The added-value of electricity for mobility

The added-value of electric mobility
Platform for electromobility Statement on the Plenary vote on AFIR

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As the AFIR prepares a solid legislative basis for the decarbonisation of transport in the next years, it is important to support only clean solutions and to refuse the usage of fossil fuels. An increasing penetration of e-mobility also implies a demand-reduction for fossil-fuel, that are mostly imported from instable regions, and thus higher security of supply. The European Union should be very cautious with the list of alternative fuels. Fossil fuels cannot be alternative fuels and must remain transitional with a concrete specification of their end date.

Thus, electric mobility is the most satisfactory option and should be supported in the AFIR by a strong set of targets for charging infrastructure. Here are the 4 main reasons:

Ensure energy efficiency

BEVs are the cleanest and most efficient types of powertrains for individual vehicles (T&E, 2022). Electric cars for road transport are far more energy efficient (85-90% efficient) than ICE cars (17-21%). Regarding natural gas for vehicles (NGV), 30m3 of natural gas, converted to electricity, yields 735km in an EV but 580 km in an NGV vehicle (MIT, 2010). In terms of the rail sector, it accounts for just 2% of total EU energy consumption in transport (Commission, 2021), being the most energy efficient transport mode (T&E, 2022).

T&E, 2022

Improve air quality

Road transport is a major source of air pollution in European cities. In 2019, 307,000 premature deaths were attributed to chronic exposure to fine particulate matter (PM). 40,400 premature deaths were attributed to NO2 exposure (European Energy Agency, 2021). In comparison to other technologies, electric vehicles produce no exhaust emissions. EVs are estimated to emit 20% less PM10 from non-exhaust sources per kilometre than internal combustion engine vehicles (ICEVs) (OECD, 2020) . Modal shift and the use of urban electric rail can improve air quality. In Europe, the rail sector’s share of total Nitrogen Oxide (NOx) and PM emissions of transport is respectively 3% and 4,5% (UCI, 2018).

European Energy Agency, 2021

Integrate renewable energy into the grid

Battery-on-wheel solutions, like bidirectional charging, can facilitate the integration of renewable energy to the electricity system. The combination of EVs, their batteries and smart charging functionalities as sources of ancillary services for the electricity grid will clearly bring benefits in terms of RES (Renewable Energy Sources) integration.

Platform for electromobility, 2022

Reach climate neutrality

Electric cars and trains are the only available technology to reach climate neutrality. Full life cycle emissions of electric cars in Europe emit, on average, more than three times less CO2 than equivalent fossil fuel cars (Transport & Environment, 2022). Rail accounts for less than 0,4% of transport related greenhouse gas emissions in the EU (Commission, 2021).

T&E, 2021

EV Charging: how to tap in the grid smartly?

EV Charging :
How to tap in the grid smartly?

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With a market penetration of 10% in Europe in 2021[1], and with a purchase price and total cost of ownership outperforming that of the internal combustion engine (ICE) before the end of 2027[2], the take-up of electric vehicles (EVs) is expected to accelerate significantly in the coming years. The widespread electrification of transport is the most efficient way to reach Europe’s climate objectives for the sector. Challenges may lie ahead, but smart charging must not be overlooked as the main asset for overcoming these hurdles.

A critical mass of EVs on the market will impact electricity consumption patterns and create an overall increase in electricity demand, particularly during peak-time periods. Smart charging can be a crucial tool for increasing the adoption rate of EVs, by mitigating the stress on the grid and supporting the transition towards sustainable electricity; each connected EV helps reduce CO2 emissions further. Smart charging can reduce CO2 by an estimated annual 600,000 tons by 2030, through the greater integration of renewables in the grid.[1]

With the electrification of usages, a rapid increase in decentralised and local loads could – if not managed correctly – overstretch the current low-voltage distribution grids, particularly in residential or commercial areas[2]; smart-charged EVs provide a solution. Bidirectional charging and other flexible services – where appropriate – can also provide solutions and benefits, both to the grid and to the end-user (of the grid and of the vehicles), and should not be overlooked.

The Platform for electromobility therefore welcomes that the ‘Fit for 55’ package recognises the importance of smart charging for integrating transport in the energy system but we encourage more robust and consistent support for smart charging throughout the package. In order to unlock all the benefits smart charging can deliver to the electricity system, to EV users, to the environment and to society at large, the following considerations should be respected in a coherent manner throughout all relevant legislative files.

  1. What should be classified as smart charging?

Definitions of smart charging differ between legislations. Indeed, different levels of ‘smartness’ are possible, depending on the business solution deployed and the level of involvement of the consumers. The Platform for electromobility believes that charging installation should be considered smart if:

  1. it provides real-time adjustment
  2. it adjusts charging in response to external signals
  3. the adjustments give additional clear benefits to the EV driving consumers, providing flexibility to the grid.

Bidirectional charging comes to complement smart charging services. While unidirectional charging enables adjustment to the charging process depending on external signals, bidirectional charging – also known as V2X (‘vehicle-to-everything’) goes a step further. It 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.

What are the benefits of smart and bidirectional charging?

Flexibility services are a vital enabler for grid management in the energy system of a carbon neutral Europe, and smart charging can play a crucial role in delivering this flexibility. New and refurbished charging installations (public and private) should therefore be smart.[1] The timeframe for a potential eventual retrofit of existing stations should be defined through a comprehensive impact assessment, coordinated with the stakeholders of all affected sectors and Member States. Such an impact assessment will allow a comprehensive overview of the requirements for retrofitting, and will therefore optimise both the cost and the deployment of smart charging points.

  1. Smart charging will have a key role for the user in:
  • Empowering consumers in the energy transition, by transforming electric vehicles into an energy asset.
  • Taking full advantage of low electricity prices in the system for consumers and reduce the consumer’s bill of electricity (savings are estimated between €60 and €170 per year[2]).
  • In the heavy-duty vehicle (HDV) segment such as e-buses, smart charger capability offers the possibility to optimise the charging process according to the e-bus’s schedule, managing the allocation of the available power at charging depots (e.g. identifying and setting different priorities and criteria for charging the vehicle based, for example, on the order of arrival, departure-time priority, etc.).

  1. Smart charging will have a key role for the grid in:
  • Increasing system efficiency, by integrating the road transport sector into the energy system. This will optimise the use of the electricity grid and reduce the investments required in the power grid (which could reach €375-€425 billion by 2030[3]) compared to those of unmanaged charging.
  • Avoiding grid congestion, by lowering the load pressure and consequently enabling the more efficient integration of EVs into the power system.
  • Taking full advantage of the availability of renewable electricity, therefore increasing the penetration of variable renewable energy within our energy system.

  1. Bidirectional charging could also have a key role for the user in:
  • Empowering the consumer in the energy transition to an even greater extent, by transforming the electric vehicle into a ‘battery on wheels’.
  • Taking full advantage, and in particular Vehicle-to-Home (V2H), of self-consumption while mitigating their exposure to high prices for customer exposed to dynamic tariffs.
  • Selling back electricity to the grid to bring further significant financial benefits for the consumer.
  • Generating further revenue streams for public transport operators and/or fleet managers, in particular in the case of depot charging, allowing reductions to the total cost of ownership and thus offsetting the cost of charging infrastructure while generating additional revenues.[4]

In addition, other technological innovations capable of bringing flexibility to the system in the future – as well as a proper determination of the correct balance between charging modes using a case-based approach – should not be ignored but rather be carefully considered.

How to make smart charging work?

An enabling policy framework is needed to unlock these benefits and deliver them to both the electricity system and to society at large. The legal framework should be consumer-focused, consistent, future-oriented, and should allow appropriate reactivity, coordination and data sharing:

  1. Consumer focused: Any legal framework should create provisions that ensure that those EV drivers who provide flexibility by adopting smart charging solutions receive net positive effect for so doing. Consumer adoption is key to a successful implementation of smart charging technologies, and therefore should be made the central stakeholder.
  2. Consistent: Any definition and provisions set out in the AFIR, the REDIII and in the revision of the EPBD, should be both mutually consistent and consistent with energy directives in general, in line with the definition of storage. In particular, it will be essential to maintain consistency between the different definitions for smart and bidirectional charging. Furthermore, it will be vital that regulations consistently pursue a level playing field for smart charging and other technologies that provide flexibility to the grid. Consistency between legal definitions should also be ensured by avoiding overlap with the definition of ‘digitally connected stations’. To run the smart charging system in a coherent way, regulatory framework must also support the different actors of the eco-system to cooperate together, including OEMs, to optimize the benefits while ensuring that batteries are preserved.
  3. Future-oriented: A legal definition of smart charging should be sufficiently broad, and mention benefits without mentioning technicalities, so as to include future technologies.
  4. Reactivity: Smart charging should allow adjustments that are rapid enough to deal with grid disturbances and emergencies.
  5. Data: To ensure this necessary level of reactivity, smart charging requires access to information from the battery management system. On the basis of a contractual agreement, relevant and necessary data should be made available to vehicle owners and users, as well as third parties acting on their behalf.
  6. Cooperation: Smart charging needs the different actors of the eco-system to work together, including OEMs, to optimize the benefits while ensuring that batteries are preserved.

Our specific policy recommendations for smart and bidirectional charging

Incentives and support for the uptake of smart charging should be proposed, as it can offer a full range of additional services compared to regular charging. Bidirectional charging should also be encouraged when demonstrating the positive socioeconomic impact and creating a net benefit for the EV driving consumer who is contributing to the energy efficiency of the entire system.

The Platform calls for ensuring the consistency of the RED III with both the new Regulation on the deployment of alternative fuels infrastructure and with the energy performance of buildings directive (EPBD). The current definition of smart charging and bidirectional recharging should be aligned, and any changes to the related definitions and provisions in one text should also be made in the other.

The Platform welcomes the Commission’s recognition of the role of smart charging in the AFIR for enabling system integration. Improvements should also be made to support smart charging deployment. We therefore call for improvements to the requirements on smart charging (art. 2 and 5.8). You can read more details in our paper dedicated to AFIR here.

Time with the vehicle plugged: as important as using a smart charger: To realise the full potential of smart charging, the recharging points should be deployed at locations where vehicles park for extended periods of time. This allows the flexibility of choosing when to start and stop charging. At or near home is the main one, followed by the workplace. On average in EU, 60% of passenger cars have access to off-street parking at home, where is relatively easy to install a small charger. The other 40% of the car fleet will depend on the urban public infrastructure to recharge their batteries, as most of them won’t have access to a parking space at work.

On average, a battery passenger car in the EU consumes around 50 kWh/week. Three main prototypes of public recharging exist: high-power charge stations (equivalent to a petrol station), chargers in commercial areas (typically 22-90 kW) or chargers in residential areas (3.7-11 kW). High power chargers have limited flexibility. Here drivers usually seek the maximum power in the shortest amount of time possible  In a commercial area, the vehicle will need between one to two hours a week, while in a residential area, the car can be plugged in for more than 12 hours a day (even more during weekends) replicating the use case of people with off-street parking at home. In other words, in residential areas, the vehicle can be plugged in for 64-times longer than in a commercial location.

[1] https://insideevs.com/news/564628/europe-plugin-car-sales-2021/#:~:text=Thanks%20to%20the%20strong%20second,in%20ten%20was%20all%2Delectric.

[2] https://www.transportenvironment.org/discover/evs-will-be-cheaper-than-petrol-cars-in-all-segments-by-2027-bnef-analysis-finds/

[3] Elia Group “Accelerating to net-zero: redefining energy and mobility”

[4] Smart charging: integrating a large widespread of electric cars in electricity distribution grids – EDSO, 2018

[5] Exceptions such as underground parking lot, where Wi-Fi to is impossible may exist or through location management system.

[6] https://www.concerte.fr/system/files/concertation/Electromobilite%CC%81%20-%20Synth%C3%A8se%20vFinale.pdf

[7] “Connecting the dots: Distribution grid investment to power the energy transition”, Monitor Deloitte, E.DSO & Eurelectric, January 2021

[8] Currently, and assuming that the availability band made available by the e-buses in depot is 50 KW, it is expected that “Bus 2 Grid” will reduce the costs of the infrastructure to zero and generate additional annual revenues of €1000 per bus. Enel Foundation 2021 “Scenari E Prospettive Dell’elettrificazione Del Trasporto Pubblico Su Strada”.


Ou response to the consultation on the Transeuropean Network of Transport (TEN-T)

Transeuropean Networks - Transport
Our response to the consultation

The Platform for electromobility welcomes the EC proposal for a revision of the TEN-T guidelines as a necessary instrument to make transport modes more sustainable by setting firm incentives and requirements for transport infrastructure development.

In particular, we welcome:

  • The introduction of “The promotion of zero emission mobility in line with the relevant EU CO2 reduction targets” as first point in the Sustainability’s objective of TEN-T.
  • The direct link to AFIR provisions on the deployment targets of charging infrastructure for LDV & HDV as well as for the onshore power supply infrastructure.
  • The extended core network to be completed by 2040.

However, some adjustments to the proposal are deemed necessary:

Promotion of the transition towards a clean and zero-emission transport system and fostering its charging infrastructure. The “energy efficiency first” principle should be reflected in planning and investment decisions related to the deployment of recharging and refueling infrastructure. The “zero-emission” solutions and deployment of related infrastructure should be explicitly identified within the additional priorities in the promotion of projects of common interest (PCI) for all transport modes.  The TEN-T is closely linked to the TEN-E, hence it is paramount to reinforce and support the seamless integration of EV and charging infrastructure with the energy system stimulating solutions such as “energy storage” and “vehicle grid integration”.

Covering regions beyond the Core Network. The deployment targets of charging infrastructure along with the comprehensive TEN-T network as foreseen in the AFIR proposal for LDV should be brought forward as per the Core network. It will fill the gap in terms of social and economic disparity.

Consistency with the AFIR revision. The proposed TEN-T regulation includes clear provisions on indicators for the provision of alternative fuel recharging/refueling infrastructure for the different modes of transport. Its successful implementation will strictly depend on the synergies between the TEN-T and the AFIR, as both are intrinsically dependent on each other. For example, the AFIR proposal regulates the provision of charging/refueling points on the TEN-T network, while the TEN-T Regulation provides the infrastructural basis for their wide deployment from an EU network perspective.

Introduction of the reference to alternative fuels for rail. There is potential for alternative fuels as a complement, particularly where direct electrification is not a viable option. In particular, Art. 14 extends the list of rail infrastructure components including rail services facilities, rail access routes and last mile connections. However, it is sometimes not feasible or economically relevant to mandate direct electrification for some of these segments of the network. In these specific cases, possibility should be opened to offer zero-emission solutions based on alternative propulsion systems (e.g., battery trains). A more flexible derogation process under Art. 15 should also be considered to allow for the deployment of such technologies.

Guarantee of an appropriate level of funding. In this sense, the EC considers that the largest part of investments is estimated to originate from public funding (national public funds, EU funds) and would amount to €244.2 billion over 2021-2050. As possible and suitable additional funding support, the budget for Connecting Europe Facility (CEF) transport could be increased. In addition, given the significant funding allocated to mobility infrastructure including the TEN-T Network within Member States’ National Recovery Plans (NRPs), the tight deadline for the commitment of funds (2023) and its subsequent implementation (2026), the Platform supports the Commission to increase and facilitate further synergies between CEF and funding from the NRP and the Cohesion Policy Programs.


Reaction Paper to the new Article 12 “Infrastructure for sustainable mobility” (EPBD)

Reaction Paper to the new Article 12 “Infrastructure for sustainable mobility” of the Revision of the Energy Performance of Buildings Directive

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Last year, 2021, set a record for the battery electric vehicle (EV) sales, which achieved 10%[1] of total sales in the European automotive market. This trend is expected to continue to rise, driven by the new ambitious objectives set by the EU along with the national recovery plans implemented by Member States. However, the challenge remains immense. Indeed, the number of EVs is set to increase throughout the EU as a result of the proposed ban of internal combustion engines (ICE) sales by 2035, set out in the revision of the Regulation on the CO2 standards for cars and vans as part of the Fit for 55. Consumer demand for electric bicycles is also increasing strongly, with more than 4.5 million units sold in 2020, representing more than 20% of total sales.

If Europe is to succeed in its transition towards zero-emission mobility, the correct charging infrastructure needs to be put in place to push the EV market into achieving the required growth and ensuring a positive customer experience. Here, the deployment of private charging is of the utmost importance for encouraging the growth of electromobility, as 90% of all charging takes place at home or in the workplace. However, the current electromobility provisions of the Directive on the energy performance of buildings (EPBD) will fall significantly short in establishing the right conditions for the widespread adoption of EVs.

The Platform for electromobility therefore fully supports the revision of the EPBD

The Platform for electromobility therefore fully supports the revision of the EPBD presented in December 2021, as it is the main EU legislation for addressing private charging. The introduction of Art. 12 in the Commission’s proposal, which relates to electromobility in buildings, is therefore central to supporting zero-emission mobility in the EU. In particular, the Platform welcomes the:

Provisions we support

However, the Platform believes that further improvements are needed, and has therefore set out five recommendations:

Clarify the scope of application of Art. 12.

The way Art. 12 is currently drafted could be interpreted as meaning that requirements only apply to parking spaces if ‘the car park is physically adjacent to the building’ but not if it is ‘located inside the building’. We believe this is not the Commission's intention and therefore ask for further clarification.

Ensure charging solutions in existing buildings.

Some 80% of the EU’s current building stock will still be in use by 2050, with the average annual major renovation rate just 2.7% for non-residential buildings and 1.5% for residential buildings. As a result, the EC should ensure the installation of charging points in existing buildings.

Our key recommendations

Completing the charging requirements for new and under major renovation buildings.

The Platform asks to complete the charging requirements for new buildings and buildings undergoing renovation in order to mandate the deployment of smart-charging ready recharging points in all new and existing buildings.

Our key recommendations

Reinforce the deployment of smart charging functionalities

The development of smart charging and bidirectional charging (V2G) in buildings is an opportunity for EV users. It provides a superior charging experience and reduces the consumers’ electricity bill. Indeed, in France, on average with V2G, the annual cost of recharging an electric vehicle is 240€/year, compared to 420€/year without smart charging functionalities. The Commission has recognised, in its AFIR Impact Assessment, that every smart recharging point could on average create a system benefit of more than 100€/year by 2030. Smart charging also reintegrates electricity surpluses into the grids (V2G) and/or reuse it in the buildings (V2B) and homes (V2H), as well as supporting the uptake of electromobility. It can also create synergies with renewable energies, by integrating them into the electricity grids and providing flexibility services to the system. Furthermore, smart charging complements the right-to-plug by ensuring that charging points optimise the use of the grid capacity of a building and removes the argument that grid connections need to be reinforced.

Our key recommendations

Reinforce the measures to ensure pre-cabling

Pre-cabling of buildings should refer to both the technical cabling (cable path, technical sheaths, drilling) and the electrical pre-equipment in collective electrical installations (switchboard, horizontal electrical column, bus cable).

The comprehensive pre-cabling of buildings will enable the subsequent connection of individual charging points, at minimum cost, by simply installing a home charger. Furthermore, the pre-cabling of renovated buildings is a low hanging fruit, with little cost involved when done during the construction phase – which is the most efficient way to do it. Cabling after construction is completed is not cost-efficient and would lead to highly cumbersome discussions with project developers. Ducting infrastructure is a future-proof and cost-effective solution, the installation cost of which is minimal when compared to the total cost of constructing or renovating a building. By way of comparison, failure to ensure ducting infrastructure would entail costs that could be up to nine times higher if a building needs to be retrofitted.

Our key recommendations

The 10 points for success of the new Alternative Fuels Infrastructure Regulation (AFIR)

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The Platform for electromobility supports the AFIR proposal, which is vital for boosting the electrification of transport and providing the right tools to drive the growth of electromobility.

In particular, the Platform welcomes:

  • The switch from a Directive to a Regulation

As supported by our members in a previous communication, a Regulation will ensure the strong, rapid and more uniform implementation in all Member States.

  • The setting of minimum mandatory targets for light-duty vehicles (art. 3)

The AFIR sends the right signals to meet the EV demand on the roads. The sales of electric vehicles (EVs) in the EU1 continue to grow. Combined with the coming ban on sales of internal combustion engines by 2035 - as proposed in the revision of the Regulation on the CO2 emission standards for cars and vans - it is key to speed-up the roll-out of charging infrastructure across Member States. This will require the deployment of operational and accessible charging points where they are needed, and capable of delivering the right power output. Combining fleet-based targets with distance-based targets on the TEN-T ensures that the roll-out of charging stations matches the uptake of EVs.

  • New mandatory targets for heavy-duty vehicles (HDVs), maritime and inland waterway ports and stationary aircraft (art. 4, 9, 10 and 12)

The Platform fully supports the proposal for setting mandatory targets for HDVs, as this addresses the specific charging needs of electric trucks on the TEN-T networks as early as 2025. We also welcome the introduction of targets for maritime and inland waterway ports and stationary aircraft, as it helps boost the electrification of the transport sector.

Keeping those provisions is the first priority to make AFIR a success. However, the Platform believes that further improvements are needed, and has therefore set out a series of recommendations:

Clarify the definition of “alternative fossil fuels for a transitional phase”

The definition of “alternative fossil fuels for a transitional phase” (CNG, LNG, LPG, synthetic and paraffinic fuels produced using non-carbon-free energy) should specify until when this transitional phase will last.

Strengthen the level of ambition of the mandatory targets for light-duty vehicles (LDVs) (art. 3)

Currently, the power ratio of 1kW per 100% battery EV (BEV) and 0.66kW per plug-in hybrid EV (PHEV) would be already met by all but one of the Member States. In addition, the Commission’s analysis follows a methodology in terms of kW used (consumption evenly distributed during the year), which does not allow a response to peak demand. It is essential to consider the actual power delivered by a charging station, not the maximum power output (art. 2.37).

- Accordingly, the targets for BEVs and PHEVs should significantly increased until a point where a market can function organically. The targets should then be progressively lowered as the EV fleet size grows, and then ultimately phased out entirely when it reaches 7.5% of the entire fleet, as by then there will be sufficient demand to support a competitive private sector for EV recharging.

- The distance-based target of 60km between charging stations along the TEN-T network should be maintained during the upcoming negotiations. The customer-friendliness of charging stations should also be taken into consideration.

- The targets for the TEN-T comprehensive network should be brought forward by five years, so that all citizens can reach any destination within the EU using an EV.

- The deployment of alternative fuels infrastructure at the local level should be based on systematic consultation with local authorities as well as on the content of Sustainable Urban Mobility Plans (‘SUMP’).

- A density parameter can be included, to ensure that urban areas are properly covered and that there is a balanced territorial coverage.

Increase the power output for HDV-charging targets and consider the development of electric road systems for HDVs (art. 4 and 13)

Member States should have the possibility of promoting the deployment of Electric Road Systems (ERS) on sections where this is appropriate, in order to complement the targets for electric recharging stations. The Commission’s estimation of zero-emission trucks is significantly lower than the sales envisaged by truck makers.

- An increase total power output of HDV-charging pools along the TEN-T network should be considered, along with higher targets for urban nodes and for safe and secure parking areas.

- Targets for (semi-)public chargers at logistics centres and depots should also be introduced.

- The current timeline (targets starting from 2025 along the TEN-T core network) should be maintained, in order to not hinder the ramp up in the market for zero-emission trucks.

Complement rail electrification with additional guidance on deploying alternative fuels for the rail sector

We welcome the fact that the deployment of alternative fuels for railways has been included within the scope of the Regulation proposal, in the context of the National Policy Framework (art. 13). Setting decarbonisation targets for the rail sector would be consistent with the objectives set out in the European Green Deal and the Sustainable and Smart Mobility Strategy.

- Given the specific circumstances for investing in railway infrastructure, the deployment of hydrogen refuelling points or electric recharging points for battery trains are best dealt with on a national level. This should be done via the National Policy Framework of article 13, respecting the general EU principle of subsidiarity.

- Investment in alternative fuels infrastructure should take into consideration the national context as well as those rail network segments that are not going to be electrified.

- Investment in alternative fuel infrastructure for railways would be consistent with the provision -under the CEF2 Work Programme - of funding eligibility for hydrogen refuelling infrastructures for rail. Therefore, provisions of the Commission proposal for deploying rail alternative fuels infrastructure should be maintained (as set in art. 13.1 point (p)).

Improve the requirements on smart charging (art. 2 and 5.8)

The Platform welcomes the Commission’s recognition of the role of smart charging in the AFIR for enabling system integration. However, Platform has concerns over the retroactive effect of the measure. The following improvements should also be made to support smart-charging deployment.

- Amend the definition of smart charging (art. 2.59) as follows: “a recharging operation in which the power of charging can be adjusted within a specified time, based on external commands in order to enable a better integration of EVs into the whole power system to allow the possibility of a grid- and user-friendly way services”.

- Clarify the scope of ‘digitally-connected charging’ (art. 2.14), which should be limited to communication capacity needed for availability status and payment methods. The definition as currently written is confusing, as it may interfere with the smart modulation of power, thus overlapping with the definition of smart and bidirectional charging. The definition should leave a degree of flexibility, in order to take into account the differing levels of technological maturity in Member States.

- Cater for the future introduction of bidirectional charging capabilities in art. 5.8, allowing this technology to advance in the coming years. In addition, the development of bidirectional charging should not be left to an assessment by System Operators alone (art. 14); it should involve all relevant stakeholders, in order not to limit its uptake.

- The obligation in art. 5.8 should apply to all newly installed and refurbished or replaced recharging facilities as well as those financed by public funds.

- Given the environmental issues and to avoid the high compliance costs for CPOs, Member States should evaluate regularly (e.g., every three years) the need to retrofit existing charging stations.

- The reference to ‘normal power’ should be removed. Smart charging should be done in coherence with the proposal of revision of the Renewable Energy Directive. Therefore, para. 8 of art. 5 should be amended as follows: “From the date referred to in Article 24, operators or recharging points shall ensure that publicly accessible newly built and refurbished as well as publicly funded recharging stations operated by them are capable of smart charging.”

Harmonise the status of charging at EU level

The AFIR should harmonise the status of charging (as a good or as a service) without modifying the statuses that are already in place at national level in the majority of the Member States. The alignment between the different elements of legislation on the interpretation of what constitutes a recharging session would avoid business uncertainties.

In art. 2.46, the ‘recharging service’ definition should be amended as follow: “‘recharging service’ means a service consisting of multiple elements, including the  provision of electricity and services, through a  recharging point;”

Remain flexible and forward-looking, in order to be ready for future innovation while avoiding prematurely mandating standards (art. 19 and Annex II)

We welcome the proactive identification of standardisation needs. This will bring benefit from an interoperability point of view. We support the fact that the proposal is not prematurely mandating unfinished standards (such as IEC 63110 and IEC63119) as to retain the possibility to identify additional needs at a later stage and avoid possible technology lock-ins.

- In line with this approach, we would like to point out the need for additional technical specifications for communication between the EV, its owner and the EV services infrastructure. This is necessary to ensure control for the user and a fair and open ecosystem. For example, EV drivers should be able to connect their EV to any home energy or fleet management system, as well as to grant access to their charging data to the e-mobility service providers of their choice.

- This should be done in agreement with the expert group of the Sustainable Transport Forum mandated by the European Commission.

Bring forward the date of submission of the National Policy Frameworks (art. 13 and 16)

The Platform believes that the calendar for the NPFs (National Policy Frameworks) should be brought forward by one year, for both the submission of the first draft to the European Commission (to 2024) and the final NPFs (to 2025).

Maintain consistency with other ‘Fit for 55’ legislation

The Platform would also like to underline that any definition and provisions set out in the AFIR, and the revision of the Renewable Energy Directive (REDIII), should be consistent2 with the revision of the Energy Performance of Buildings Directive (EPBD), given that its art. 12 will address private charging. In particular, it will be vital to keep consistency between the different definitions on smart and bidirectional charging.


Our response to the consultation on the revision of the TEN-T regulation


Platform's reply on the revision of EPBD

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The Platform for Electromobility warmly welcomes the EC’s willingness to revise the Directive on the energy performance of buildings (2010/31/EU, EPBD).

In light of the roadmap and scenarios proposed by the EC, the Platform does not only take a stand for the option 3 but points out that electromobility needs to be addressed as one of the key elements of the EPBD revision if the EU wishes to deliver the objectives set in the Smart and Sustainable Mobility Strategy, the Energy System Integration Strategy and the Renovation Wave Strategy. The deployment of private charging is as important for the growth of electromobility and the decarbonisation of transport as that of charging accessible to the public. The Platform also thinks that the electric bicycles (incl. e-cargo bikes, e-two-wheelers, e-moped and e-cars) should be considered when revising the EPBD.

Given that 90% of EV charging happens at home or in the workplace and that 80% of the EU’s current building stock will still be in used by 2050, the EC must tackle the outstanding barriers to the installation of EV chargers and collective charging infrastructure in all (non-) residential buildings to ensure that all EV users have a “right to plug”. In this regard, art. 8 of the EPBD should be revised.

To that end, the Platform shares its key recommendations.

Set minimum infrastructure requirements for all types of buildings (new and existing)

The EPBD should encourage Member States to implement measures to pre-equip all buildings. The Platform recommends putting in place minimum requirements for the pre-cabling of the installation of EV chargers and ensuring that all buildings will be pre-equipped by 2035.

Guarantee the right-to-plug to all EV users

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

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

Introduce requirements for smart charging

The development of smart charging in buildings is an opportunity for EV users: it ensures a better charging experience, reduces the consumers’ electricity bill1 and could reintegrate the surplus of electricity into the grids (V2G) and/or reuse it in the buildings (V2B). It could also support the uptake of electromobility and can create synergies with renewable energies by integrating them into the electricity grids and providing flexibility services to the system.

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

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


Guidance Note on "Recharge and Refuel" Flagship un the Member States recovery plans

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Introduction

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

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

 

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

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

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

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

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

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

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

  • Private, semi-public and public charging

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

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

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

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

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

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

  • To prepare such a plan properly, data is needed to understand the situation now, needs and gaps
    • Funds must be made available to support MS in gathering this data.
    • The capacity building of grid operators to be part of local infrastructure planning should be enlarged. The process of involving DSOs could include municipal, regional and highway charging infrastructure planning, the development of best location-plans with information on grid capacity and reinforcement needs, with information on costs being made available to all relevant industry actors directly involved in establishing the business case of the operation of the infrastructure, while respecting all data privacy requirements.
  • For proper infrastructure deployment planning purposes, data is needed to map:
    • Current infrastructure (in Charge Point Equivalent terms)
    • Geographic coverage and gaps
    • Available power levels
    • Accessibility of stations
    • Grid capacity (overall and at precise locations)
  1. The grids should be prepared for increased EV integration

 

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

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

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

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

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

  1. Smart-charging should be future-proof

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

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

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


An ambitious revision of the AFID consistent with the EU Green Deal

Key recommendations
The Platform for Electromobility calls for an ambitious revision of the Alternative Fuels Infrastructure Directive (2014/94/EU, AFI) consistent with the EU Green Deal
February 2021
An ambitious revision of the AFID is vital to accompany and boost the electrification of transport and reduce GHG emissions as requested by the EU Green Deal and the EU Smart and Sustainable Mobility Strategy. The current AFI Directive was adopted at a time the market for alternative fuels was still an emerging market. Europe must now equip itself with the right public and private charging infrastructure to support the surge of electric vehicles (EVs) and the transition to a zero-emission mobility.
In this context, the Platform for Electromobility calls for:
EXTENDING THE SCOPE OF THE DIRECTIVE
Given the EC’s goal to reduce EU GHG emissions by 55% by 2030, the revised AFID must incentivise the uptake of low and zero emission vehicles.
Key actions:
• Prioritise the electrification of transport as the most effective and efficient pathway compatible with the objectives of the EU Green Deal and the decarbonisation of mobility. In particular, the Platform underlines that the decarbonisation of the transport sector cannot be achieved with the fossil fuels still supported in the current AFID.
• Set minimum mandatory targets for the availability of recharging points in all public parking facilities from 2025 (e.g. supermarkets, shopping malls, car park operators etc.).
• Introduce an updated definition of charging points based on their power levels to the existing one, i.e. ultra-fast (≥150 kW) and fast charging (22-150 kW). Criteria for minimal requirements should embrace the number of points, charging power, ratio to the number of EVs. The market should decide the most useful power level to apply.
• Apply the revised directive also to charging infrastructure for Heavy Duty Vehicles (HDVs) (trucks and buses), electric charging for two wheelers and rail infrastructure. For HDVs, the specific charging needs of electric trucks should be addressed by introducing requirements for the roll-out of public charging infrastructure and electric road system for electric heavy-duty commercial vehicles (vans and trucks) in medium and large urban areas by 2025, as well as along the TEN-T Core Network.
• Require Member States to propose to the EC a decarbonisation strategy for their rail system, identifying the alternative fuels that they intend to make available on the parts of their network that are neither electrified nor mandated to be electrified under an existing EU regulation. In particular, MS should include in their strategy a plan to replace current refueling facilities as defined in point 2.(i) of Annex II of the Directive 2012/34/UE “Recast”.
• Revise consistently the AFID and the Energy Performance of Buildings Directive (2010/31/EU, EPBD) to ensure the same level of ambitions in both texts. The way article 8 of the EPBD imposes an obligation for the deployment of charging infrastructures in non-residential buildings may have an impact on publicly accessible charging infrastructure since some non-residential buildings are open to the public such as malls. Besides, the EPBD should address the issue of private charging in all types of buildings as it is also important for the development of electromobility.
SETTING MINIMUM BINDING TARGETS for the deployment of publicly accessible charging infrastructure
Key actions:
• Introduce minimum binding targets per Member States on the number of public chargers deployed per type of transport (Light Duty Vehicles, Heavy Duty Vehicles) starting in 2025. Minimum binding targets should also be set for the deployment of charging infrastructure for airport infrastructure for ground movements and onshore power supply or boat ‘refuelling’ in maritime and inland ports.
• Develop an EU methodology to set the binding targets introducing penalties in case targets are not satisfied. These targets should ensure that – at the minimum – the EU objective of 1 million public chargers in 2025 and 3 million in 2030 are reached. The penalties of each MS should be reinvested at national level for zero-emission mobility measures (like funds for electric infrastructures, public subsidies for EV uptake in favour of citizens or businesses like purchasing aid or fiscal measures etc.).
• Establish a new bottom-up EU metric considering the charger power level of charging points, the number of EVs, assessing locally the right geographical coverage of infrastructure (via geographic, traffic and density criteria) and including the level of access to a private charging infrastructure. Given that two thirds of cars are parked overnight on the street (or public car parks), EV users living in condominiums, in particular, should be able to benefit from a public charging point in their residential area when it is not possible to install a charger in their building.
• Empower local authorities to take clearer and simpler administrative procedures to install public charging infrastructure.
• Request Member States to decarbonise the non-TEN-T part of the rail network, through further electrification, where economically feasible, or through battery and hydrogen powered trains.
ENSURING CONSISTENCY between the AFID and the TEN-T Core and Comprehensive Networks
The EC should revise the TEN-T guidelines in line with the requirements of the revised AFID.
Key actions:
• Make the minimum target of one charging point/60 km mandatory, as defined in the TEN-T Core Network for both TEN-T Core and Comprehensive Networks by 2025 to make the EVs convenient for long road journeys and ensure the coverage of the TEN-T Networks with ultra-fast chargers, including urban fast charging hubs.
• Align the TEN-T high-power recharging infrastructure requirements with the electricity development plans.
• Focus on the part of the main line rail network which is not part of the TEN-T as well as nodes on the Core and Comprehensive networks (ports, multimodal terminals for example).
DEVELOPING SMART CHARGING
The Platform emphasises the capacity, in general, of electricity system operators to integrate EVs even with an ambitious target for 20301. However, in some places of Europe this would require the adoption of smart-charging
1 In France, the French DSO Enedis has concluded in a report that the needed investment to integrate EVs into their grids will only represent 10% of their total investment by 2030 (cf. Enedis, Report on the integration of electric mobility in the public electricity distribution network, November 2019)
strategies to optimise network investment and, potentially, reduce the need for grid reinforcement. The Platform underlines that smart charging should be developed in accordance with the evolution of mobility needs of EV users and with their consent.
Key actions:
• Introduce a definition of “smart charging” as charging of an EV which facilitates the security (reliability) of electricity supply while meeting the mobility needs of the user. The definition should serve as basis and be referred to in other legislations. It should be coherent with already existing legislations supporting the integration of EVs in the power system (e.g. electricity regulations on the role of DSOs).
• Ensure that publicly accessible normal charging points (<22 kW) installed from now on are smart and future proof. This requirement should specifically apply in residential areas and cities where people may have limited access to private charging points.
GUARANTEEING INTEROPERABILITY via a user-centric approach
The electricity charging infrastructure should be interoperable to provide seamless EV charging experience to the users through the use of open and compatible standards and open and shared data on information, location and availability of chargers as well as price transparency to deliver more intelligent services such as smart charging, roaming of service and common ad-hoc payments (at least at national level). The EC should provide a harmonised framework for product and security requirements for charging and data exchange at the different interfaces without excluding technology already in the market.
Key actions:
• Put in place interoperability principles for the operation of various technical standards and protocols on the market to promote a competitive market environment and improve user experience.
ENSURING A STRONG IMPLEMENTATION OF THE DIRECTIVE
To ensure the rapid and strict implementation of the binding targets and provisions set in the revised AFID, the EC should tighten the EU monitoring and further involve the local level.
Key actions:
Consult with local authorities and distribution system operators when developing National Policy Frameworks or strategies to implement them.
• Create independent national reporting authorities within Member States (such as National Energy Agencies) in order to strengthen EU monitoring of the implementation Member States’ target.
,
• Turn the AFI Directive into an ad-hoc EU Regulation for road transport infrastructure to ensure a strong, rapid and more uniform implementation in all Member States. However, considering other modes of transport (inland waterways, maritime transport) for which alternative fuels are less mature, the directive should remain the preferred regulatory tool.