EPBD: Completing the charging requirements for new and under major renovation buildings.
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.
Key recommendations:
- Include depot charging for heavy- and light-duty vehicles, i.e. extending the scope of the EPBD to cover new or renovated private depots, as well as logistic hubs and distribution centres. This would require them to be ready for future battery electric truck charging (350 kW+ chargers), so that trucks can conveniently charge while loading/unloading. This should include pre-equipment, as well as an appropriate grid connection.
- Charging facilities for e-bikes should match those for e-cars. There are two options:
- recharging points for electric vehicles would be equipped with a household power socket, allowing for the easy charging of both e-bikes and e-scooters as well as certain types of L-category vehicles such as e-mopeds, or
- deploy a separate bicycle charging infrastructure, with dedicated bicycle recharging points.
- The requirements should apply to all buildings that are undergoing a major renovation, regardless of whether the car park is included in the renovation measures.
- Greater ambition for parking spaces for non-residential buildings; there should be a minimum of 50% of parking spaces with charging points.
EPBD: 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.[1] As a result, the EC should ensure the installation of charging points in existing buildings.
Key recommendations:
- Extend the scope of Art. 12 to ensure requirements for installing charging points in existing buildings. Incentives or enforcement mechanisms, to make sure that the stakeholders involved comply, should be introduced.
- Avoid putting a disproportionate burden on building owners and tenants, by addressing the necessary elements to reduce the costs of private charging installation.
- Introduce per-cabling requirements for existing buildings:
- 2027: all parking spaces in 15% of all buildings
- 2030: all parking spaces in 30% of buildings (100% for all publicly owned buildings)
- 2035: all parking spaces in all buildings.
- More ambitious charging point requirements for non-residential buildings (15% of parking spaces (2030), 30% (2035) applicable for all buildings with more than ten parking spaces.
[1] EPBD Impact Assessment.
Platform general comments for the trilogue negotiation on Battery Regulation
Battery Regulation
Our recommendations for trilogue
During current trilogue negotiation on the Battery Regulation between institutions, we welcome several changes introduced by the European Parliament (EP) and Council. Notably, we support:
✓ The change of scope for the carbon footprint declaration per battery model and plant, rather than per batch, as initially proposed by the Commission.
✓ In the EP text, ambitious deadlines for recycling and material recovery conditions for batteries on the European market whether they are imported or not.
✓ We welcome the emphasis on the waste hierarchy and the clarification on reuse of batteries when available on the market, notably the explicit transfer of Extended Producer Responsibility from producer to second user.
✓ Both texts base due diligence obligations on the UN Guiding Principles on Business and Human Rights and OECD Guidelines for Multinational Enterprises, and that both EP and Council have strengthened the environmental risk categories in Annex X.
✓ The Grandfathering clause for spare parts proposed in the EP text.
We have however reservations and will remain vigilant on the following points:
Timeline & targets
The innovative approach of this regulation requiring multiple new sustainability criteria declaration and control, accompanied by close to 40 currently unknown secondary acts, is a first in terms of implementation.
➢ Recommendation: ample resources should be dedicated by lawmakers to ensure that the proposed targets and timelines for the implementation of the new sustainability criteria can be met.
Guarantee of origins
Concerns over the explicit possibility in the Council text to use guarantees of origin alone as proof of clean and renewable energy for the purposes of the battery carbon footprint calculations.
Recycling and end of life
Binding recycling content should always go hand in hand with a careful assessment of the environmental costs and benefits, and compatible with the real technological state of the art and availability of recycled materials.
Further, availability of batteries for second life must be considered. We would like to stress that EV batteries should always be handled by professionals with a certain level of qualification, and that the same goes for potential EV battery waste. Minimum conditions for battery recycling outside Europe should be ensured, accompanied by a deadline for when such conditions must be established. This can help to get extra-EU battery recycling industry ready for incoming EOL battery volumes.
➢ Recommendation: Recycling targets in Article 57, Annex XII must be brought forward in the Council text (in line with the timelines proposes by the Commission) to reflect the vital need for a domestic supply of raw materials. At the same time, the possibilities for reuse must be clarified as more EV batteries are available for second life.
The substances needed for EV batteries should always remain in a waste loop. Future potential restrictions of substances must take into consideration the strategic autonomy objective of the EU battery sector, the performance of EV batteries and the closed loop of the substances needed for batteries. In addition, second-life batteries should not be exempted from obligations on performances and durability.
Removability
We want to highlight the significant technical difficulties, safety and performance challenges coming with the EP’s proposed removability and replaceability requirements for EV and industrial batteries at cell level. Such requirements would remove any incentive or space to innovate and contradicts the idea of longer lasting and better performing batteries if battery pack designs are not allowed to change over time.
➢ Recommendation: we do not support the extension of the removability and replaceability requirements to all batteries at cell level, as they would threaten the performance, safety, and technical integrity of the whole battery. We therefore call on maintaining the Commission’s current article 11 setting removability and replaceability requirements for portable batteries only.
6th E-Mobility Power System Integration Symposium
– 10 October 2022 – Delft / The Hague, Netherlands
Supported by the Platform for electromobility, the purpose of the E-Mobility Power System Integration Symposium is to discuss the challenges that arise with increased power demand due to electric vehicle charging, and how they can be met by coordinating with renewable power production in the electrical system. The selection of topics also highlights the need for integrating the required electric vehicle charging infrastructure with the expansion of the distribution and transmission system.
The Symposium offers a prime opportunity to discuss the significant future impact of electromobility on power system design and operation. It aims to bring together experts on electric vehicles, charging infrastructure, power system operators, and stakeholders of the renewable energy industry as well as power system regulators and universities.
Discover the agenda HERE
Registration HERE
Find more information on the Symposium website.
PV – EV : A powerful duo to make Europe drive clean
The three keys for a join deployment of solar power and electric vehicles
Electric vehicles (EVs) deployment needs to significantly accelerate in the coming years. However, challenges to its deployment (lack of distribution grid availability, low consumer engagement, challenges to the deployment of the infrastructure during renovation, etc.) show very close similarities with those posed by the deployment of distributed photovoltaic solar power plants (PVs). Therefore any successful solutions should benefit both EV and PV deployment.
The uptake of EVs, together with PVs deployment (mainly via rooftop solutions), opens an important opportunity for unlocking a European ‘prosumer’ potential. ‘Prosumer’ refers to a model where individuals manage their own energy supply and consumption. Prosumer models can become a powerful enabler of Renewable Energy Sources (RES) integration, including photovoltaic solar power plants (PV). The joint integration of PV and EV will also have a significant impact on citizen carbon footprint (for their home energy and transport), by ensuring EV charging take place during periods of highest renewable content.
The rapid, massive uptake of EVs has the potential to become both a flexible asset for grid management and an opportunity for prosumer business models. EVs will also provide a boost to increasing the cost-effective penetration of renewable energy – like PV – within the electricity system. The combination of EVs, their batteries and smart-charging functionalities as sources of ancillary services for the distribution grid will bring clear benefits, in terms of RES integration, for both individual and collective projects. Electromobility and renewable energy therefore offer a win-win partnership. The benefits of smart and bidirectional charging in regions with high solar capacities are clear: when sun sets and falls, EVs can optimise consumption and grid constraint and avoid polluting at peak times.[1]
Recent European legislation, through the ‘Fit for 55’ package, leverages these opportunities, notably in the revision of the Renewable Energy Directive (see our full position here and here), but there is still more that can be done to increasingly make cars in Europe run on renewable energy.
Signed by both renewable energy suppliers, charge points operators (CPOs) and other relevant stakeholders, this joint call shows the enthusiasm within the whole industry to explore the synergies between solar electricity and EV charging solutions. To enhance these synergies and solve common challenges between EVs and PV, we recommend:
1. Developing an enabling framework for EV drivers to become prosumers
A significant share of EV drivers (30-50%) charging at home are usually interested in installing PV panels as part of their broad decarbonation objectives and to maximise their contribution to climate change objectives.
This offer considerable potential for encouraging prosumer behaviour, but in order to realise this potential, an appropriate regulatory and technological framework is needed. To make this a reality, the EU should develop a distributed energy strategy capable of empowering and boosting prosumers with solar PV, battery and EV, and, at the same time, ensure that the electricity distribution grid can connect distributed RES. It should be noted here that the adoption of these distributed loads does not pose a problem for the distribution grids in the short- and medium-term, since the most significant impact will occur principally in very specific areas and at a later stage, when greater investment will be needed.[2]
Rooftop solar, EVs and other local flexibility resources will only realise their full potential once they are able to also provide grid services via flexibility markets. This will require the full implementation of the Clean Energy Package across Europe. However, because this is not yet the case – despite the deadline expiring – the EU should look into options for applying greater pressure on Member States. A full implementation would allow entry into the next phase, which will see the designing of local flexibility markets, together with the European DSOs, to find appropriate flexibility signals for EV users.
2. Ensuring an enabling framework for solar PV deployment
To support the use of renewable energy in electric mobility, an enabling framework must be build. PPAs contracts must be facilitated, through clear frameworks and financing support – the guidelines on PPAs will be critical here. In addition, the stability of investment signals and market rules will be key.
In addition, permitting still pose significant barriers to solar PV project development. Here, the RED II provisions must be implemented, and the Commission should support the exchange of best practices.
3. Helping transition to needed new skills
With the development of new economic sectors, boosted by EV uptake such as PV industry, the transition to electromobility does not pose a threat but rather an upskilling opportunity for workers. New skills will indeed be needed, both to adapt the manufacturing of vehicles and to install the required infrastructure across Europe. We recommend the launch of a Skills Initiative on Solar installers, in synergy with CP operators and installers, as well as a Distributed Energy Installers Skills Initiative.
From a forward-looking perspective, it will be possible to identify specific initiatives for integrated retrofits.
In highly specific use cases, new approaches could be explored to reduce the installation and integration cost related for the combined installation of Solar PV, Home Storage and V2X charging. Early-stage experience has shown that the integration of AC-DC conversion technologies across the different voltage levels could be a solution for reducing PV and EV integration costs in certain use cases, such as isolated houses or rural areas (up to 30%-50%[3]). From that perspective, we would suggest identifying how the application cases can be addressed through Horizon Europe or similar calls in the areas of R&I identified above.
[1] For example, in California, a study has shown that “the real strength of grid-integrated vehicles in mitigating the duck curve is in avoiding large system-wide ramping, as seen in figures 3(c) and (d). In the V1G-only case, down-ramping and up-ramping are both mitigated by more than 2 GW/h by 2025. In the case with a mix of V1G and V2G vehicles, however, substantially larger gains are seen. Both down-ramping and up-ramping are substantially mitigated, by almost 7 GW/h, equivalent to avoiding construction of 35 natural gas 600 MW plants for ramping mitigation”. “Clean vehicles as an enabler for a clean electricity grid”, Jonathan Coignard, Samveg Saxena, Jeffery Greenblatt, Dai Wang, 2018
[2] Debunking the myth of the grid as a barrier to e-mobility, Eurelectric 2021 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
[3] Calculations made by Dcbel on real pilot home data in England
First feedbacks to the revision of the CO2 emission performance standards for new heavy-duty vehicles
CO2 Standards for HDVs
Our first feedbacks to the Commission
The Platform for electromobility very much welcomes the Commission’s willingness to revise the HDV CO2 standards. The standards are a fundamental tool to advance the zero emission transition, as outlined in the European Green Deal and advance the transport sector. More ambitious standards set the right pace and a clear trajectory for manufacturers and logistics operators. Hence, the revision of the Directive (EC) 2019/1242 is a needed and welcome step of the Commission to lower emissions from trucks and other heavy-duty vehicles. The revision should align the CO2 targets for the transport sector with the EU’s overall -55% GHG reduction target in 2030 and the climate neutrality target of 2050. Importantly the HDV CO2 standards are the single most effective tool to achieve scaling effects in production and technology development, which contributes to making electric HDVs more competitive and widespread.
In particular, the Platform calls the European Commission to prioritise the following:
- Almost all newly registered heavy duty vehicles (including long haul) should be zero emission at the latest by 2035, whilst an exemption can be considered for some niche vocational vehicles (such as construction trucks) with a 100% ZEV target by 2040.
- The introduction of an intermediary target in 2027 is necessary to accelerate the transition to electric trucks already in the 2020s
- Strengthening the ambition in 2030 is crucial to spur the momentum and further scale up production and sales of ZETs.
- Crucially, no mechanism for renewable and low-carbon fuels should be included under this regulation
The Platform wants to stress that with regards to urban buses the revision of the CO2 standards should also take into account the demand-side targets from the Clean Vehicle Directive (Directive 2019/1161), especially when taking into account the purchasing of heavy-duty ZEVs for public authorities. The standards are an important tool to drive down the prices of buses of publicly procured vehicles, making them affordable for public institutions.
Lastly, the Platform highlights that the transition to electric trucks and buses is a considerable opportunity for the European electromobility value chain and the competitiveness of the economy. Ambitious targets would make Europe a leader in zero emission HDVs and thus further unlock the potential of the electromobility value chain.
Electrifying heavy trucks is particularly crucial in the wider context of reducing Europe’s GHG emissions as it makes up the largest part of the HDV emissions and allows to drastically improve noise and air pollution.
Investments need to be made for higher grid capacity to serve truck charging demand.
The 10 points for success of the new Alternative Fuels Infrastructure Regulation (AFIR)
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.