The revision of the art. 8 of the EPBD must ensure the right-to-plug to all EV users in order to facilitate the installation of charging infrastructure for tenants and properties under shared ownership aligned with Spanish, Dutch and Norwegian legislations and the current EPBD recommendations. In France for instance, condominiums still face barriers when wishing to implement charging solutions due to non-adapted standards.

The EC needs to tackle the remaining obstacles for the installation of charging points in buildings by removing the unnecessary exemptions applied to SMEs and addressing the administrative hurdles (e.g. EV charging as extralegal benefit for employees) as well as collective action problems (e.g. split incentives between EV and non-EV drivers, renters vs. owners, employee vs. employer, etc.). The EC should ensure that the right to plug is as simple as a subscription to other services like internet, phone provider, etc. The request for the installation of charging stations in collective properties should not exceed 3 months. EV users without charging station at home should have a right to plug at work.

Aligned with a definition on smart charging that the Platform urges to be introduced in the revision of the Alternative Fuels Infrastructure Directive (AFID), the existing requirements set in art.8 of the EPBD should be strengthened to support the deployment of smart charging in multi-family and nonresidential buildings in order to provide flexibility services to the power system via EV connection to the grid and to buildings.

The EPBD must be revised in coherence with the AFID to ensure the same level of ambitions in both texts and a coherent framework for the deployment of charging infrastructure across Europe. In line with the Renovation Wave, the EC also needs to ensure that funding and recovery plans tackle the rollout of smart charging infrastructure in the building renovations. A long-term funding programme (about 10 to 15 years) for local authorities and governments could be developed for example and channelled through the Member States to support the cabling of residential and office buildings’ in all parking spots.

1. General Comments

Establishing a level playing field between all modes of land transport requires an ambitious revision of the Eurovignette directive. A level playing field across single market will then allow the development of a clean transportation system in Europe. Both rail and Zero Emission heavy duty vehicles ZE HDVs) will benefit from it, therefore reducing the impact of land transport on the environment. Revising the Eurovignette directive is therefore a necessary step towards 2050 climate objectives.

Two aspects of the new Eurovignette directive can have a true and significant impact on the deployment of ZE HDVs: external cost charges for air and noise pollution on the one hand, and improving the CO2-based tolling system on the other. Internalization of cost and an improved tolling system will significantly reduce CO2 emissions. The distance-based infrastructure charging coupled with CO2 differentiation is the ideal for incentivizing cleaner vehicles. Here external cost charging is crucial as well as the application of the “polluter pays” principle.

This reaction paper presents the Platform for electromobility’s point of view vis-à-vis the positions adopted by the European Parliament and the Council. Although ideally the “polluter pays” principle will be applied in all modes, the paper provides the realistic expectations of the electromobility sector to actors in the trialogue negotiations. This paper complements a precedent paper issued after the Commission’s proposal in 2017.

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Introduction

Last year, the electric car market reached a tipping point in the EU with sales surging to 10,5% on average. However, to meet the EU climate goals and achieve the target of 30 million zero emission vehicles on the road in 2030 set by the EU Smart and Sustainable Mobility Strategy, steep the acceleration in the sales of electric vehicles (EV), the deployment of EV charging infrastructure and the extension of public transport is necessary. The European Commission has set the objective to reach one million public chargers in 2025 and three million in 2030 and thus the fair contribution of each Member State (MS) towards reaching that target is key.

As part of the Recovery and Resilience Facility (RRF), the EC strongly encourages Member States to put forward investment and reform plans on the so-called ‘Recharge and Refuel’ flagship. This flagship is identified as one of the areas for investments and reforms with tangible benefits for economy and citizens across the EU^[1].

In order to make climate objectives and tap on the benefits of clean and cheap electromobility, it is essential that Member States place a strong focus on the ‘Recharge and Refuel’ flagship in their recovery plans. Both private, commercial and public charging infrastructure for cars and vans as well as public transport infrastructure should absolutely be on top of the agenda, while charging infrastructure for heavy commercial vehicles should also be clearly targeted. The electric truck market, from commercial urban vehicles to long-haul trucks, is expected to ramp up quickly in the next years which means that financing and funding support are necessary to support the rollout of the dedicated charging infrastructure: at the depot, at the distribution centre and at public locations, being it urban areas or along highways.

Given that charging infrastructure is disproportionately concentrated in 4 countries, special attention should be paid to ensure that new stations funded under the NextGenerationEU program are more distributed and that the proper ambitions are expressed in all MS proposals. That is the only way to reach the 3 million target in 2030 and ensure there is a truly pan-European network for all EU citizens.

Overall, the principle of cost-effectiveness should steer the support towards increased electrification of road transport across all vehicle segments. From small vehicles to heavy-duty trucks with long-range transport applications, the battery technology is proven to be the cleanest, most energy-efficient and competitive alternative for the long-term and should therefore be prioritised in the road transport decarbonisation plans of the Member States.

This Guidance Paper provides some recommended elements that Member States should prioritise in their recovery plans and that the EU evaluators should look for in evaluating MS plans. The Platform for Electromobility strongly feels that these elements are key to ensure that the deployments under the RFF meet the needs of EV drivers and public transport users across the EU and to form the necessary trigger for accelerated private investment. It is essential that Member States place a strong focus on the Recharge and Refuel Flagship in their recovery plans and prioritise RRF funds towards charging infrastructure.

To make sure public funds are allocated in the most targeted way, the Platform believes Member States should develop national e-mobility and related infrastructure masterplans, which include ambitious deployment targets for both vehicles and infrastructure and form the basis of the allocation of the public investments. These plans and targets will provide the necessary trigger for private investment.

1. All types of locations and all use cases should be targeted

In order to ensure that the Recharge and Refuel Flagship proposals in the Recovery and Resilience Plans submitted by MS achieve the goals laid out by the EC, it is critical that they look broadly at all the opportunities and locations where charging infrastructure and electric road system can be deployed. Investments should also target national EV charging networks for long distance travel. Specific support should also be considered for operators looking to invest in charging deserts. We elaborate on some specifics in the next two points:

• Private, semi-public and public charging

The major growth areas for EV charging are workplace and community locations, including multi-unit buildings and (semi-)public charging in residential neighbourhoods. In many cases, especially shared private facilities, private charging infrastructure performs the same function as public infrastructure, being accessible to multiple users. MS plans must prioritise significant EV infrastructure deployment at these types of locations, based on their national needs’ assessment and ambitions. In this regard, a close collaboration between national and local authorities in developing such plans is key to steer recovery funds towards relevant investments needs for charging infrastructure.

• Develop and modify local building codes to provide specific rules and guidance around the deployment of EV charging infrastructure in new and existing buildings.
• Set a pre-installation requirement of EV charging infrastructures in the design of new buildings and a specific requirement for community infrastructures which enable smart charging.
• Support the “right to plug” so that interested tenants in a building have the standing to request an EV charging station in their building/at their parking space and simplify the administrative procedure for the installation burden is on the municipality or other responsible parties to object, and planning funds are available.
• Address the “first mover” problem by earmarking funds to support the wiring and cabling of the shared/communal portions of new and existing buildings.
• Make public funds available for some private and semi-public charging infrastructure, where it supports a whole group of users (such as employees of a company, vehicles in a depot, tenants of a building, visitors to a building, etc) – i.e. more than just the single owner of the vehicle.
• Destination charging at public parking facilities (e.g. shopping malls, sports facilities, restaurants, hotels, etc.) are essential and should also be supported.
• Do tendering processes in a way to support open markets and optimal service delivery and ensure the best companies for installing and operating EV charging infrastructure are selected through a fair and competitive process.
• Take into account the extension of public transport infrastructure (e.g. for electric buses) in MS plans.
• Dedicated focus on electric trucks, which yield the greatest synergies

Fully electric heavy-duty vehicles (HDVs) are very much a reality and already driving on European roads. The number of these will rise quickly in the years to come. Member States must plan for this by deploying the proper infrastructure.

By planning for the growth of the battery electric vehicles (BEV) HDV’s, Member States can also generate the greatest infrastructure synergies, as in some cases these hubs can support a range of high and lower power users.

• Funds should be used to encourage the creation of high-powered charging hubs to support HDVs and other users should be planned and developed on main roads and highways, at rest areas, near off/on ramps around logistics hubs, and at depots
• Funds and plans must consider the state of the electricity grid and the need to either extend or upgrade it or provide options for local onsite generation from renewable energy sources coupled with onsite storage.
• Grid capacity should be factored in decisions to build or upgrade a truck resting area to facilitate such high-power charging (e.g. megawatt chargers). This could help lower deployment costs and accelerate grid readiness for e-trucks to come.

2. Deployment and investment decisions should be based on data and real conditions

Proper planning for charger deployment and (possible) grid improvements require data to inform those decisions. Data on existing charging stations and grid conditions should be made promptly available (to municipal, regional authorities and relevant industry actors).

• To prepare such a plan properly, data is needed to understand the situation now, needs and gaps
  • Funds must be made available to support MS in gathering this data.
  • The capacity building of grid operators to be part of local infrastructure planning should be enlarged. The process of involving DSOs could include municipal, regional and highway charging infrastructure planning, the development of best location-plans with information on grid capacity and reinforcement needs, with information on costs being made available to all relevant industry actors directly involved in establishing the business case of the operation of the infrastructure, while respecting all data privacy requirements.

• For proper infrastructure deployment planning purposes, data is needed to map:
  • Current infrastructure (in Charge Point Equivalent terms)
  • Geographic coverage and gaps
  • Available power levels
  • Accessibility of stations
  • Grid capacity (overall and at precise locations)

3. The grids should be prepared for increased EV integration

The MS plans should require distribution grid connections and available capacity to be future proof, by defining minimum standards which will be necessary for the upgrading and the extension of the infrastructure network, both in urban and rural areas.

• Grid capacity upgrade support should be factored into decisions to build hub areas, commercial parking spots, or resting areas to facilitate high power charging. This could help lower deployment costs and accelerate grid readiness for different types of vehicles, from ride-hailing vehicles to e-trucks.
• Sufficient tools should be given to distribution network operators to operate the grid in the smartest way possible; time-varying network tariffs aimed at shifting EV network use away from peak hours in order to reduce the need for grid reinforcement for example can help to address grid capacity or congestion challenges at particular locations.

4. Interoperable infrastructure should be embedded and roaming enabled

The adoption of open, non-discriminatory and interoperable communication standards in EV charging infrastructure as a key requirement is fundamental to facilitating a seamless charging experience for the driver across national EV charging networks, but also across borders.

Publicly accessible charging infrastructure at commercial or public locations should never be locked into an equipment or network provider, either commercially or technically. Any publicly financed charging stations under the RRF should therefore require open protocols and standards for the backend communications and for enabling smooth roaming. This will help to encourage and accelerate the uptake of EVs and address availability concerns by EV drivers.

At the same time supporting infrastructure that enables roaming on publicly accessible charging stations will allow drivers to charge at stations belonging to the network of another operator (not their “home” operator) with a single subscription provided by a mobility service provider. This applies both within and across national borders. The MS recovery plans should therefore steer eligible publicly accessible charging stations to require the use of the open, roaming communication protocols to facilitate roaming agreements.

5. Smart-charging should be future-proof

EVs could help realising the EU’s renewable energy objectives by increasing the share of RES in the network through smart charging. Future charging stations should be prepared to deliver a basic level of smart charging services, e.g through load balancing and time of use, in particular in regard to private charging at home and/or in residential areas when there is not possibility for EV users to install a charger in the building. It will be important to work towards a situation in which smart and bi-directional charging are standards applied in practice in the coming years. The plans should therefore include smart charging incentives:

• Incentives should focus on supporting the business case for smart charging, for instance by facilitating variable time-based pricing policy, but not prescribe technical means to achieve this additional capability. These facilitating measures should focus on increasing the willingness of consumers and their ability to participate in smart charging.
• Support could also cover the risks in business cases of market parties in the roll-out and/or the operation of smart- or bi-directional charging infrastructure.
• Support should be steered towards future innovations, such as smart charging and state of the art system integration technologies, including vehicle-to-grid (V2G) capability.

^[1] European Commission (2020), EU Recovery and Resilience Facility: https://ec.europa.eu/info/business-economy-euro/recovery-coronavirus/recovery-and-resilience-facility_en

Read full paper here: PDF

In the past years, electricity-based transport technologies, such as electric vehicles (EVs), have significantly developed and decreased in cost. These technological improvements and demonstrated benefits of electrification call for an improvement of the sectoral target for renewable energy in transport to better reflect the positive environmental contribution of electric transport, as part of the envisaged reopening of the Renewable Energy Directive 2018/2001 (RED II). In parallel, EU Member states’ National Energy and Climate Plans (NECPs)’ pledges show prospects for an accelerated deployment of renewables in the energy mix, and in particular in the electricity system, supporting the decarbonisation of transport along the full lifecycle of the fuel.

While many studies have demonstrated the scope for an increased volume of renewables in transport[1], it is critical that the Renewable Energy Directive’s framework for renewables in transport is revised to accelerate the electrification of the transport sector with renewable electricity generation.

The Platform therefore recommends introducing an obligation for Member states to introduce fuel-neutral credit trading mechanisms as a mean for obligated fuel suppliers to account for renewable energy used in transport.

The implementation of the RED II, which all Member states (MS) are required to transpose by June 2021, offers a great opportunity to accelerate EV uptake and the efficient penetration of renewable electricity in the transport sector. Yet, most MS and their national policies on renewable transport fuels still do not allow electromobility to contribute to the achievement of the RES-T target[2]. Most national policies still implement the RED II by means of a blending mandate imposed on the obligated parties, i.e the fuel suppliers. Yet, renewable electricity is not a drop-in fuel that can be blended and is not properly accounted in RES-T targets, creating a missed opportunity to properly reflect the decarbonisation of transport and creating a missed level playing field.

The introduction of fuel-neutral credit trading mechanisms could support the adaptation of the RED II framework to the accelerated electrification of transport. Fuel-neutral credit trading mechanisms consists in requiring obligated parties to meet their renewable energy obligation by means of fuel-neutral credits, accounted in energy equivalent (kWh, KJ, Gcal or other). In parallel, fuel-neutral credits are allocated by a public authority to defined parties for each energy unit of renewable fuel used in transport. As for electricity, various possibilities exist concerning the party entitled to receive credits (charging station operator, electricity supplier, etc.). Obligated parties can then either acquire fuel-neutral credits by increasing blending in their fuel supply or by procuring credits from third parties through a dedicated platform. Such schemes have already been introduced in the Netherlands, in Germany, in California and in France, and are being elaborated in Canada[3]. The Platform believes credit revenues shall be used as a leverage to support electromobility in Member States.

Electricity credit mechanisms represent a low hanging fruit that could adequately value the contribution of renewable-based electromobility to the decarbonisation of transport. Importantly, they would also generate resources for the diversity of players in the electromobility sector without weighing on state budgets. For instance, credit revenues could support charging point operators to improve the business case of charging infrastructure and – as a result – accelerate the roll-out of the millions of chargers needed and help the EU reach its objective of establishing 1 million charging points by 2025, as set out by the European Commission in its European Green Deal communication[4].

Further, future credit trading mechanisms should follow the specific principles below, subject to implementation in Member states:

• Fuel neutral credits should be granted for the renewable share of the electricity used in EVs, calculated on the basis of the share of renewable electricity in the national mix as close as possible to real-time. This would incentivize for a better real-time match between the renewable generation and EV charging.
• Future credit mechanisms should allow for the accounting of 100% renewable electricity used in transport. As a principle and as specified in article 27 of the RED II, fuel neutral credits should be granted for the renewable share of the electricity used in EVs, calculated on the basis of the share of renewable electricity in the national mix in the previous maximum two-year period. Yet, Member states should also allow for the accounting of 100% renewable electricity supply to transport, such as electricity supplied through a direct connection to a renewable energy generator or via an innovative supply contract such as Power Purchase Agreement (PPA).
• As most kWhs used by EVs will be charged at home or in the workplace and not at public chargers, it should also be assessed how future credit mechanisms could account for the renewable kWhs charged at home or in the workplace, which will also enable to maximize the share of electrons captured.

[1] Among other studies: 17% of final energy demand in transport will be renewable by 2030 (in final energy demand, without multipliers or subtargets) according to SolarPower Europe (2020). 100% Renewable Energy Europe

[2] Transport & Environment (2019) Using Renewable electricity in the Renewable Energy Directive

[3] On the Dutch, German and Californian example, see Transport & Environment (2019) Using Renewable electricity in the Renewable Energy Directive.

The government of Canada is considering establishing a clean fuel standard that will count and credit clean electricity used. Networked charging operators (including utilities operating charging) and, in its 2018 Proposed Regulatory Approach, proposed that automakers be able to participate using vehicle telematics in the crediting system and market.  Canada’s program is expected to start in 2022. For further information: https://ww2.arb.ca.gov/resources/documents/lcfs-electricity-and-hydrogen-provisions

https://www.emissionsauthority.nl/topics/themes/energy-for-transport

The French government is designing a crediting system too as part of the revision of its 2021 budget bill, in current article 15. For more information, see http://www.assemblee-nationale.fr/dyn/15/textes/l15b3360_projet-loi

[4] https://ec.europa.eu/info/sites/info/files/european-green-deal-communication_en.pdf