EUROPEAN COMMISSION

Brussels, 14.7.2021

SWD(2021) 631 final

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT

Accompanying the

Proposal for a Regulation of the European Parliament and of the Council

on the deployment of alternative fuels infrastructure, and repealing Directive 2014/94/EU of the European Parliament and of the Council

{COM(2021) 559 final} - {SEC(2021) 560 final} - {SWD(2021) 632 final} - {SWD(2021) 637 final} - {SWD(2021) 638 final}

Table of contents

1.Introduction: Political and legal context

1.1.Political context

1.2.Legal context

1.3.Policy context

1.4.Evaluation of the existing Directive

2.Problem definition

2.1.What are the problems and their implications?

2.1.1.Lack of ambition and coherence in MS infrastructure planning leading to insufficient and unevenly distributed infrastructure

2.1.2.Interoperability issues persist in terms of physical connections and communication standards

2.1.3.Publicly accessible infrastructure does not fully correspond to user needs

2.2.What are the problem drivers?

2.2.1.Lack of binding provisions leads to different ambitions by Member States

2.2.2.Setting of targets by Member states not consistent with market developments and GHG reduction ambition

2.2.3.Implementation fails to consider necessary requirements/standards for ensuring full interoperability

2.2.4.Lack of user information about and at refuelling and recharging points

2.2.5.No uniform ad hoc payment method available at all recharging points

2.3.How will the problem evolve?

2.3.1.Lack of ambition and coherence in MS infrastructure planning leading to insufficient and unevenly distributed infrastructure

2.3.2.Interoperability issues persist in terms of physical connections and communication standards

2.3.3.Publicly accessible infrastructure does not fully correspond to user needs

3.Why should the EU act?

3.1.Legal basis

3.2.Subsidiarity: Necessity of EU action

3.3.Subsidiarity: Added value of EU action

4.Objectives: What is to be achieved?

4.1.General objectives

4.2.Specific objectives

5.What are the available policy options?

5.1.What is the baseline from which options are assessed?

5.2.Policy measures and policy options

5.2.1.Discarded policy measures

5.2.2.Retained policy measures and policy options overview

5.3.Description of policy options

5.3.1.Policy option 1

5.3.2.Policy Option 2

5.3.3.Policy Option 3

5.4.Discarded Policy Options

6.What are the impacts of the policy options?

6.1.Economic impacts

6.1.1.Impact on alternative fuels vehicles and infrastructure markets

6.1.2.Administrative burden for public authorities

6.1.3.Infrastructure costs

6.1.4.Costs and benefits on vehicle and vessel manufacturers

6.1.5.Impacts on SMEs / professional vehicle users and businesses

6.1.6.Functioning of the internal market and competition

6.1.7.Impact on innovation and industry competitiveness

6.2.Social impacts

6.2.1.Impacts on households and consumers

6.2.2.Impacts on employment and social skills

6.2.3.Impact on persons with disabilities and those with reduced mobility

6.2.4.Impact on public health

6.3.Environmental impacts

6.3.1.CO2 emission reduction

6.3.2.Air pollutants emission reduction

7.How do the options compare?

7.1.Effectiveness

7.2.Efficiency

7.3.Coherence

7.4.Proportionality and subsidiarity

7.5.Summary of comparison of options, including stakeholder views

7.6.Infrastructure needs depending on the level of stringency of CO2 standards for LDVs

7.7.Sensitivity analysis on sufficiency and share of fast chargers

7.8.Sensitivity analysis on the requirements for HDVs charging points

8.Preferred option

8.1.Context

8.2.Identifying the preferred option

8.3.REFIT (simplification and improved efficiency)

9.How will actual impacts be monitored and evaluated?

Annex 1: Procedural information

Annex 2: Stakeholder consultation

Annex 3: Who is affected and how?

Annex 4: Analytical methods

Annex 5: Methodology for the definition of policy options and measures

Glossary

1.Introduction: Political and legal context

1.1.Political context

The European Green Deal 1 puts climate action at its core, by setting an EU climate neutrality objective by 2050. The Commission proposal for a European Climate Law turns this commitment into a legally binding target and also proposes a new colletive , net greenhouse gas emissions reduction target of at least 55% below 1990 levels by 2030 for the Union. The European Parliament and the Council have found a provisional political agreement on the European Climate Law setting into law the objective of a climate-neutral EU by 2050 and of the collective net greenhouse gas emission reuction target of at least 55% by 2030.

The Commission’s Communication on a Sustainable and Smart Mobility Strategy 2 confirms the ambition of the European Green Deal to achieve a 90% reduction in the transport sector emissions by 2050 and sets out various milestones to show the sectors path towards achieving this objective. Those include among others the ambition to have at least 30 million zero-emission cars and 80,000 zero-emission lorries in operation by 2030 and that by 2050 nearly all cars, vans, buses as well as new heavy-duty vehicles will be zero-emission. This is also in line with the Zero Pollution ambition set up by the European Green Deal.

A comprehensive and easy to use network of recharging and refuelling infrastructure is a prerequisite to enable the widespread uptake of zero- and low-emission vehicles. Such an achievement is also of central relevance to the recovery of the European economy after the COVID pandemic – in particular of the automotive sector – and reflected accordingly in the Annual Growth Strategy 2021 3 under the ‘recharge and refuel’ flagship initiative.

This impact assessment addresses the needs, options and benefits for revising Directive 20014/94/EU on the deployment of alternative fuels infrastructure (AFID, in the following: the Directive) in order to ensure the necessary deployment of interoperable and user-friendly public accessible infrastructure for recharging and refuelling zero- and low-emission vehicles.

This initiative forms part of the overall effort to bring the Union on track to climate-neutrality, deliver on the long-term climate, environmental and energy objectives and build back better in terms of economic recovery, among other. It is part of a package of initiatives adopted under the “Fit for 55” package 4 approach of the Commission in 2021. It is particularly complementary to the legislative proposal for setting new CO2 emission performance standards for cars and vans post 2020 – together both policy initiatives create a coherent approach to vehicle and infrastructure market take up.

1.2.Legal context

The Directive establishes a common framework of measures for the deployment of publicly accessible alternative fuels infrastructure. Building-up such publicly accessible infrastructure to enable the uptake of zero- and low-emission vehicles shall reduce oil dependence and mitigate environmental impacts specifically of road and waterborne transport. While it covers a range of fuels, including electricity, hydrogen, biofuels, natural gas and synthetic and paraffinic fuels, it particularly defines certain minimum requirements for fuels that require distinct infrastructure (electricity, gas, hydrogen).

The directive obliges Member States to develop National Policy Frameworks (NPFs) that shall enable to develop the market for alternative fuels and the infrastructure to support them. Member States have to assess the current state and future prospects, set targets for deploying the infrastructure and the measures necessary to meet them (electricity and natural gas for both roads and ports whereas hydrogen is voluntary). There is no common methodology for informing the development of NPFs. Member States have to ensure by certain dates a coverage of the TEN-T core network with appropriate recharging and refuelling infrastructure (“appropriate” not being defined). The directive also norms certain user information (e.g. on comparison of alternative fuels unit prices, on fuel labelling). Member States report every three years on the implementation of their NPFs.

Member States are required to support the commercial development of infrastructure, whereas public financing should support the development of infrastructure in early stage of market development and cases of market failure. This is further clarified by the revised Electricity Directive that bans Distribution System Operators to own and operate recharging points unless there is proof that no private operator is willing to do so.

The directive equally norms common technical specifications in its Annex II. Some of those technical specifications have been supplemented by means of delegated acts under the directive, following the implementation of a standardisation requests that the Commission had mandated to the European Standardisation Organisations (ESOs).

The Directive also addresses to some extent the role and responsibility of operators of recharging and refuelling points accessible to the public, for example with respect to a general obligation for price transparency, non-discrimination and the obligation to offer ad hoc payment solutions (users to charge without entering into a contract with the operator).

1.3.Policy context

The common scenarios underpinning the Climate Target Plan and the Sustainable and Smart Mobility Strategy showed at least 30 million zero-emission cars and 80,000 zero-emission lorries in operation by 2030 and also showed that by 2050 nearly all cars, vans, buses as well as new heavy-duty vehicles will be zero-emission while also the other transport modes need to shift towards zero emission fuels. The directive aims at ensuring that sufficient publicly accessible recharging 5 and refuelling infrastructure is in place for all modes to ensure that the low and zero emission vehicles and vessels coming into the market are supported by a sufficient number and full geographic coverage of interoperable infrastructure.

The directive is an important complement to other policy instruments that address European policy objectives on climate change, transport, energy and environment. As the main policy instrument for alternative fuels infrastructure it interacts with a broad range of different policy instruments, many of which are also revised under the “Fit for 55” package. They include:

·CO2 emission performance standards: The regulations on EU emission standards for cars and vans 6 and heavy duty vehicles 7 set emission standards for vehicle manufacturers fleets. They provide a strong push for deployment of zero- and low-emission vehicles, creating demand for alternative fuels infrastructure. The Impact Assessment of the revision of the CO2 standards for cars and vans will provide an analysis on the numbers of zero- and low-emission vehicles needed to contribute to the increase in overall climate ambition by 2030. The revision of the directive enables this uptake by providing sufficient infrastructure.

·Energy and fuels policy: the Renewable Energy Directive 8 and the Refuel Aviation 9 and FuelEU Maritime initiatives 10 set obligations on the supply of, or demand for, renewable and low carbon transport fuels. The Fuel Quality Directive 11 addresses the reduction of the GHG emission intensity of road transport fuels. The CO2 emission standards for cars and vans and trucks address newly registered vehicles and ensure the increased supply and affordability on the market of new efficient and zero-emission vehicles. Fuels related legislation provides incentives for the use of low-carbon and renewable transport fuels in the existing vehicle fleet. Those are complementary instruments aiming at the reduction of transport emissions and creating demand for alternative fuels infrastructure in line with the EU Strategy for Energy System Integration 12 .

·Related infrastructure policy: the Energy Performance of Buildings Directive 13 (EPBD) addresses private recharging infrastructure by stipulating requirements for roll-out of recharging infrastructure in buildings. The EPBD is complemented by flanking action in the context of the strategy “a renovation wave for Europe” 14 . AFID and EPBD are required to work together to provide a sufficient level of recharging infrastructure; the relationship of public and private recharging infrastructure has been thoroughly addressed in this Impact Assessment 15 . The Regulation on the Guidelines for the Trans-European Transport Network 16 enables at present the rollout of alternative fuels infrastructure as part of the deployment of innovation and new technology actions in form of individual projects on the TEN-T network corridors, which are established by that Regulation. Those projects have grown in scale over the years, leading to a substantive, but far from complete equipment of the TEN-T with alternative fuels infrastructure. This initiative and the initiative for the revision of the Regulation on the TEN-T guidelines are fully complementary. This initiative establishes concrete requirements for the deployment of recharging and refuelling infrastructure along the TEN-T core and comprehensive network, in urban nodes and in TEN-T ports and airports. Those requirements will be referenced in the proposal for the revision of the TEN-T regulation, so that there is a coherent policy framework

·Other policies set incentives for low- and zero-emission vehicles and vessels and their recharging and refuelling infrastructure, by internalising the climate and environmental externalities (the Eurovignette Directive 17 , the Emission Trading System 18 and the EU Energy Taxation Directive 19 , currently under revision), by boosting vehicle demand through public procurement (the Clean Vehicles Directive 20 ) and by setting new requirements for electric vehicle batteries (proposal for a Batteries Regulation 21 ). The pollutant emission standards, Euro 6 for cars and vans 22 and Euro VI for buses and lorries 23 require that all vehicles, including those fuelled with alternative fuels, do not emit, on the roads, more than the prescribed emission limits.

·The EU’s 2021-2027 long-term budget, together with NextGenerationEU, supports accelerated investment in alternative fuels infrastructure through Member States’ recovery plans under the Recovery and Resilience Facility (RRF). That support can be complemented by extended financing under the Connecting Europe Facility but also the InvestEU instrument and the European Structural and Investment Funds. Horizon Europe will address research and development strand, particularly through the 2Zero and Batteries Partnerships and the Fuel Cell and Hydrogen Joint Undertaking.

This Directive is fully complementary and delivers additional value added to these instruments. It is the main policy instrument to set the overall requirements for technical interoperability of alternative fuels infrastructure, related consumer information and rollout of publicly accessible infrastructure. In light of the above, the revision of this Directive sits within the broader context of the ‘Fit for 55% package’. The interactions between this impact assessment and particularly the impact assessment supporting the revision of the CO2 emission standards are most relevant, but furthermore also with the Renewable Energy Directive, the Energy Efficiency in Buildings Directive, the Energy Taxation Directive, the EU ETS, the FuelEU maritime and RefuelEU aviation and the revision of the TEN-T regulation. This impact assessment is therefore building on the analytical work of the Climate Target Plan 24 , which takes into account the interaction and combination of the various policies. The interactions are further explored and assessed in the next sections.

1.4.Evaluation of the existing Directive

A REFIT ex-post evaluation showed that the Alternative Fuels Infrastructure Directive has supported the development of policies and measures for the roll-out of alternative fuels infrastructure in Member States, particularly through the requirement to develop National Policy Frameworks (NPFs) (see Annex 10). Despite the great differences in ambition and supportive policy measures across Member States, those policy frameworks have started to help building a medium-term perspective on infrastructure for electricity, natural gas and hydrogen until 2030 in all Member States.

However, shortcomings of the current policy framework have also been pointed out and the key objective of the Directive, namely to ensure a coherent market development in the EU, has not been met. Shortcomings arise in particular in the following three areas that are further addressed in chapter 2:

·The uptake of alternatively fuelled vehicles and deployment of corresponding infrastructure is not coherent across Member States. It has not led to a complete network of infrastructure allowing seamless travel across the EU. This is in particular the case for electric recharging points and hydrogen refuelling stations as well as with respect to on-shore power supply (OPS) and LNG infrastructure in ports. Furthermore, infrastructure for zero emission heavy-duty vehicles (HDV) is largely missing across the EU. The overall ambition for the deployment is not sufficient to meet the EU’s GHG reduction target of 55% by 2030 and the 2050 climate neutrality objective in view of the necessary significant increase of zero and low-emission light and heavy duty vehicles as well as vessels.

·While standards have been developed and prescribed to ensure interoperability between the vehicles and infrastructure, new technologies are emerging requiring further common technical specifications to ensure interoperability. In this context, and while alignment with electricity market legislation has been ensured, for the mass uptake of electric vehicles in the future, further provisions may be required to fully enable smart recharging through appropriate standards.

·User aspects have already been addressed to a certain extent in the Directive but this has not lead to full user information, uniform and easy to use payment methods and full price transparency across the EU.

The evaluation concluded that six years after the adoption of the Directive, the overall European market for alternative fuels infrastructure is still in a rather early development phase, though markets in some parts of the Union are maturing. The development of infrastructure has, however, largely kept pace with the development of the vehicle fleets that show different trends (see Annex 6 for further detail). In view of the overall relevance of ensuring sufficient infrastructure to support the needed uptake of vehicles and vessels, the evaluation recommended to retain the legislation but to revise it. The results of the ex-post evaluation are reflected in this impact assessment.

Table 1: Links between conclusions of the ex-post evaluation and the impact assessment

2.Problem definition

Without further EU level intervention, lack of recharging and refuelling infrastructure is likely to become a barrier to the pervasive market growth in vehicles and vessels that is needed to meet the increased climate ambition of the EU for 2030. The ambition in target setting and support measures for infrastructure rollout varies greatly between Member States, as described in detail in section 2.1. Moreover, ease and transparency of use of recharging and refuelling infrastructure is a prerequisite for user acceptance and final successful vehicle and vessel uptake. Current market practice do not always guarantee this ease of use and problems of interoperability persist. At present, customers are confronted by a myriad of approaches to information on availability and accessibility of infrastructure, diverging use conditions and not fully interoperable services. Without further policy intervention, users of vehicles and vessels will continue to face an infrastructure that is not easy and transparent to use across borders in the EU. The underlying drivers, problems and implications that are relevant for the revision of the Directive are presented in the figure below:

Figure 1: Overview of drivers, problems and implications

2.1.What are the problems and their implications?

2.1.1.Lack of ambition and coherence in MS infrastructure planning leading to insufficient and unevenly distributed infrastructure 

As already noted in chapter 1, there are significant differences in the level of ambition, targets set, and comprehensiveness of the measures adopted among Member States to support the rollout of alternative fuels infrastructure 25 . `76.5% of respondents to the OPC on this question (232 out of 303) confirmed this problem analysis.

With respect to electric recharging points for road LDV the overall deployment figures match the demand from vehicles at an overall, average EU level. However, large differences in the pace of infrastructure roll-out among Member States clearly have impacts on cross-border continuity and will in some Member States also severely limit the uptake of low- and zero-emission vehicles. At present, more than 70% of all publicly accessible recharging points are located in just three Member States: The Netherlands, Germany and France. The uneven geographical distribution is likely to persist and may even intensify, as the Commission assessment of national implementation reports under the Directive 26 in conjunction with the evaluation shows (see chapter 2.3.1, Annex 10).

Figure 2: Amount of recharging points per Member State in 2020

This discrepancy between Member States is not only evident in total numbers but also relative to the number of registered vehicles. While for example the Netherlands already have 7 recharging points deployed per 1,000 registered cars and vans, in 16 Member States less then 0.5 recharging points are installed per regsiered car/van.

Figure 3: Number of Recharging points per 1000 cars and vans, 2020

Furthermore, for electric LDV, there is an increasing gap between the growth rates for vehicle registrations and infrastructure deployment. The strong increase in new battery electric and plug in hybrid vehicle (cars and vans) registrations in 2019 (+50%) and 2020 (+52%) was not nearly met by the increase in publicly accessible recharging infrastructure (+38% and +30% respectively). While the deployment of faster recharging technology can help to address part of the increased vehicle uptake, a continued gap increase would imply a serious risk that infrastructure deployment will not go hand in hand with electric vehicle uptake in the years to come, which is expected to accelerate due to more stringent CO2 emission standards. This in turn risks to restrict the growth in electric vehicle uptake in particular post 2030.

With respect to other fuels in road transport, hydrogen infrastructure for fuel-cell hydrogen LDV is only addressed by half of the Member States in their NPFs leading to an incoherent development across the EU 27 with huge gaps within the road network not allowing for seamless travel across the EU. For CNG and LNG, refuelling networks are developed across the EU albeit with huge differences among Member States. However, the envisaged density of refuelling stations for LNG (every 400 km along the TEN-T core network) and CNG (every 150 km along the core network) has been largely achieved in most Member States (see Annex 6 for further information).

Furthermore, there is currently no coherent approach towards the deployment of electric recharging and hydrogen refuelling infrastructure for HDV across Member States. This means that there is no network of recharging or refuelling infrastructure across the EU, which is problematic since an increased uptake of zero emission trucks is necessary for manufacturers to meet their obligation under the CO2 emission performance standards by 2025 already.

With respect to ports the existing legal provisions oblige Member States to ensure an appropriate number of LNG refuelling points to allow for circulation along the TEN-T core corridor by 2025 for maritime and 2030 for inland waterways. However, the present rate of growth in the network, that will also support the increasing replacement of LNG by biogas and synthetic gaseous e-fuels, appears to be slow. Furthermore, the development of OPS is only taking place in a small number of EU ports 28 . There is a risk that deployment will continue to happen in a limited and uncoordinated manner. The Sustainable and Smart Mobility Strategy notes that zero-emission sea-going ships should be market-ready by 2030. A non-coordinated approach is likely to not lead to effective identification of needs and preparation of adequate rollout strategies for infrastructure.

Efforts have to be undertaken to decarbonise the aviation sector. Electricity supply for stationary aircraft is a low hanging fruit, but is not yet ensured throughout the EU and in particular not for outfield positions. Work has started on the development of zero-emission aircraft, including large-scale aircraft, where the Sustainable and Smart Mobility Strategy sets the milestone of having such aircraft market ready by 2035. The sector has to equally prepare for the built up of related infrastructure, but a non-coordinated approach is likely to lead to insufficient action. In the rail sector, an increasing number of projects deploy battery electric and hydrogen trains to decarbonise train operations on tracks that can’t be electrified. Again the absence of a strategic coordination in Member States risks not to lead to an effective approach.

2.1.2.Interoperability issues persist in terms of physical connections and communication standards 

Common technical specifications help ensure full interoperability of physical connections and communication exchange between vehicle, infrastructure and user. The Directive and subsequent delegated regulations, supported by a standardisation request to European Standardisation Organisations (ESOs) 29 , has mandated various European standards. Those relate to the physical connection between the vehicle and the infrastructure for electricity recharging, natural gas refuelling and hydrogen refuelling for light duty road transport vehicles as well as electric recharging and hydrogen and natural gas refuelling in waterborne transport.

At present, requirements under the Directive focus exclusively on electro-technical issues, such as plugs, outlets and electrical safety specifications, but do not recognise the particular needs of trucks infrastructure. Furthermore, the Directive has not focused on minimum requirements for appropriate communication interfaces and data models, which is particularly relevant for electric mobility. In the Open Public Consultation (OPC), 69% (222 out of 324) of respondents noted that further mandatory technical requirements (standards) are needed to ensure full interoperability of infrastructure and services, whereas only 11% (36 out of 324) thought this was not the case.

The lack of common technical specifications for communication exchange have strong implications on the interoperability and transparent exchange of information among users and the different market actors within the electro-mobility ecosystem. Without further requirements, there will not be a smooth exchange of information on billing, charging session information, reservation, authorization, parking spot information and compatibility with smart charging and vehicle to grid functionalities, as many market operators will take forward their own approaches. With respect to the integration of electric vehicles into the electricity system, the current provisions of the Directive ensure alignment of the rules between recharging infrastructure and the electricity markets, clearly assigning all rights of the final customer in the electricity market to the CPOs. However, future mass vehicle uptake risk putting additional stress to the electricity system especially if the additional electricity demand incurs at peak times. The Impact Assessment for CO2 emission performance standards 30 shows that by 2030 cars and vans would represent around 2% of the EU’s electricity consumption that would increase to 10% by 2040 and to 11% by 2050. From an overall network perspective, management of additional electricity demand of that magnitude over the next decades appears to be feasible. However, if this demand would occur at times when the network is already operating at the maximum, grid capacity problems in particular in the distribution grid, could arise when electric vehicles will have reached a significant share in the overall vehicle fleet 31 . To enable smart recharging and thereby help to avoid capacity problems, common communication standards between the recharging point and the electricity grid are required.

Additional technical specifications and standardization work becomes also necessary to ensure full interoperability of the hydrogen refueling ecosystem for heavy duty road transport, including liquid hydrogen refueling. Concerning maritime transport and inland navigation, new standards are required to facilitate and consolidate the entry on the market of alternative fuels, especially in relation to fuel supply for electricity, hydrogen, advanced biofuel, methanol and ammonia bunkering, as well as communication exchange between vessel and infrastructure. Also for OPS further standards may be required considering the variety of ships at berth with different power demand.

The absence of common technical specifications in the areas addressed above risk that many recharging and refuelling services cannot develop in a competitive manner and instead proprietary solutions will develop. This will be detrimental to the internal mobility market, affecting directly consumers, infrastructure operators and service providers and vehicle manufacturers. In consequence, a lack of standardisation risks to harm the uptake of zero- and low-emission vehicles.

2.1.3.Publicly accessible infrastructure does not fully correspond to user needs 

The evaluation concluded that there are still gaps and limitations in terms of ensuring access to adequate and relevant consumer information. Consumers cannot easily identify where, how and at what price they can recharge or refuel their vehicles, especially when travelling cross border. In the OPC, 80% (119 of 148) of respondents noted to have often or sometimes problems in finding alternative fuels infrastructure. While the Directive requires that information on the geographic location of the refuelling and recharging points is shared by the operators of the infrastructure, it does not impose quality requirements for those data nor does it specify where such information needs to be displayed. As a consequence, and despite the increasing availability of online platforms and digital applications, there is still no open data framework in place to provide real-time information to users, primarily for electro-mobility, but also for other alternative fuels infrastructure.

The Directive also requires charge-point operators to charge prices for public recharging that are reasonable, easily and clearly comparable, transparent and non-discriminatory. However, the evaluation and OPC revealed that often there is limited information available to the user on the price he will eventually have to pay for a recharging session. In the OPC, only 31% of respondents (37 out of 121) felt well informed on a regular basis. This problem was corroborated in the targeted consultations: prices are often not clearly displayed at a recharging point and are often also not accessible through apps. In addition, many different price components exist, including possible hidden fees that only appear at the stage of billing. This results in difficulties for users to compare end user prices. This lack of price transparency does not allow informed consumer choices and is detrimental to competition in the recharging services market.

Furthermore, the Directive sets provisions on ad hoc payment to ensure that no user gets stranded due to difficulties of payment. 32 However, because the Directive does not set clear provisions for a common unified ad hoc payment method (such as credit/debit bank card payment), different ad hoc payment options using different technological solutions emerged, making it difficult for users to actually pay for a recharging service, e.g. by requiring pre-registration or the purchase of pre-payment cards.. In the OPC, 65% of respondents (72 out of 113) confirmed this problem. This issue may also incur in the future for other refuelling infrastructure, e.g. hydrogen, once private users will purchase hydrogen cars/vans and will depend on publicly accessible refuelling stations.

The OPC identified a clear need to change provisions on interoperability and user information, which will particularly facilitate cross-border trips: 79% of respondents to the OPC (255 out of 324) noted this to be very important or important.

All those aspects make it more difficult and cumbersome to travel across the EU and sometimes even within a Member State with an electric vehicle 33 . Such negative user experiences can refrain other consumers from buying alternative fuels vehicles and thereby become a barrier for their uptake. Moreover, this market fragmentation can be detrimental to competition, can imply higher costs for the different market actors and can aggravate innovative service development.

This problem ultimately affects consumers. It also affects infrastructure services providers and entities that operate in the market of supplying infrastructure data to consumers.

2.2.What are the problem drivers?

2.2.1.Lack of binding provisions leads to different ambitions by Member States

Transport network coverage for road transport

The Directive requires each Member State to adopt a national policy framework (NPF) for the development of the alternative fuels market in the transport sector and the deployment of its relevant infrastructure. In particular, the NPFs have to comprise national targets and objectives for the deployment of alternatives fuels infrastructure 34 , taking into account national, regional and union-wide demand. However, there is no clear and explicit link with reaching greenhouse gas reductions, which has become essential under the European Green Deal. In addition, Member States had to provide the necessary measures to reach national targets and the objectives set out in the NPFs. However, Member States are free to set their own targets and are not bound by any methodology to determine the need for infrastructure.

In its 2017 assessment of the NPFs (including in its 2019 update) 35 and in its Assessment of the National Implementation Reports (NIR) 36 in 2021 which informed the overall evaluation of the Directive, the Commission concluded that the NPFs and NIRs are not fully coherent from an EU-wide perspective in terms of the priorities they set. Member States’ ambition with regard to the uptake of alternative fuels and their targets for infrastructure varied significantly in the absence of a common methodology to set targets. For example, the share projected by Member States for electric cars and vans in the total fleet for 2030 varies between less than 1% for Cyprus and Greece and up to 45% in the case of Luxembourg. For 2020, 10 Member States planned to have less than 1000 recharging points installed and 16 less than 2000 and large parts of the TEN-T core network do not have recharging points installed every 60 km as recommended 37 . In conclusion, a coherent network of infrastructure has not developed across the EU, even if the last two years saw considerable increase in overall investment. In the OPC, a majority of respondents noted for most of the different use cases of alternative fuels infrastructure that NPFs were not a fully adequate tool to solely rely on (see annex 2 for detailed breakdown).

Transport network coverage for waterborne transport

The Directive requires that LNG vessels can circulate along the TEN-T core network by 2025 (maritime) and 2030 (inland waterways) respectively without setting a clearer mandate as to which ports need to be equipped with LNG bunkering facilities. The directive equally requires that each NPF assesses the need for shore-side electricity – at sea and inland ports – and that this be installed, unless there is no demand or costs are disproportionate.

The assessment of the application of this Directive 38 identified that plans to deploy LNG in maritime and inland ports for 2025 varied greatly between a few countries with high ambition (e.g. Spain, with a target of 42 maritime ports and Italy with a target of 12 maritime ports and 20 inland ports) and most others were there was no or little consideration of bunkering facilities for LNG.

With respect to shore side electricity, the evaluation found that 23 Member States assessed the need for shore-side electricity supply for inland waterway vessels and seagoing ships in their NPFs. Following their assessment, BE decided to increase on-shore power supply (OPS) in all ports, EL aimed to install supply at tourist ports and major maritime ports, while EE, FR, MT, and RO all established specific targets either for the year 2025 or 2030. Furthermore, AT, BG and SI noted the need for further studies to be carried out to better understand the benefits. The other Member States either did not specifically address the issue or concluded that it is not economically viable to install OPS supply considering the current market demand and as such no objectives were set.

For the shipping sector it can therefore be concluded that the legally binding provisions for LNG under the current Directive will ensure that a sufficient network will develop on the TEN-T core network, which is of particular relevance to sea ports. However, the lack of clear provisions with respect to OPS makes it unlikely that a coherent network of OPS develops in TEN-T core maritime and inland waterway ports in the timeframe foreseen by this Directive and corresponding to the expected increase following the ambition of the refuel EU maritime initiative.

Scope

The Directive currently defines a number of specific fuels as alternative fuels 39 . However, since the adoption of the Directive, some technology advancements have taken place. The 2020 update of the Commission’s Report on advanced alternative fuels 40 lists, for example, road electrification technologies, electrification/hybridisation of aircrafts used for short-distance and training flights, use of new fuel technologies in waterborne transport (e.g. advanced biofuels, ammonia, methanol, hydrogen as well as electricity for inland waterways and short sea shipping/ferries) or development of hydrogen fuel cell powertrains in rail transport. Moreover, while the scope of the Directive does not exclude recharging and refuelling stations for heavy-duty vehicles, it was formulated with a primary focus on light-duty vehicles. The inclusion of hydrogen into the NPFs has been voluntary and only half of the Member States addressed hydrogen. As a result of this approach and of rapid technology development in this segment, the Directive is currently not fully adjusted to cater for the infrastructure requirements of battery- and fuel-cell electric powertrains in the heavy-duty road sector, which is the focus, in particular, of the Hydrogen strategy 41 .

Furthermore, questions have been raised whether the current scope diverts resources away from the infrastructure for zero-emission vehicles by including of natural gas as an alternative fuel. The use of fossil fuels is regarded to not contribute to overall emission reduction, but delay the necessary transition to zero-emission mobility. 55% of respondents the OPC (165 out of 268) asked for the exclusion of natural gas and thereby of CNG and LNG infrastructure from the scope of the directive, with strong presence of environmental NGOs, the electricity sector, electric mobility industry representatives and citizens. However, 45% (133 out of 298) of respondents, in particular representatives from the gas industry, biogas and biofuel producers, waterborne transport industry and parts of the automotive industry argued that LNG is still indispensable for maritime transport, as also noted under the FuelEU maritime initiative, and for long-distance road haul due to a lack of market-ready alternatives. Furthermore, biogas and e-gases use the same refuelling infrastructure as natural gas. Fossil natural gas can therefore be increasingly blended and phased out with low-carbon and renewable fuels (biogas and renewable synthetic e-gas) and thus fully contribute to the climate-neutrality objective.

2.2.2.Setting of targets by Member states not consistent with market developments and GHG reduction ambition 

The Commission’s 2017 assessment of Member State NPFs 42 and the 2021 assessment on the NIRs 43 identified that in many Member States, projections on the uptake of alternative fuelled vehicles were rather low and consequently the infrastructure targets risk to be insufficient to support the expected growth in alternatively-fuelled vehicles. Since national policy frameworks were adopted (by end 2016), the EU has committed 44 to reduce the EU’s greenhouse gas emission by 2030 by at least 55%, compared to the previous 40% reduction target. This has a major impact on the required uptake of sustainable alternative fuels, vehicles and infrastructure. In order to achieve these ambitious targets, the uptake of low and zero-emission vehicles and the related infrastructure needs to accelerate significantly in all market segments of light-duty and heavy-duty vehicles. Efforts will need to be considerably greater than the efforts reported by Member States under the Directive. This does not only relate to road transport but equally to other transport modes such as waterborne transport and aviation.

56% of OPC respondents (160 out of 288) noted that NPFs are not the right instrument and 31% (89 out of 288) noted that they are only partially sufficient in view of the increased policy ambition for 2030. Of those who responded to the question who should set mandatory deployment targets, 53% (142 out of 268) favoured direct EU legislation, whereas 38% (102 out of 268) considered the national level, but following a common methodology.

Furthermore, recommendations for using specific metrics to determine sufficient infrastructure are no longer adequate. The Directive recommends to have 1 recharging point per 10 electric vehicles. This recommendation on the number of recharging points per vehicle does not reflect variations in market requirements. The Sustainable Transport Forum of the Commission reviewed the recommendations and concluded that they should be elaborated further 45 , including consideration of the larger demand for alternatively-fuelled vehicles, the increased vehicle ranges and different power levels of recharging points and their locations; e.g. a 350 kW recharging point can serve a considerably higher number of vehicles per day than a normal charger of 7 kW.

2.2.3.Implementation fails to consider necessary requirements/standards for ensuring full interoperability 

The Directive sets common technical specifications for physical connectors. With the latest set of technical specifications added by means of Commission Delegated Regulation (EU) 2019/1745 those technical specifications set under the Directive have proven to be highly relevant.

However, new needs for technical specifications under the Directive have emerged as described in chapter 2.1.2 that are currently not foreseen under annex II of the Directive. These concern particularly the interoperability and transparent exchange of information among the different players within the electric vehicle charging system and standards for recharging heavy-duty vehicles and refuelling liquid and gaseous hydrogen. In addition, maritime transport, inland navigation and aviation will also benefit from further common technical specifications to facilitate and consolidate the entry on the market of alternative fuels, especially in relation to fuel supply for electricity and hydrogen as well as hydrogen based fuels.

In line with the Commission’s Strategy for Smart Energy System Integration 46 the cost-efficient integration of an increased number of electric vehicles in the electricity system must be ensured. However, the Directive does currently not require common communication standards between the recharging point and the electricity grid that is a prerequisite for the development of smart and bidirectional recharging services in an open and competitive market 47 .

Without a clear, updated legislative mandate to develop such standards at the EU level, there is a risk that such standards will not develop in a timely manner and hence delay market uptake of emerging technologies and services. In the OPC 78% of respondents (216 out of 278) noted it very important or important to revise the related provision of the Directive.

2.2.4.Lack of user information about and at refuelling and recharging points

Location and availability of recharging and refuelling points

A key issue for consumers is the concern that it may not be possible to find a suitable refuelling/recharging station before running out of fuel/electricity. Contributing to this, particularly on long-distance journeys on highways, is the lack of information on the distance to the next suitable recharging/refuelling station. Although the AFID requires that ‘the data indicating the geographic location of the refuelling and recharging points accessible to the public of alternative fuels covered by this Directive are accessible on an open and non-discriminatory basis to all users’, it does not specify where such information needs to be displayed. Furthermore, the evaluation also found out that action by some Member States (individually and on basis of EU funded activities) should be expected to contribute towards improving the availability and quality of information, but that this will not ensure consistent data provision and access to data across the EU network. 70% of respondents to the OPC (231 out of 324) agreed that users should get information on locations based on coherent requirements.

Digital Connectivity

A prerequisite for providing such location data, but in particular dynamic data on the availability on recharging points and on prices through digital means, is that recharging/refuelling points are digitally connected. The ability to manage contract-based payments for electric charging at other stations (i.e. when roaming) also requires stations to be digitally connected. According to estimates, by 2019 around 45% of the 1.3 million public, semi-public and private recharging points across Europe were digitally connected; by 2024 it is expected that over 60% of the recharging points will be digitally connected. 48

In the OPC, 90% of respondents (244 out of 269) agreed that information, including based on dynamic data, should be made available to the user by digital means. In the OPC, 62% (200 out of 324) noted that consumers should have real-time access to reliable information about the location and availability of recharging points, which requires digital connectivity of infrastructure.

Information on pricing and billing

An additional key feature to ensure user acceptance is that prices are clearly communicated before the recharging session. The Directive already requires that prices charged by the operators at publicly accessible recharging points are reasonable, easily and clearly comparable, transparent and non-discriminatory. However, no detailed provisions regulate the way prices need to be displayed.

Despite these legal requirements, 30% of respondents to the OPC (80 out of 276) noted to never or seldom have full information about prices charged, 28% (76 out of 276) noted this to be sometimes the case and 33% (92 out of 276) did not know, whereas only 11% (29 out of 276) noted that they always had full information. This confirms a practical problem with the current implementation. 67% (187 out of 278) supported a harmonisation of the display of prices at the EU level.

Moreover, for contract-based charging – which is not currently addressed in the provisions of the Directive - the actual invoiced amount often included extra charges, such as roaming charges that are not communicated beforehand to the consumer.

2.2.5.No uniform ad hoc payment method available at all recharging points 

The Directive requires that users must be able to recharge their electric vehicle at any publicly accessible recharging point on an ad hoc basis, i.e. without needing to enter into a long-term contract with the operator or energy supplier. This requirement has been implemented in very diverse ways across the EU. Charge point operators developed individual solutions varying between Member States, and even within Member States. Ad hoc solutions offered at recharging points include credit card payments, pre-paid cards or payments through charge point operators’ specific apps that need to be downloaded by the user. The use of some of these payments solutions is extremely cumbersome and may even not allow for spontaneous ad hoc charging at some charging points (.e.g. when a prepaid card is required).

According to a recent assessment 49 , many charge point operators do not provide a user friendly ad hoc charging possibility to drivers. Instead, to be able to easily use a publicly accessible recharging station, a driver must sign up for a contract with its operator. A recent overview of various aspects on price transparency in four Member States 50 found that ad-hoc payment systems are not widely used or offered in the Netherlands, but it is more common to use dedicated cards or web-based apps. The report concluded that ad-hoc payment is better developed in Germany and Austria but less so in France. Still, a test of 53 recharging points in Germany conducted by the German automotive club ADAC in May 2018 found that ad hoc charging was not possible in 23% of recharging cases in one of the most advanced markets in the EU 51 . Only 8% of respondents to the OPC (9 out of 113) noted that they never faced difficulties when trying to pay. Similarly, representatives of the hydrogen sector also noted challenges with regard to uniform payment options.

2.3.How will the problem evolve?

2.3.1.Lack of ambition and coherence in MS infrastructure planning leading to insufficient and unevenly distributed infrastructure

As outlined in chapter 2.1.1 the trend towards an uneven distribution of recharging infrastructure for road transport is likely to continue and even to intensify. While there has been continuous development of AFI across the EU, progress has been very uneven across Member States, both in terms of planning and actual deployment of AFI. Deployment has been fragmented resulting in some well served hotspots but also large gaps in coverage leading to a network that is not sufficiently dense and widely spread to remove concerns around AFI availability. Furthermore, there are also indications that the roll out of AFI is not consistent with market and technological developments, as planning and deployment occurs at a different and mostly slower pace than markets for vehicles.

In the absence of an intervention, these problems and limitation are likely to continue to exist, with rapid developments in vehicle uptake not accompanied by an effective deployment of the needed AFI in a coherent manner throughout the EU. Those expected developments can be best demonstrated by comparing the Member States target setting as per their NPFs and NIRs 52 .

Based on these targets as reported by 17 Member States it can be concluded that the problem of incoherent development in recharging infrastructure will continue to grow. For example, in Germany and Luxembourg there will be more than 20 recharging points for 1000 registered cars/vans, while other Member States will have very little recharging infrastructure with less than 2 recharging points serving 1000 cars/vans 53 . Such a disparity in infrastructure development will not allow for easy cross-border travel. It also risks to limit the uptake of zero-emission vehicles in those Member States that provide only very little infrastructure. This is likely to undermine the accelerated uptake of vehicles to meet the increased 2030 climate ambition.

Figure 4: Targeted number of recharging points per 1000 registered cars/vans 2030, based on NIR targets of Member States

Source: National Implementation Reports, Assessment Report on the National Implementation Reports.

In conclusion, the planned AFI deployment by Member States under their NPFs and NIRs is not ambitious enough to align with the infrastructure needs induced by other policies (as outlined in the European Green Deal, the 2030 Climate Target Plan and the Smart and Sustainable Mobility Strategy). However, all policies need to contribute together to the ultimate goal of achieving necessary substantive emission reductions from the transport sector.

Such shortcomings are equally to be expected in other road transport segments. For example, only a limited number of Member States plan for hydrogen infrastructure. It will not allow for the development of a coherent network across the EU. The same goes for the heavy-duty segment, which is currently not specifically addressed in the Directive nor in most Member States’ NPFs. Besides generally requiring faster recharging and refuelling, the heavy-duty segment’s needs and use cases differ significantly from those of light-duty vehicles, and in particular of personal cars. Different use cases and related recharging/refuelling needs can be defined in relation to e.g. urban delivery, regional distribution, planned and unplanned long-haul freight transport. Furthermore, the need to integrate recharging and refuelling times in the logistics and operational planning – including by coordinating them with mandatory driver breaks as well as loading/unloading times at logistics hubs and/or at destination – will play a factor in defining the way the infrastructure is used; interactions with requirements for safe and secure parking places needs also to be taken into account. Confidence in the possibility to recharge and refuel seamlessly across borders is a crucial pre-condition for the deployment of alternative fuels in the long-haul transport sector. Without a clear European policy framework in this area it is very unlikely that a sufficiently dense European network particularly of electric charging and hydrogen refuelling stations will develop that allows the deployment of an appropriate share of low- and zero-emission vehicles into the heavy duty segment.

In contrast, the network of CNG and LNG refuelling stations across the EU’s road network is already existent and largely mature. Punctual re-enforcements are needed to accommodate the expected uptake in particular of LNG HDV. However, CNG and LNG vehicles can only contribute to the necessary emission reductions if natural gas will be gradually decarbonised and finally fully replaced by biogas and renewable low-carbon e-gases. Such decarbonisation of fuels pathways can be ensured through the existing refuelling infrastructure that can accommodate gaseous drop-in biofuels and renewable low carbon synthetic fuels needed to contribute to climate objectives.

What concerns other transport modes, it is unlikely that the On Shore Power Supply (OPS) will develop in EU ports without strengthening of the legislative requirements as only a few Member states currently plan to do so. This is in contrast to the clearly described ambition in the European Green Deal to oblige docked ships to use shore-side electricity and the FuelEU maritime initiative that aims to ensure that all containerships, cruise ships and Ro-Pax ships are equipped with OPS by 2030. Similarly from the NPFs it is not obvious that the current provisions in the Directive can ensure that alternative power trains in the shipping sector and their corresponding fuels infrastructure in ports will develop. For the maritime sector, the FuelEU maritime initiative will lead to increased demand for alternative fuels, including LNG as a short-term available fuel alternative, while zero-emission sea-going vessels are targeted for 2030.

In the absence of any provisions on aviation it is unlikely that electricity supply for all stationary aircrafts will become available. Increase demand for sustainable aviation fuels as required by the RefuelEU aviation initiative can be met by existing infrastructure. However, in the absence of any provision it is unlikely that a coherent strategic planning for the development of needed infrastructure needed for large-scale zero-emission aircraft will develop.

2.3.2.Interoperability issues persist in terms of physical connections and communication standards

As described in previous chapters, common technical specifications have been mandated in particular for physical connections through the Directive. However, as discussed in section 2.2.3, several issues still remain and new needs have emerged. While improvements will continue to take place, there is a real possibility of moving towards a fragmented ecosystem, where multiple standards will compete for a long time to become dominant, generating additional costs to operators and users. The lack of interoperability of both physical connections and communication standards could strongly prevent the progress towards a wider use of alternatively-fuelled vehicles, conditioning user aceptance. In particular:

·Interoperability and exchange of information among the different players within the electric vehicle charging ecosystem would continue to grow, however, identification and authentication of users, as well as payment methods and smart recharging solutions could develop under multiple different solutions at different paces across the EU, but not at the speed required and without the information transparency expected from users. Additionally, mass market development is likely to be affected due to user reluctancy. Certain areas of the charging ecosystems would not reach an agreement to common technical specifications, being ruled out by proprietary solutions, continuing and further deepening a plethora of non-user-friendly approaches in consequence.

·Standards for recharging HDV and refuelling HDV with liquid and gaseous hydrogen are required, but would develop at lower pace and would have less market impact if not transposed into European law.

·In addition, maritime transport and inland navigation would witness slower adoption of common technical specifications and hence a slower entry on the market of alternative fuels, especially in relation to supply of electricity and hydrogen as well as hydrogen based fuels.

2.3.3.Publicly accessible infrastructure does not fully correspond to user needs

Ever since alternatively-fuelled vehicles started gaining traction in the market, issues regarding availability of adequate consumer information have existed. With different industry players using different ways of communicating information to consumers, the problem is likely to continue to exist if there is no action to ensure a harmonised way of and a minimum set of data to be communicated by the recharging and refuelling point operator to consumers.

With respect to the lack of user information about and at recharging and refuelling points, the evaluation of the Directive found that some progress should be expected to continue to contribute towards improving the availability and quality of information (see Annex 10). Work under the Programme Support Action "Data collection related to recharging/refuelling points for alternative fuels and the unique identification codes related to e-Mobility actors" is of relevance here. 54 However, withouth further policy intervention, the evolution will likely be limited to single Member States and not ensure consistent access to such information across the EU transport network. It is likely that important limitations in terms of the availability of information on the location of AFI infrastructure would remain, whereas other essential variables not included in the Directive would not become available. It could also become more problematic to make data accessible through the National (or Common) Access Points (NAPs) as established in the Directive 2010/40/EU on Intelligent Transport Systems. 

Also without further harmonisation on EU level, individual companies will decide on the way to present prices to consumers. Such bottom-up approach would not lead to truly transparent prices across the EU.

Lack of information or filtered information on alternative fuels infrastructure locations, availability and prices, will hamper the development of a truly competitive alternative fuels services market. Only with full upfront information on their different recharging and refuelling options can consumers identify the recharging or refuelling point that best meets their needs, allowing markets to develop as competitive markets.

With respect to ad hoc payment method that has to be available at all recharging points, it is expected that without further harmonisation, individual charge point operators will continue to provide individual ad hoc payment solutions that will continue to pose problems of accessibility and understanding for consumers especially when travelling across borders.

3.Why should the EU act?

3.1.Legal basis

To ensure the correct functioning of the internal market the Treaty on the Functioning of the EU (TFEU) establishes the EU’s prerogative to makes provisions for the Common Transport Policy, Title VI (Articles 90-91) and for the trans-European networks, Title XVI (Articles 170-171). With this legal framework in mind, EU action allows better coordination for even and widespread deployment of AFI, instead of relying on the uncoordinated action of individual Member States only. This coordinated approach helps facilitating travel across the EU for consumers and transport operators. It also helps to remove lack of alternative fuels infrastructure as a potential barrier, encouraging the vehicle industry to commit to vehicle production knowing the infrastructure is in place.

3.2.Subsidiarity: Necessity of EU action

At the time of the development of the AFID, the impact assessment (European Commission, 2013) identified an EU initiative in this field as necessary - Member States did not have the instruments to achieve pan-European coordination (among vehicle manufacturers, infrastructure providers, national authorities and final users) in terms of technical specifications of infrastructure and timing of investments, and AF technology standards were not common EU-wide, thereby discouraging potential industry players, and leading to the fragmentation of the internal market.

According to the Directive itself, establishing a common framework of measures and promoting a broad market development of AFs for different transport modes and fuel types “cannot be sufficiently achieved by the Member States individually, but can rather, by reason of the need for action to meet the demand for a critical mass of alternatively fuelled vehicles and for cost-efficient developments by European industry, and to allow Union-wide mobility of alternatively fuelled vehicles, be better achieved at Union level”. Subsequent documents have provided further justification of the ongoing need and added value for action at EU level. According to the Commission’s Clean transport good practice examples published in 2016, EU intervention in the case of AFI was justified by the fact that the build-up of a European AFI “allows for free movement of goods and persons, with vehicles running on alternative fuels across the whole EU” and “facilitates the development of a single EU market for alternative fuels and vehicles which will permit the industry to benefit from economies of scale”.

3.3.Subsidiarity: Added value of EU action

The evaluation of this Directive, in conjunction with the assessment of national implementation reports of Member States under this Directive, also underlined the EU added value of the intervention in the sector, in terms of its effectiveness, efficiency and synergies that it brings. The evaluation showed that the development of a common EU framework for alternative fuels infrastructure has contributed towards avoiding the fragmentation of measures in relation to the promotion of AFIs, and thereby supporting Member States in the development of the AFI network, creating a level playing field within the industry and facilitating the free circulation of AFVs throughout the EU. All Member States have seen an increase in the level of AFI that, despite the gaps, suggest a relatively more coherent network with fewer gaps that what would have been the case in the absence of EU level intervention. Through encouraging interoperability, relevant technical standards and setting of targets on similar timescales, EU level action has provided some cost savings and better value for money by facilitating economies of scale, avoiding duplication of effort and resources, and providing funding investments for infrastructure. The implementation of the Directive (and its supporting activities) have facilitated cooperation and information exchange on alternative fuels between the relevant industry and public actors which would otherwise likely not exist.

Without EU intervention it would be very unlikely that a coherent and complete network of fully interoperable alternative fuels infrastructure develops across all Member States that will ensure that travelling across the EU with an alternatively fuelled vehicle is possible. This in turn is a prerequisite for the uptake of such vehicles across the EU which is vitally important for the EU to meet its GHG reduction ambition.

4.Objectives: What is to be achieved?

4.1.General objectives

The general objectives of this initiative are to contribute to achieving climate neutrality by 2050 (i.e. achieve net zero GHG emissions by 2050) and to contribute to the reduction of air pollution. To this end, and in line with the 2030 Climate Target Plan, the objective is to reach at least 55% net greenhouse gas emission reductions by 2030 compared to 1990 and the environmental goals of European Green Deal. This requires a coherent policy architecture for GHG reduction in transport, including the provision of sufficient and user friendly alternative fuels infrastructure as a prerequisite for the uptake of alternatively fuelled vehicles.

In particular, the transition to a climate-neutral economy requires a robust policy framework in the area of alternative fuels, in particular addressing renewable and low-carbon fuels, with the main aim of supporting the deployment of zero-emission vehicles, and infrastructure for all transport modes that must be open to future innovations. This initiative seeks to ensure the availability and usability of a dense, wide-spread network of alternative fuel infrastructure throughout the EU. All users of alternatively-fuelled vehicle/vessel/aircraft shall circulate at ease across the EU, enabled by key infrastructure such as motorways, ports and airports.

4.2.Specific objectives

This initiative is designed to effectively address the existing barriers that hamper the further deployment of a dense network of interoperable infrastructure. The specific objectives (SOs) and their correspondence with the problem drivers are presented in Figure 5 .

Figure 5: Correspondence between the specific objectives and the problem drivers

SO1: Ensuring sufficient infrastructure to support the required uptake of alternatively fuelled vehicles across all modes and in all MS to meet the EU’s climate objective. It is essential to increase the number of recharging and refuelling points across Member States and across modes to ensure that sufficient infrastructure is available for the expected rapid uptake of alternatively fuelled vehicles and vessels in all Member States required to meet the EU’s 2030 climate ambition and 90% GHG emission reduction from transport by 2050.

SO2: Ensuring full interoperability of the infrastructure. Interoperability relates to both, physical interfaces and communication protocols as a prerequisite to provide assurance to investors about investments in recharging and refuelling infrastructure across all modes. Furthermore for road transport, it ensures that services – including smart and bidirectional recharging - can develop in a competitive manner.

SO3: Ensuring full user information and adequate payment options. Sufficient and accurate information for consumers, including information on location, accessibility, prices, payments and compatibility of fuels and recharging infrastructure are a prerequisite for users to purchase alternatively fuelled vehicles. They guarantee certainty and transparency about the use case; users know that they can use the vehicle without hassle and without surprises anywhere in the EU. Adequate payment options are highly relevant in this context – they ensure that users do not get stranded in front of recharging or refuelling points and always have a common and easy to use payment option at hand.

5.What are the available policy options?

5.1.What is the baseline from which options are assessed?

The EU Reference Scenario 2020 (REF2020) is the common starting point for the impact assessments for all the initiatives of the “Fit for 55” package and for this reason it is also used as a baseline for this impact assessment. The EU Reference scenario 2020 reflects the agreed 2030 EU climate and energy targets, the main policy tools at EU level to implement these targets as well as the aggregate ambition and, to the extent possible, the range of foreseen national policies and measures of the final National Energy and Climate Plans (NECPs) that Member States submitted in 2019 according to the Governance Regulation 55 . The EU Reference scenario 2020 also takes into account the impacts of the COVID-19 pandemic that had a significant impact on the transport sector. More detailed information about the preparation process, assumptions and results are included in the Reference scenario publication 56 . The most relevant information for this impact assessment is also presented in Annex 4.

The Reference scenario projects that EU level policies like CO2 standards for vehicles, together with the national contributions put forward in the NECPs and national incentives for the uptake of electric vehicles would result in an uptake of around 44 million electric light duty vehicles (30 million battery electric and 14 plug-in hybrid vehicles) by 2030. It shows that emissions from transport including intra-EU aviation and intra-EU maritime would go down by around 17% by 2030 relative to 2015 (or by 11% when all intra-EU and extra-EU aviation and maritime emissions are considered). The REF2020 scenario models the impacts of targets and policies already adopted, but not the revised EU climate ambition for 2030 or the target of net-zero emissions by 2050. Post-2030, there are no additional policies driving the decarbonisation. However, several of the measures in place today will continue to deliver emissions reductions in the long term. By 2050, the CO2 emissions from transport including intra-EU aviation and intra-EU maritime are projected to be 39% lower relative to 2015 (27% lower when all intra-EU and extra-EU aviation and maritime emissions are considered).

With regard to infrastructure, for road transport, in the baseline the trend towards an uneven distribution of recharging infrastructure is projected to continue, as explained in chapter 2.3. Eighteen Member States 57 set targets for the deployment of recharging infrastructure for 2030 in their NPFs and NIRs, summing up to 1.9 million public recharging points in those 18 Member States. The total number of recharging points at EU level is projected to increase from 165,106 in 2019 to slightly over 2.3 million by 2030 58 . For hydrogen infrastructure, the number of refuelling points is projected to increase from 127 in 2019 to 1,371 by 2030, which is however not expected to allow the development of a coherent network across the EU by that date 59 . The network of CNG and LNG refuelling stations across the EU’s road network is already mature. The number of CNG refuelling stations is projected to go up from 3,519 in 2019 to 8,299 by 2030, while the number of LNG refuelling stations from 242 in 2019 to 3,527 by 2030. The uptake of liquid and gaseous drop in biofuels and synthetic fuels will be ensured through the existing refuelling infrastructure.

Less than 50% of all TEN-T maritime ports are currently equipped with LNG bunkering facilities. However, of the 22 Member States that have core TEN-T maritime ports, half are already planning to deploy LNG bunkering infrastructure in their core ports. In the baseline, 71 core TEN-T maritime ports out of 90 are projected to have LNG bunkering facilities in place by 2030. The total installed capacity for the OPS infrastructure in the maritime ports has been increasing since the 2000s and it is currently around 90MW across the EU, according to EAFO database. This trend is projected to continue, reaching 174 MW by 2030 60 .

Based on the NPFs, 36 core TEN-T inland ports are planned to offer LNG bunkering infrastructure by 2030, out of the 85 inland TEN-T core ports in the EU. By 2030, it is also planned that 139 inland ports (67 core TEN-T ports and 72 comprehensive TEN-T ports) will have OPS installed in at least one berth.

Electricity supply for stationary aircrafts beyond what is already established and infrastructure for battery electric or hydrogen trains on railway lines that cannot be electrified are not projected to develop by 2030 in the baseline, in the absence of provisions on aviation and rail.

The Reference scenario does not include the “Fit for 55” initiatives. In order to ensure consistency with the other “Fit for 55” initiatives and in particular with the revision of the regulation on CO2 standards for vehicles, the policy options are designed in the context of the MIX policy scenario 61 . The MIX scenario is also consistent with the “TL_MED” option of the impact assessment accompanying the revision of the emission performance standards for new passenger cars and for new light commercial vehicles. More explanations on the approach are provided in section 6 and Annex 4.

5.2.Policy measures and policy options 

As a first step, a comprehensive list of possible policy measures was established after extensive consultations with stakeholders, expert meetings, independent research and the Commission’s own analysis. This initial list is presented in Annex 5.2. This list was subsequently screened based on the likely effectiveness, efficiency and proportionality of the proposed measures in relation to the given objectives, as well as their legal, political and technical feasibility.

5.2.1.Discarded policy measures

As a result of this analysis, several measures were not retained in the policy options, although, in some cases, their important role as complementary measures, supporting for example the climate objective for the maritime transport sector, is fully recognised. Based on the initial screening and tested in the OPC and through a dedicated stakeholder survey, a range of policy measures were discarded in the context of this impact assessment, also because some of the aspects will be addressed through other EU legislation or soft policy instruments.

The key discarded measures are the following:

Specific targets for electric recharging for two- and three-wheelers: In the absence of dedicated policy measures on the demand side, the uptake will be largely determined by national and regional policies which would make it impossible to determine adequate targets at EU level. Moreover, connectors for two- and three-wheelers can also be installed at recharging points preliminary designed for cars and vans, making it not necessary to create a dedicated infrastructure.

Specific deployment targets for rail such as for hydrogen refuelling, electric recharging points or electrification of railway lines: First projects are being developed in the EU on hydrogen and battery electric trains while electrification off the TEN-T core and comprehensive network is a clear EU policy priority and investments are ongoing. Those investment decisions are taken under specific consideration of the local conditions, including their specific benefits and costs. Through EU wide targets for hydrogen refuelling and battery recharging infrastructure it would not be possible to take such local condition into account. Such targets run a high risk to require unnecessary or non-optimised investment in infrastructure.

Targets for infrastructure for emerging alternative fuels in ports: Zero emission powertrains using fuels such as ammonia, hydrogen and electricity are being developed and tested in the shipping sector. However, at this stage only very few vessels are in operation. In addition, the modelling done in support of the impact assessment accompanying the FuelEU maritime initiative only shows a negligible share of those fuels in shipping until 2035. The Sustainable and Smart Mobility Strategy of the Commission notes 2030 as the milestone by when zero-emission sea-going vessels should become available to the market. A review clause at the end of 2026 under the revised Directive is well suited to ensure that the market situation can be reviewed and on that basis the Commission can decide to propose further targets for ports. For hydrogen, the policy options include mandates for hydrogen refuelling stations in urban nodes. Those can be installed in multimodal hubs such as ports and serve different transport modes at those locations. Furthermore, more detailed provisions can be better introduced into the revised NPF requirements ensuring the development of alternative fuels on TEN-T corridors for inland waterways and short sea shipping.

Targets for infrastructure to fuel hydrogen or electric (hybrid) aircrafts: First electric and hybrid planes have already been developed. The European Union Aviation Safety Agency announced 62 the certification of an electric airplane, the Pipistrel Velis Electro, the first type certification world-wide of a fully electric aircraft. Furthermore, Airbus has revealed 63 three concepts for the world’s first zero-emission commercial aircraft which could enter service by 2035. All of these concepts rely on hydrogen as a primary power source. However, as for ports above, the Commission does not yet have a clear indication with respect to the concrete market uptake of such aircrafts. The Sustainable and Smart Mobility Strategy notes 2035 as the milestone by when zero-emission large-scale aircraft should be available to the market. Therefore, possible infrastructure targets will be analysed under the review clause end of2026 when the markets will be more mature. In the meantime, Member States can be required through the national policy frameworks (NPF) to assess the emerging needs for recharging (electricity) and refuelling (hydrogen, other fuels) infrastructure for rail, ports and airports on their territory every two years and report in the National Implementation Reports. This should form the basis for developing a strategic framework of operation at national level. Furthermore, a dedicated infrastructure for Sustainable Aviation Fuels (e.g. biofuel blends) is not required as those fuels can be used in the existing refuelling infrastructure of airports.

Dedicated infrastructure for high blend biofuels (e.g. E85). Biofuels used in the EU are largely drop-in fuels that do not require a specific infrastructure. However, high blend biofuels require a dedicated infrastructure. Those are only used in a few Member States, in particular in Finland. Vehicles require special engines that allow them to use such fuels next to ordinary liquid fuels. However, very few manufacturers produce such vehicles or have announced that they will manufacture them in the future. In addition, the use of sustainable biofuels in the road sector will remain largely stable in the next two decades and is expected to decline post 2040 with an envisaged shift of sustainable biofuels towards other transport sectors (maritime/aviation), indicating that there is no need for shifting towards high biofuel blends in road transport that require a dedicated infrastructure. In the OPC and in dedicated interviews, stakeholders have not indicated the need of dedicated biofuels infrastructure. While individual Member States may still wish to build up their own dedicated biofuels infrastructure, there does not seem to be sufficient demand to justify EU-wide rules for dedicated biofuels infrastructure. Furthermore, vehicles that can use for example E85 can also use conventional fuels allowing such vehicles to travel across the EU without the need for dedicated EU wide biofuels infrastructure.

Exemption of certain recharging points from quality requirements. The Directive distinguishes between publicly accessible and not publicly accessible infrastructure. In particular, with respect to recharging points, publicly accessible infrastructure needs to meet certain quality and information requirements. Some stakeholders have therefore argued that “semi-public” recharging points, e.g. located at privately operated parkings at supermarkets, shopping malls, etc. could be exempted from certain quality requirements to reduce investment costs. This issue was also discussed at a dedicated workshop under the Sustainable Transport Forum, with the vast majority of stakeholders indicating that such exemptions would severely risk to jeopardise the overall objective to have a sufficient coverage of fully interoperable infrastructure accessible to all drivers across the EU.

Price setting issues. The Directive prescribes that prices charged by the operator of recharging points must be reasonable but without further specification what this should mean in practice. Over the last years there have been a number of complaints that prices charged by Charge Point Operators (CPO) to EV-drivers were very high and that the operators also charged different prices to different Electro Mobility Service Providers (EMSP). In some Member States, anti-trust authorities further analysed individual practices in this regard but have not taken action. As there is currently no evidence that there is a structural issue with discriminatory or unreasonable price setting, no policy options was considered that would further interfere in the business-to-business or business-to-customer price setting of charge point operators.

Contract-based payments through roaming. The Directive only addresses ad-hoc payments. It does not address in detail contract-based payments that requires roaming when travelling across the EU. In order for roaming to function, a bilateral agreement must be established between the operator of a recharging point (CPO) and the driver’s EMSP. As not all charge point operators offer the same conditions to all EMSPs, some calls have been made by individual stakeholders to regulate the CPO – EMSP contract setting. Such a policy measure was not further analysed in the impact assessment because of a lack evidence that there is a structural problem and because any measure would interfere heavily in the contractual freedom between the different market actors. Furthermore, further improvements are addressed under the policy options to ensure that every driver can easily pay at every recharging point in the EU. Therefore, contract based payments through roaming are not an absolute necessity to ensure that drivers can easily circulate across the EU.

Access to recharging and refuelling infrastructure to citizens with disabilities has been addressed in the evaluation support study, the impact assessment support study and in the OPC. In this context it is important to note that while the rules of the Directive on accessibility requirements for products and services 64 will apply from 2025 onwards to payment terminals, the Directive does not apply to alternative recharging and refuelling infrastructure in its totality. It is up to Member States to decide if they apply accessibility requirements of the built environment. Stakeholders representing the interests of people with disabilities, did not indicate any concrete problems with the existing infrastructure, neither in their repsonses to the questionnaires nor in the interviews. While those stakeholders issued some general statements on ensuring the usability of infrastructure for all citizens in line with the Directive on the accessibility requirements for products and services 65  and identifying for example the height of the connector as an important issue, they did not establish any additional concrete requirements for the roll out of infrastructure. In the absence of concrete requirements from stakeholders, no concrete policy options could be formulated and quantitatively assessed that would address the specific need of citizens with disabilities. Those aspects will nevertheless need to be addressed by Member States in their NPFs. In addition the Commission may consult its expert group, the Sustainable Transport Forum, on this issue and in addition proposes a mandate to ESOs to review the situation and develop, if need be, concrete standards concerning the the usability of infrastrucure for all citizens.

Smart Recharging – aspects addressed in other EU legislation: the uptake of electric vehicles can potentially cause congestion in the electricity grid and therefore may make expensive grid improvement necessary in some areas. However, introducing smart and bidirectional recharging and thereby shifting charging to times when there are capacities in the network or providing back up storage through electric vehicles batteries can significantly reduce such investments in electricity grids. A number of conditions must be met to ensure that smart charging can take place and is rewarded by the markets, including functioning electricity flexibility markets, technical aspects on the vehicle side, and access to battery data to ensure the development of competitive markets on the service provision side. Those aspects are outside the scope of AFID and are dealt with in other pieces of EU legislation, in particular electricity market legislation 66 .

Near real-time access to the battery data. In order to allow the development of fully competitive markets in the area of smart and bidirectional recharging, many stakeholders pointed to the need to have near real-time access to the battery data to efficiently manage the charging process. This data is currently only available to the car manufacturers. While non-discriminatory access to such battery data is crucial for the development of competitive markets, the issues needs to be seen in the wider context of access to in-vehicle data, including for example maintenance data. Those aspects are being addressed in the ongoing work on access to in-vehicle data, where also the issue of access to battery data is being addressed in detail 67 .

5.2.2.Retained policy measures and policy options overview

The retained policy measures have been grouped in 3 policy options (POs) as presented in Table 2 . It presents the links of the retained policy measures with the specific policy objectives and the POs.

Table 2: Overview of specific objectives, measures and policy options

The uptake of zero- and low-emission vehicles is driven by different policy initiatives under the ‘Fit for 55’ package, including most notably the CO2 emission performance standards for cars and vans. The Directive must ensure that sufficient infrastructure is available to allow that all those vehicles can come into the market and a lack of infrastructure does not become a barrier for the market uptake. In this logic, the policy options look at ensuring that sufficient infrastructure is available to serve the number of zero- and low-emission vehicles that is anticipated under the Fit for 55 package approach as necessary to meet the EU’s climate ambition and achieve at least 55% emission reduction by 2030. This Impact Assessment is drawing here on the findings of the Impact Assessment of the CO2 standards for cars and vans. The methodology to determine sufficient recharging and refuelling infrastructure is described in Annex 7.2. In the course of the development and assessment of the policy options, a sensitivity analysis has been carried out to test the results of different approaches to the assessment of the sufficiency of infrastructure as presented in the POs (see section 7.6).

In order to ensure that sufficient infrastructure will be available across all modes and in all Member States (SO1), mandatory deployment targets are considered to offer strong prospects, given that the indicative target setting applied under the current Directive has not delivered on this objective in all Member States.

When it comes to road transport, the analysis considers mandatory quantified targets on the basis of a minimum recharging capacity to ensure sufficient supply for the national fleet of electric vehicles on the Member State level (PO1). Fleet based targets are relevant for electric LDVs because of the more limited range of electric vehicles compared to other vehicles, the relatively long charging times (requiring more recharging points per vehicle than for example hydrogen stations per vehicle), and the great numbers of electric vehicles expected to come into the market post 2020. The rapid increase of electric LDVs require a spatially inclusive and comprehensive network of recharging points throughout the Member States.

To ensure full cross-border transport connectivity in the TEN-T core and comprehensive network, distance based targets on the TEN-T core and comprehensive network can be set in addition to fleet based targets (PO2). In addition, targets can mandate infrastructure for specific locations such as petrol stations to further determine common locations across the EU (PO3). The three policy options therefore all rely on fleet based targets but for PO2 and PO3 more specific requirements are considered for the installation of recharging points by Member States to ensure a full spatial coverage allowing for cross-border connectivity.

For hydrogen LDV and HDV, but also battery-electric HDV no fleet based targets are considered as the refuelling patterns are distinctively different from electric recharging for LDV. Instead POs propose a mix of distance based targets along the TEN-T network and location based targets in urban nodes, as defined in the TEN-T regulation. The different policy options reflect increasing ambitions in terms of size of the refuelling and recharging stations and the prescribed locations. Similarly, the provision of the current Directive for Member States to provide for an appropriate number refuelling points for LNG accessible to the public (for trucks) by 2025 is maintained, in view of the need for addressing outstanding gaps in the network.

For maritime and inland waterway ports mandatory targets have already been set for LNG refuelling in the Directive but could be strengthened for maritime ports, anticipating that such LNG infrastructure will increasingly serve higher biogas blends and e-gases. For on shore power supply (OPS) binding requirements, expressed in the form of quantified minimum targets, are considered as a measure to ensure that container, cruise and Ro-Pax ships will be offered OPS in ports and thereby enable the maritime sector to meet their obligations under the FuelEU maritime initiative. FuelEU maritime initiative proposes a goal-based approach and requires fuels used in navigation and at berth to meet maximum GHG intensity targets, while also including a reward mechanism for overachievers that will include an additional push for the use of low-carbon renewable transport fuels as part of the so called “basket of measures” approach. AFID caters for the deployment of infrastructure for certain alternative fuels that require distinct infrastructure and that are market ready. There is hence no overlap between the initiatives. Rather, the initiatives are designed to work coherently with each other. Both focus on the same type and size of vessels for which an OPS requirement is put in place. Both also anticipate an exemption for vessels staying at berth for less than 2 hours for technical reasons (i.e. the time for a vessel to connect and disconnect). Also, AFID does not require 100% coverage of OPS calls in a port but rather 90%. This difference caters for calls which for technical reasons are also excluded from FuelEU Maritime legal draft proposal (such as calls for emergency reasons, repairs etc. or calls from ships using zero-emission technologies). In addition, the maximum demand limit of AFID represents a realistic approach in that maximum energy demand need for a port may not be reached but for a few days in a year, thus a 100% demand would lead to underused investments. Furthermore, AFID introduces a minimum limit of calls below which a port would not be required to invest. This limit is set at quite low level, which indicates only occasional calls (less than once per week in most cases). The number of such calls on the one hand is low enough not to impact FuelEU Maritime initiative and on the other hand does not lead to excessive investments. With regard to the geographical scope (core, comprehensive or all ports) a narrower AFID scope as proposed under PO1 (where a mandate is introduced only on TEN-T core ports) would force a shift in traffic flows for vessels towards the OPS equipped ports as - after a small transitional period - FuelEU demands use of OPS or a penalty is imposed. Here however, it should be underlined that AFID does not restrict a port from investing in OPS, but it introduces in essence a minimum requirement. PO3 covers all ports whereas PO2 covers TEN-T core and comprehensive ports. However, despite the large number of non TEN-T ports, the impact of rerouting would be minimal to those ports. According to EMSA, of the total port calls in 2019 that would be covered under the requirements of the FuelEU Maritime only a small percentage would go to non TEN-T ports (11% of cruise vessles calls, 4% of container ships calls and 8% of Ro-Pax vessels calls).

For aviation, binding requirements for electricity supply to stationary aircrafts are considered to reduce the CO2 emission of aviation. The provision of Fixed Electrical Ground Power (FEGP) and Pre-Conditioned Air (PCA) to aircraft at the airport gate reduces emissions by allowing the aircraft to obtain electricity direct from the local grid and use the airport’s air conditioning system to control the temperature on board instead of using the Auxiliary power Unit (APU) which uses normal jet fuel 68 . Here binding targets for aircrafts at gates (PO1) and aircrafts at gates and outfield positions (PO2 / 3) are considered.

With respect to interoperability (SO2), policy interventions are considered to complement the existing technical specifications already set for e.g. electric car recharging to recharging and refuelling heavy-duty vehicles, hydrogen refuelling, etc. Likewise, new technical specifications, not addressed under the current Directive, are retained to ensure the functioning of a common governance and IT architecture that is fully coherent with the different areas of communication within the recharging and refuelling ecosystems. With respect to communication protocols, PO1 mandates common technical specifications based on open protocols developed by the market. This approach would already cover a part of the EV charging ecosystem, namely the recharging stations software management communication (Open Charge Point Protocol (OCPP)) and the e-roaming communication (Open Charge Point Interface (OCPI). In contrast, PO2 and PO3 foresee that the Commission requests to the European Standardisation Organisation (ESOs) to develop and adopt standards covering all areas of the EV charging ecosystem, including communication between the vehicle and the recharging point and overall communication with the grid, thus ensuring full harmonisation.

Regarding user aspects (SO3), different levels of interventions are considered to oblige operators of recharging and refuelling stations to provide full and transparent information about recharging and refuelling prices at the refuelling point as well as static (e.g. location, power of the recharging point, etc.) as in PO1 and additionally dynamic (availability, occupancy, etc.) as in PO2 and PO3 data through National and Common Access Points. When it comes to payments mandatory bank card payment is being assessed with different level of prescription of the technology to be used throughout the different policy options.

While all POs deliver the necessary overall ambition for rollout of alternative fuels infrastructure, they differ in their substance and the regulatory approach to a certain extent. One difference concerns the level of degree to which the policy options address detailed requirements for the physical roll-out in a Member State – here, PO1 is least intervening into Member State action autonomy, whereas PO3 is most heavily intervening. Another difference concerns the level of degree to which the policy options address detailed requirements regarding interoperability, user information and payment services. In this area PO2 and PO3 go beyond PO1 in terms of market segments covered and the level of detail and individual standards when it comes to communication protocols. PO2 and PO3 also differ in terms of the legislative instrument, as PO3 builds on a Regulation. Table 3 provides a tabular overview on the main elements of the policy options.

Table 3: Overview of policy options in terms of ambition and level of intervention

5.3.Description of policy options

5.3.1.Policy option 1 

This policy option proposes a number of significant changes to the Directive to fully deliver on the 2030 Climate Target Plan objectives.

Description of the option

This options sets mandatory quantified targets on the basis of a minimum total recharging power to ensure sufficient supply for the national fleet of electric LDV on the Member State level. In addition, this option introduces mandatory distance-based targets for recharging and refuelling infrastructure on the TEN-T core network for hydrogen refuelling stations and electric recharging points for HDV, with an increase in ambition over time. All targets were derived from the methodology explained in detail in annex 7 that determines sufficiency levels for the deployment of infrastructure. Member States will be required to update their National Policy Framework with a view to detailing their planning for implementation of infrastructure rollout, including identification of emerging needs in rail and aviation, and corresponding monitoring and reporting.

Setting of mandatory targets includes (see annex 7.2 for the methodology to determine sufficient infrastructure levels):

·Member States have to ensure that there is always sufficient recharging capacity installed at publicly accessible infrastructure for the electric LDV fleet registered in that Member State. That capacity is prescribed by the Directive as installed capacity per registered electric vehicle 69 . The compliance will be reported every year to the Commission.

·For recharging infrastructure of HDV, distance-based targets apply: Member States must ensure at least 700kW installed capacity, with 350kW (or higher) charging points, every 60 km in each direction on TEN-T core network by 2025 and 1400 kW installed capacity with 350kW (or higher) charging points by 2030. In addition, MS must ensure at least 700kW installed capacity, with 350kW (or higher) charging points every 100 km on the TEN-T comprehensive network by 2030 and 1400 kW installed capacity with 350kW (or higher) charging points by 2035. In addition, a mandatory target for safe overnight parking for heavy-duty vehicles is introduced: by 2030, each safe and secure parking area has at least one recharging point of 50kW minimum.

·For hydrogen refuelling infrastructure, distance-based targets apply: Member States must ensure every 150 km on the TEN-T core network at least one station serving both directions for heavy-duty vehicles at 700 bar (while 350 bar is optional) by 2030. Light-duty vehicles should be enabled to fuel at all stations. Stations have to provide a minimum daily output capacity of 1t. In addition, a mandatory target for providing at least one hydrogen refuelling station per urban node of the TEN-T network with a capacity of 1t hydrogen per day is defined for 2030. This target is required to ensure that destination refuelling in urban nodes is possible 70 .

·For CNG/LNG refuelling infrastructure, the option foresees no change to the provisions of the current Directive.

Concerning waterborne transport, this option sets provisions for deployment of OPS on the back of the retained current requirements for provision of LNG infrastructure in TEN-T core ports by 2025. Those include a requirement for inland waterway ports on the TEN-T core network to have by 2025 at least one OPS installation per port. Furthermore, maritime TEN-T core ports shall provide one OPS installation in terminals receiving cruise, container, and Ro-Pax above 5000GT by 2030. Ports whose average annual traffic volume during the past 3 years is less than 25 cruise ship calls, 50 container ship calls, 40 ferry calls are exempted.

For TEN-T core and comprehensive airports, this option introduces a requirement that all stationary commercial passenger aircrafts shall have electricity supply at all gates by 2025.

This option extends the set of technical specifications under the Directive to address interoperability, including requirement for additional physical standards for charge points (e.g., charging standards for trucks, supplementary standards for hydrogen). Moreover, all new charge points need to be equipped with the following communication interfaces and protocols: Open Charge Point Protocol (OCPP) 71 to ensure full communication of the charging point with the back-end of the charge-point operator and Open Charge Point Interface (OCPI) to enable full communication with roaming platforms. 72 Moreover, operators have to provide static data to Member States national (or common) access points on location, opening time and specific charging station characteristics as well as clearly display prices following a format to be defined in the directive. Charge point operators must offer bank card payments through either a chip card terminal, an NFC interface or through a QR code leading to a specific payment side for the specific charging event.

5.3.2.Policy Option 2 

This policy option thoroughly revises the Directive. It increases the level of policy intervention: it sets the same mandatory national fleet based targets for electric LDV, but adds targets for infrastructure for electric LDV on the TEN-T network and for electric HDVs in urban nodes. It increases the level of ambition for recharging and refuelling infrastructure for HDV. It also introduces stricter deployment targets for waterborne transport and for stationary aircrafts. This policy option introduces ambitious measures in terms of interoperability and user information, including a greater level of harmonisation on physical and communication standards and more user friendly ad hoc payment options. It further substantiates provisions on price transparency and other user information, including physical signposting of recharging and refuelling infrastructure.

Description of the option

In addition to the targets already included in PO1, target setting in PO2 for alternative fuels infrastructure for road transport includes:

·In addition, Member States must ensure at least 300 kw installed capacity, including at least one 150kW recharging point, every 60 km in each direction on the TEN-T core network by 2025 and 600kW installed capacity, including at least two 150kW in each direction on the TEN-T core network by 2030. In addition, Member States must ensure every 60km on the TEN-T comprehensive network 300 kW installed capacity, including at least one 150kW, by 2030 and 600kW installed capacity, including at least two 150kW recharging points, by 2035.

·In addition to the location based targets on the TEN-T network for HDV, Member States have to ensure a minimum of electric recharging capacity (600 kW installed by 2025 and 1.2 MW installed by 2030) in every urban node of the TEN-T network (as defined in the Regulation on TEN-T guidelines 73 ) in particular to serve urban delivery trucks.

·For hydrogen refuelling infrastructure the minimum daily capacity per refuelling station increases to at least 2t of hydrogen. In addition, Member State have to ensure that every 450 km on the TEN-T network a hydrogen refuelling station serves liquid hydrogen to trucks. Moreover, the option norms a requirement to also serve liquid hydrogen in at least one third of urban nodes.

·For LNG refuelling infrastructure, Member States have to ensure that an appropriate number of refuelling points for LNG accessible to the public are put in place by 2025, at least on the TEN-T Core Network, so that LNG heavy-duty vehicles can circulate throughout the Union, where there is demand, unless the cost are disproportionate to the benefits, including environemtnal benefits. 74  

Additional target-setting for waterborne and aviation transport include:

·For inland waterway ports, Member States have to ensure that – in addition to the installation in TEN-T core ports as in PO1 - that 1 OPS is also installed in all TEN-T comprehensive ports by 2030. The policy option removes the requirement under the current Directive for LNG bunkering in TEN-T core ports that foresees that vessels must be able to circulate along the TEN-core network.

·For maritime ports, Member States have to ensure that OPS is installed to cover at least 90% 75 of demand for all TEN-T core and comprehensive ports at for terminals receiving: cruise, container, Ro-Pax above 5000GT by 2030. Ports whose average annual traffic volume during the past 3 years is less than 25 cruise ship calls, 50 container ship calls, 40 ferry calls, are exempted from this obligation.

·For TEN-T core and comprehensive airports, the option norms a minimum requirement to supply electricity to stationary commercial passenger aircrafts at all gates and outfield positions by 2030.

This options includes a broader range of requirements to address full interoperability. In addition to requirements for additional technical specification for road transport as in option 1, it sets a requirement for additional technical specifications for maritime transport and inland navigation (e.g., a single solution for shore-side battery recharging points for maritime and inland waterways vessels; hydrogen, methanol and ammonia refuelling points and bunkering for maritime and inland waterways vessels). In addition, also particular aviation technical specifications would be considered. The Directive would extend the range of communication aspects covered and also require that instead of prescribing open protocols for recharging points, technical specifications are adopted by European standardization organizations and subsequently transferred into the Directive to fully cover the communication between vehicle and the charging point, the communication of the charging point with the back-end of the charge point operator, the communication with roaming platforms and the communication with the grid. Those would replace the requirements for standards as in option 1. The advantage of adopting standards developed by European standardisation organisations is that those standards are developed with the support and final consent of all Member States and all key industry players, ensuring wide support from all parties concerned.

The option foresees further harmonisation of Member State provisions for recharging infrastructure, e.g. Member States will no longer be allowed to require shutters or any other specific technical requirements to ensure that recharging points can be sold without modifications throughout the EU. Moreover, this option tightens provisions for bank card payment: all new fast chargers (>50kW) have to provide either NFC or terminal payment. Other chargers can also offer QR codes. Moreover, at every charge point, the customer must have the right to choose the payment method before initiating the charge. If automatic authentication under contract-based charging is offered by the charge-point operator, the user must have the right to choose either an ad hoc payment option or pay through another EMSP supported by the CPO.

The option extensively addresses user information aspects. In addition to static information on recharging points and price information through digital means (option 1) option 2 requires CPOs to make dynamic data available (Operational status, Availability, Price ad-hoc). It sets a requirement to install signposting of recharging points and hydrogen refuelling stations within parking and recharging/refuelling areas along the TEN-T core and comprehensive network.

The option prescribes the requirement to Charge Point Operators to display prices at all recharging points. Moreover, Mobility Service Providers must clearly communicate all existing price components (incl. possible roaming fees) to consumers prior to the recharging session via a dedicated application (except if only fixed subscription fee applies). Charge Point Operators cannot unduly differentiate (or discriminate) between the prices charged to B2B customers (EMSPs) and the prices charged to B2C customers (i.e. the ad hoc price charged directly to EV-drivers). Price charged to different Mobility Service Providers must equally be non-discriminatory. The current Directive only addresses price setting vis-à-vis the end user but not towards other businesses. Such widening of the non-discriminatory clauses is deemed relevant to ensure that non-favourable business practice, which currently represents very isolated cases, do not develop into a structural problem in the future.

5.3.3.Policy Option 3

This policy option replaces the current Directive with a Regulation and increases further the level of ambition, resulting in a very ambitious mandate for the installation of recharging and refuelling infrastructure in roads and ports, mandating infrastructure on TEN-T core and comprehensive network corridors, at locations and through fleet based targets. Concretely, it extends the mandatory targets of option 2 with additional mandatory deployment targets for electric recharging points on petrol stations and earlier deployment targets for hydrogen stations and increases considerably the ambition of installation of alternative fuels infrastructure in ports.

Equally, strict deployment targets are introduced for waterborne transport and aviation and foresees shortening of the NPF reporting cycle from 3 to 2 years. The option reduces flexibility for charge point operators by making terminal payment at fast chargers the standard ad-hoc payment solution.

Description of the policy option

This policy option combines all distance-, location- and fleet-based target requirements of option 1 and 2. It adds a mandate for deployment of recharging points for LDV:

·by 2025, every petrol station with 12 or more pumps must be equipped with at least one recharging point with a minimum capacity of 150kW and

·by 2030, every petrol station with 8 or more pumps must be equipped with at least one recharging point with a minimum capacity of 150kW

A similar mandate is introduced for trucks (1 recharging point of 350 kW) in all petrol stations that serve trucks. This option also includes a mandate to Member States to ensure that every 150 km on the TEN-T core network there is a CNG refuelling station. The requirements for hydrogen refuelling infrastructure are the same as in option 3, but will have to be met by 2025 already.

In addition, it sets up a high ambition for provision of alternative fuels infrastructure in ports. For inland waterway ports, 1 OPS installation per TEN-T core and comprehensive port has to be achieved by 2025 while LNG . Moreover, the option mandates electricity supply for battery vessels at each TEN-T inland waterway core port by 2030. The option foresees mandatory LNG bunkering in all TEN-T core ports in 2030, thus replacing the existing provision that only prescribes that circulation on TEN-T core ports must be possible without specifying which port must deploy LNG bunkering. The option also requires the OPS provision of option 2 for all EU maritime ports. The option foresees the same requirements for airports as option 2.

The option foresees the same requirements for interoperability of infrastructure as policy option 2, but restricts ad-hoc payment by bank card at new fast chargers (>50kW) to terminal payment. It also prescribes that cables are fixed to AC chargers (helical) and DC chargers. It foresees the same requirements for user information as option 2, but extends the requirement for road signing to be available to the full TEN-T core and comprehensive network. Recharging points and hydrogen refuelling stations must be signalled along the motorways, and not only within parking areas.

A regulation marks a significant change in the legislative instrument, as it directly and automatically applies in its entiety to all Member States and defines precisely the means of achieving certain results, whereas a Directive requires Member States to achieve certain objectives, but leaves them to adopt the measures to incorporate into national law to achieve the objecticves set in the directive. In the consultation, a broader group of participants called for the directive to be changed into a regulation. Option 3 therefore design measures under the instrument of a regulation, including also measures that are binding on specific entities such as petrol stations.

5.4.Discarded Policy Options

Some stakeholders in the OPC but also in public workshops and meetings expressed the view that fleet based targets would not be required at Member State level. Instead, distance based targets along the TEN-T core network as well as location based targets at petrol stations would also ensure a sufficient level of recharging infrastructure for LDV that would deliver on the minimum infrastructure requirements for 2030. Following the stakeholder opinions the impact assessment analysed if such policy measures alone would indeed be sufficient to ensure sufficient infrastructure deployment to meet the demands of the vehicle fleet expected under the Climate Target Plan objectives in all Member States. Two policy options (POA and POB) were analysed in accordance with the proposed measures in PO2 and PO3, both excluding fleet based targets.

POA (same distance based targets as in PO2):

·For recharging infrastructure of LDV, Member States must ensure at least 300 kw installed capacity, including at least one 150kW recharging point, every 60 km in each direction on the TEN-T core network by 2025 and 600kW installed capacity, including at least two 150kW in each direction on the TEN-T core network by 2030. In addition, Member States must ensure every 60km on the TEN-T comprehensive network 300 kW installed capacity, including at least one 150kW, by 2030 and 600kW installed capacity, including at least two 150kW recharging points, by 2035.

POB (same distance based targets as in PO2 plus location based as in PO3)

·As regards a mandate for deployment of recharging points for LDV by 2025, every petrol station with 12 or more pumps must be equipped with at least one recharging point with a minimum capacity of 150kW and

·By 2030, every petrol station with 8 or more pumps must be equipped with at least one recharging point with a minimum capacity of 150kW

Using the same methodology as for the assessment of the policy options 1 – 3, the impact assessment concluded that neither individually nor combined, those two policy options would ensure sufficient recharging infrastructure for LDV in all Member States.

In fact, POA would increase the overall number of recharging points in the EU by around 6,800 recharging points compared to the baseline in 2030 while POB would lead to an increase by around 57,600 throughout the EU. However, this would not sufficiently change the overall deployment of recharging points, leaving 15 Member States short in providing sufficient infrastructure to support the required vehicle fleet under the 2030 Climate Target Plan objective. In 2030, those 15 Member States (BG, CZ, EL, IE, IT, LV, LT, PL, PT, SK, ES, RO, CY, MT, HR) would be short of a combined total of over 700,000 recharging points.

These two policy options would ensure full cross border connectivity but they would not provide sufficient recharging infrastructure to support the national electric vehicle fleets required to meet the objectives of the 2030 Climate Target Plan. The lack of infrastructure would thereby act as a barrier to the uptake of vehicles in 15 Member States not allowing for the required emission reductions. The two policy options have been discarded as they are not coherent with the Climate Target Plan ambition.

6.What are the impacts of the policy options?

This section summarizes the main expected economic, social and environmental impacts of each PO across all transport modes 76 . In terms of time horizon, the assessment has been undertaken for the 2025-2050 period (in five-year steps). The measures that are part of the POs are assumed to be implemented from 2025 onwards, with a particular emphasis on understanding impacts for 2030, but going beyond. The analysis presented in this section covers the EU27 scope. Costs and benefits are expressed as present value using a 4% discount rate.

The impacts of the policy options, focusing on the design of the policy instrument, are assessed in the context of a policy environment achieving the overall 55% emission reduction objective by 2030. This policy context is mainly represented by the MIX policy scenario that follows a combined approach of carbon pricing instruments and regulatory-based measures, and is also consistent with option TL_Med of the impact assessment accompanying the revision of the emission performance standards for new passenger cars and for new light commercial vehicles which provides the vehicle fleet relevant for the design of the policy options. Detailed information on the methodological approach and on the MIX policy scenario can be found in Annex 4.

In view of the need to ensure consistency with other policy initiatives under the Fit for 55 package, this impact assessment has carried out an assessment of cost of infrastructure under the preferred policy option for all options assessing the different target levels in the impact assessment accompanying the revision of the emission performance standards for new passenger cars and for new light commercial vehicle, (including TL_Low and TL_High, in addition to TL_Med). This analysis is presented in section 7.6.

6.1.Economic impacts

Both quantitative and qualitative assessments of economic impacts have been undertaken for each policy option. In general, quantification of impacts using the PRIMES-TREMOVE model by E3Modelling has mainly focused on the measures covering problem area 1 (in particular road transport), and the measures related to other problem areas (2-3) have mainly relied on input from stakeholders and desk research.

6.1.1.Impact on alternative fuels vehicles and infrastructure markets

In general, investments in quantity and quality of infrastructure will not directly lead to the uptake of alternatively fuelled vehicles which are determined by other policies, e.g. the CO2 emission performance standards. However, only if sufficient, interoperable infrastructure is available that provides minimum services to consumers, it can be expected that the vehicles as considered necessary to achieve the EU’s Climate Target Plan objective will make it into the market.

Measures setting targets for road transport

The measures introducing targets for road transport aim at ensuring that sufficient infrastructure is deployed in all Member States so a lack of infrastructure does not form a barrier for the expected vehicle fleet. The structure of the vehicle fleet, which is the same under all policy options, is driven by the new policy initiatives under the “Fit for 55” package, in particular the revision of the CO2 emission performance standards for cars and vans (i.e. option TL_Med).

In the policy options, the number of battery electric vehicles (BEV) is projected to increase at a much higher speed than in the baseline and is projected to be more than twice the numbers in the baseline by 2050. By 2030, close to 37 million BEVs would be registered in PO1/PO2/PO3 relative to 30 million in the baseline. This gap is projected to widen significantly post-2030, with 140 million BEVs in 2040 and 235 million in 2050 in PO1/PO2/PO3 relative to 67 million in 2040 and 97 million in 2050 under the baseline. In contrast, PHEV will develop similarly under the policy options and the baseline until 2040 but will only play a limited role in 2050 with 15 million vehicles in PO1/PO2/PO3 compared to 54 million in the baseline.

Similar to electric LDVs, the uptake of electric HDVs is projected to be much higher in the policy options relative to the baseline by 2030 (around 110,000 in PO1/PO2/PO3 vs 50,000 in the baseline). This gap will further widen in 2040 and 2050 when 1 million and 2.4 million vehicles, respectively, are expected under the policy options (i.e. around 10 times more electric HDV by 2050 than under the baseline).

A similar development pattern is projected for fuel cell vehicles, albeit with considerably lower overall numbers than for electric LDV and higher uptake in particular expected post 2040. Relatively similar number of light duty fuel cell vehicles are projected by 2030 in the policy options and the baseline (around 306,000 vehicles in the baseline and 416,000 in the policy options). By 2040, in PO1/PO2/PO3 the number of fuel cell LDVs is projected at 12.8 million relative to 3.9 million in the baseline, while by 2050 the gap is projected to widen even further (38.7 million in the policy options versus 10.3 million in the baseline). Fuel cell HDVs are projected to play a more limited role by 2030 in the baseline and under the policy options. Post-2030 their uptake is however projected to significantly go up: to around 549,000 in the policy options compared to 63,000 in the baseline for 2040 and 1.9 million in PO1/PO2/PO3 by 2050, which is in stark contrast to the baseline where only around 102,000 vehicles are projected.

The overall numbers of LNG and CNG vehicles are projected to go up by 2030 relative to 2020, but to be lower than in the baseline for 2030. The stock of CNG vehicles is projected to reduce significantly post-2030 in the policy options and be less than half a million by 2050. CNG vehicles are expected to be strongly concentrated in only a few Member States. Almost 70% of all CNG LDVs are projected to be registered in Italy by 2030, representing however less than 6% of the fleet, and only in two other Member States (BG, SE) are CNG LDVs expected to represent more than 2% of the fleet. LNG trucks in PO1/PO2/PO3 are projected to grow at a somewhat lower rate than in the baseline and reach around 510,000 vehicles in 2030 and 1.1 million in 2040. They are expected to be gradually replaced by zero emission technologies post 2040.

Table 4: Uptake of vehicles in the baseline and in the policy options (in thousands)

Source: Ricardo et al (2021), impact assessment support study, PRIMES-TREMOVE model results (E3Modelling)

What concerns electric recharging points, the assessment of national policy planning (on the basis of the implementation reports for AFID) under the baseline shows that 18 Member States (BG, CZ, EL, FI, FR, HU, IE, IT, LV, LT, PL, PT, SK, ES, RO, CY, MT, HR) will not provide sufficient recharging infrastructure by 2030 to accommodate the anticipated number of electric vehicles that meet the 2030 increase in climate ambition. In total, there would be 2.3 million public accessible recharging points under the baseline. They will just be somewhat sufficient to accommodate the vehicle fleet under the baseline. Only 9 Member States are planning for sufficient infrastructure to accommodate the higher fleets under PO1. This gap is expected to increase even further towards 2040 and 2050 when the uptake of electric vehicles takes further pace while infrastructure is not catching up. Around 4.2 million public accessible recharges are projected in the baseline by 2040 and 6.9 million by 2050.

All POs set mandatory targets for Member States to ensure that the infrastructure is sufficient in relation to the LDV fleet. The analysis shows that overall infrastructure for electric LDV develops in all Member States by 2030 and beyond, in line with electric vehicle fleet. Based on the sufficiency index of determined as an average capacity of a recharging point for a battery electric vehicle of 1 kW and for a plug in hybrid of 0.66 kW, the POs result in a total installed capacity of 47-58 GW for 2030 at EU level (47 GW in PO1, 49 GW in PO2 and 58 GW in PO3) relative to 29 GW in the baseline. Expressed in terms of equivalent number of recharging points, while assuming an increase in the average capacity of recharging points for the LDV fleet from currently 11 kW to 14-16 kW by 2030 because of the deployment of more fast recharging points compared to 2020 (14 kW in PO1/PO2 and 16 kW in PO3 - because of the additional high power recharging points in petrol stations under PO3), POs show 3.50 to 3.57 million recharging points in the EU in 2030 compared to the baseline of 2.3 million. However, assuming that the share of fast recharging points stays constant as in 2020, the POs show a total number of recharging points of over 4 million (or over 6 million recharging points under the assumption that only normal recharging points of an average of 7.4 kW were deployed). The analysis assuming that the share of fast recharging points stays constant as in 2020 is provided in section 7.7.

Under PO1, recharging infrastructure for LDV risks, however, not to ensure an even distribution along the TEN-T network. Especially in Member States that currently plan for limited infrastructure deployment, there is a risk that the planning is not fully sufficient with respect to the deployment along the TEN-T corridors in terms of distance between recharging stations and the total power provided. 77 For PO2 and PO3, 11,363 charging points for LDVs are estimated to be deployed on the TEN-T network (including urban nodes) by 2030 and 12,112 by 2040.

All POs lead to approx. 11.4 million recharging points in 2040 and 16.3 million by 2050, providing sufficient recharging infrastructure for the expected fleet uptake until 2050.

Table 5: Projected deployment of recharging points for LDVs in the baseline and in the policy options in 2030 (difference to the Baseline) by Member State

Source: Ricardo et al (2021), impact assessment support study

The policy options will lead to a considerable increase in infrastructure for electric HDVs in the EU by 2030 with over 6,100 charging points in PO1, 6,500 under PO2 and more than 7,600 under PO3 relative to the baseline, under which less than 100 recharging points are deployed. By 2050, the number of recharging points would go up to around 13,000 in PO1 and PO2 and more than 14,000 in PO3. All options provide sufficient infrastructure on the TEN-T network for the expected vehicle uptake, with additional targets in PO2 (urban nodes for delivery trucks) and PO3 (fast recharging points in all petrol stations along TEN-T) adding extra convenience for the users.

For hydrogen infrastructure the baseline includes some very ambitious Member State plans. For example Germany alone plans for 1,000 stations by 2030. However, many Member States currently do not plan sufficient investments in hydrogen refuelling infrastructure that would allow for the development of a coherent network across the EU. In all Member States all policy options will provide a similar and sufficient number of refuelling stations. However, the total capacity of those stations will be about twice as high in PO2 and PO3, which will add considerable convenience for the user. In addition, PO3 ensures that the infrastructure required for the vehicle numbers in 2030 is already available in 2025 to provide more investment security for the sector.

What concerns gaseous fuels, CNG vehicles are a mature technology and the deployment of CNG refuelling stations largely market driven. The same can be expected for LNG HDV, once a minimum infrastructure along the TEN-T core network is being established and thereby investment security is provided. Such investments into the TEN-T core network have already been triggered through the Directive and Member States planning suggests that sufficient infrastructure will be available in almost all Member States already in the baseline, building on the requirement under the current AFID. For LNG the mandatory target included in PO2 and PO3 would only ensure filling the remaining gaps in the TEN-T core network by 2030, relative to PO1 (where such requirement is not included), and thus ensuring full certainty about cross-border connectivity for those operators using this transitional technology. However, relative to the baseline all options show lower number of LNG refuelling stations due to the lower uptake of LNG HDVs.

For CNG the mandatory deployment targets under PO3 would only increase the total numbers minimally in 2030, relative to PO1 and PO2, by filling in remaining gaps in the TEN-T core network. However, the number of refuelling stations in 2030 would be lower in all policy options relative to the baseline, due to the lower uptake of CNG LDVs. It is also worthwhile noting that because of the expected rapid decline of the number of CNG vehicles post 2035, the required number of refuelling stations will go down to around 600 stations by 2050 which is well below the existing numbers of over 3,000 stations. Equally for LNG, the numbers will go down to around 2,900 refuelling stations by 2050 following the slow replacement of LNG vehicles by zero-emission technologies post 2040.

Table 6: Expected AFI deployment in the baseline and in the policy options for 2030-2050 (number of recharging points/facilities)

Source: Ricardo et al (2021), impact assessment support study

All policy options are considered to provide sufficient infrastructure for the required vehicle fleet in 2030 and beyond hence ensuring that infrastructure is not a barrier for the uptake of vehicles.

Measures setting targets for AFI for waterborne transport

In the case of LNG bunkering facilities in TEN-T core maritime ports, that can also be used for decarbonised gases (i.e. bio-LNG and renewable low-carbon e-gas) to fully support the EGD objectives, the new measure is anticipated to contribute to the deployment of new infrastructure although the available evidence suggests that a significant level of deployment is expected to take place already under the baseline.

Article 6 (1) of the current Directive already required Member States to ensure that an appropriate number of refuelling points for LNG were put in place at maritime ports in the TEN-T Core Network by 2025. In the baseline scenario, 71 core TEN-T ports would have such facilities in place by 2030. The new measure under PO3 on LNG bunkering for maritime ports is anticipated to lead to the deployment of 19 additional facilities such that all 90 core TEN-T ports would be covered by 2030. It is also worth noting that, of the 22 Member States that have core TEN-T maritime ports, half are already planning to deploy LNG bunkering infrastructure in their core ports (i.e. as part of the baseline scenario); the other 11 78 would need to deploy infrastructure in one to three core ports each to meet the new target.

Table 7: Expected AFI deployment in 2030 by PO and in the Baseline regarding LNG bunkering for maritime ports (number of facilities)

Source: Ricardo et al (2021), impact assessment support study

The removal of the provision for LNG bunkering in inland ports in PO3 could stop further deployment of this infrastructure for inland ports. Article 6 (2) requires Member States to ensure that an appropriate number of refuelling points for LNG are put in place at inland ports in the TEN-T core network by 2030. In the baseline scenario, 36 core ports are expected to offer LNG bunkering out of the 85 inland TEN-T core ports in the EU. By removing this provision, it is possible that some of this deployment would not take place. However, the question is also whether there is a need for such infrastructure given the expected limited use of LNG for inland navigation in the future and the availability of other solutions to achieve the environmental goals. Stakeholders that participated in the consultation for the impact assessment support study were also asked about a revision of this provision. Many respondents, including ports representatives, argued that there was no need for specific targets because LNG is not economically viable for inland navigation. As a result, the deployment of this type of infrastructure might no longer take place in the future.

For OPS infrastructure in maritime ports, the total installed capacity has been increasing since the 2000s and is now around 90MW across the EU 79 . This trend is expected to continue in the baseline scenario, to reach 174 MW by 2030. However, it will fall short from providing the necessary capacity for servicing the containerships, passenger ships and Ro-Pax vessels that are to be equipped with OPS by 2030, in line with the FuelEU maritime initiative proposal. The total installed capacity is expected to grow significantly compared to the baseline if the new measures are adopted, especially under PO3 which covers all EU ports that meet the minimum requirements. The FuelEU initiative works in tandem to this initiative by mandating the use of OPS by the three types of vessels, thus providing the demand and increasing the business case for ports to install this technology.

Table 8: Expected AFI deployment in 2030 by PO and in the Baseline regarding OPS in maritime ports

Source: Ricardo et al (2021), impact assessment support study

For OPS infrastructure in inland ports, up to 139 OPS facilities could be deployed in the baseline by 2030. The new measures could contribute to 18-106 additional ports in the EU having OPS depending on the policy option (values represent the upper bound of each option).

Table 9: Expected AFI deployment in 2030 by PO and in the Baseline regarding OPS in inland ports

Source: Ricardo et al (2021), impact assessment support study

Measures setting targets for aviation

Overall, mandatory targets for stationary aircrafts are expected to have a limited effect on the availability of infrastructure for electricity supply for stationary aircraft above what is expected under the baseline. As required by the 8th indent of Article 3(1) of the Directive, 23 Member States have considered the need to install an electricity supply for use by stationary airplanes - among those Member States 80 , 81 , AT, DK, EE and LT stated that electricity supply is already in place in a sufficient number of airports but without proving details on the installations. Other Member States have indicated deployment of electricity supply in major airports, although in most cases it is difficult to identify whether this is sufficient to support all aircraft. Moreover, three Member States (SI, SK, NL) have set targets in their NPFs to install this type of infrastructure.

A large number of airports already provide this type of infrastructure: 82% of respondents to an ACI EUROPE members survey already provide FEGP (fixed electrical ground power). 82 Furthermore, 46% of them have 81-100% of their stands equipped with FEGP. As a result, the measure is considered to not lead to significant increase in FEGP stations at major airports, but it might be more relevant for medium-sized airports.

Because of the lack of accurate data, it is assumed that the average number of outfield positions across all airports is approximately twice the number of passenger gates. Under these assumptions, the impact under PO2 and PO3 are expected to be significantly greater than under PO1 as these measures support all gates and outfield positions in the EU with FEGP. At the same time, given the high baseline deployment, the total number of FEGP units is expected to grow by around 48%. No impacts on the uptake of aircraft are expected from this measure.

Table 10: Expected AFI deployment in 2030 by PO and in the Baseline regarding electricity supply in airports

Source: Ricardo et al (2021), impact assessment support study

Measures to promote interoperability and user information of AFI

Measures focusing on promoting interoperability include requirements for ad-hoc payments, the freedom for consumers to choose payment methods, technical specifications for recharging points, physical and communication standards and improved user information. All above measures are expected to positively impact customer experience through improved convenience and reliability of recharging services. While the impact of each of the measures separately may be relatively small, combined, they could be expected to have a higher positive impact, making the entire experience of using an AFV and AFI easier and enabling a higher level of uptake of AFVs. Standards in physical and communication interfaces increase the investment security of AFI investments and the development of such European standards will therefore contribute to the deployment of AFI in all modes.

6.1.2.Administrative burden for public authorities

The costs to public authorities arise mostly from the requirements for Member States to review and update their national policy frameworks (NPFs) and subsequently report on the implementation. In the baseline, based on Member States estimates on costs for developing the NPFs under the current directive, those costs are estimated to be €3,400,000 (€126,000 per Member State) for each reporting circle with the main costs being personnel costs for drafting and publication of the document. In PO1 and PO2 the reporting cycle is kept unchanged relative to the baseline. Therefore, no additional costs are expected in PO1 and PO2 relative to the baseline. However, the reporting cycle is shortened from three to two years for PO3, which will slightly increase the overall costs. In addition, monitoring costs may increase for public authorities to report on compliance with the strict targets set under the different policy options. However, the additional costs relative to the baseline can’t be quantified; and the provision of standardised data formats, digitised data transfer and a common system of reporting to national access points of Member States will simplify overall reporting under the Directive.

6.1.3.Infrastructure costs 

Road transport

Based on the expected deployment of the infrastructure as described in chapter 6.1.1, and using the cost estimates as described in annex 4, total average annual investments for road transport infrastructure for the period up to 2030 for the private sector and public authorites would be between €0.80 and 1.55 billion in the different policy options in addition to the baseline. The lowest additional annual average investments relative to the baseline are estimated for PO1 (€0.80 billion) and the highest in PO3 (€1.55 billion), with PO2 falling in between the two at €1.07 billion. For 2031-2050 the average annual investments will increase to €4.41 to 4.58 billion in the different policy options in addition to the baseline.

Table 11: Average annual investments for private operators and public authorities for 2021-2030 and 2031-2050 in the baseline and in the policy options (expressed as difference to the baseline)

Source: Ricardo et al (2021), impact assessment support study

Average annual maintenance costs for private operators are estimated at €0.05 to 0.16 billion in addition to the baseline for the period up to 2030 and €1.12 to 1.21 billion compared to the baseline for 2031-2050. Maintenance costs are attributed only to the private sector.

Table 12: Average annual operation costs for private operators for 2021-2030 and 2031-2050 in the baseline and in the policy options (expressed as difference to the baseline)

Source: Ricardo et al (2021), impact assessment support study

The total additional costs relative to the baseline for the private and public sector for the period 2025 – 2050, expressed as present value over 2021-2050, are estimated between €49.9 billion in PO1 and 58.9 billion in PO3, with PO2 falling in between (€53.3 billion). However, as explained in section 6.1.1, for PO1 especially in Member States that currently plan for limited infrastructure deployment, there is a risk that the planning is equally insufficient with respect to the deployment along the TEN-T corridors in terms of distance between recharging stations and the total power provided for LDVs.

Table 13: Total capital and operation costs for private operators and public authorites in the baseline and in the policy options (difference to the baseline), expressed as present value over 2021-2050 83

Source: Ricardo et al (2021), impact assessment support study; Note: Assumed economic lifetime of investments is 10 years for electricity recharging infrastructure and 15 years for hydrogen, CNG and LNG fuelling facilities; annualised capital costs are derived assuming a weighted average costs of capital of 8%. For calculating the present value, a discount rate of 4% is assumed.

Around 46-48% of the total costs in the policy options over 2025-2050 (expressed as present value over 2021-2050) are estimated to be dedicated to electric recharging infrastructure for LDVs in POs, 3% for recharging points for HDVs, 38-40% for hydrogen refuelling points, 5-6% for LNG and 5-6% for CNG refuelling infrastructure. However, when looking at the additional costs relative to the baseline, the costs of CNG and LNG fuelling facilities would decrease relative to the baseline due to the lower uptake of the CNG and LNG vehicles.

The costs per recharging point and per refuelling station are expected to decrease over time due to economies of scale. Annex 4 provides the evolution of the capital costs per recharging point and refuelling station for 2020-2050, in five years steps. On one hand, the unit capital costs per type of recharging and refuelling station would decline over time, driven by the larger uptake of zero emission vehicles and the induced learning effects, also on the infrastructure side. On the other hand, the change in the structure of recharging points (i.e. the increase in the average capacity due to the larger share of fast chargers) and the higher capacity per refuelling station in the policy options pushes the costs up. In addition, the larger uptake of zero emission vehicles in the policy options is incentivised by more stringent CO2 standards for vehicles. As the number of zero emission vehicles increases relative to the baseline, so does the total number of recharging points and refuelling stations. Total costs therefore increase in the policy options relative to the baseline, due to the changes in the structure of recharging points and in the capacity per refuelling station as well as due to the higher number of zero emission vehicles.

Costs for authorities

Meeting the AFI targets set in the policy options will require a significant level of public support and contribution to the totat investment cost presented in the section above. This is expected to be needed for as long as the level of demand from vehicles remain at comparatively low levels and will not allow for the commercial viability of investments. However, with increasing vehicle fleets also the level of support is expected to go down to a point where public support will only be needed for infrastructure in remote locations with little demand. This is reflected in the assumptions that up to 50% public financing will be required for hydrogen and recharging stations with the remaining financing expected to come from the private sector. The share of public financing will however go down to 10% on average post 2030. For natural gas only little financing is required until 2030 while no support is expected to be required post 2030. No public support is required to cover operation costs as those costs are full covered by the operators of the recharging and refuelling infrastructure. The assumptions about the share of public support up to 2030 draw on information about the existing national and EU level support schemes.

Table 14: Estimated public support for road recharging and refuelling infrastructure, expressed as share of investments

Source: Ricardo et al (2021), impact assessment support study. The estimations are based on public financing under existing national and EU level support schemes. A detailed analysis is provided in the support study.

Under the assumptions in Table 14 , and drawing on the total average annual investments in Table 11 , public support in comparison to the baseline is estimated at €0.39 to 0.71 billion on average per year up to 2030 and €0.45 to 0.47 billion on average per year for 2031-2050 (see Table 15 ). The rest of investments in Table 11, more specifically €0.42 to 0.84 billion on average per year up to 2030 and €3.96 to 4.11 billion on average per year for 2031-2050 would come from the private sector.

Table 15: Average annual investments by public authorities for 2021-2030 and 2031-2050 in the baseline and in the policy options (expressed as difference to the baseline)

Source: Ricardo et al (2021), impact assessment support study

At Member State level, the costs for the public sector vary significantly.

Some Member States have already very ambitious plans under the baseline (e.g. Germany for recharging points and hydrogen). The increase in the average annual investments for public authorities in the policy options relative to the baseline in this case is explained by the difference in the type of recharging points and hydrogen fuelling facilities deployed. For example, for recharging stations for LDVs, the average capacity would increase from around 12 kW in the baseline to 14-16 kW in the policy options. For hydrogen fuelling facilities, the capacity would increase from around 0.4 t per station in the baseline to 1 t per station in PO1 and 2 t per station in PO2 and PO3.

Table 16 presents the average annual investments for public authorities for all policy options relative to the baseline. It also shows their share in the GDP. While higher average annual investments are expected in Germany, France, Italy, Spain and Poland, when expressed as a share of GDP they would be less than 0.02% in all Member States in PO1 and PO2 and less than 0.03% in PO3. The highest share of public investments would be required for recharging points for LDVs and hydrogen fuelling facilities.

Some Member States have already very ambitious plans under the baseline (e.g. Germany for recharging points and hydrogen). The increase in the average annual investments for public authorities in the policy options relative to the baseline in this case is explained by the difference in the type of recharging points and hydrogen fuelling facilities deployed. For example, for recharging stations for LDVs, the average capacity would increase from around 12 kW in the baseline to 14-16 kW in the policy options. For hydrogen fuelling facilities, the capacity would increase from around 0.4 t per station in the baseline to 1 t per station in PO1 and 2 t per station in PO2 and PO3.

Table 16: Average annual investments by public authorities by Member State for 2021-2030 in the policy options (expressed as difference to the baseline, in €million) and share of GDP

Source: Ricardo et al (2021), impact assessment support study

Measures setting targets for AFI for waterborne transport

Based on the expected infrastructure deployment described in section 6.1.1, the following costs were estimated for the different shipping targets. For LNG bunkering in maritime ports, infrastructure costs include:

·Capital costs linked to costs of installing LNG bunkering and storage tanks, acquisition of land, connection to natural gas pipeline, construction of quay for bunkering, other engineering works and licence costs.

·Operational costs linked to costs of pipeline, LNG terminal take-out fee, personnel / safety training and transhipment costs from import hub.

The nature and extent of these costs can vary significantly from port to port, given the differences in capacity requirements, existing infrastructure in ports, and type of bunkering implemented (i.e. Ship-to-Ship (STS), Pipeline-to-Ship (PTS), and Truck-to-Ship (TTS)). The key factors influencing the overall cost differences is the cost of truck, vessel and terminal, and the capacity. Furthermore, not all costs apply to each of these bunkering options. For example, construction of a quay and connection to the pipeline is only relevant for Pipeline-to-Ship. Even within each bunkering option, the costs are highly variable depending on the nature of each installation. The capital costs (CAPEX) of each bunkering method are estimated to be €0.2-100 million per port for TTS, compared to €23-73 million per port for STS and €33-237 million per port for PTS. Similarly, the operational costs (OPEX) vary between each port and bunkering method, although to a lesser degree.

The infrastructure is assumed to be deployed between 2025 and 2030. For the purposes of this impact assessment, we have assumed 3 scenarios in which all ports are equipped with the same type of bunkering method, thus representing a lower bound (in case of TTS) and an upper bound (in case of PTS). Based on the individual specificities of each port, the solution to fulfil the obligations under PO3 at EU level will likely include a combination of the bunkering methods. The total infrastructure costs are estimated to be between €1.1 and 3 billion relative to the baseline, expressed as present value over 2021-2050.

Table 17: Infrastructure costs of policy option 3 in comparison to the baseline regarding LNG installations for maritime ports, by bunkering method (EU total)

Source: Ricardo et al (2021), impact assessment support study; Notes: For calculating the present value, a discount rate of 4% is assumed.

The costs of OPS installations for maritime ports are also specific to each port and ship type. They are associated to different elements in an OPS installation, including a building/shelter and technical equipment (e.g. switchgear, transformers and frequency converters). Furthermore, cost increases with the power demand requirements such that installations in cruise berths, which require more power, will be more expensive than in ferry berths.

Overall, CAPEX can vary between €1 and €25 million depending on the size and complexity of the installation 84 . The average capital cost per MW of OPS capacity installed was estimated at €1.5 million for cruise ships, €1 million for container ships and €1.2 million, for Ro-Pax vessels. In addition, a ratio of operating and maintenance costs per installed MW per year has been used to estimate OPEX (estimated to be around €4,300 per year and per MW installed) 85 .

Overall, total OPS infrastructure costs are estimated to range between €1.2 billion and €6.5 billion relative to the baseline for the period between 2025 and 2050, expressed as present value over the 2021-2050 horizon.

Table 18: Summary of infrastructure costs of policy options in comparison to the baseline regarding OPS installations for maritime ports

Source: Ricardo et al (2021), impact assessment support study; Notes: For calculating the present value, a discount rate of 4% is assumed.

The deployment requirements for installations of OPS at inland ports are the same as those for maritime ports. That is, OPS installations in inland ports still require the same building/shelter and technical equipment. However, inland vessels are typically much smaller than seagoing ships and therefore the power needs for each OPS installation is much less. Thus, the costs will be lower than for maritime ports. For the purposes of this impact assessment it has been assumed that power deployed in each installation is the same for all ports. Specifically, each installation comprises 12 CEE 400V sockets and 4 Powerlock 400V sockets, which are suitable for cargo vessels and river cruise vessels, respectively. Thus, the CAPEX and OPEX is assumed to be the same for each OPS installation across all inland ports in the EU.

The CAPEX for each installation was taken from the infrastructure costs of OPS deployment in Basel and is equal to €2.5 million, while the OPEX costs have been derived using the same method as for maritime ports, based on the operation costs reported by five EU ports 86 . Overall, total infrastructure costs are estimated to range between €65 million and €412 million relative to the baseline, expressed as present value over 2021-2050. Infrastructure is assumed to be deployed between 2022 and 2025 in the case of PO1, and between 2022 and 2030 in the case of PO2 and PO3.

Table 19: Summary of infrastructure costs of policy options in comparison to the baseline regarding OPS installations for inland ports

Source: Ricardo et al (2021), impact assessment support study; Notes: For calculating the present value, a discount rate of 4% is assumed.

Costs for authorities

In light of the total infrastructure costs to achieve the targets, it is expected that a part of the total investment costs as presented in the previous section will be covered through public support. This is particularly relevant to help port authorities overcome the high capital costs associated with the deployment of OPS and to a lesser extend LNG bunkering. This will be needed until the market is mature enough such that the demand for these technologies/fuels ensures that the business model for deployment is viable. The public funding will comprise a combination of national policy instruments and EU level funding. According to the impact assessment support study, support is expected to amount to 20% for LNG bunkering and 25% for OPS up to 2030 while no support is expected to be required post 2030 87 .

On the basis of the above scenario, the total public investments expected for the period 2021-2030 are provided in the table below. The average annual investments are estimated at € 25.5 million to 190.4 million relative to the baseline scenario, where a number of Member States are already expected to invest in AFI under the current plans.

Table 20: Estimated costs to authorities for shipping, by policy option compared to the baseline

Source: Ricardo et al (2021), impact assessment support study

Measures setting targets for aviation

The main capital costs associated with FEGP installation are evenly split between hardware costs and adapting the power supply network in airports to ensure it extends to all stands 88 . The size of the aircraft determines the system required and in turn the cost. 89 It can be assumed that capital costs scale linearly with the power capacity of the system.

In the survey carried out as part of this study, an approximation of capital costs of €100,000 per stand was provided if electricity provision to the stand is already established for other purposes as well. In the case where airports do not already have electricity provision, the capital costs per stand is around €200,000 90 . These costs are comparable to the costs reported in another study 91 , which ranged from €102,000-300,000.

On this basis, total infrastructure costs are estimated to range between €227 million for PO1 and €949 million for PO2 and PO3. Infrastructure is assumed to be deployed between 2022 and 2025.

Table 21: Infrastructure costs of policy options in comparison to the baseline regarding electricity supply to aircraft

Source: Ricardo et al (2021), impact assessment support study; Notes: For calculating the present value, a discount rate of 4% is assumed.

Costs for authorities

By introducing the mandates in the revision of the directive, the number of airports and the number of stands needed at each airport will increase. Given that large airports are already well equipped, the majority of investment costs will be directed at smaller airports. In the survey, ACI Europe underlined that smaller airports would benefit the most from additional support, especially as it is not easily implemented in many small airports because they frequently 'reconfigure' to accommodate seasonal/annual schedule/aircraft type changes. As such, public support will likely be needed to cover the investment costs of small airports, most likely from national funding. However, it is difficult to determine the proportion of costs covered in such cases, as there is no information available on this. At the same time, it can be expected that the level of public support will increase as a proportion of total costs from PO1 to PO2 and PO3 as the number of infrastructure needed increases, particularly for small airports, where support is needed.

Measures to promote interoperability and user information

Introducing interoperability requirements will lead to varying investment requirements but will also unlock some cost reductions through common technical specifications for AFI. The evaluation support study shows that the provision of relevant standards on an EU level has not introduced any unnecessary costs; on the contrary, since the Directive norms compulsory common technical specifications (while CEN/Cenelec standards are voluntary) it mitigates costs and prevents supplementary costs that otherwise would have been provoked by multiplication of systems 92 . Common technical specifications ensure interoperability between Member States and avoid costs such as redundant infrastructure or underutilised infrastructure due to incompatibility between manufacturers. This observation has been reiterated by stakeholders in the impact assessment consultation process in view of areas where no or limited common technical specifications exist under the current AFID (including communication protocols). Here, standards such as ISO 15188 are nearing completion: whereas the final cost cannot be concretely assessed yet, there is widespread stakeholder support that a final comprehensive approach that is backed by all industry actors will bring much greater benefits than cost.

Mandatory bank card payment functionality will likely be the biggest source of costs for this problem area and will lead to added costs for complying with the requirements of the Directive for an ad hoc payment system to be available at each charging point. 93 As a baseline, it is estimated that 25% of new slow chargers are installed with a bank card payment options (one of Chip + Pin, NFC or QR code) and 50% of new fast chargers are installed with such an option. All policy options allow CPOs to install one of three payment options for ad hoc charging on slow chargers. For the estimates, an equal split was assumed between the three payment methods. The same split was used for fast chargers under PO1. Under PO2, an equal split between Chip + PIN and NFC terminals installations was assumed for fast chargers. PO3 requires that all fast chargers include Chip + PIN terminals.

Single-use QR code displays are expected to be significantly cheaper than the card terminals since they only require a display and software integration. No estimate for the cost of including a QR code system is available. The impact assessment support study estimated €100 in investment costs and €10 annual operating costs for the analysis.

Table 22: Costs associated with ad hoc payment options

Source: Ricardo et al (2021), impact assessment support study

The costs for policy measures proposed for ensuring interoperability and improving the user experience are expected to be limited, especially in comparison to the expected benefits:

·The freedom for the consumers to choose the payment method is likely to represent a small cost derived from necessary back-office/software changes.

·Introduction of physical standards may lead to retrofit costs to adjust existing infrastructure to fit the new technical specifications. The new standards will also require investment into AFI production to fit the new requirements. However, single-standard infrastructure is cheaper to produce than multi-standard infrastructure and will unlock economies of scale and ultimately the additional costs could be almost negligible.

·Back-office/software changes will also be required with the introduction of communication standards for e-mobility. The required adoption of the OCPP standards in PO1 is likely to require less investment since it is already widely adopted. Several responses to the AFID OPC also noted that the use of open standards and protocols such as OCPP will lower costs. Investment in compliance with the OCPI standard (also for PO1) consists of a one-time cost of engineering staff time, but concrete costs are not available. PO2 and PO3 will cover a larger number of communication areas of the EV charging system and may therefore lead to additional costs for CPOs to implement all standards. However, standardisation will also allow AFV and AFI producers to streamline the development and production of the product parts and software involved in communication.

·Most of the measures above also include some work from official standardisation organisations to develop the technical specifications and standards. Therefore, the specifications are not determined as of yet and no associated cost can be estimated for their development (by both the standardisation bodies and the industry and government players participating in those efforts) and implementation (mostly for industry stakeholders).

Introducing requirements that ensure transparency and information availability will lead to some investment requirements for CPOs and EMSPs. Ensuring ad hoc price transparency as required under PO1 will not require significant investments and will be limited to IT, app and website adjustments – the same is true for contract-based price transparency in PO2 and PO3. Installation of physical display at the recharging stations, as proposed under PO2 and PO3, will lead to additional costs for installing such displays at each recharging station. While it was not possible to determine the costs of such displays, it is expected that many charge points already include such a display, and as such for those this would be a matter of software changes to display the price as per the measure.

The requirement for non-discrimination on prices charged to consumers is unlikely to require any additional investments, although it may lead to changes in business models, thus impacting revenues of AFI operators. A requirement for the provision of static and dynamic data by CPOs to Member State NAPs is unlikely to result in significant costs beyond those associated with software changes.

The most significant expenditure with regards to requirements for consumer information is related to roadside indicators on refuelling stations/charging areas along the TEN-T Core and Comprehensive networks. Cost data based on two roadside indicator suppliers’ product catalogues is used to estimate costs for the signs, posts and foundation. An installation cost of €200 per sign is assumed 94 . It is assumed that 50% of recharging and refuelling stations are already marked by indicators within the parking or recharging/refuelling area and will not require additional investment; for the remaining ones, it is assumed that one signpost would be needed. In addition, 25% of stations are assumed to be already marked by roadside indicators; for the remaining ones, two sign posts would be needed (one of each direction in the road).

Table 23: Costs associated with roadside indicators along TEN-T Core and Comprehensive (2030)

Source: Ricardo et al (2021), impact assessment support study. The number of units are based on the number of recharging/refuelling sites expected in PO2 and PO3.

6.1.4.Costs and benefits on vehicle and vessel manufacturers 

For vehicle and vessel manufacturers, all POs will enable to increase the uptake of zero and low-emission vehicles, but for road only as a result of the revised CO2 emission performance standards and other legislation addressing the demand side. Sufficient provision of infrastructure ensures that vehicle manufacturers can realise increasing cost reductions because of growing vehicle fleets. 95 Manufacturers also get new business opportunities with selling mobility services to their customers. 96  

For the broader AFI sector, the new targets but also measures related to interoperability will increase the demand for recharging and refuelling infrastructure and supporting services and thus will bring benefits for the manufacturers of related equipment and other businesses along the value chain (i.e. suppliers of parts/components, software developers, and other support services providers). The measures will provide certainty to the AFI market and, as the measures become more demanding through the policy options, the business opportunities for AFI manufacturers will increase. Furthermore, the increase in the level of investment expected should also help reach the relevant economies of scale for the manufacturers of AFI as well as the service providers, allowing for efficiencies and cost reductions for the relevant businesses.

6.1.5.Impacts on SMEs / professional vehicle users and businesses

It was not possible to quantify these impacts. However, no area was identified in the analysis, where significant and disproportionate cost for SMEs, in comparison to all enterprises, would result from the changes under the different policy options. All policy options increase certainty of long-term market demand in all Member States, though at different degree. This will generally benefit all enterprises that are active in this market. Moreover, provisions for common data provision to the national access points of Member States will create a data basis on which enterprises can develop new market services, providing opportunities for innovative SMEs.

With increasing market ramp-up, project volumes and market competition will grow. It could become more difficult for SMEs to compete with larger enterprises in the market for access to sites, particularly if permitting and concession practice benefit the incumbents. However, those impacts are subject to intervention of EU competition law and planning, permitting and concession policy which are in the responsibility of Member States authorities.

Corporate fleets already today sign responsible for a significant market take-up of zero-emission cars. Such fleet operators will benefit from the revision of the Directive, as provisions ensure secure vehicle use for both short- and long-term distance anywhere in the EU. While there is a benefit under all options, PO2 and PO3 ensure certainty for fleet operators in terms of full coverage of the TEN-T core and comprehensive network and hence full cross-border connectivity. The revision particularly creates long-term certainty for logistic operators that alternatively fuelled trucks and particularly zero-emission trucks will be able to recharge and refuel when they go long-distance on the TEN-T network, supporting the market take up of such vehicles.

6.1.6.Functioning of the internal market and competition

Impacts have been qualitatively assessed. All policy options are expected to have a positive impact on the functioning of the internal market, both through increasing the even spread of the infrastructure and through simplifying its use throughout the Union, including through better ad-hoc payment services. All options provide for a level playing field. PO2 and PO3 will lead to subsequent standardisation of the interoperable communication exchange between the electric vehicle, the charge point and the backend of the charge-point, as well as with the electricity grid, creating a better level-playing field in line with the increasing maturity of the market. But these two options also foresee better equipment of ports and airports with relevant alternative fuels infrastructure and powering units, yielding additional benefits of a better functioning of the internal market in that sector.

All policy options lead to more uniform provisions for customer information that will enable the customer to better understand and compare available services and their cost at charging points of different operators. This will facilitate competition among operators and service providers, facilitated by improved requirements for data sharing through the national access points. Again, PO2 and PO3 excel in terms of their impact on market, as the requirement to share both certain static and dynamic data will enable better customer information and hence greater competition.

6.1.7.Impact on innovation and industry competitiveness

All the POs are considered having a positive impact on innovation, particularly in the area of innovative user services, related business models but also in the development of more innovative recharging and refuelling technologies. Vehicle innovation such as higher battery power, more efficient fuel cells or higher recharging and refuelling capability will remain key drivers for innovation in recharging and refuelling infrastructure technology, whereas the impact of the revision of this Directive is particularly expected in the area of service innovation and new business models. Extending the rollout of recharging and refuelling infrastructure throughout the Union coupled with the requirement to share static and dynamic data as included under PO2 and PO3 will particularly enable better innovation of use services at greater scale, enabling quicker spread of innovation in the EU.

Competitiveness of enterprises active in installing and operating recharging and refuelling infrastructure will increase under all policy options, as higher demand for recharging and refuelling practice as triggered by the CO2 emission performance standards for cars and vans, but also for heavy-duty vehicles, will lead to better profitability of operations, complemented by decreasing cost of technologies. Policy options affects also the competitiveness of the automotive sector, because the provision of sufficient infrastructure has an impact on the market uptake of zero-emission vehicles which again influences the competitiveness of the automotive sector.

6.2.Social impacts

6.2.1.Impacts on households and consumers 

Impacts on consumers will largely come from common physical and communication standards that will ease the use of infrastructure and help new services to develop to the benefit of the consumers. Benefits will come from improved information on infrastructure adding certainty about location, accessibility and use (pricing) conditions as well as price transparency that will reducing informational cost of households and allow consumers to take informed choices and reduce costs. Introducing requirements for bank card payment will likely increase the investment cost of some charge points, in some case considerably (up to around €800 per charger for a PIN terminal). This could negatively impact the costs of mobility and mobility services for consumers, as some of these costs could be passed to consumers. However, these costs are balanced by bringing positive impacts as bank card payments will increase price transparency, ease the use of zero-emission vehicles, have positive impacts on the level of demand and on competition on the AFI market and thus counterbalancing any possible additional costs. Moreover, the further standardisation of infrastructure and infrastructure use services and the resulting possibilities for smart recharging services will benefit consumers who are in a position to offer their vehicle to support such smart recharging services and receive remuneration in return. Moreover, the Impact Assessment for the CO2 standards for cars and vans demonstrates overall benefits for consumers and society, resulting particularly from fuel cost savings and lower maintenance cost. Here, again, the revision of AFID helps ensure that those benefits for consumers can be fully accrued.

Costs impacts for consumers from a wide availability of AFI is likely to be indirect. More infrastructure will increase competition and will likely reduce charging and refuelling costs. It will equally enable more zero- and low-emission vehicles to come into the market driving down the vehicle costs.

6.2.2.Impacts on employment and social skills 

The impact of the targets on employment is expected to be positive, although it has not been possible to quantify these. By increasing the demand for new infrastructure and supporting services, the new measures can lead to the creation of new jobs in construction, manufacturing, electricity, among other sectors. The impact is expected to increase with the level of ambition of the targets through the policy options. Those jobs are highly location-specific and cannot easily be relocated outside the EU, meaning a full benefit to the European employment market.

The measures introduced to promote interoperability will benefit the AFV and AFI markets and will require additional investments. This will have a small positive impact on employment in the industry. The introduction of standards may adversely impact some producers that do not currently comply with such standards; however, this is likely to be negligible.

6.2.3.Impact on persons with disabilities and those with reduced mobility 

The qualitative analysis of this impact area concludes that while a lack of accessibility for persons with disabilities would negatively impact their mobility there is currently no evidence of such an issue. This is evidenced by the fact that none of the representatives of those person groups indicated any concrete problems with the existing infrastructure in the consultations.

6.2.4.Impact on public health 

Enabling changes in the use of fuels are likely to result in reduced air pollutant emissions and subsequent positive impacts on public health. For road transport, NOx and PM emissions are projected to decrease by 7-8% relative to the baseline in 2030 and by over 90% by 2050. These decreases are mainly driven by the higher uptake of zero-emission vehicles relative to the baseline, enabled by the deployment of infrastructure, but also by other policies part of the “Fit for 55” package and other forthcoming initiatives as explained in section 6.3. The policy options would results in €1.8 billion savings in the external costs of air pollution relative to the baseline in 2030, €9.6 billion in 2040 and €10.3 billion in 2050. Expressed as present value over the 2021-2050 period, the total savings amount to €75 billion relative to the baseline.

Table 24: External costs savings on air pollution from road transport

Source: Ricardo et al (2021), impact assessment support study, PRIMES-TREMOVE model results (E3Modelling)

The introduction of electricity as a power source at ports (inland and maritime via OPS) and airports will ensure that air pollutant emissions from stationary vessels and aircraft will be minimal. Additionally, the provision of LNG bunkering facilities at maritime ports will enable the increased refuelling with decarbonised gas (i.e. bio-LNG and e-gas), which have positive air pollutant reduction benefits compared to their diesel and heavy fuel oil counterparts. Finally, at airport level, the introduction of such measure will bring further positive impacts, from the reduction of the noise emitted on the ground, as it is an important source of noise for those who live in the vicinity of the airport, for passengers and airport workers.

6.3.Environmental impacts

The analysis of environmental impacts covers the following impact categories arising from measures identified under each policy option:

Environmental benefits represent the key rationale for taking action towards the faster and broader deployment of alternative fuels infrastructure. The PRIMES-TREMOVE model has been used to quantify the impacts of selected measures/options on CO2 emissions and air quality, in particular those relating to road transport. Environmental impacts from interoperability and consumer information can’t be quantified and are not further assessed.

6.3.1.CO2 emission reduction

As explained in section 6.1.1, investments in the quantity and quality of infrastructure will not directly lead to the uptake of alternatively fuelled vehicles, which are determined by other policies like for example the CO2 emission performance standards. However, only if sufficient and interoperable infrastructure is available that provides minimum services to consumers, it can be expected that the vehicles as considered necessary to achieve the EU’s Climate Target Plan objective will make it into the market.

CO2 emissions are capped by the Emissions Trading System. Considering its assumed extension to the road transport sector (and the maritime sector) this would also set the impulse for the road transport sector that the required emissions reductions are delivered according to the ETS cap - even if the infrastructure does not deliver and the CO2 emission performance standards for vehicles are not met. For example, in the foreseen case of a separate ETS for road transport this would result in a higher price of allowances to deliver the same emissions reductions and higher reduction in the road traffic if the uptake of zero emission vehicles is not possible.

Road Transport

On tank to wheel basis, the CO2 emissions from road transport 97 are projected to decrease by 5.3% in 2030 in all policy options relative to the baseline. The reduction in emissions relative to the baseline would be much higher post 2030 (65.1% decrease in 2040 and 99% decrease in 2050), due to the higher uptake of zero-emission vehicles and renewable and low carbon fuels in road freight transport. It should be recalled that all policy options already include all other policy initiatives part of the ”Fit for 55” package and other initiatives (e.g. CO2 emissions standards for vehicles, carbon pricing, improvements in the efficiency of the transport system, etc.) and these contribute to the CO2 emissions reductions from road transport.

Table 25: Tank to wheel CO2 emissions from road transport in the policy options and the baseline

Source: Ricardo et al (2021), impact assessment support study, PRIMES-TREMOVE model results (E3Modelling); Note: excluding powered two-wheelers.

On well to wheel basis 98 , CO2 emissions from road transport would go down by 19.3% in the baseline scenario by 2030, by 35.6% in 2040 and by 44.3% by 2050 relative to 2015. In all policy options, higher emissions reductions are projected (23.9% decrease in 2030, 75.5% in 2040 and 98% by 2050 relative to 2015) due to the higher uptake of zero-emission vehicles, but also due to the power generation sector that is set to achieve decarbonisation by 2050. The power generation mix plays an important role in this time perspective considering the large scale electrification of road transport.

The reduction in external costs of CO2 emissions is projected at €445 billion relative to the baseline over the 2021-2050 period, expressed as present value. These have been monetised using the Handbook on the external costs of transport 99 .

Waterborne Transport

For OPS (both maritime and inland waterway), the CO2 emissions reduction only applies when the vessel is at berth. While OPS reduces onboard emissions at berth, consideration also needs to be given to the emissions associated with power generation as such, as similar to road transport the source of this electricity will have an influence on the overall emissions reductions achieved. This is particularly relevant for 2030 because, as explained above, the power generation sector is set to achieve decarbonisation by 2050. The emissions reductions are driven by the replacement of marine gasoil with electricity supply for auxiliary engines and is directly correlated with the number of vessels that are capable of using OPS. Hence, PO3 shows the highest cumulative reduction as this measure serves all maritime ports with OPS such that all ships can use electricity when at berth. The greatest reduction in emissions is expected to be derived from container ships, which emit the highest volume of CO2 at berth. For the period up to 2050, the cumulative reduction of CO2 emissions on well to wheel basis is between 48.4 million tonnes of CO2 in PO1 and 83 million tonnes of CO2 in PO3, which corresponds to 1.5 to 2.5% of total maritime emissions during that period. We note, however, that in the context of total EU maritime CO2 emissions the impact of OPS is limited, even for the most ambitious policy option covering all EU maritime ports.

Table 26: CO2 emissions impact of policy options concerning OPS for maritime in million tonnes, on well to wake basis

Source: Ricardo et al (2021), impact assessment support study

Given the nature of OPS, the environmental impacts for inland waterway can be considered to be of the same nature as maritime. Specifically, CO2 emissions reduction occurring at berth, with the extent of the reduction deepening on the energy mix in electricity production.  It is however worth noting the total EU CO2 emissions generated by inland navigation are significantly lower than those of the maritime sector due to the smaller vessels and much lower number of vessels. Given the limited information available on the current environmental performance of inland navigation, in particular when vessels are at berth, it has not been possible to calculate an estimated CO2 reduction. Nevertheless, it is expected that PO2 and PO3 would have the greatest impact as each of the policy options have the greatest AFI deployment, covering all TEN-T Core and Comprehensive ports.

Unlike OPS, the provisions for LNG bunkering will impact the CO2 emissions in ports when vessels are at berth and when vessels are in operation, though the exact extent is subject to discussion following continued assessments of fossil LNG emissions. However, the impact assessment accompanying the FuelEU maritime initiative has shown that fossil LNG will be gradually replaced with liquified biomethane (or bio-LNG) from 2030 onwards and renewable low-carbon synthetic e-gas from 2035 onwards. By 2050, renewable and low carbon fuels are projected to represent the large majority of gaseous fuels used in maritime. Such decarbonised gases (bio-LNG and e-gas) use the same infrastructure as the LNG and are projected to represent 21% of the fuel used in international shipping by 2050, according to the impact assessment accompanying the FuelEU maritime initiative.

Aviation

The use of FEGP in airports allows the aircrafts engines and auxiliary power unit (APU) located in the tail to be switched off once the aircraft is on stand. FEGP provides an alternative to the traditional jet fuel used to run APUs, as it runs on grid electricity and thus has a much lower carbon intensity. The exact fuel burn and environmental impact of running APUs are dependent on various factors such as aircraft type, weight and turnaround times. Furthermore, unlike aircraft main engines, APUs are not certificated for emissions, and the manufacturers generally consider information on APU emissions rates as proprietary. As a result, little data are publicly available to serve as a basis for calculating APU emissions and the extent of environmental benefits that FEGP brings is difficult to quantify and we can only provide a general assessment.

In the context of total aviation emissions, the environmental impact of FEGP is limited because APUs account for a small proportion of CO2 emissions in aviation (approximately 1% or 1.4 Mt of CO2 in 2018). Consideration needs to be given to the emissions associated with power generation and as such, the source of this electricity will have an influence on the overall emissions reduction achieved in the 2030 perspective. In particular, if renewable energy is used, near‐zero emissions of CO2 and other air pollutants can be achieved when the aircraft is on stand, representing a 1% reduction in total aviation CO2 emissions.

6.3.2.Air pollutants emission reduction 

Road Transport

By 2030, driven by the uptake of zero-emission vehicles enabled by the deployment of infrastructure, NOx and PM emissions from road transport 100 are projected to decrease by 6.6% and 7.6%, respectively, relative to the baseline. The reductions in air pollution emissions relative to the baseline are much higher post-2030, due to the larger penetration of the zero emission vehicles for both LDVs and HDVs (i.e. 60.5% decrease for NOx and 62.3% decrease for PM emissions in 2040 and over 90% decrease in 2050 for both NOx and PM emissions). Similarly to CO2 emissions, it should be recalled that all policy options already include all other policy initiatives part of the ”Fit for 55” package and other initiatives, and these contribute to the air pollution emissions reductions from road transport.

As explained in section 6.3.1, CO2 emissions are capped by the Emissions Trading System. Considering its assumed extension to the road transport sector (and the maritime sector) this would also set the impulse for the road transport sector that the required emissions reductions are delivered according to the ETS cap - even if the infrastructure does not deliver and the CO2 emission performance standards for vehicles are not met. For example, in the foreseen case of a separate ETS for road transport this would result in a higher price of allowances to deliver the same emissions reductions and higher reduction in the road traffic if the uptake of zero emission vehicles is not possible. The higher price of allowances for road transport would also result in lower air pollution emissions relative to the baseline, driven by the reduction in the road traffic and the energy use in road transport.

Table 27: Air pollutant emissions from road transport in the policy options and the baseline

Source: Ricardo et al (2021), impact assessment support study, PRIMES-TREMOVE model results (E3Modelling); Note: excluding powered two-wheelers.

Waterborne Transport

The reduction of air pollutants and improvement on local air quality is the main environmental benefit for both OPS and LNG as they both offer substantial reductions in air pollutants. Given that air quality is considered the top priority for ports 101 this environmental impact represents a significant benefit to those in the maritime and inland waterway sectors. The uptake of LNG will impact both local air quality and air pollutants produced when the vessel is in operation, while OPS has a much more localised impact. As vessels spend less time at berth than navigating, understandably the volume of air pollutants at berth is limited when compared to the total emissions of a ship. However, unlike when navigating, the emissions of a vessel at berth have a direct impact at port-cities (as ports are often or within the cities) and the coastal areas. As these cities are often densely populated, the impact of emissions at berth is therefore disproportionately affecting these areas.

Electricity generation is typically located some distance from densely populated areas, whereas dockside shipping emissions will often occur close to city centres as a consequence of a port’s typical location. As with CO2 emissions, consideration needs to be given to the emissions associated with power generation. While coal‐fired power plants emit more CO2, they have lower emissions of nitrogen oxides, particulate matter and sulphur oxides, compared with those associated with burning marine diesel fuel with a 0.1 sulphur content. Hence, all policy options supporting OPS are expected to have a positive impact on air pollutants, with the effect increasing as the policy options become more ambitious and the frequency of use of OPS from vessels more widespread.

The uptake of LNG in maritime is also expected to result in a reduction on air pollutants under PO3 as a result of the uptake of LNG vessels. LNG contains little sulphur and LNG engines are tuned to emit low NOx emissions, which makes LNG an attractive fuel for ships that operate in Emission Control Areas (ECAs), where ships must comply with more stringent air quality standards. This is similar for decarbonised gases (bio-LNG and e-gas).

Aviation

An additional benefit of using FEGP in replacement of jet fuel powering APUs is the reduction of air pollutants at ground level. The main air pollutants considered here are NOx, HC, CO and PM10. As noted previously, consideration needs to be given to the emissions associated with power generation, although this is a minor issue as power generation occurs at some distance from airports. Nevertheless, it is expected that lowers emissions of air pollutants compared to the burning of jet fuel in APUs. As such, the measure will offer benefits across all air pollutants and the effects will increase the policy options become more ambitious.

As already highlighted in the section on GHG reduction, the extent of the reduction of air pollutants is difficult to assess on the basis that the exact fuel burn and environmental impact of running APUs are not well documented and dependent on various factors such as aircraft type, weight and turnaround times. Nevertheless, at Zurich Airport, it was estimated that FEGP and PCA provision at all stands would offer a reduction of NOx pollutants while stationary by 96% of APU emissions 102 .

7.How do the options compare?

7.1.Effectiveness

The effectiveness of the options is compared against the general and specific policy objectives as described in section 4. For the overview, Table 28 presents the objectives and the indicators that have been developed to monitor the level of achievement of the objectives. The effectiveness of each policy option in achieving the objectives is presented in detail in annex 8, using the indicators described below.

Table 28: Linking of policy objectives to indicators

Concerning SO1, PO1 shows good effectiveness as it links emerging road vehicle fleet demand to overall infrastructure deployment and also ensures sufficient infrastructure to enable full circulation of heavy-duty vehicles. It is, however, less effective with regard to LDV recharging infrastructure on the TEN-T network as it leaves public authorities and operators with greater flexibility for the allocation of infrastructure, by not setting specific requirements for LDV recharging infrastructure on the TEN-T core and comprehensive network. This could impact, however, the overall effectiveness of the policy to ensure the transition to zero-emission mobility, as insufficient provision of public accessible recharging points could remain in the TEN-T, which can limit full connectivity.

PO1 is also least effective in view of OPS installation in ports, as it only addresses TEN-T core ports. PO2 is more effective than PO1, as it addresses TEN-T LDV infrastructure, recharging infrastructure for HDV in urban nodes and OPS in TEN-T core and comprehensive ports. PO3 is most effective, as it provides recharging points in all larger petrol stations for LDV and HDV. It also ensures greater equipment of ports with alternative fuels infrastructure than PO2.

PO2 and PO3 are more effective compared to PO1, when it comes to SO2 and SO3. They include a greater level of harmonisation on payment options, physical and communication protocols and interfaces standards and rights of consumers while charging. Those options also better substantiate provisions for adequate consumer information and payment options, notably through making available full static and dynamic user information and better harmonised payment options. PO3 can be considered slightly more effective compared to PO2, as it includes a more comprehensive approach to physical signposting of recharging and refuelling infrastructure.

Annex 8 provides a detailed and quantitative overview on the effectiveness of the policy options in relation to the specific objectives.

7.2.Efficiency

Efficiency concerns "the extent to which objectives can be achieved for a given level of resource/at least cost". The combined measures under the three POs have economic, social and environmental impacts. The major costs of the policy options come in the form of capital and operation costs for the installation and maintenance of public accessible recharging and refuelling infrastructure and measures related to interoperability and user information. A summary of these costs is provided in Table 29 .

Table 29: Summary of capital and operation costs related to infrastructure – present value for 2021-2050 compared to the baseline (in €billion)