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.

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.

The Platform for electromobility is pleased to see the progress established by EP ITRE Committee on the recast Renewable Energy Directive (RED). This revision represents an unmissable opportunity to achieve two strongly related public policy objectives: accelerate the transport sector’s transition towards zero emissions and modernize the current legislative framework for renewable energy as a whole, and more specifically for Europe’s transport system.

With the European Parliament scheduled to formalize its position on the file in mid-September, the Platform would like to shed the light on some elements that could improve the EP’s position:

• Include private charging in fuel neutral credit trading mechanisms

The Commission’s proposed EU-wide requirement for Member States to set up a fuel neutral credit trading mechanisms is highly welcome. However, the mandated credit system, as established by art 25(2), should not, as it would as the text stands, limit the scope of this new system to public charging points only. Any charging points should be allowed for inclusion under national credit mechanisms.  Limiting the scope of the credit mechanism at EU level to public recharging stations will lead to inefficiencies and distortions, and affect the deployment of charging infrastructure. The ITRE Committee has gone in the right direction,  leaving the option for Member States to set up their system in the way they see best fit, including a voluntary inclusion of private charging.

Given that the vast majority of EVs in the EU (>70%) will be charged at home or at the workplace, the Platform believes a stronger wording is needed, namely expressly including private recharging stations in the mechanism.

• Ensure appropriate energy efficiency ratios regardless of accounting methodology 

The current RED allows countries to choose between setting transport targets based on energy volumes/content or GHG emission reductions. Contrarily, both the Commission’s proposal and the ITRE Committee Report call Member States to set targets based on GHG reductions only, in clear countertrend compared with the 24 out of 27 Member States currently using an energy-based system. With this new proposed accounting methodology comes the deletion of the existing “multiplier system” or ‘Energy Efficiency Ratio (EER)’. The multiplier or EER accounts for the superior energy efficiency of renewable electricity, and is currently set at 4 for electricity. The mandate for the new transport targets does contain an “implicit” EER, i.e. a different fossil fuel baseline.

Nonetheless, as Member States are expected to push for maintaining the flexibility to choose between GHG- or energy-based targets, it is crucial to maintain an Energy Efficiency Ratio (EER) of at least 4  regardless of the accounting methodology used (in case  a member states chose to keep an energy-based system or the current proposed implicit multiplier in case of GHG emission reductions system), reflecting the fact that EVs are between 4-5 times more efficient than internal combustion engine cars (“well to wheel” efficiency) powered by any renewable fuels.

Hence, the Platform believes that, while it would be welcomed to maintain flexibility for countries to choose their accounting system, appropriate EERs should be kept ensuring that direct electrification is able to compete on a level playing field.

The Platform for Electromobility welcomes the timely revision of the Commission’s proposal for the RED (Renewable Energy Directive). This will be key in supporting the EU in reaching carbon neutrality, notably by advancing the case for an electrified, decarbonised and efficient transport sector. In fact, clean direct electrification is the most cost-effective way of decarbonising Europe and reaching the 2030 and 2050 climate targets.

Moreover, direct electrification of transport has accelerated in recent past years, and the pace is only expected to increase. According to a recent BNEF study, in order to reach 100% CO2 emissions reduction by 2035, some 67% of passenger cars sales in Europe will need to be electric by 2030.

This rapid, massive uptake of EVs has the potential to become – thanks to smart charging – a flexible asset for grid management and an opportunity for prosumer business models. It will also provide a boost to the increased and cost-effective penetration of renewable energy in the electricity system. The combination of EVs, their batteries and smart charging functionalities as sources of ancillary services for the distribution grid will clearly bring benefits in terms of RES (Renewable Energy Sources) integration. Electromobility and renewable energy therefore offer a win-win partnership.

In this context, the Platform welcomes the recognition of smart charging and, where appropriate, bidirectional charging for integrating transport in the energy system. Two aspects in particular stand out; 1) the relevance of the charging points located at long-time-parking spaces, and 2) that national regulatory frameworks do not discriminate against electric vehicles participating in the electricity markets.

However, we do believe there are certain key aspects that can still be further reinforced within the Commission proposal. These will help support EV uptake and lead to swifter decarbonisation of both the transport and energy sectors

Greenhouse Gas based mandate

The Platform for electromobility raises concerns over the shift from an energy-based target for transport to a greenhouse gas (GHG) metric. If we support the fact that a threshold expressed in terms of GHG provides a relevant tool for accelerating the decarbonisation of transport while guaranteeing technology neutrality among low-carbon technologies, it may – within the framework of the RED – add complexity to the metric. Furthermore, it does not seem to bring any genuine added value to boosting renewable energy when compared to the existing framework. In fact, multipliers are implicitly integrated in the GHG-emission calculation method, and the GHG-emission based target of 13% is equal to the 24-26% in final energy consumption considered by the European Commission in its public consultation.

Furthermore, given that currently 24 of 27 Member States implement an energy-based target, it should be noted that using such a metric will have an impact on the current implementation of the Directive; these countries will have to start from scratch again, having just finished transposing the current RED II. This could result in delays in meeting the RES-T target and the overall EU binding RES target. France, for example, is currently working on the implementation of its credit mechanism, aimed to have this enter into force by 2022 using an energy-based RES-T target. With the switch to an emission-based target, France would have to revise its credit mechanism almost immediately following its implementation, leading to further delays.

Platform Members therefore invite the Commission to provide further information on its motive and rationale behind introducing a new GHG emission-based transport target.

Inclusion of electricity in national compliance mechanisms

The Platform is pleased that the proposal levels the playing field between biofuels and electricity by including electricity in national credit systems for fuel supplier compliance. This is a feature of the Directive that we called for in an earlier communication. The proposal shall as well ensure level playing fields between zero emissions options, especially between electricity for BEVs and RFNBOs . For instance, hydrogen can claim credits for private charging while renewable electricity for electric vehicles is restricted to public recharging stations only.

Focusing specifically on ‘public’ recharging points is discriminatory and inefficient. This is because it excludes some 80% of electricity supplied to road vehicles and provides incentives for people to charge their cars at public charging points rather than at home, as well as for companies not to charge their trucks and buses at their depots. The scope of the electricity credit mechanism should therefore be expanded to include recharging stations more generally, encompassing both public and private ones. It should also be possible for such a credit mechanism to also be applied to other types of transport such as rail, aviation or shipping.

The text is unclear as to whether it would apply to charge point operators (CPOs) alone, or whether it would also apply to electricity suppliers.  Within the current proposal, this could lead to a situation with different incentive schemes resulting in confusion amongst actors and the relevant incentive schemes.

Permitting

The Platform supports the Commission’s proposal to tackle the remaining barriers, including those relating to permitting procedures. We welcome in particular the proposed publication of a guidance on best practices to accelerate the permitting of projects. We urge the European Commission to publish such a guidance swiftly and ensure the best practices are disseminated to local authorities. Nevertheless, the review of permitting administrative procedures must be urgently addressed in the short term in the RED III and not be left until 2024. This will be key to preventing bottlenecks that may hinder the achievement of national RES commitments and the deployment of renewable installations more generally. We also recall that this should be done in cooperation with grid operators in order to preserve the security/stability of the grid.

Coherence with the Alternative Fuels Infrastructure Regulation (AFIR) and the upcoming revision of the Energy Performance of Buildings Directive (EPBD)

The Platform calls for ensuring the consistency of the RED III with the new Regulation on the deployment of alternative fuels infrastructure. The current definition on smart charging and bidirectional recharging should be aligned and any change to the related definitions and provisions in one text should be made in the other.

Furthermore, given that the European Commission has integrated provisions on the private charging points regarding smart charging in the RED III, we would like to underline the necessity of ensuring their coherence with the upcoming revision of the EPBD, which addresses private charging in its Article 8.

Coherence with Battery Regulation

On the data-sharing requirements relating to batteries, the Platform recommends ensuring consistency with proposed requirements under the EU Battery Regulation proposal and avoiding any duplication. For example, new performance and durability requirements for batteries are already included in Article 10 of the Battery Regulation proposal.^[1] Similarly, the information on the state of health of the battery is included in Article 14 of the proposal.^[2]

^[1] The UNECE has recently developed performance and durability requirements via GTR, and therefore may be directly applied by the EU.

^[2]This is also regulated by UNECE GTR on in-vehicle battery durability, namely ‘State of Certified Energy’ (SOCE), or capacity fading, and ‘State of Certified Range’ (SOCR).