Commission Proposal for a draft Directive on the Deployment of Alternative Fuels Infrastructure (COM (2013)18 final)

Orgalime generally supports the promotion of a sustainable range of transport solutions and the build-up of interoperable, alternative fuels infrastructure in Europe as a means to stimulate sustainable growth, jobs and technology take up. As representing, among other, producers of the equipment that represents the essential link between the electric vehicle and the electric grid, Orgalime’s specific interest in the proposal for a Directive on the deployment of alternative fuels infrastructure relates to the provisions concerning electric vehicle infrastructure. 

We believe that the present regulations for electrical installations have brought electrical safety in Europe to a very high level. This must not be undermined by the introduction of e-vehicles whose charging infrastructure is integrated in the electrical networks and must respect the requirements of electrical regulation in Europe, derived, as they are both from the Low Voltage and EMC directives and from national codes and/or wiring regulations. 

Furthermore, in our view, electrical infrastructure needs to be able to ease the stress on the electricity grids through proper energy and load management and to evolve over time according to use patterns of customers that require convenient solutions. We therefore welcome the proposal that such points should be equipped with intelligent metering systems that will enable flexible energy consumption, potential energy storage and dynamic pricing. 

We support the inclusion of an ambitious target for the number of national recharging points, as well as that 10% publicly available charging points should be put in place in each Member State in a certain time frame, but caution that adjustments may be required depending on the state of the national policy frameworks and Member States’ own strategies for electric vehicle infrastructure deployment. Given the challenge of achieving this, we recommend allocating specific funding towards innovative projects in the sector. 

We agree with the general concept that slow and fast recharging points for electric vehicles should comply with technical specifications by a certain deadline. However, Orgalime has consistently advised against forcing a political decision in this area. We are an active promoter and supporter of the European standardisation work on e-mobility and electric vehicles which, in our view, has brought significant results following mandate M468. Consequently, we note with some reservations that the draft Directive imposes a political decision on a standard interface between the infrastructure and the e-vehicle through a defined technical specification. 

On the issue of comitology, Orgalime suggests introducing a stakeholder consultation mechanism.