obtain the needed capacity for BEHDVs, both at their depots and on the road, due to a lack of effective planning. Even where capacity increases are possible, long delays for connection and procedural constraints present barriers to the swift adoption of BEHDVs.

Grid infrastructure varies between usages. While large charging hubs for BEHDVs along motorways will be the exception and the depot/destination charging overnight the rule, the need for very high-level connection capacity along the motorway should be tackled. Medium- and high-voltage connections to the power grid will be necessary to support the fast charging times in the event of opportunity charging. To deliver the necessary power capacity, grid strengthening may be required at both public locations and – for different reasons – at private charging depots/distribution centres.

BEHDVs-suitable charging locations can be mapped and the power needs for those locations assessed. Recent existing mapping[1] – based on the GPS records of large numbers of trucks routes during one year throughout Europe – can provide a good starting point. Truck stakeholders can subsequently confirm or propose new locations for the recharging infrastructure and the power required. Distribution System Operators (DSOs) and Transmission System Operators (TSOs) should confirm whether there is sufficient capacity and, where necessary, propose alternatives.

We would welcome support for undertaking a similar mapping exercise for coaches and interurban buses. Such analysis would also support the task forces (see below) in deciding the pre-equipment needed for depots and distribution centres, as well for existing service stations. This would ensure that delays in installing charging stations for BEHDVs do not exceed reasonable timescales.

Mapping analysis shows some 10% of locations will account for half the opportunity charging stops.[2] Pre-identifying these would help accelerate the coordinated development of charging infrastructure for BEHDVs and facilitate discussion within the dedicated task forces.

B. Task Forces

The task forces – constituted as follows – should be established and moderated by transport ministries or designated government agencies. National task forces: DSOs or their representations; TSOs; manufacturers of BEHDVs, BEHDVs operators and national associations[3]; representations of energy aggregators operators; fleet managers; road and urban planners; national Charging Point Operator (CPOs) associations.

Such task forces would be well suited for indicating the investments required to extend and reinforce charging infrastructure and to determine suitable charging locations and power requirements. This will enable DSOs and TSOs to plan the necessary grid extensions and reinforcements. This is extremely important for those areas that are not being developed by project developers due to high investment costs and long lead times for grid connections. The bottom line for achieving a comprehensive approach to planning involves early engagement with fleet managers, road operators, local municipalities, CPOs and grid utilities. Such an approach helps in proactively addressing public acceptance, potential land use challenges and in establishing a workable and timely power delivery schedule.

C. National deployment plans

In order to forge a stronger link between the AFIR implementation and the deployment of charging infrastructure for BEHDVs, we propose that Member States base their own national deployment plans on the AFIR targets, reflecting the anticipated demand at each location.

These plans should align with the anticipated demand for BEHDV charging, while also considering such factors as traffic density and projected growth in BEHDV usage and stops. By adopting such an approach, Member States can provide network operators and other stakeholders with longer lead times for planning future infrastructure uptake and anticipated connection requests, particularly post-2030.

D. Public & private investments

A high-capacity grid does not come without costs. Ultrafast charging stations are expected to require large MVA network connections, which usually occur directly at high voltage level but can also occur at MV level, depending on Member State specificities.

Well-designed European financing programmes can attract private investments for BEHDV infrastructure development. To facilitate implementation, and considering the high CapEx involved, public funding should be made available: The Connecting European Facility (CEF) is a vast programme, one that is primarily focused on passenger cars rather than on BEHDVs. This limits its alignment with the needs of the heavy-duty vehicle sector. Typically, the Alternative Fuels Infrastructure Facility (AFIF) Call of the CEF Programme supports BEHDVs infrastructure between 150kW and 350kW while for 800kW and higher, power the financial solutions provided by European Commission are too limited. The annex should be adapted to better take account of the needs of BEHDVs.

2. The Data Framework

A. Align grid codes, regulations to ultrahigh-power charging standards under development

The introduction of ultrahigh power charging standards necessitates global and European recognition. When being designed, standards should take into account factors such as space and interoperability as well as the futureproofing of those ultrahigh power charging standards currently under development. Any existing regulations that did not anticipate BEHDVs and their charging infrastructure must be updated to in order to accommodate this new paradigm. Definitions of technical aspects and use cases must be integrated into existing technical codes and regulations. Temporary exceptions will likely be required in areas such as standardised and certified energy metering concepts, which are currently lacking for megawatt charging. Member States should implement standards for BEHDV infrastructures for both public and private applications. Last, it is not possible to apply to EU funding for deployment of standards that have yet to be adopted.

B. Harness the flexibility potential of BEHDVs

Smart and bidirectional charging can be key in increasing the uptake of renewable energy and in offering flexibility potential to the grid. While initially this may seem challenging to implement, given the fast-charging requirements dictated by the road transport business model based on opportunity charging. Yet, the potential to harness the flexibility of the BEHDVs is actually significant, particularly considering their battery sizes, the high predictability of their routes and time schedules and the predominance of depot/overnight charging.

Smart energy management systems can therefore be deployed, specifically through the implementation of balancing mechanisms between connectors. This will synchronise with renewable energy production and provide a fast-frequency response to keep the grid stable. This would further require signals to use the flexibility from batteries, such as incentives for aggregators and dynamic tariffs, etc. Beyond advanced planning, tariffication incentives and financial incentives in the grid services markets are other crucial elements for minimising grid impact and allowing potential grid balancing.

Bidirectional and smart charging can be particularly suitable for certain business models, notably buses and trucks that are not operated on a 24/7 basis (short-haul and regional transport). Their large batteries can offer key services to the grid. Smart meters should be considered as one of the solutions for smart charging in depots and distribution centres. However, regulatory frameworks will need to be adapted in order to enable bidirectional charging and provide economic incentives.

Finally, the sector is currently exploring the potential of flexible storage positions within local energy systems, such as incorporating stationary batteries into charging stations or exploring battery swapping solutions. Such approaches can help reduce the strain on the grid, offering advantages to both charging operators and system operators by enhancing flexibility. In addition, configurations integrating renewable energy sources on site should be examined for smart charging, as they have the potential to mitigate expected peak loads.

C. Data sharing for smooth logistic operations

A proper regulatory framework would also enable data and information exchange along with digitalisation for cross-sector integration:

Smooth reservation and non-discriminatory access to, and reliable operation of, public recharging infrastructure can accelerate the transition to BEHDVs. Standardised data sharing and interoperability between value chain players are a prerequisite for third-party operators of smart charging services and for the proper functioning of smart charging technologies.

Currently, however, data sharing and interoperability are often limited, which can lead to inefficiencies and reliability challenges. For example, charging point operators may not have access to real-time data on the location and battery state of charge of heavy-duty trucks. This in turn can make it challenging to plan optimal power needs and manage the charging process. Likewise, logistics operators may not have access to real-time data on the availability of charging infrastructure, which can lead to delays in delivering goods. There are multiple data types for multiple use cases that require a minimum of data sharing across the industry to enable efficient logistics and reliable charging.

Agreeing minimum specific list of data points for BEHDVs, interoperability standards and developing a robust, open and non-discriminatory data sharing framework will allow logistics operators, truck manufacturers, grid and charging point operators to put solutions in place for improving the reliability and efficiency of logistics operations and recharging infrastructure.[1] The European Commission should support the parties involved, with the aim of establishing an open data-sharing framework built around a set of industry-agreed data types, made accessible to the market and public authorities. Ultimately, it should strive to establish a reliable European legal framework for smooth data exchange for electric HDV recharging operations throughout the EU.

D. Understand the charging patterns

Last, further research is required to understand the charging patterns and to demonstrate the cost opportunities for transport operators and Mobility Service Providers (MSPs) of participating in the flexibility services market. TSOs – in collaboration with fleet operators – can play a crucial role, for example by introducing pilot projects and regulatory sandboxes to gather experience on grid impacts and reactions to time-varying tariffs, and to eventually assess the real flexibility potential.

The Land

A. Quantity: Sufficient space for trucks and buses public and private charging

According to the European Commission[1], there is a shortage of around 100,000 suitable parking spaces for HDVs, of which only around 54,000 offer a reasonable standard of safety. We can therefore no longer ignore the shortage of parking space for truck drivers. This current lack of parking leads to improperly parked trucks, leading to both environmental and safety issues for truck drivers and other road users and places a considerable burden on truck drivers. Even existing parking areas frequently lack adequate facilities or are in a state of disrepair.

The need for additional charging infrastructure created by the advent of electrification makes these issues even more acute. Consequently, the availability of ample parking space – now in parallel with charging facilities – represents more than a mere convenience; rather, it is an indispensable prerequisite for driving the transition to a decarbonised transport system.

B. Quality: Safe and Secure Truck Parking Areas (SSTPAs) suited to charging

Private investment in constructing increasingly costly infrastructure such as large-scale parking facilities, warrants reinforcement through European and national public funding initiatives. Such incentives include grants, tax benefits and subsidies geared to attracting private investment in the construction of parking areas with integrated charging stations for BEHDVs. Such moves can help offset initial infrastructure costs and incentivise the expansion of such facilities. While establishing more ambitious – yet attainable – targets for each Member State at an EU level emerges as a sensible strategy, the reality of achieving these minimum standards is frequently faced with lack of available land, particularly in densely populated areas. To overcome this challenge, the EU should support Member States in pursuing following options:

  • Earmarking publicly owned land for investors to develop new parking and charging spaces. Alternatively, streamlining the permitting process and alleviating bureaucratic complexities to incentivise private investments in additional parking capacity.
  • Enhancing the synergy between private landowners and operators of parking and charging spaces through improved matchmaking mechanisms and by leveraging digital platforms.
  • Tendering (greenfield) locations where investors are hesitant via a ‘concession model‘, eventually combined with incentivised deployment on certain locations. In a concession model, governments can accelerate permitting and realisation of grid connections.
  • Cooperating with system operators to secure grid capacity on shared (or tendered) locations.

C. Must-have for market models

Other market models (land sale, rental, long lease) are viable alternatives, but lead to more commitment in implementation (profitable business case, cooperation, multiple operators on one site). All market models should consider monopoly on ‘premium’ sites, market forces in designated locations, differences between HDV and LDV infrastructure markets and maximising market forces.

D. The role of concession holder

In essence, the role of concession holder can play an ever-more prominent role in accelerating the market by:

  • Taking the lead in all restrictive conditions (such as grid connection, land ownership)
  • Securing grid capacity before locations are offered for tender. Participate with system operators to secure grid capacity on multisite (multiple operators using a single grid connection). Facilitate consortia to own and initiate a shared site with multiple operators of zero emission infrastructure.
  • Acting as a bridge function in sharing construction and basic infrastructure costs when multiple operators settle on a site (such as direction on site layout, site paving).
  • Promoting a location for charging infrastructure operators by attracting other services (retail, hospitality, etc).

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The Grid

[1] https://www.acea.auto/press-release/electric-trucks-new-data-maps-out-priority-locations-for-charging-points/ 

[2] https://www.isi.fraunhofer.de/content/dam/isi/dokumente/cce/2021/ACEA_truckstop_report_update.pdf 

[3] Shippers and carriers such as TLN in the Netherlands or RHA in the United Kingdom.

The Data Framework

[1] Smart charging, BET eRoaming, Plug and Charge, Value Added Services (i.e., Preconditioning), flexibility provision services in relation to battery degradation patterns etc.

The Land

[1] https://www.iru.org/system/files/Final-Report-SSTPA-27022019.pdf


CO2 Standards for HDVs : Our warning against inclusion of Carbon Correction Factor

Platform for electromobility warns against the inclusion of renewable and low-carbon fuels and a carbon correction factor in the CO2 Standards for trucks and buses

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Ahead of the vote on the CO2 Standards for trucks and buses Regulation in Plenary of the European Parliament on the 21st November, the members of the Platform for electromobility would like to express their deep concern regarding the potential introduction of low-carbon fuels (advanced biofuels), synthetically produced fuels (e-fuels) and a Carbon Correction Factor (CCF) to account for them, in the CO2 Standards for Heavy-Duty Vehicles (HDVs). We urge you to carefully consider the implications of such a measure and, in the best interests of our regulatory framework and environmental goals, reject its introduction unequivocally.

Opening the door to these fuels into the revisions of the CO2 Standards poses significant challenges. The introduction of a Carbon Correction Factor (CCF) to account for them would be equivalent in lowering the average specific emissions of a certain manufacturer, as per the Impact Assessment of the EC[1]. Since the Renewable Energy Directive – REDIII already rewards the use of low-carbon fuels like bioethanol, bio-methane or synthetic fuels produced from renewable electricity, with the strongest possible economic incentives by setting sales mandates for the deployment of such low-carbon fuels across all sectors, including freight transport, this would mix well-to-tank (fuels and electricity from RED) and tank-to-wheel (vehicle tailpipe emissions from CO2 standards) regulation,  leading to potentially regulatory inconsistencies and, at its worst, result in unenforceable legislation. This would blur the roles and responsibilities of different market participants, even though this regulation primarily applies to vehicle manufacturers, potentially constituting double counting, as highlighted by NGOs[2] and studies[3]

Moreover, beyond the immediate concern of CO2 emissions, the introduction of a CCF could adversely impact air quality, especially in urban areas. Allowing last-mile delivery trucks to emit more pollutants in cities could contradict existing legislation, such as the Air Quality Directive, which was recently adopted in the European Parliament. The directive aims to achieve improved air quality, particularly in cities, by 2030, aligning with the World Health Organization (WHO) standards and ultimately striving for zero pollution by 2050. Lowering the ambition of the CO2 standards for HDVs would run counter to these efforts to enhance air quality.

We understand that there has been debate regarding the competitive advantages of e-fuels compared to battery-electric technologies. However, it is important to note that battery-electric technologies can already satisfy almost all of European freight road transport needs, a share that will likely increase with the growth of intermodal logistical systems.

Furthermore, we emphasize the inherent inefficiency of e-fuels. 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. It is worth noting that these fuels are scarce resources sorely needed to reduce greenhouse gas emissions in the aviation and shipping sectors, whereas the road transport sector can easily be electrified. As a result, e-fuels do not provide a viable alternative to existing zero-emission solutions. 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. In addition, E-fuels aren’t currently produced at commercial volumes[4]. 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.[5]

In conclusion, we urge Members of the European Parliament to carefully consider the potential ramifications of introducing a Carbon Correction Factor in CO2 Standards for Heavy-Duty Vehicles, as it would not bear significant results, while setting a dangerous precedent and creating great uncertainty for European truck manufacturers. We believe that maintaining a clear and consistent regulatory framework, along with our commitment to improving air quality, should guide our decisions in this matter. We appreciate your attention to this critical issue and look forward to further discussions.

In addition, we would like to remind the key recommendations from previously published position:

  • keep the ambition of the CO2 emission reduction targets (final and intermediate), to fully decarbonize the sector by 2050, at least as per EC proposal;
  • The proposed 2030 target of -45% is lacking ambition and is below what manufacturers have announced. It should be increased to an emission reduction level of at least 65%.
  • The proposal’s new definition of zero emission (5 gCO2/tkm) creates a dangerous loophole for continuous sales of emitting vehicles even after 2050. The Platform strongly advocates to keep it as it is (1 gCO2/kWh).
  • Keep the 100% ZEV mandate target at 2030 for urban buses, including an intermediary target with a 70% ZEV mandate by 2027 . Two subcategories of urban buses, namely class II low-entry (i.e. 31L2 and 33L2), should be moved into the coach segment.

[1] compared to the medium ambition scenario (TL Med), the average CO2 emissions per tkm of the new vehicles fleet of this option increases by around 13% in 2030 and leads also to a higher uptake of ICEV instead of ZE ones. All in all, the CO2 tailpipe emissions during the period 2031-2050 increase by about 8% of the cumulative emissions in TL_Med. In addition, food- and crop-based biofuels are associated with significant indirect climate emissions, causing higher GHGs than their fossil counterpart (ICCT, 2017 link) and e-fuels, would not be able to reduce air pollutant emissions in any meaningful way (T&E 2021 link). [2] “A carbon correction factor for trucks? Don’t be fooled by the oil industry’s latest con “ Transport & Environment. October 12th 2023. Link. [3] ICCT 2018 Decarbonization potential of electrofuels in the European union [4] Production sites, including experimental facilities are 18 at the moment. E-Fuel Alliance. link [5] Odenweller et al. (2022). Probabilistic feasibility space of scaling up green hydrogen supply. Link.


Weights and Dimensions Directive: How to accelerate the uptake of zero-emission heavy-duty vehicles

Review of the Weights and Dimensions (W&D) Directive:

 

How to accelerate the uptake of zero-emission heavy-duty vehicles

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In July 2023, the European Commission published the Greening Freight Package with the purpose of making freight more sustainable and efficient. As part of this Package, the review of the Weights and Dimensions (W&D) Directive aims to promote the uptake of electric and hydrogen trucks and buses.

The Commission proposes to increase the weight and length limits of zero-emission (ZE) heavy-duty vehicles. These provisions are intended to ensure ZE trucks don’t have to sacrifice cargo weight on long-haul routes, and ZE buses don’t have to decrease the number of passengers, in comparison to a comparable combustion model. However, the proposal fails to ensure the full application of the ZE weight allowance.

Despite noble intentions, the Commission includes several provisions which would keep the EU anchored to diesel trucks. In particular, the proposals on gigaliners[1] and combustion vehicles of 44 tonnes risk steering investment away from the zero-emission sector. Furthermore, the review should pay more attention to road wear and bridges.

The proposal also needs changes to make it truly intermodal and interoperable with other modes like (electric) rail. Such changes cannot be designed without having a perspective on what the Combined Transport Directive (CTD) will look like. This Directive plays an important role in reducing the carbon footprint of the whole logistic sector. For this reason, and as detailed in the Platform’s recent letter, we ask the European Commission to present the CTD without further delay. As such both proposals can be truly treated “as a package”, as was originally intended.

The need for a review of the W&D Directive

The heavy-duty vehicle (HDV) sector needs to decarbonize rapidly. In the first half of 2023, diesel trucks accounted for 95.6% of newly registered trucks[2]. While trucks account for just 2% of vehicles on the road, they are responsible for nearly 30% of greenhouse gas emissions from road transport in Europe.

Under current policies, this share is set to grow. According to the European Commission, truck activity will increase by about 40% between 2019 and 2050. Over the same period, bus and coach activity is expected to grow to a smaller but still considerable extent (+10%). Although buses are decarbonising much faster – 30% of new urban bus sales in 2022 were ZE – diesel buses still represented 67.3% of the new sales in Europe in 2022[3].

The EU thus needs to rapidly transition to 100% zero-emission HDV sales. As ZE trucks and buses weigh more than their diesel counterparts, a review of the W&D Directive is needed to really incentivise their uptake and set the sector in line with the Union’s goal of climate neutrality by 2050.

Our shared vision

We welcome the Commission’s intention to give zero-emission trucks a 4t weight allowance (as well as 2t to ZE buses). However, co-legislators need to intervene and ensure zero-emission trucks can fully use it, so that it is ensured that under no use case long-haul ZE trucks, which require bigger batteries, would have to sacrifice cargo weight. The proposal severely hampers the application of the ZE allowance, leaving road freight across key national borders (e.g. between France and Belgium) largely to diesel trucks.

The Commission requires the use of the ZE weight allowance for cross-border movement only, underestimating the relevance of national transport. Also, the wording of the Annex risks giving the 4t ZE allowance to diesel tractor units only because they pull electric trailers.

An increase in driving axle weight is essential for long-established truck-makers to switch from making fossil vehicles to electric. However, truck-makers don’t need the proposed 1t increase (from current 11.5 to 12.5t), which also fails to incentivise them to switch to clean sheet designs (lighter, optimised e-trucks).

The proposed regularisation of the cross-border movement of 44t combustion vehicles and of European Modular Systems (so-called gigaliners) brings them out of their current legal grey area. These longer, heavier vehicles will however only achieve real emission reductions if they are zero-emission. Unfortunately, the Commission does not provide any sunset clause for the cross-border movement of fossil gigaliners, nor does it propose a ZE weight allowance for these vehicles, thereby offering no incentive for the use of ZE gigaliners by fleet operators. Extending the use of 44t combustion vehicles and gigaliners risks delaying the take-up of electric vehicles, particularly during the 2020s. Making internal combustion trucks more attractive for long-haul transport also increases the fossil fuel dependency of the European freight sector, and therefore the EU’s dependence on imports.

Intermodal logistics system

Enhancing intermodal logistics in Europe is crucial to reach CO2 reduction objectives. Intermodal compatibility must be ensured throughout the revision process of the W&D Directive (which should not penalise rail freight) and the upcoming Combined Transport Directive.

Therefore, the Platform supports prior assessment for new gigaliner routes / movements so that they do not take traffic from rail or waterway. This prior assessment should also include an analysis of road safety and the need for additional driver training. As Kristian Schmidt, DG MOVE’s land transport director, has noted, reform should not promote truck traffic at the expense of rail, or “we’re in all kinds of political trouble[4].”







[1] Longer and heavier vehicle combination consisting of more modules and with a typical length of 25,25m.

[2] ACEA (2023). New commercial vehicle registrations: vans +11.2%, trucks +20%, buses +15% in the first half of 2023. Link.

[3] This share decreased to 63% in the first half of 2023.

[4] Politico, 29 September 2023.

[5] UK Department for Transport (2010). HGV maximum weights. Link.

[6] More specifically, wide-base high-efficiency single tyres on the steering axle and a dual tyre configuration on the driving axle; the alert threshold of the Tyre Pressure Monitoring system set at 0.6 bar, rather than current 1.2 bar, with a duty to restore under- or over-inflation at the nearest available facility; an acceleration limiter, with 1.2 m/s2 as a limit.

[7] An indicative phase-out date of 2035 should be set for ZE buses.