Input to the Inception Impact Assessment of Directive 2014/94/EU on the Deployment of Alternative Fuels Infrastructure
The European Commission is assessing the revision of the AFI Directive.
ChargeUp Europe considers this comes at a critical time in Europe’s shift to a green and sustainable economy.
In order to enable the development and deployment of clean, electric mobility, the impact assessment needs to focus on the policy options that ensure that charging infrastructure can handle the scale of electric vehicles expected to come onto market in the coming years and enable the EU to achieve its goal of climate neutrality by 2050.
You can see our contribution here and below:
Introduction
ChargeUp Europe is an alliance representing the electric vehicle (EV) charging infrastructure industry. It has been formed to accelerate the switch to zero emission mobility and ensure that people can have a seamless driver experience with access to high quality, readily available charging infrastructure across Europe. As of today, it represents a combined network of over 150,000 charging points in Europe.
ChargeUp Europe welcomes the opportunity to provide input into the Inception Impact Assessment (IIA) of Directive 2014/94/EU on the Deployment of Alternative Fuels Infrastructure (AFID).
Input
The evaluation of AFID comes at a critical time in Europe’s shift to a green and sustainable economy. In order to enable the development and deployment of clean, electric mobility, the impact assessment needs to focus on the policy options that ensure that charging infrastructure can handle the scale of electric vehicles expected to come onto market in the coming years and enable the EU to achieve its goal of climate neutrality by 2050.
PRIORITY: LEGISLATIVE INSTRUMENT
Replace Directive with Regulation. Alternative fuels infrastructure policy should aim to deliver an accelerated rollout of harmonised infrastructure, enlarged in scope for all types of electric vehicle charging across the EU. This will ultimately support investments, and lead to the smooth uptake of e-mobility and a seamless driver experience across the EU, not to mention substantial benefits to the energy system. In order to achieve this, ChargeUp Europe recommends replacing the current Directive with a Regulation which can deliver a faster, more effective and harmonised approach across the EU.
PRIORITY: SCOPE
Focus only on zero emission fuels and examine use cases for different fuel types. If the EU is serious about achieving climate neutrality by 2050, the Directive needs to be revised to prioritise only those options with the greatest potential to decarbonise the road transport sector. The impact assessment should analyse the use-cases of different alternative fuels for different sectors. In this regard, electrification is already proven to be the most sustainable and efficient option for reducing CO2 and other particle emissions across the road transport sector and achieving the European Green Deal objectives.
Public and private charging. The scope of the legislation needs to be widened to harmonise technical requirements and ensure an ambitious and coherent increase for public charging, private charging accessible to the public, and private charging that is not accessible to the public. The impact assessment should assess the need to further define what “publicly accessible” means and the need to include private charging in the scope of the Directive, alongside corresponding distinctive (minimum) requirements for different use cases.
PRIORITY: CHARGING NETWORK COVERAGE AND TARGETS
Ambitious smart targets. The legislation needs to enable smart and targeted minimum coverage across the EU. Binding targets at Member State level should be set and these targets should be further weighted taking into account aspects such as: the specificities of the charging infrastructure (e.g. targets for public charging versus targets for charging on commercial properties which are publicly accessible); regional traffic and housing characteristics and; existing national needs (e.g. home charging may be more common in one Member State and public charging in another). The impact assessment needs to examine regulatory barriers in national housing laws that discourage EV adoption and explore how to build on existing best practices on EV charging and the ‘right to plug’ (installation of charging infrastructure).
Ambitious binding targets will ensure less fragmentation across Member States and lead to more consistent development of the EV market across the EU.
At their core, these targets will encourage private investment in EV charging infrastructure and ensure that public investment is primarily directed towards addressing possible coverage gaps (e.g. in less populated areas or areas where there are no market incentives to invest).
Heavy duty vehicles. The impact assessment should look at how to address the specific requirements of electric heavy-duty vehicles (HDVs, incl. vans and trucks) as their recharging requirements will differ from those of light passenger vehicles. Appropriate coverage for HDVs across the EU road network and in urban areas is key and synergies between the transport and energy sectors need to be promoted. The revision of TEN-T should be linked to TEN-E in order to smartly map out and plan charging infrastructure locations (e.g. rest areas with charging facilities for long haul, multiple uses for different types of charging stations). The current Directive has been successful in harmonising the plug standard for cars and a revision should aim to deliver the same uniform development for heavy duty vehicles.
PRIORITY: INTEROPERABILITY, COMMUNICATION PROTOCOLS AND CONSUMER INFORMATION
Open and interoperable. The development of e-mobility across the single market will depend on open interoperable technology and communication protocols. The impact assessment should look at how to address any existing fragmentation or proprietary network arrangements with regard to standards, communication protocols and product design. Adoption of open, non-discriminatory and uniform communication protocols (such as OCPP and OCPI) and related standards in EV charging infrastructure are fundamental pre-conditions for the acceleration of the installation of charging stations and to facilitate a seamless charging experience for the driver across charging networks and across Member States.
Consumer-centric. The legislation needs to have the consumer at its core. It should ensure that there is:
Quality data for all consumers irrespective of their networks and charging locations
Interoperability and choice with regard to authentication and payment systems and
Price transparency in the networks and via roaming to optimize driver experience.
PRIORITY: SMART CHARGING
Increased focus and clear definition. The legislation should recognise the importance of smart charging for a future renewables-based power system. The impact assessment should assess the need to provide a clear definition of smart charging (e.g.V2X) and set out what this means in terms of functionality to ensure that new charging infrastructure is future-proof and directed to smart, connected charging technology. It should evaluate the potential of the normal charging segment to deliver consumer, environmental and societal energy system benefits.
The future legislation should address the question of battery data access in order to deliver the benefits of smart charging listed above.
PRIORITY: MARKET ACCESS, TRANSPARENCY AND GOVERNANCE
Market access. The impact assessment should assess the current openness of the market and what barriers exist for charging infrastructure players entering the market. It should also examine and clarify the role for Distribution System Operators (DSOs) in the marketplace, which should be limited to addressing specific market gaps (e.g. similar to the procedures outlined in the Electricity Market Design Directive (EU) 2019/944).
Transparency and governance. The impact assessment should also examine transparency and governance issues. In order to ensure the speedy and efficient rollout of EV charging infrastructure and facilitate the growth of the EV market, DSO processes need to be adapted in order to speed up time to connection, permit procedures and provision of information to charging infrastructure businesses.
ChargeUp Europe looks forward to contributing in greater detail to the public consultation on this issue.