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Platform’s proposals to boost zero-emission vehicles in corporate and urban fleets
Platform’s proposals to boost zero-emission vehicles in corporate and urban fleets
With the European Union agreement on -55% greenhouse gas emissions (GHG) by 2030, all economic sectors will have to pull their weight towards this goal. Unfortunately, the transport sector has a poor decarbonization track-record with emissions steadily growing since 1990.
Looking at all transport modes, road transport is still the largest emitter (71%) and will remain so in the near future[1]. Recently adopted CO2 emission performance standards, investment in charging infrastructure, etc. will eventually drive down emissions, but new initiatives aimed at “quick wins” are needed to fast-track decarbonization.
These initiatives should be based on the idea that when fighting against climate change and local pollution, not all vehicles are equal. Fleet vehicles (i.e. corporate fleets) drive on average 2.25 times[2] more than private cars. Public fleets, such as urban buses which account for 8%[3] (per passenger per km) of greenhouse gases (GHG) emitted by the transport sector, are also big players. Last but not least, as fleet vehicles are often parked in depots and large parking lots, their batteries could be used to optimise the RES integration and the use of smart charging could provide benefits to local utilities and to the whole power system[4].
Against that background, the Platform for electromobility welcomes the European Commission’s ambition to electrify public and corporate fleets recently introduced in the Smart and Sustainable Mobility Strategy.
In this paper, we share our insight and expertise to make this a reality. We first recommend ensuring an ambitious implementation of the Clean Vehicle Directive (CVD) for public fleets in all Member States (MS). Second, new legislation dedicated to the electrification of corporate fleets should be envisaged.
Implementing the Clean Vehicle Directive
While at its adoption in 2019, we expressed our enthusiasm that the CVD would pave the way for a broad deployment of clean vehicles across Europe – electric buses in particular – it seems likely that few MS will transpose the directive in time.
As of April 2021, only France has implemented the directive, and only a few more MS have started the transposition process which is due to be completed by 2nd August 2021. There is a risk that an unequal transposition of the directive will lead to fragmentated and non-harmonized access to clean transportation and its benefits for citizens between MS.
Recent bus registration figures also show that while the sales of electric buses are progressing, most countries are still nowhere near the CVD targets [6]. Therefore, we call the legislators to push for a better and faster implementation of the CVD in most MS. National governments should make the best use of available funds, including national and European recovery plans, to achieve the targets of the directive.
Electrification of public fleets covered by the CVD is only one step on the road to a 90% cut in transport emissions by 2050. Electrifying corporate fleets[7] constitute another powerful leverage towards the decarbonation of transportation in Europe.
Leveraging corporate fleets to curb emissions
Corporate cars represent millions of high-mileage vehicles circulating in Europe with a high turnover. They now also represent the main part of the car market in Western Europe. According to a recent Deloitte[8] report, in 2010 the private and corporate market segments were almost equally large in Western Europe (respectively 7.3 million vs. 7.2 million car registrations). In 2016, the balance had already tilted in favour of corporate cars (58%), and by 2021, Deloitte forecasts a share of new car registrations of 37% for the private and 63% for the corporate channel. In countries not covered by the study like Poland, corporate cars share in a new passenger car market is even larger, reaching 75% in 2020[9].
Corporate cars quickly become private cars via the second-hand market after an average ownership of 36 to 48 months. Most Europeans indeed purchase private cars after they used corporate functions[10]. The electrification of corporate fleets is therefore key to also electrify the whole stock (owned by individuals) with a reasonable time gap.
Corporate fleets represent 20% of the total vehicle park in Europe, 40% of total driven kilometers but is responsible for half of total emissions from road transport. Starting with corporate fleets is the quickest way to reach emission cuts.[11]
Additionally, corporate cars are highly visible in our cities. By leading by example and supplying the second-hand market, electrified corporate vehicles will increase acceptability and accessibility of electric cars for European households. The electrification of this market therefore is not only a ‘low hanging fruit’, it has significant indirect impacts on other markets. As such, it is a major element for the electric vehicles (EVs) market to reach a critical mass.
Additionally, corporate cars are highly visible in our cities. By leading by example and supplying the second-hand market, electrified corporate vehicles will increase acceptability and accessibility of electric cars for European households. The electrification of this market therefore is not only a ‘low hanging fruit’, it has significant indirect impacts on other markets. As such, it is a major element for the electric vehicles (EVs) market to reach a critical mass.
Yet, the electrification potential of corporate vehicles remains largely untapped, due to a lack of clear rules and incentives. Indeed, along with main files such the Eurovignette Directive currently under negotiation, and which would be an important incentive for greening fleets, a whole patchwork of initiatives is included in existing and upcoming legislations. We remind that a successful electrification of corporate fleet shall be linked with a strong roll-out of public and private of charging infrastructures. Annex 1 below outlines our positions on these legislative files and why they will suffice to yield the way to a full decarbonisation of corporate fleets.
With no legislative instrument at hand today, the European policy lacks teeth when it comes to electrification of corporate fleets. We invite policy makers to require more and more fleets such as company cars, taxis, leasing and renting companies and delivery vehicles to electrify, and support companies towards this goal.
To do so, we call for the establishment of a new single regulation dedicated to the electrification of corporate fleets.
Call for a new proposal on the electrification of corporate fleets
A new legislation on the electrification of corporate fleets would set a clear path and objective. This new legislation should include the following provisions:
For a start, such a legislation should equally apply across the European internal market. Therefore, we believe a regulation would be the most suitable legislative instrument to accelerate fleet electrification. The regulation would harmonize the European market by preventing risks of increased gaps between MS during the implementation. This is particularly important for internal market cohesion and regulatory clarity for businesses owning fleet across the EU. A regulation would have the final benefit of having a direct effect.
A realistic yet ambitious mandate should be put on companies to decarbonise their vehicle fleets in accordance with the European Green Deal’s objectives. Fleet electrification is a journey that requires following a roadmap and trials before scaling up in largest companies. Considering the timing of application of the regulation and the ability of companies that recently purchased vehicles or have larger fleets to react a stepwise approach is with interim targets therefore required.
| We recommend setting a gradual approach to progressively but eventually reach the objective of 100% of new vehicle purchase in corporate fleets to be electrified by 2030. |
To avoid imposing a heavy burden on the smallest companies, the regulation should apply to fleets above a certain size. Thresholds should be based on a robust methodology to consider the different segments, industries and MS characteristics while keeping in mind the lower the threshold, the higher the incentives should be for smaller fleets. Next to the electrification of the corporate fleets, companies should consider multimodal packages where a Zero-emission vehicle is combined with other sustainable transport solutions.
The Regulation’s provisions should differentiate between fleets in their capacity to make the change based on their usual turnover and nature of the transport they perform. Some fleets should face stricter and faster pace to electrification while other could be given more time to electrify. For example, new taxis and private hire vehicles (PHV) committed to drive fully electric vehicles should be issued licences in priority over ICE drivers while fleets in specific industries with technological obstacles (e.g. logging/lumbering industry) may be given derogations.
Along with mandatory targets and compliance mechanisms, incentives for fleet owners will also be needed at European and national levels to accompany the shift. Inspiration for positive incentives should be drawn from lessons learnt from well-designed benefit in kind systems for corporate cars across MS. The Platform for electromobility will soon propose a document outlining such best practices.
[1]https://www.eea.europa.eu/data-and-maps/indicators/transport-emissions-of-greenhouse-gases-7/assessment
[2]https://www.transportenvironment.org/sites/te/files/publications/2020_10_Dataforce_company_car_report.pdf
[3] EU Commission Expert Group on Clean Bus Deployment; D2 Procurement and Operations.
[4] Flagship 1 – Boosting the uptake of zero-emission vehicles, renewable & low-carbon fuels and related infrastructure
[6] https://www.acea.be/uploads/press_releases_files/ACEA_buses_by_fuel_type_full-year_2020.pdf
[7] In this paper, we include into corporate fleets all “Vehicle owned or leased by a private a company, and used for business purposes.”
[8] https://www2.deloitte.com/content/dam/Deloitte/cz/Documents/consumer-and-industrial/cz-fleet-management-in-europe.pdf.
[10] DG Climate Action, European Commission. https://ec.europa.eu/clima/sites/clima/files/transport/vehicles/docs/2nd_hand_cars_en.pdf
[11] “Accelerating fleet electrification in Europe”, Eurelectric, 2021 (www.evision.eurelectric.org)
[12] Infographic on assessing the feasibility (https://evision.eurelectric.org/infographics/) – with examples of several fleet use-cases / Eurelectric
Our response to the consultation on the revision of the TEN-T regulation
What should be the main focus of transport infrastructure policy at EU level?
In the revised regulation, requirements should
1. prioritize zero-emission technologies and ensure the consistent roll-out of charging infrastructure for all modes of transport to be consistent with the decarbonisation of transport sector and the revised AFID,
2. enabling further digitalisation/automation of transport
3. enhance number and integration of urban nodes in the TEN-T corridors’ governance to ensure consistency between corridors priorities & urban policies for transport decarbonation.
What type of adjustment would you deem most necessary?
– Make the minimum target of 1 charging point/60 km mandatory on TEN-T road networks to ensure their coverage with ultra-fast chargers, incl. urban fast charging hubs
– Direct public funding into the Comprehensive network & outside of the TEN-T network
– Support the ERTMS full deployment on the network as a first step to digitalise railway operation & improve its performance (ATO)
– Speed-up Member States’ coordination for cross-border charging and connections
What conditions would you deem most necessary to be extended from the core to the comprehensive network?
– Ensure full coverage of charging infrastructure for all modes of transport on the Core/Comprehensive
TEN-T , and of urban nodes, to reach the decarbonisation of transport and be in line with the revised AFID.
– Support deployment of ERTMS on the Core & Comprehensive Network, and digitalisation of transport
(e.g. development of Automatic Train Operations in rail transport)
– Include requirement on-shore power supply explicitly in the list of priorities for maritime infrastructure
development
Adjustment you deem necessary to strengthen TEN-T implementation instruments?
All implementation instruments should be reinforced to avoid delays that are, in today’s projects, beyond normal level in most TEN-T sites. All proposed instruments should be clearly defined, transparent, proportionate and non-discriminatory In addition, the monitoring of the Member States’ TEN-T guidelines implementation should be reinforced without jeopardizing the implementation targets. Rail investments with CEF 2 funding should be boosted to achieve the 2030 and 2050 TEN-T deadlines.
Are there other measures concerning infrastructure quality and resilience that could be considered?
Cyber-threats are an area of concern for railways which have complex interdependences and legacy infrastructure. Electrification and smart mobility must be considered in light of the cyber security threat that comes along, taking into account the increasing interdependency of the various components and actors of the EU interconnected power system. The TEN-T revision should incorporate the key elements of the forthcoming new EU Cybersecurity Strategy
The revision of the TEN-T regulation should strengthen sustainable and multimodal transport. With the surge of EVs, integrating minimum binding requirements per vehicle type would contribute to giving the right
charging infrastructure to the EU. Boosting digitalisation through intelligent services and charging infrastructure is key to make transport efficient, sustainable, resilient but also more user-friendly.
Another focus area should be to recognize the role of active mobility. Infrastructure quality should include requirements regarding active mobility infrastructure. At the same time, in many places the infrastructure is
simply missing. Especially the potential of Electrically Assisted Pedal Cycles (EPACs), and integrating it into the guidelines. The current TEN-T network is clogged by local commuting, on many sections constituting over 90% of traffic. These are often the most expensive sections. Properly integrating cycling into TEN-T would provide a cost-efficient, healthy and sustainable alternative.
Fit-for-55: how to make europe lead on electromobility
The Commission is due to present its “Fit for 55 package” — aimed at achieving a 55 percent emissions reduction by 2030 — in June. The event will launch the political debate, present and bring together various priorities on each of the main files related to electro-mobility by industrial stakeholders.
Keynotes speeches
Julia Poliscanova, T&E
Daniel Mes, Member of Cabinet of EVP Frans Timmermans
Q&A – with keynote speakers
Self-challenging Panel discussion between sectorial stakeholders*
Suppliers- Emilia Valbum, 3M
Manufacturers
– Marie-France Van der Valk, Renault
– Jos Dings, Tesla
Infrastructures
– Arne Richters, Allego
Rail
– Nicolas Erb, Alstom
Energy-
Giovanni Coppola, ENEL X
Wrap-ups
Views of the demand side – Sandra Roling, EV100
*Representatives from the five key industries of electromobility will challenge each-other in an innovative webinar format based on questions sent ahead of the event by attendees.
Electromobility: a green boost for European automotive jobs?
First-ever beforehand presentation of Study on the impact of the shift to electromobility on automotive employment in Europe
The automotive sector is a major employer facing the largest technological transition it has ever known. The automotive industry and its direct supplier represent today more than 6 million European jobs and over 18 million cars. By 2030, at least 30 millions of them will be operating without traditional fuels on European roads. This ambition by the European Union will lead to an unprecedented shift for the automotive industry which has to transform their production from combustions cars to electric vehicles, as well as a high impact on charging infrastructure needs. When Europe will turn to electromobility, what is the impact on the affected jobs within these sectors?
The Boston Consulting Group (BCG), along with the Platform for electromobility, will be present beforehand the result and findings of their recent study on the impact of the shift towards electromobility for the European jobs in the industry. The study covers affected industries from OEM to Tier’s and infrastructure at a European level. The study shows a major shift within the industry. Countries and regions that will be best prepared to capitalize on emerging opportunities by embracing the shift -invest in the new technologies, create a favorable policy environment, invest in re-skilling workers, etc- will have a much higher chance to do so. Those who hold on to the past will be left with an obsolete industry, decreased demand, and face serious unemployment challenges.
Agenda
Welcome Address – Arne Richters, Chair of the Platform for electromobility
Presentation of the results of the Study and reaction from the European Commission
– Daniel Kuepper & Kristian Kuhlmann, BCG
– Frank Siebern-Thomas, Acting Head of the Unit “Fair, Green, and Digital Transitions” DG EMPL
Panel discussion: Capitalize on emerging opportunities
– Marie-France Van der Valk, Renault
– Julie Beaufils, EuropeOn
– Alex Keynes, T&E
– Representative from Trade Union (TBD)
Closing Remarks – Nicolás Gonzales-Casares, MEP (S&D)
Platform's reply on the revision of EPBD
The Platform for Electromobility warmly welcomes the EC’s willingness to revise the Directive on the energy performance of buildings (2010/31/EU, EPBD).
In light of the roadmap and scenarios proposed by the EC, the Platform does not only take a stand for the option 3 but points out that electromobility needs to be addressed as one of the key elements of the EPBD revision if the EU wishes to deliver the objectives set in the Smart and Sustainable Mobility Strategy, the Energy System Integration Strategy and the Renovation Wave Strategy. The deployment of private charging is as important for the growth of electromobility and the decarbonisation of transport as that of charging accessible to the public. The Platform also thinks that the electric bicycles (incl. e-cargo bikes, e-two-wheelers, e-moped and e-cars) should be considered when revising the EPBD.
Given that 90% of EV charging happens at home or in the workplace and that 80% of the EU’s current building stock will still be in used by 2050, the EC must tackle the outstanding barriers to the installation of EV chargers and collective charging infrastructure in all (non-) residential buildings to ensure that all EV users have a “right to plug”. In this regard, art. 8 of the EPBD should be revised.
To that end, the Platform shares its key recommendations.
Set minimum infrastructure requirements for all types of buildings (new and existing)
The EPBD should encourage Member States to implement measures to pre-equip all buildings. The Platform recommends putting in place minimum requirements for the pre-cabling of the installation of EV chargers and ensuring that all buildings will be pre-equipped by 2035.
Guarantee the right-to-plug to all EV users
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.
Introduce requirements for smart charging
The development of smart charging in buildings is an opportunity for EV users: it ensures a better charging experience, reduces the consumers’ electricity bill1 and could reintegrate the surplus of electricity into the grids (V2G) and/or reuse it in the buildings (V2B). It could also support the uptake of electromobility and can create synergies with renewable energies by integrating them into the electricity grids and providing flexibility services to the system.
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.
Our vision on the future of Eurovignette
- 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.
Air & noise external cost charges
Based on ‘user pays’ and ‘polluter pays’ principles, road charging will make logistic cleaner and limit transport’s climate impact. The Platform for electromobility supports the Parliament’s position on air and noise external cost charges (Am. 68). This support is conditional to:
Air and noise pollution should always be considered together. External cost charge shall be applied for traffic-based air and noise pollution to HDVs by Member States levying tolls. The fight against one pollution type should not be at the expense of the other. Applying external cost charge to either/or of these two pollution types would contradict the ‘polluter pays’ principles. (To avoid any doubt, an external-cost charge for air and noise pollution should not be added as a choice that would rule out varying the infrastructure charge for CO2).
The Platform promotes external-cost charging – in principle for all vehicles – by reducing scope for exemptions. External cost charge should not be limited to HDVs and to “vans intended for carriage of goods”. Road charging will then contribute to an efficient transport system, where prices reflect the true external costs of logistic. It will thus give clean options, such as electric road vehicles but also trains, a level playing field to compete. It will also reduce risks of switching between vehicle categories (e.g. trucks to vans).
Finally, external-cost charging should be made mandatory for HDVs on all tolled roads within the scope of the directive from April 2023 (the same time as CO2 variation becomes mandatory on these same roads).
The Council’s position however raises concerned about the certainty of the application of various measures. Indeed, the text proposed by the Council leaves a great deal of discretion to the Member States to grant exemptions. It makes pollution charged only mandatory “where environmental damage generated by heavy duty vehicles is the most significant” (italics added). Because the terms “the most significant” are not defined to ensure the enforceability of the provision, the Platform suggests removing this condition and making an external cost charge for traffic-based air and noise pollution mandatory for HDVs on all tolled roads.
Any exemption to apply air and noise external noise costs on the tolled network should be very limited. Additionally, the burden must shift to MS to supply to the Commission the information backing the decision not to charge any particular road section in each case. Diversions can be an example of a very limited exemption. Such an exemption could be allowed where a MS is able to demonstrate that adding air and noise external costs on a particular road section would likely and significantly increase the number of freight vehicles diverting to use a non-tolled alternative.
CO2-based tolling
The Eurovignette should not be only about the stick but also about the carrot: shifts to cleaner vehicles should be somehow rewarded. The Platform therefore welcomes the toll reduction for “CO2 emission class 5 – zero-emission vehicles” (ZEVs) from 50% to 75% applicable from April 2023, noting that a toll reduction of up to 100% can be given until the end of 2025. An adequate, clear, easily-applicable tailored methodology should accompany these measures, based on E.U. emissions standards, in order to provide visibility and transparency in road charging schemes.
Beside, on LDVs, the CO2 variation of tolls should remain mandatory as proposed by the Commission.
Finally, the Council proposed a well-developed and balanced, system of CO2-based tolling which could be embraced almost entirely, adding the following improvements:
- Secure mandatory re-classification of emission class 2 and 3 vehicles after 6 years – not merely an ‘assessment’ as currently provided for in the Council GA.
- Ensure more time certainty regarding the timeframe for emission classes 2 and 3; [X] on p47 of the GA should be 6 months.
These two improvements are important. The first would help to differentiate classes in a future proof manner because without mandatory reclassification, there would be failure to keep pace with the linear emissions reduction trajectory upon which the truck CO2 standards are based, and Member States could take conflicting approaches to trucks six years after their first registration. Second, time certainty is important for emission classes 2 and 3 so that truck sellers and buyers have clarity over the likely toll costs of planned vehicle sales/purchases. With investment certainty, more sustainable purchasing practices and technologies are incentivized.
A revenue neutral approach
Distance-based infrastructure charging, when coupled with CO2 differentiation outlined in the previous section, is ideal for incentivizing the shift towards cleaner vehicles.
The Platform supports revenue-neutrality for the CO2 differentiation of tolls as outlined in 7g4: “The variations referred to in this Article shall not be designed to generate additional revenues”. To show relevant variations over time, annual reporting by Member States should also include toll revenues per vehicle-km, by weight and axle category (art. 11.2f).
The intended effect of the CO2 differentiation of tolls is to incentivise users to switch to cleaner vehicles, leading to decreased tolls for zero emission vehicles in particular. Such a decrease is to be offset by a higher level of tolls (average toll rate), in respect of ‘user pays’, but also for the sake of fair competition with other transport modes such as rail.