ETS 2: Staying the course for an effective and fair transition to e-mobility
Vehicles & Markets
The Platform for Electromobility, representing a broad coalition of industries committed to the decarbonisation of transport, reiterates its firm support for the timely implementation of the ETS 2 (Emissions Trading System for road transport and buildings) as scheduled in the previous mandate, in line with the vote of the European Parliament on April 18, 2023.
1. Uphold ETS 2 to unlock investments
Rolling back or delaying the ETS 2 would undermine investor confidence and reduce the available financial tools to accelerate the uptake of electric vehicles, the development of alternative and collective mobility modes, and related infrastructures. The new system is not only a pillar of the Fit for 55 package, it is also a key driver for directing public and private capital towards the clean transition ecosystem and industries.
Any deviation from the agreed implementation path would generate uncertainty, reduce the credibility of the EU’s climate framework, and jeopardise our ability to meet emissions reduction targets.
2. Timely transposition: a key step for fair and effective implementation
As of today, only 10 Member States have transposed the ETS 2 directive into national law. Accelerating transposition is essential to ensure a coherent and effective rollout of the system across the EU. It will provide legal certainty, enable better coordination among stakeholders, and help deliver the expected climate and social benefits in a timely manner. Encouraging swift action from all Member States will also strengthen the credibility and impact of ETS 2 as a key pillar of the EU’s climate policy.
Moreover, citizens and businesses need a clear price signal. A stable and well-communicated carbon price will encourage behavioural change, spur investment in energy efficiency and zero-emission solutions, and support long-term planning across the value chain.
3. Ensuring ETS 2 is effective and socially fair
To guarantee that ETS 2 delivers both environmental and social outcomes, we recommend the following measures:
- Reinvest 100% of ETS 2 revenues into decarbonisation and targeted social support. We call to ensure transparency and additionality of Member State spending, so EU funds do not replace existing national support schemes.
- Strengthen complementary policy tools: ETS 2 must work alongside a robust regulatory framework. This includes preserving the CO₂ reduction ambitions for cars and heavy-duty vehicles, supporting the Clean Corporate Vehicles initiative, and ensuring the rollout of charging and multimodal infrastructure.
- Frontload ETS 2 revenues. We must accelerate investment to protect vulnerable groups from the impact of rising carbon prices and to deliver visible benefits early in the transition.
- Reinforce the Social Climate Plans (SCPs): push Member States to increase the co-financing rate above 25% to ensure meaningful national action.
- End fossil fuel subsidies: Use ETS 2 as an opportunity to rebalance taxation in favour of electrification, including reducing the tax burden on electricity and removing outdated exemptions for fossil fuels.
- Early auctions should be launched in 2026. Early auctions would help market participants form their view on expected prices. It would be a market friendly move to enhance transparency and ensure a smoother transition into full system operation.
Conclusion
"ETS 2 is not only about cars – it is also key to decarbonising heavy-duty transport. By sending a predictable price signal, the system will support investment in zero-emission trucks, strengthen the CO₂ standards for heavy-duty vehicles, and accelerate the rollout of charging and refuelling infrastructure needed for long-haul freight."
— Koen Noyens, Head of Public Affairs, MILENCE
ETS 2 is a cornerstone of Europe’s decarbonisation strategy. It must be implemented as planned to send a clear signal to markets, enable effective carbon pricing, and channel investments into clean mobility. Our coalition of industries stands ready to support this effort and ensure that ETS 2 is both socially just and economically effective.
Swift and Smooth | Cross-sectoral recommendations for a swift transport electrification, smooth for the grid
ENERGY & INFRASTRUCTURES
The transport sector is electrifying across the EU. Optimised integration of electric vehicle (EV) charging infrastructure to distribution grids is one of the main enablers to EV uptake. Currently, System Operators[i] face a high number of connection requests from sectors electrifying in parallel while often being bound to managing these requests on a first-come-first-served basis. At the same time, electrified transport offers significant flexibility potential from battery storage, which can be leveraged to optimise use of existing grid capacity, notably when using smart charging solutions.
In this context, the members of the Platform for Electromobility recognise the need for a policy framework that supports beneficial and grid-friendly transport electrification. We welcome the opportunity to contribute to the development of such a framework following the announcement of the Automotive Action Plan. With this paper, we align our views on three key topics addressed by the upcoming Action Plan:
- Acceleration of grid connection requests
- Standardisation for interoperability and data exchange
- Future needs to guide anticipatory investments
As announced in the Automotive Action Plan, the Commission is working on the Guidance and recommendation on shortening grid connection procedures and grid connection prioritisation. The Platform welcomes the initiative, considering the unprecedented demand for grid connections from various sectors and recognising that Member States need flexibility in their approaches to grid connection queue management beyond ‘first-come, first-served’ as the default method. We see the upcoming Guidance as going in the needed direction of greater harmonisation of grid connection processes across the EU where currently, practices differ greatly among system operators.
This paper outlines shared recommendations from our sectors on how European legislators can support us in addressing these challenges in a coordinated and forward-looking manner[ii].
[i] System Operators in this document refers to both DSOs and TSOs [ii] The Platform would like to thank the Regulatory Assistance Project (RAP) for its technical advice supporting this paper.
I. More efficient grid connection requests
Recommendation 1/ Prioritising grid connection requests
Many system operators have identified inefficiencies with the ‘first-come, first-served’ approach, such as “ghost applications” to secure potential charging sites. System operators should have the possibility to actively manage these queues, with proper guidance from their national governments and regulators, where ‘first-come, first-served’ is no longer useful for their customers or themselves. Some Member States[i]are already moving beyond this principle by introducing criteria for projects to be connected, e.g. mature and fully developed projects, projects that provide system value. The Platform recommends that the Commission consider the options mentioned in this paper in view of accelerating grid connections while using tools to use existing grid capacity most efficiently.
The prioritisation of grid connection requests to manage limited grid capacity more efficiently and reduce connection queues is essential to enable a timelier connection of critical infrastructure for the electrification of transport – particularly charging stations for electric heavy-duty vehicles (e-HDVs). Clear criteria for prioritisation should be established at European and national level by governments and national regulatory authorities (NRAs). These guidelines should allow system operators to prioritise projects that provide the greatest benefit to the grid and society and, at the same time, give system operators legal certainty in their allocations of grid connections.
[i] European Commission. (2023, December 14). Communication on future-proof network charges for a decarbonised and increasingly digitalised electricity system. https://energy.ec.europa.eu/publications/communication-future-proof-network-charges-reduced-energy-system-costs_en
Recommendation 2/ Balance technological neutrality with emerging markets needs
Guidelines for prioritising requests must be integrated into the regulatory framework to avoid delays and ensure that urgent, high-priority projects are fast-tracked. It is important to note that, under existing regulations, DSOs and TSOs must remain technology-neutral in their planning and investment decisions. While no specific technology type should be prioritised by default, the application of clear and objective criteria can help identify projects that offer the greatest system-wide value. In this context, EV charging projects that enhance overall network efficiency, resilience, and flexibility may merit prioritisation, provided they are assessed based on their contribution to broader system benefits.
In emerging and still-fragile market segments, such as infrastructure for eHDVs, some degree of prioritisation may be justified, particularly where projects demonstrate clear potential to contribute to grid flexibility or resilience. Similarly to how renewable energy projects were prioritised in the early stages of the energy transition, certain eHDV charging projects may warrant faster access through the connection queue, provided they meet predefined, transparent criteria. The Clean Transport Corridors initiative under the EU Automotive Industry Action Plan offers a relevant example of how public authorities can support the roll-out of strategic infrastructure without undermining technology neutrality for system operators, by focusing on systemic benefits rather than specific technologies.
Recommendation 3 / Regularly updating grid hosting capacity maps
To accelerate grid connection processes and support efficient deployment of recharging infrastructure, accessible and regularly updated information on available grid capacity should be accessible. Examples from Flanders show that maps with regularly refreshed data and clear visualisation significantly improve stakeholder engagement and planning. Conversely, tools such as the Dutch colour-coded heatmaps, while a step forward, have limited usability. In the UK, the open data portal also is a promising model[i][ii] . Overall, increasing the digitalisation, transparency, frequency, and functionality of capacity maps would empower project developers, reduce delays, and support more effective grid usage. In order to ensure harmonisation across the Union, we call upon the European Commission to create open and updated pan-European grid capacity maps to coordinate with project promoters on locations already available for grid connection. Regulators should ensure that such improvements are incentivised or at least cost-neutral for DSOs and TSOs.
[i] UK Power Networks. (n.d.). Open Data Portal. Retrieved June 30, 2025, from https://www.ukpowernetworks.co.uk/our-company/open-data-portal
Recommendation 4/ Digitalisation of requests via confidentiality agreements
Digitalisation and standardisation are increasingly recognised as essential enablers for managing the growing volume and complexity of grid connection requests. As electricity demand rises, manual approaches are no longer sufficient. Digital tools should not only streamline internal workflows and technical assessments for system operators, but also ensure that those requesting a grid connection, such as CPOs and other stakeholders, have easy and transparent access to key information. This includes the procedures to submit a connection request, timelines for each step, the current status of their application, and any additional relevant updates. Making this information accessible through digital means is crucial for improving transparency, predictability, and efficiency in the connection process and any additional relevant updates and upfront information on costs and fees.
To fully leverage these advancements, there is a clear need for transparent and accessible information for current and future connection request and plans to be provided by CPOs to DSOs. For a competitive and well-functioning market, it is essential to ensure information on CPOs’ future connection request and charging network planning is shared bilaterally with involved DSOs in a manner that ensures confidentiality and protect commercial sensitivities when this information is needed for DSOs to prepare network development plans and efficiently plan infrastructure upgrade and modernisation
Recommendation 5/ Flexible grid connection agreements
Electrification of transport increases the load on electricity distribution grids, leading sometimes to network congestion during specific periods of time of certain days. By introducing flexible, timed connection options while new distribution infrastructures are built, peak-time demand can be managed more effectively, ensuring that more EVs can be connected to the grid without causing congestion or reducing grid expansion cost. When deemed necessary by the system operators, flexible connection agreements can accelerate the efficient and timely connection of new projects to the grid. In some Member States, such as Sweden, certain grid operators already offer flexible grid connections; however, they face uncertainty in managing the technical aspects due to the lack of complete standardisation.
These agreements, often useful as a temporary solution before physical grid reinforcement should include provisions for vehicle-to-grid readiness, smart charging capabilities, and power requirements for different charging use cases (e.g., ultrafast vs. overnight). Such agreements can in some cases, such as charge points with limited hours of operation, be a more permanent solution when there is a specific agreement in place for that situation. It should also be acknowledged that the concept of flexible connection is defined differently across Member States, and national interpretations and frameworks may vary accordingly. This can facilitate the early adoption of zero-emission vehicles of all sorts however, the regulatory framework must support timely investment in the grid, with a clear timetable for the provision of firm capacity. Without replacing market-based alternatives, permanent flexible connection agreements could also be offered as a viable solution only if agreed by both parties
Recommendation 6/ Smart pricing to ensure best use of existing power networks
Enabling smart and, where possible, bidirectional EV charging, based on the growing offer of smart charging tariffs and services, would help consumers use the grid most efficiently. National energy regulators implementing time-varying network tariffs , based on recent EU guidance recognising the pressing nature of network pricing reform[i] are a basic key ingredient to drive efficient grid utilisation from grid customers such as EV fleets and CPOs.
[i] European Commission. (2024). [Title of the publication] (Publication No. 96b7e60d‑9efe‑11ee‑b164‑01aa75ed71a1). Retrieved July 9, 2025, from https://op.europa.eu/en/publication-detail/-/publication/96b7e60d‑9efe‑11ee‑b164‑01aa75ed71a1
II. Standardisation for interoperability and data
Recommendation 7/ Establishing common standards
The importance of interoperability between EVs and the grid is critical for ensuring seamless connectivity across borders and vendor-independent. This includes establishing common standards for charging infrastructure and vehicle-to-grid (V2G) communications to ensure that EVs and charging stations can interact with the grid across the EU. Adopting common standards for data exchange across the EU is essential to seamlessly exchange information on charging infrastructure, capacity needs, and vehicle data. Therefore, clear guidelines for data sharing formats need to be developed to ensure that all parties involved can easily access and use the relevant data. Standardisation ensures interoperability, safety, and efficiency in the integration of electric vehicles with the power grid.
The promotion of common standards is paramount for ensuring interoperability and reliability across V2X systems. These should allow the Electric Vehicle Charging System (EVSE) to provide smart and bidirectional charging. and communicate with the grid. The necessary standards should be implemented as soon as the standardisation processes are finalised, in the charging stations, the cars and the grid. , while taking into consideration industry capabilities. This is key to deploy future-proof infrastructure and to deliver the smart-charging services we will need for the energy transition to succeed. Standardisation bodies should prioritise development of standardised protocols for battery efficiency and warranty and for EV charging protocols between both the grid and vehicle. This will bolster consumer confidence and trust in V2X technologies.
Recommendation 8/ EU-wide interoperability grid data and asset certification
The data sets and formats based on common definitions concerning available grid capacity across EU distribution system operators would significantly facilitate project development for grid users operating in multiple EU countries, by improving transparency and comparability of grid information. In parallel, certification for assets connecting to the grid plays a crucial role in ensuring that charging infrastructure complies with quality standards and safety requirements.
This certification process typically involves a formal assessment to verify that electrical assets, such as charging stations and associated equipment, meet defined technical, safety, and quality benchmarks prior to grid connection.
Technical compliance ensures that the infrastructure is compatible with the operational requirements of the grid and does not introduce disturbances or compromise stability. Safety standards are assessed to protect both users and grid operators, covering aspects such as protection against electrical faults, fire risks, and correct installation procedures. Quality assurance confirms the infrastructure’s reliability, durability, and performance over time, supporting long-term functionality and user confidence.
Establishing common EU-wide certification requirements and procedures would support cross-border deployment of charging infrastructure and reduce administrative complexity for manufacturers and operators alike.
III. Future needs to guide anticipatory investments
Recommendation 9/ Detailed forecasting and transparency in demand
Accurate forecasting of future transport demand and the capacity needs for EVs is critical to guide infrastructure investments and grid planning. Early data on power requirements per station enables system operators to have better-informed decisions and to prioritise grid connection requests more effectively. A clear guidance on how this data needs to be collected and shared in full respect of protection of commercial interests among the stakeholders involved is needed to reduce connection queues and help manage grid capacity congestion efficiently.
Recommendation 10/ Anticipatory Investments in grid capacity and Infrastructure
A stable and predictable legal framework that also allows anticipatory investments enables the network to meet capacity requirements when needed. Such a framework needs to be built on holistic European and national energy plans formed with policies that fully deliver on decarbonisation ambitions, keeping in view sufficiently long-time horizons, and implemented and monitored by independent energy regulators. Anticipatory investments[i] are not a new form of grid investment, and as such do not require a brand-new regulatory framework, though regulatory frameworks can often be further improved in this respect. Optimal investment still entails investing so that the additional cost of build matches the expected societal benefit of this extra capacity.
The need for anticipatory investments[ii] and a concomitant regulatory framework that facilitates their implementation are key for ensuring that grid infrastructure is developed ahead of demand. This includes addressing the growing demand from transport while simultaneously investing in grid upgrades to prevent future congestion. To target these investments optimally, demand forecast processes should be structurally embedded in a wider and regular scenario building exercise and joint grid planning process.
Based on the aforementioned outlined checks and risk evaluation with regards to future utilisation, DSOs should be empowered to make anticipatory investments that can handle future needs, particularly in areas where high-capacity charging stations are required (e-HDVs). These investments should support the implementation of the AFIR provisions and the rollout of grid-optimised e-HDV charging infrastructure TEN-T networks, e.g. via the Clean Corridor initiative, with a specific focus on enabling cross-border traffic, thereby avoiding price distortion in the emerging market for truck charging services.
[i] Regulatory Assistance Project (RAP): Revitalising regulation to guide anticipatory investment. https://blueprint.raponline.org/deep-dive/revitalising-regulation-to-guide-anticipatory-investment/
[ii] European Commission. (2025, June 2). EU guidance ensuring electricity grids are fit for the future. Retrieved June 13, 2025, from https://energy.ec.europa.eu/news/eu-guidance-ensuring-electricity-grids-are-fit-future-2025-06-02_en
Recommendation 11/ Implementing a blueprint for recharging infrastructure
The costs and complexity of grid connections can be rationalised by optimising the deployment of recharging infrastructures, in accordance with charging infrastructure needs (number of points to be installed per EVs on the road, location, power, type of socket, etc.). If the infrastructure is installed at the right place, taking into account EV user demands and patterns of charging behaviour, namely where the grid is already available or sufficiently robust, with consistent sizing, the cost and length of grid connection processes can be mitigated. To this end, it is necessary to promote the cooperation between local/regional authorities and stakeholders of the electromobility ecosystem in the deployment of recharging infrastructures, for instance by implementing a “blueprint for recharging infrastructure”. This document, defined by local authorities in consultation with relevant stakeholders, would comprise the local planning rules for the implementation of recharging infrastructure in main highways and national roads and would assess charging infrastructure needs, considering the existing publicly accessible infrastructure and also the existing and expected private charging infrastructure. It could further enhance existing work completed by the Sustainable Transport Forum (STF).[i].
[i] Autoriteit Consument & Markt. (2024, May 22). Codebesluit prioriteringsruimte bij transportverzoeken. https://www.acm.nl/nl/publicaties/codebesluit-prioriteringsruimte-bij-transportverzoeken
The final word by our member
“This paper is clear evidence of the power of cross-sectoral cooperation in addressing the challenges of transport electrification. Breaking down siloes between the electricity and mobility sectors is essential to ensuring a swift and smooth energy transition. In the context of the Automotive Action Plan, it is encouraging to see E.DSO members actively driving this collaboration forward”
—Charles Esser, Secretary General at E.DSO
Prioritising energy efficiency in EU's transport ecosystem
Energy & Infrastructures
The Platform for Electromobility highlights the critical importance of maximising energy efficiency in achieving the EU’s decarbonisation goals. We are collectively worried of the proposal to bring forward the revision of the CO2 Standards for Cars and Vans and the proposal to expand the use of e-fuels, masquerade through a call for “technology-neutrality”. As the European law-makers prepare to review the upcoming amendment to the regulation on CO2 emission performance, we highlight risk such amendment poses to overall energy consumption of the continent.
1. What is energy efficiency in transport?
Energy efficiency refers to the amount of energy, measured in kilowatt-hours (kWh), required to travel a certain distance (kilometers) per passenger. The more energy-efficient a mode of transport is, the less primary energy is needed to be produced for the vehicle to travel the same distance, regardless of the energy’s source—whether it comes from fossil fuels, nuclear energy, or renewable sources.
2. Why is energy efficiency crucial?
Energy efficiency should be a cornerstone of the EU’s energy transition for transport. As transport remains one of the largest consumers of energy, improving energy efficiency directly supports European energy autonomy and security by reducing Europe’s reliance on imported fossil fuels, particularly from politically unstable regions. According to BloombergNEF, favoring energy-efficient transport could save up to 1.5 million barrels of oil per day, equivalent to over €40 billion annually in reduced imports[1].
In addition to strengthening energy security, energy efficiency has direct economic benefits. As energy costs may continue to rise, more efficient transport solutions can help reduce operational costs for businesses and drivers alike. This would make travel more affordable for citizens and improve the competitiveness of European industries.
Furthermore, a key objective of the EU is to increase the share of renewable energy in its energy mix. However, less energy-efficient transport modes would require a unnecessarily increase in renewable energy production to meet demand. It would increase the risk of “Not-In-My-BackYard” movement against such renewable energy plants, and ultimately Europeans’ resistance against energy transition. Prioritising energy efficiency helps maximize the utility of renewable energy and minimize the impact in Europe.
[1]https://about.bnef.com/blog/electric-cars-have-dented-fuel-demand-by-2040-theyll-slash-it/#:~:text=So%20far%2C%20the%20growing%20fleet,far%20off%2C%20arriving%20in%202027.
3. Which transport modes are the most energy efficient?
Among all transport modes, trains are by far the most energy-efficient for long distances[1]. Europe is already a global leader in rail transport, and a concerted push to increase modal shift from road to rail could unlock substantial efficiency gains. We thus support the call to further roll-out of TEN-T as well as plans for an ambitious European high-speed rail network, night train and rail freight. The ecological advantage is especially there for freight transport. On the local level, public passenger transport by metro, tram, bus and urban rail collectively moves large numbers of people, using less energy and emitting less CO2 per passenger-kilometre than private vehicles.[2]
However, passenger cars remain at the center of current political debate. They represent the most widespread form of personal transport and are undergoing major changes amid political debates and upcoming review of the CO2 Standards for cars and vans. When it comes to energy efficiency, not all cars are equal. Energy efficiency among cars varies dramatically, depending on the type of propulsion used. For example, as illustrated by graph 1 above, on the same amount of energy of 15 kWh, similar passenger cars travel very different distances[3]:
- An internal combustion engine vehicle running on synthetic fuels created from renewable energy and climate neutral can travel 20km;
- a hydrogen fuel cell vehicle, running on synthetic fuels created from renewable energy and climate neutral can travel 35km, using the same amount of energy.
- a battery electric vehicle (BEV) can travel 100 km on the same amount of energy, five times more the range of the ICE car.
It is clear that BEVs significantly outperform vehicles powered by e-fuels in terms of energy efficiency.
[1] https://www.iea.org/energy-system/transport/rail [2] In its Urban Mobility Framework (point 2.4), the Commission writes "Public transport such as urban rail, metros, trams, buses, water buses, ferries or cable cars represent the safest, most efficient and sustainable ways for large numbers of people to travel.". There is also a comparison of emissions per mode that includes buses (and coaches) in the EEA Transport and Environment Report 2021 (figure 4.3) [3] Research Center for Energy Networks and Energy Storage
4. Why are they differences in energy efficiency?
Producing e-fuels requires much more energy than producing fossil fuels or using direct electrification when looking at energy use from production to tank. The main issue with e-fuels is their low efficiency throughout the production process. In order for an e-fuel to truly be carbon-neutral, each step—making hydrogen, capturing carbon, and then synthesizing the fuel— needs to be renewable. However, each of these steps require energy and result in large energy losses. This makes e-fuels less efficient in areas where electrification use is possible, especially since electric motors are far more efficient than combustion engines[1].
While a BEV uses 77% of the primary energy to move its wheels, a vehicle powered by e-fuels converts only 20% of the original energy input into motion[2]. The later would thus need about four times more primary energy than the former to travel same amount of kilometres. This large difference underscores the need to prioritise more efficient technologies. Energy efficiency is not a marginal criteria.
Additionally, such an efficiency gain is without counting on the benefits BEVs can have for the energy system if grid-integrated thanks to smart and bidirectional charging, where their batteries can improve the efficiency of the entire energy system. As the making synthetic fuels in itself is already very energy intensive. Each Kwh used for the production of synthetic fuels is one that cannot serve other, more efficient means.
[1] https://www.spglobal.com/_assets/documents/ratings/research/101595057.pdf [2] https://www.transportenvironment.org/articles/e-fuels-too-inefficient-and-expensive-cars-and-trucks-may-be-part-aviations-climate-solution
Which policies can promote most energy-efficient transport?
To ensure that Europe’s future vehicle fleet is as energy efficient as possible, we recommend the following policy actions:
- No U-turn: Any early review or any U-turn in already agreed policy is detrimental for investment confidence in the energy transition.
- Limit the role of e-fuels in CO2 standards: In the upcoming review of the CO2 standards for cars and vans, we urge policymakers to restrict the use of e-fuels to niche markets that cannot be directly electrified, for emergency services, or vehicles of specific usages such as forestry.
- Focus e-fuels on hard-to-abate sectors: Divert the use of limited e-fuels to other sectors where electrification is still not an option and where so much is needed: aviation, long-haul maritime.
- Introduce differentiated taxation: Vehicle taxation should be tied to energy efficiency. Registration taxes, road taxes, and fuel duties should favour energy-efficient vehicles. For instance, a bonus-malus system could be introduced, where less efficient vehicles face higher taxes, and more efficient options benefit from tax breaks. The revision of the Energy Taxation Directive could be instrumental in this perspective.
- Prioritise energy efficiency in public procurement: Public procurement can be a powerful tool to set an example. Green public procurement criteria should prioritize the energy efficiency of vehicles used in the public sector. By including energy efficiency requirements in public tenders, governments can drive demand for the most efficient technologies. The Net Zero Industrial Act already paves the way in this direction.
Conclusion
Energy efficiency is not just a technical consideration, it is a strategic imperative for Europe’s energy security, economic competitiveness, Europeans’ cost of living, and environmental sustainability. By prioritising the development and use of the most energy-efficient transport modes, the EU can reduce its dependence on imported fossil fuels, lower costs for consumers, and ensure that the shift to renewable energy is as efficient as possible.
We strongly urge you to take decisive action in the upcoming CO2 standards review and to adopt policies that will promote the most energy-efficient transport solutions. This is essential to meeting the EU’s decarbonisation objectives and securing a sustainable future for all Europeans.
"Enhancing the resilience of our energy system is crucial and be achieved by optimising the efficiency of our energy use. Electrification plays a key role in this transition: EVs consume significantly less energy than traditional alternatives, while also supporting the grid by offering flexibility and facilitating the cost-efficient integration of renewable energy."
— Anaïs Faucher, SolarPowerEurope
Our recommendations to Commissioner for Energy
Energy
Energy policies enabling decarbonised transport, and vice-versa
Our recommendations for Dan Jørgensen
European Commissioner-designate for Energy
As we move into the next five years of the European Parliament mandate, the members of the Platform for Electromobility remain committed to advancing sustainable transport solutions that drive decarbonisation of land transports in Europe. To achieve this, it is essential to create a synergetic ecosystem between energy and transport infrastructures and assets.
Indeed, the emerging ecosystem of sustainable, decarbonized transport sits at the intersection of the energy and transport sectors. The electrification of transport is not just a transport initiative but a crucial energy challenge that requires coordinated efforts across both domains. With transport now a major driver of electricity demand, engagement of next European Commissioner for Energy in electric mobility policy initiatives will be essential to successfully achieving the European Union’s climate and energy goals.
Below, we outline the necessary legislative steps that a seamless, win-win integration between energy and transport ecosystem requires.
1/ Ensuring the implementation of the Green Deal
As you begin your new mandate, we urge you to uphold and fully implement the commitments of the European Green Deal, particularly those within the Regulation on the CO2 standards for new passenger cars and vans, the Renewable Energy Directive (RED) and the 2019 and 2024 Electricity Market Design (EMD) reforms. These legislative files are enablers of Europe’s transition to a sustainable transport system, accelerating renewable energy adoption and creating a more flexible, efficient electricity market. Next European Commissioner for Energy’s leadership will be essential to ensure their timely implementation and to hold Member States accountable for meeting their ambitious targets.
To ensure the success of these ambitious directives and Regulation, it is crucial to pair the Green Deal’s implementation with a robust investment plan. This should include dedicated funding mechanisms to support renewable energy projects, grid modernization, and infrastructure development. By aligning public and private investment with the goals of the Green Deal, Europe can foster innovation, enhance energy security, and create sustainable jobs across Member States.
Key policy asks
Ensure the full and timely transposition of the Renewable Energy Directive (RED) and the Electricity Market Design (EMD) across all Member States. – More details: Our statement on Electricity Market Design.
Uphold the targets already set out in the Regulation on the CO2 standards for new passenger cars and vans.
Support the presentation of a strong Net-Zero Investment Plan to implement the Green Deal. – More details: Investing in energy infrastructure to enable the Green Deal
2/ Upgrading and smartening the electricity grid for e-mobility
The integration of electric vehicles (EVs and eHDVs) into Europe’s electricity grid presents both opportunities and challenges. However, a modern, smart, and flexible power grid across Europe is the key to accommodating the increasing demand for electricity from EVs, ensuring grid stability notably via ancillary flexible services that smart vehicles can deliver. Investments in grid infrastructure, smart technologies, and flexibility services will be essential to managing this transition effectively.
To support this transition, the Platform for Electromobility emphasizes the importance of coordinated action between all stakeholders, including Distribution System Operators (DSOs), Charge Point Operators (CPOs), flexibility service providers, and regulators. A harmonized approach to grid planning, smart charging solutions, and vehicle-to-grid (V2G) technologies will maximize the benefits of EV integration, both for the grid and for consumers.
We encourage you to prioritize the following actions:
Promote the development of national EV charging blueprints and anticipatory grid investments, ensuring that Member States facilitate seamless EV charging infrastructure deployment in alignment with grid capacity.
– More details: The right governance for smooth integration of e-mobility solutions into the grid.Support the reform of grid connection agreements and foster the implementation of smart and bidirectional charging technologies, enabling EVs to contribute to grid stability and flexibility.
– More details: A Comprehensive Roadmap for V2X Integration in Europe
Investing in energy infrastructure to enable the Green Deal
Net Zero Investment Plan
Area 1 : Energy Infrastructures (14.5%)
Investment in TSO and DSO infrastructure, energy storage solutions, renewable energy sources, and grid modernization, including smart grid deployment for Vehicle-to-Grid (V2G) applications, is critical for facilitating electric transport adoption and enhancing energy resilience in Europe.
Investment Areas
Energy Priorities
TSO and DSO Expansion/Upgrade
Energy Storage Solutions
Development of Renewable Energy Sources
Modernising the Grid
Smart Grid Deployment/V2G
- TSO and DSO Expansion/Upgrade
Expanding and upgrading TSO and DSO infrastructure is imperative for meeting the growing demand for electricity and facilitating the widespread adoption of electric transport. These upgrades are essential for supporting charging infrastructure for both light-duty vehicles (LDVs) and heavy-duty vehicles (HDVs), as well as for enhancing maritime and inland port grids. Reinforcing connections to the national grid for shore-side electricity will boost energy resilience and promote cleaner transport options.
- Energy Storage Solutions
Energy storage solutions play a crucial role in relieving grid congestion and accelerating the integration of renewable energy sources. Investing in such technologies will enhance grid flexibility, mitigate the variability issues associated with renewables, and support the transition to a more-sustainable and resilient energy system. Prioritising energy storage solution development and deployment is essential for ensuring grid stability and promoting renewable energy deployment.
- Development of Renewable Energy Sources
The electrification of transport is impossible without decarbonised electricity. Expanding carbon-free energy sources is fundamental to achieving energy security, reducing greenhouse gas emissions and advancing the energy transition. Europe must prioritise the development of wind, solar and hydro – as well as other renewable and decarbonised energy sources – if it is to diversify the energy mix and decrease reliance on fossil fuels.
- Modernising the Grid
Digitising and modernising the grid are essential for improving demand-supply management and streamlining the process for creating new grid connections. Through embracing digital technologies, Europe can enhance grid reliability, optimise energy distribution and support the integration of distributed energy resources. Modernising the grid will also provide the foundations for future advancements in smart grid deployment and enable realisation of benefits such as vehicle-o-grid (V2G) capabilities.
- Smart Grid Deployment/V2G
Supporting smart grid deployment, particularly for V2G applications, is essential for optimising grid operations and leveraging the potential of electric vehicles as grid assets. Smart charging technologies enable EVs to be part of demand response programmes, thus helping balance supply and demand on the grid. Investing in smart grid infrastructure will allow for the efficient use of resources, minimise grid constraints and facilitate the transition to a more flexible and resilient energy system without heavy investment in infrastructure.
A Comprehensive Roadmap for V2X Integration in Europe
Energy & Infrastructures
A Comprehensive Roadmap for V2X Integration in Europe
The paper outlines enablers and barriers concerning bidirectional charging systems, clarifies key barriers, highlights ongoing efforts to mitigate them, and underscores the critical need for concerted and regulatory actions to achieve the transformative potential of V2X integration.
Electric Vehicles (EVs) both pose particular challenges and present promising opportunities for the energy system; they mark a pivotal moment in the evolution of transportation and energy sectors. With the increased adoption of EVs lies the imperative for strategic planning and collaborative action on Vehicle-to-X (V2X), a crucial technology for smartening the road transport sector.[i]
Recently adopted legislation – as part of the European Green Deal – has already paved the way for the roll-out of smart-charging technologies in the electromobility ecosystem.[ii] We welcome these initiatives and will monitor their implementation closely. Smart charging is a fundamental prerequisite for V2X, which will deliver further advantages for people, the climate and European businesses alike.
Recognising this, this document from the Platform for Electromobility seeks to present a comprehensive roadmap on V2X, setting out a series of actionable steps that by Member States (MS) should undertake, along with measures required at the EU level. Stressing the importance of a cross-sectoral approach, our strategy seeks to navigate the complexities of V2X integration in our energy system without delving too deeply into intricate technicalities. The paper outlines enablers and barriers to adopting bidirectional charging systems, clarifies crucial barriers – and highlights ongoing efforts to mitigate them – and underscores the imperative for concerted and regulatory action to realise the transformative potential of V2X integration.
1/ Benefits of bidirectional charging
a/ Benefits for public finances & grid investments
V2X integration offers a multifaceted solution, one with the potential to unlock a wide range of benefits across various domains. Foremost among these, V2X – as with other flexibility resources – complements conventional grid reinforcement measures, helping alleviate the strain on existing infrastructure while enhancing its resilience. We are already starting to see increasing tensions in the grid and the overwhelming need to reinforce it; therefore, the deployment of V2X and the use of EVs as batteries represents a ‘no-brainer’[i] and would effectively smooth the rollout of grid reinforcement, something that usually takes between 5-15 years. V2X integration thus offers access to a realm of ‘low-hanging fruit’ opportunities, allowing the cost-efficient adaptation of the grids to growing electrification.
b/ Benefits for Europe energy autonomy
The integration of V2X will help deploy renewable energy sources (RES), by providing efficient storage solutions. It has the potential to help balance the grid and increase the penetration of renewable electricity (RES-E) into it, thus accelerating the drive to climate neutrality. Indeed, in order to ensure generation adequacy – key for the energy transition – V2X will be pivotal. As intermittent renewable energy becomes increasingly prevalent, maintaining grid stability and meeting demand poses significant challenges. Here, V2X solutions can play a crucial role in balancing supply and demand, enabling dynamic resource adequacy analyses that realise the enormous potential of V2G capabilities.
c/ Benefits for grid operators
From the perspective of the grid operators, there are manifold advantages. For Transmission System Operators (TSOs), V2X is particularly beneficials for Frequency Regulation (FCR) Services, which are pivotal functions for TSOs. In addition to mere savings in battery costs, V2X optimises both standalone and grid-connected storage battery systems. FCR plays a critical role, not only in reducing the necessity for investment in battery storage services but also in minimising the need for grid upgrades. These efficiencies translate into systemic savings, ultimately benefiting electricity consumers. For DSOs, V2X can play a major role in local flexibility markets and congestion solutions providing services to DSOs and representing a valuable flexible resource that can be procured to ease tensions on distribution grids. This requires flexibility mechanisms in which V2X value can be stacked based on related remuneration. To enable even more value of V2X for every DSO, market based procurement of flexibility based on V2X shall be stimulated.
d/ Benefits for users, people and businesses alike
From an end user’s perspective, the benefits of V2X integration will be substantial. Through leveraging V2X capabilities, users will have the opportunity to earn money from feeding energy into the grid, thus enhancing the overall value proposition of electric mobility.[ii] Remuneration mechanisms (such as those based on availability, capacity or time) will trigger further consumers to participate; once they do so, they will naturally generate demand for V2X. V2X integration will not only enhance grid resilience and promote renewable energy uptake but also pave the way for a more sustainable, efficient and adaptive energy ecosystem, one where EVs can equally participate in flex mechanisms.
2. Legislative and Regulatory Principles for V2X Integration
As we call on legislators to begin shaping the regulatory framework for V2X integration, there must be a number of core founding principles that underpin their efforts to foster innovation, interoperability, fairness and trust within the emerging ecosystem.
a/ Consumer trust
Foremost among these principles must be building and maintaining consumer trust. Legislators must prioritise creating a robust system that instils trust among users, system operators and businesses alike. This will entail ensuring transparency and accountability in V2X transactions while also safeguarding consumer rights and interests.
b/ Business models based on use cases
The deployment of V2X infrastructure must be accompanied by corresponding business models, particularly where financed/cofinanced by public entities. As the value of V2X depends on the use case of fleet and chargepoints, there need to be proper business models created that provide an incentive for consumers. Regulators should therefore facilitate mechanisms to support user compensation and fair pricing; these should recognise the pivotal role granular pricing structures play in enabling diverse business models and in incentivising dynamic energy management. The increased volatility in our energy system arising from renewables and negative grid tariffs can further stimulate consumers to engage and participate in V2X initiatives.
c/ Commonly accepted and harmonised standards
The promotion of common standards is paramount for ensuring interoperability and reliability across V2X systems. These should allow the CCS standard to provide smart and bidirectional charging. This should be implemented as early as possible in both charging stations and cars. Any further delay will lead to infrastructure that is not future-proof and will fail to deliver the smart-charging services we will need for the energy transition to succeed. Standardisation bodies should prioritise development and enforcement of standardised protocols for battery efficiency and warranty and for EV charging protocols between both the grid and vehicle. This will bolster consumer confidence and trust in V2X technologies.
d/ Affordability through democratisation
The accessibility and affordability of V2G-capable vehicles must be a priority if access to this transformative technology is to be democratised. By incentivising competition and innovation in the production of V2X-capable chargers and EVs as well as through lowering the barriers detailed below, legislators can drive down costs and promote widespread adoption. This in turn will create economies of scale and lower barriers to entry. With the right regulatory framework in place, recharging costs can theoretically be brought down to zero with bidirectional charging.[i]
e/ Equal treatment for all grid usages
Ensuring equal access, participation, and treatment for all energy usages, including all type of V2X, is fundamental. All grid users should receive equal treatment without discrimination, be they electric vehicles, wind turbines or home appliances. Any exceptions – such as tariff exemptions – should be restricted to emerging user groups, should remain temporary and should be appropriately justified.
f/ Upgradability path
In envisioning the regulatory framework for V2X integration, it is imperative to prioritise establishing future-proof systems capable of evolving alongside advancing technologies and changing needs. Although V2X technology is not as yet fully harmonised across Europe and still faces barriers, its early rollout is needed in order to facilitate improvements. Central to this endeavour is the need for an ‘upgradability path’, embedded within the regulatory framework. Such a path will not only instils trust among consumers and markets but also ensure compliance with future technological advancements and emerging requirements.
g/ Public charging hidden potential
In Europe, a significant proportion of the car fleet lacks access to home charging. As a result, publicly available charging will continue to be necessary in the future. This presents an opportunity to leverage V2X technology at these points also. We therefore encourage public charging points to be V2X-capable; this is provided that the cost-benefit analysis is positive, they are priced similarly, only implemented on slow chargers and do not impede the rollout of charging stations across Europe.
3. Barriers to V2X Deployment
Despite the potential offered by V2X integration, several barriers continue to hinder its widespread deployment. Overcoming regulatory, technical and market hurdles will require concerted efforts.
a/ Implementation of the Electricity Market Design
At the forefront of these challenges are regulatory barriers, most notably the lack of implementation by MS of the 2019 Electricity Market Design, which discriminates and disincentivises the participation of V2X in the electricity markets. To address this, there is an urgent need for MS to accelerate their implementation.
b/ Double Taxation
One of the asks of battery stakeholders (EVs and stationary) is to eliminate double taxation; that is, the taxing again of electricity injected into the grid from a battery. Double taxation[i] remains a persistent concern, particularly in scenarios where energy storage is integrated with other loads. While progress has been made in mitigating double taxation for large-scale storage, challenges persist for small-scale storage assets such as V2X. For example, in Germany, double taxation for stationary storage has been removed, yet remains in place for mobile storage.
c/ Uncoordinated grid requirements
The absence of the anticipated regulations, coupled with limited access to organised markets and revenue streams, poses significant challenges to V2X deployment. Uncoordinated grid requirements and standards between countries are exacerbating these challenges, hindering interoperability and complicating cross-border deployment efforts. Divergent communication standards and disparate smart meter adoption rates – something that is particularly evident in countries such as Germany, which has low penetration rates – underscore the urgent need for harmonisation and standardisation initiatives to realise the full potential of V2X integration.
4. Call for coherence, actions and political ownership at EU level
a/ Coherence across Member States
As the EU navigates the complexities of V2X integration, it is vital to address the prevailing divergences among MS and to foster a cohesive regulatory framework that promotes innovation and harmonisation. Despite incremental progress, no MS has successfully removed all barriers to V2X deployment, underscoring the imperative for EU-level intervention. For V2X for slow public charging, we therefore call for national capacity targets – rather an EU-wide one – because the share of cars without access to off-street parking at home differs significantly between MS.
b/ Coherence across EU legislations and regulations
To advance implementation of V2X and harness its manifold advantages within Europe, it is crucial that the newly installed European institutions adopt a holistic approach to this challenge. All V2X-relevant measures should be in the form a comprehensive regulatory framework, rather than addressing them in isolated discussions, or rather than discussion technologies (AC vs DC). One way of ensuring this seamless integration across diverse legislative frameworks – and avoiding a fragmented approach – is to establish political ownership.
c/ Multilevel coherence on V2X
Cities will, in general, be the key enablers and accelerators of V2X due to the alignment between clean air and decarbonisation strategies (such as growing adoption of zero-emission zones, electrification of heating as an alternative to petrol/gas/wood). V2X should therefore be part of an integrated mobility and energy strategy at all territorial levels. We therefore call upon the EU to adapt the proposed SUMPs/SULPs into SUMEPs/SULEPs (Sustainable Urban Logistics/Mobility and Energy Plan). This will ensure coordinated and integrated planning, helping couple mobility/logistics with energy aspects
d/ Double mandate to jumpstart the market.
Mandating V2X interoperability for all bidirectional-capable vehicles, while at the same time requiring V2X capability for public fleets and buildings would be decisive in kickstarting the market and boosting widespread adoption. It would also ensure flexibility for independent aggregators and promote the use of submeters. Requiring interoperability and encouraging public fleets to lead by example will help jumpstart the market.
Conclusion
Additional measures, including addressing communication standards and issuing non-binding guidelines for MS, will be essential for fostering coherence and facilitating the transition towards a sustainable, interoperable V2X ecosystem. With upcoming revisions to key pieces of legislation now on the horizon, it is an opportune moment for the European Commission to demonstrate leadership and to spearhead concerted action to achieving V2X integration goals. By embracing coherence at an EU level, policymakers can unlock the full potential of V2X technologies and accelerate the shift to a smarter, greener future.
Introduction [i] V2X is an EV bidirectional charging technology encompassing several sub technologies: When the vehicle is plugged and electricity automatically flows from the car back to the grid, this is known as Vehicle-to-Grid (V2G). If the charging and discharging of electricity stored in electric vehicles takes place in buildings, this technology is known as Vehicle-to-Building or Vehicle-to-Home (V2B or V2H). [ii] Notably in the Energy Performance of Buildings Directive, the Renewable Energy Directive and the Alternative Fuels Infrastructures Regulation The benefits of bidirectional charging [i] It has been calculated that V2G can offer 21TWh of upward flexibility, and 24TWh of downward flexibility by 2030, considering 30% of the EVs are charged bidirectionally. Together with other flexibility resources, €11 to €29 billion could be saved in annual savings in distribution grid investments. Source : https ://smarten.eu/wp-content/uploads/2022/09/SmartEN-DSF-benefits-2030-Report_DIGITAL.pdf [ii] In a fleet demo in Denmark, a 10-EV fleet engaging in frequency regulation (FCR) services recorded an average revenue of € 1,860 per car per year[ii]. In a residential V2G project connecting 320 homes in the UK, the V2G units were able to create ‘between £230 and £300 of value per year through the spot electricity market’ and the project team expects that ‘when combined with flexibility services this could grow to £500 per year[ii].’ In the UK, a solution already commercialized proposes the first V2G tariff in the UK where EV drivers would get free charging thanks to their V2G charger and vehicle[ii], providing clear incentives and enhancing the social acceptance of the consumer to opt for bidirectional charging. Source: https://www.ofgem.gov.uk/publications/case-study-uk-electric-vehicle-grid-v2g-charging Legislative and Regulatory Principles for V2X Integration [i] Source: https://smarten.eu/position-paper-why-flexible-consumers-matter-a-contribution-to-eu-elections-2024/, p 9 Barriers to V2X deployment [i] In fact, battery stakeholders face a triple taxation. Once when the energy is taken from the grid, twice when part of the energy is injected into the grid, and a third time when that electricity is used somewhere else. The electricity injected to the grid should not be taxed when taken by the battery nor when injected back into the grid.
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.
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:
- Be initiated and moderated by public and regulatory authorities
- Assess the grid in advance – even before any connection requests – and prioritise the flexible use of the grid
- Recommend reinforcing network components, should any overload be anticipated;
- Foster communication with municipalities to address network construction requirements when connecting charging stations
- 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.
EU Election Manifesto: People at the heart of the e-mobility ecosystem
Manifesto Third Pillar
People at the heart of
the E-mobility ecosystem
As Europe shifts to a green economy, the demand for workers in industries such as critical raw materials, batteries and renewable energy industries will grow. Therefore, it will be essential to allocate EU resources and support to help steer young people into those technical fields essential for the green transition. There should be communication campaigns aimed at raising the visibility – and value – of these technical fields. It will also be crucial to implement well-funded reskilling programmes that will attract workers away from existing traditional industrial sectors and into emerging sectors such as renewable energy, grid management, infrastructures and recycling. These programmes will upgrade workers’ skills, train future workforces and ensure a just transition for the workers, their employers, and regional authorities.
The wider adoption of electric vehicles and rooftop photovoltaic solutions offer significant opportunity to unleash ‘prosumer potential’ in Europe. Restructuring Europe’s electricity market will allow us to maximise this potential, specifically through creating opportunities for Vehicle-to-Grid (V2G) where appropriate. This would enable EV drivers to take an active part to the transition by supplying power back to the grid. Allowing them to be rewarded for providing additional grid capacity and thus making the energy system more dynamic and resilient.
It is critical that zero-emission mobility is affordable to everyone. To that end, both old and new electric mobility solutions must be scaled up across Europe: Existing facilities include public transport offerings, shared cars and e-bikes for situations where individual cars are unnecessary. When they are unavoidable, newer solutions include low-cost leasing options, targeted purchase incentives policies and industrial strategies that support the deployment of smaller, more-efficient battery models should be provided. The rapid uptake of electric vehicles within corporate fleets will accelerate their second-hand availability. Implementing the Climate Social Fund should help drive this transition with the least possible impact on lower income families.
Our statement on the reform of the Electricity Market Design
Electricity Market Design
The Platform for electromobility urges ambitious adoption of EMD reform to drive grid-friendly e-mobility
The Platform for electromobility, uniting industries, civil society organisations and cities from the transport, energy and clean tech sector, welcomes the Electricity Market Reform (EMD) proposal as an important opportunity to support the build-out of grid-friendly e-mobility across Europe. We appreciate the proposals improve the existing electricity market framework in a way that facilitates cost-effective deployment of individual or aggregated smart and bidirectional electric vehicles (EVs) charging. As the EV market is growing rapidly, smart and bidirectional charging will quickly become one of the most important sources of demand-side flexibility. In the collective European effort to decrease fossil gas imports, EV charging flexibility will be instrumental to reduce consumer costs, greenhouse gas emissions and better integrate solar and wind in the grid. Importantly, by offering additional revenues or cost saving opportunities to EV owners, the reform accelerates EV take-up and the clean transport transition.
The Platform therefore urges co-legislators to keep the level of ambition and a swift adoption. The European Commission’s EMD reform proposal supports the uptake of e-mobility in the following ways:
The reform recognises EVs as flexibility resource
Member States will have to make a detailed assessment of the needs and the potential of demand-side response and storage. Based on the assessment, an indicative objective shall be set and supportive measures, such as a flexibility support scheme, may be introduced. It is important to properly include EVs as a source of demand response and storage in both the assessment of the flexibility needs and the objective for demand response and storage, and ensure appropriate participation of EV stakeholders in these assessments processes.
The reform further supports the participation of EVs in the markets
The threshold for participation in the day ahead and intraday markets get lowered to 100 kW, which makes them more accessible to aggregations of EV fleets. This will help develop the market for user-centric smart and bidirectional charging services. It may be advisable to extend this lower threshold also to capacity markets.
The reform accelerates planning for EV charging infrastructure
Transmission and distribution system operators will be financially incentivized to fully consider local demand side resources, such as EVs, when looking for solutions for grid congestion. System operators will propose further transparency and proactivity on their planning for connecting EV charging infrastructure, for example by sharing hosting capacity available for EV charging. This is essential information for providers of EV charging services and helps accelerate grid-efficient build-out of EV charging infrastructure.
Bidirectional charging : let's avoid double taxation for EV owners
Energy Taxation Directive
Ensuring fair taxtion for EV owners providing flexibility to the grid
By purchasing more and more electrified assets, which can produce, store, or send electricity to the grid, consumers are actively participating in the energy transition. In the transport sector, Electric Vehicles (EVs) is the mean to decarbonise the sector. However, more than mere transport assets, EVs can become energy assets, ‘battery on wheels’, if they unleash their flexibility, providing benefits to the consumers and to the grid.
How? With smart and bidirectional charging. Smart charging goes in one direction and enables adjustment to the charging process depending on external signals. Bidirectional charging – also known as V2X (‘vehicle-to-everything’) goes a step further and allows the vehicle to exchange energy with the connected asset (grid, home, building) in both directions, as well as charging or discharging for as long as it is plugged in. This means that the vehicle can offer services for a longer timeframe, as unidirectional charging stops once the battery is full.
One barrier which deter the uptake of bidirectional charging schemes and similar flexibility services in the Member States is the possibility of double taxation in the current version and under the proposed revision of the Energy Taxation Directive (ETD). On the EV owner side, such double taxation disincentivises the use of bidirectional charging because it costs the driver twice as much to essentially not use the energy that is back-fed to the grid. It also hampers the development of prosumer business models supporting the active contribution of consumers in providing flexibility services to the system. On the energy supplier side, this creates unnecessary administrative burden.
Thanks to bidirectional charging capabilities, the electricity can flow between the EV battery and the grid multiple times between the moment the EV is plugged and the one when the electricity is consumed for driving. Having to track the amount of energy transferred and calculate the tax on each transaction must be avoided to prevent hindering V2G services: taxes and tariffs should be applied exclusively on the amount of energy actually exploited by the final user, by means of proper metering.
We therefore propose the following change to the current ETD proposal, to ensure these ambiguities are addressed directly in the legislation:
Proposed amendment:
Art. 22.4: …For the purposes of the first subparagraph, electricity storage facilities and transformers of electricity may be considered as redistributors when they supply electricity. Active customers (as defined in Directive (EU) 2019/944 Art. 2(8)), including electric vehicle or battery owners participating in bidirectional charging schemes and other customers providing flexibility services to the grid, shall be exempt from taxation on unused energy which they reinject into the grid.
Current proposal text:
Art. 22.4: …For the purposes of the first subparagraph, electricity storage facilities and transformers of electricity may be considered as redistributors when they supply electricity.