# C_2013271EN.01011101.xml

| 19.9.2013 | EN | Official Journal of the European Union | C 271/111 |
| --- | --- | --- | --- |

19.9.2013

EN

Official Journal of the European Union

C 271/111

---

Opinion of the European Economic and Social Committee on the ‘Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions — Clean Power for Transport: a European alternative fuels strategy’

COM(2013) 17 final

and on the ‘Proposal for a directive of the European Parliament and the Council on the deployment of alternative fuels infrastructure’

COM(2013) 18 final — 2013/12 (COD)

2013/C 271/21

Rapporteur: Mr BACK

Mr BACK

On 24 January 2013, the European Commission decided to consult the European Economic and Social Committee, under Article 304 of the Treaty on the Functioning of the European Union, on the

Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions - Clean Power for Transport: A European alternative fuels strategy

Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions - Clean Power for Transport: A European alternative fuels strategy

COM(2013) 17 final.

On 5 February and 8 February 2013, the European Parliament and the Council respectively decided to consult the European Economic and Social Committee, under Article 91 and 304 of the Treaty on the Functioning of the European Union, on the

Proposal for a Directive of the European Parliament and the Council on the deployment of alternative fuels infrastructure

Proposal for a Directive of the European Parliament and the Council on the deployment of alternative fuels infrastructure

COM(2013) 18 final – 2013/12 (COD).

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 30 April 2013.

At its 490th plenary session, held on 22 and 23 May 2013 (meeting of 22 May), the European Economic and Social Committee adopted the following opinion by 147 votes to 1 with 5 abstentions.

1.   Conclusions and recommendations

Conclusions and recommendations

| 1.1 | The EESC welcomes the Clean Power for Transport Package (1) and its aim to create conditions for mass market deployment of clean propulsion by clean power sources. |
| --- | --- |

1.1

The EESC welcomes the Clean Power for Transport Package (1) and its aim to create conditions for mass market deployment of clean propulsion by clean power sources.

1

| 1.2 | The EESC approves the approach of market development and a minimum coverage of charging/refilling infrastructure with common standards to create user confidence and ensure cross border mobility. |
| --- | --- |

1.2

The EESC approves the approach of market development and a minimum coverage of charging/refilling infrastructure with common standards to create user confidence and ensure cross border mobility.

| 1.3 | The EESC also welcomes the proposals' focus on consumer information and consumer confidence to help develop the mass market which is a vital prerequisite for affordable vehicles with alternative propulsion systems. |
| --- | --- |

1.3

The EESC also welcomes the proposals' focus on consumer information and consumer confidence to help develop the mass market which is a vital prerequisite for affordable vehicles with alternative propulsion systems.

| 1.4 | The EESC welcomes the contribution to the creation of growth and jobs that can be expected to follow from the new market opportunities and improved competitiveness of European industry due to development of alternative fuels and their infrastructure. |
| --- | --- |

1.4

The EESC welcomes the contribution to the creation of growth and jobs that can be expected to follow from the new market opportunities and improved competitiveness of European industry due to development of alternative fuels and their infrastructure.

| 1.5 | Implementation of a strategy for clean fuels should not be limited to a number of mature fuels but also address long term issues regarding other clean power sources, the rapid and broad development in this sector and the need to encourage innovation and market introduction. |
| --- | --- |

1.5

Implementation of a strategy for clean fuels should not be limited to a number of mature fuels but also address long term issues regarding other clean power sources, the rapid and broad development in this sector and the need to encourage innovation and market introduction.

| 1.6 | The EESC refers to the issues raised in its opinion on Indirect land-use change (ILUC)/Biofuels (TEN/502 - CES2363-2012), and in particular points 1.9 - 1.12, that demonstrate the complexity and long term character of these issues and the need for constant reassessment. |
| --- | --- |

1.6

The EESC refers to the issues raised in its opinion on Indirect land-use change (ILUC)/Biofuels (TEN/502 - CES2363-2012), and in particular points 1.9 - 1.12, that demonstrate the complexity and long term character of these issues and the need for constant reassessment.

| 1.7 | The EESC therefore thinks that the long term strategic aims of the communication should be better followed up in the proposal. For instance, the national policy framework for clean fuels and their infrastructure, which Member States are to create under the proposal, should include all those energy sources, such as biofuels, that are seen as important in the communication. |
| --- | --- |

1.7

The EESC therefore thinks that the long term strategic aims of the communication should be better followed up in the proposal. For instance, the national policy framework for clean fuels and their infrastructure, which Member States are to create under the proposal, should include all those energy sources, such as biofuels, that are seen as important in the communication.

| 1.8 | The proposal should therefore define an economically and environmentally optimised fuel mix at EU level where coordinated national policies could enhance development and deployment. Articles 3, 8 and 10 as well as Annex I of the proposal should be reviewed in this sense. |
| --- | --- |

1.8

The proposal should therefore define an economically and environmentally optimised fuel mix at EU level where coordinated national policies could enhance development and deployment. Articles 3, 8 and 10 as well as Annex I of the proposal should be reviewed in this sense.

| 1.9 | The EESC doubts that public loading infrastructure for electric vehicles can be provided without public funding, at least during the initial phase, until the number of electric vehicles has attained a level where charging fees may reasonably finance the investment. |
| --- | --- |

1.9

The EESC doubts that public loading infrastructure for electric vehicles can be provided without public funding, at least during the initial phase, until the number of electric vehicles has attained a level where charging fees may reasonably finance the investment.

| 1.10 | The EESC underscores the need to ensure a smooth and viable transition to a modified energy mix, and the importance of bearing in mind the potential of improving the environmental record of fossil fuels. |
| --- | --- |

1.10

The EESC underscores the need to ensure a smooth and viable transition to a modified energy mix, and the importance of bearing in mind the potential of improving the environmental record of fossil fuels.

| 1.11 | The EESC draws attention to the danger of blocking the development of new and more viable technical solutions for different modes and user groups. One example of this danger is the strong commitment to LNG for shipping although new and cheaper alternatives are being developed. Likewise, new user-oriented power solutions are appearing, for instance, for lorries, buses and two-wheeled vehicles. |
| --- | --- |

1.11

The EESC draws attention to the danger of blocking the development of new and more viable technical solutions for different modes and user groups. One example of this danger is the strong commitment to LNG for shipping although new and cheaper alternatives are being developed. Likewise, new user-oriented power solutions are appearing, for instance, for lorries, buses and two-wheeled vehicles.

2.   Introduction: policy context and presentation of the communication and the proposal

Introduction: policy context and presentation of the communication and the proposal

| 2.1 | In its flagship initiatives ‘Resource efficient Europe’ and ‘Innovation Union’, the Europe 2020 strategy for a smart sustainable and inclusive growth addresses climate change, energy and resources scarcity, the need to enhance competitiveness and improve energy security by improved resource and energy efficiency. In the field of transport, the 2011 White Paper on transport policy calls for transport's dependence on oil to be broken and sets a target of a 60 % reduction of greenhouse gas emissions stemming from transport by 2050. In its ten goals for a competitive and resource efficient transport system, the White Paper refers to developing and deploying new and sustainable fuels and propulsion systems. The list of initiatives in the White Paper addresses those aims under Initiative 24, ‘A technology Roadmap’, and Initiative 26 ‘A regulatory framework for innovative transport’. The communication and the proposal for a directive address these issues, entirely or in part. |
| --- | --- |

2.1

In its flagship initiatives ‘Resource efficient Europe’ and ‘Innovation Union’, the Europe 2020 strategy for a smart sustainable and inclusive growth addresses climate change, energy and resources scarcity, the need to enhance competitiveness and improve energy security by improved resource and energy efficiency. In the field of transport, the 2011 White Paper on transport policy calls for transport's dependence on oil to be broken and sets a target of a 60 % reduction of greenhouse gas emissions stemming from transport by 2050. In its ten goals for a competitive and resource efficient transport system, the White Paper refers to developing and deploying new and sustainable fuels and propulsion systems. The list of initiatives in the White Paper addresses those aims under Initiative 24, ‘A technology Roadmap’, and Initiative 26 ‘A regulatory framework for innovative transport’. The communication and the proposal for a directive address these issues, entirely or in part.

| 2.2 | In a number of opinions, the EESC has called for an initiative by the Commission to promote alternative fuels and the related infrastructure. They include the following:






  — | The opinion on the transport policy White Paper (2), points 4.19 and 4.20, where the EESC took a favourable attitude towards the development and deployment of cleaner and more energy efficient propulsion systems and supported the Green Cars Initiative and the 2010 strategy for the development of clean vehicles. In point 4.30 the EESC took favourable note of the attention given to the deployment of electric vehicles and the necessary charging infrastructure, referring to its opinion on Toward the wider uptake of electric vehicles (3) where the EESC expressed strong support for measures with this objective in order to reduce greenhouse gas emissions and dependency on imports of oil. The importance of smart technology was also indicated in enabling the use of electric vehicles as energy providers at peak hours. |
| --- | --- | --- |

2.2

In a number of opinions, the EESC has called for an initiative by the Commission to promote alternative fuels and the related infrastructure. They include the following:

—

The opinion on the transport policy White Paper (2), points 4.19 and 4.20, where the EESC took a favourable attitude towards the development and deployment of cleaner and more energy efficient propulsion systems and supported the Green Cars Initiative and the 2010 strategy for the development of clean vehicles. In point 4.30 the EESC took favourable note of the attention given to the deployment of electric vehicles and the necessary charging infrastructure, referring to its opinion on Toward the wider uptake of electric vehicles (3) where the EESC expressed strong support for measures with this objective in order to reduce greenhouse gas emissions and dependency on imports of oil. The importance of smart technology was also indicated in enabling the use of electric vehicles as energy providers at peak hours.

2

3

| — | The opinion on the sulphur content of marine fuels (4) where the EESC welcomed the Commission's intention to improve compliance conditions through a ‘toolbox’, including technology measures such as alternative fuels (LNG) and shore-side electricity, through investments by both the private and public sectors. |
| --- | --- |

—

The opinion on the sulphur content of marine fuels (4) where the EESC welcomed the Commission's intention to improve compliance conditions through a ‘toolbox’, including technology measures such as alternative fuels (LNG) and shore-side electricity, through investments by both the private and public sectors.

4

| — | The opinion on the proposal for new guidelines for the Trans-European Transport Network (5). The EESC argued that the requirement on the availability of alternative clean fuels needed to be strengthened, as it would be crucial to link the TEN-T Guidelines to the forthcoming alternative transport fuels strategy. |
| --- | --- |

—

The opinion on the proposal for new guidelines for the Trans-European Transport Network (5). The EESC argued that the requirement on the availability of alternative clean fuels needed to be strengthened, as it would be crucial to link the TEN-T Guidelines to the forthcoming alternative transport fuels strategy.

5

| 2.3 | The package presented by the Commission consists of the following elements:






  — | The communication provides an overview of the policy background and aims together with an overview of the current main fuel alternatives, and sets out the priority fields for further EU action. |
| --- | --- | --- |

2.3

The package presented by the Commission consists of the following elements:

—

The communication provides an overview of the policy background and aims together with an overview of the current main fuel alternatives, and sets out the priority fields for further EU action.

| — | The proposal aims to ensure the build-up of a minimum alternative fuel infrastructure and the implementation of common technical specifications for this infrastructure in the EU to ensure EU wide mobility and economies of scale. |
| --- | --- |

—

The proposal aims to ensure the build-up of a minimum alternative fuel infrastructure and the implementation of common technical specifications for this infrastructure in the EU to ensure EU wide mobility and economies of scale.

| 2.4 | The fuels covered by the communication are natural gas including biomethane (LNG, CNG, GTL), electricity, biofuels (liquid) and hydrogen, with different characteristics and different uses. The communication sets out a strategy for all modes of transport. The strategy seeks to establish a long term framework to guide technological development and investment in the deployment of alternative fuels with the aim of reducing oil dependence, improving fuel security and reducing emissions. Actions foreseen by the strategy concern four areas:






  — | Alternative fuels infrastructure should be built with sufficient density to create certainty about utilisation possibilities and ensure mobility throughout Europe. This will make possible more widespread use of vehicles and ships using alternative fuels, with a focus on electricity, hydrogen, CNG and LNG. The EUR 10 billion cost calculated for building the necessary infrastructure will be paid back with the market take-up. Direct use of public funding can be avoided if use is made of tools such as building permission requirements, concessions, procurement regulations, access and charging regulations and non-financial incentives. |
| --- | --- | --- |

2.4

The fuels covered by the communication are natural gas including biomethane (LNG, CNG, GTL), electricity, biofuels (liquid) and hydrogen, with different characteristics and different uses. The communication sets out a strategy for all modes of transport. The strategy seeks to establish a long term framework to guide technological development and investment in the deployment of alternative fuels with the aim of reducing oil dependence, improving fuel security and reducing emissions. Actions foreseen by the strategy concern four areas:

—

Alternative fuels infrastructure should be built with sufficient density to create certainty about utilisation possibilities and ensure mobility throughout Europe. This will make possible more widespread use of vehicles and ships using alternative fuels, with a focus on electricity, hydrogen, CNG and LNG. The EUR 10 billion cost calculated for building the necessary infrastructure will be paid back with the market take-up. Direct use of public funding can be avoided if use is made of tools such as building permission requirements, concessions, procurement regulations, access and charging regulations and non-financial incentives.

| — | Common specifications are needed, most urgently for the interface between electric vehicles and the recharging points, but also for hydrogen, CNG and LNG. |
| --- | --- |

—

Common specifications are needed, most urgently for the interface between electric vehicles and the recharging points, but also for hydrogen, CNG and LNG.

| — | Consumer acceptance is vital. The means to obtain consumer acceptance span from non-financial measures, such as privileged access for electric vehicles and information campaigns, to financial incentives. |
| --- | --- |

—

Consumer acceptance is vital. The means to obtain consumer acceptance span from non-financial measures, such as privileged access for electric vehicles and information campaigns, to financial incentives.

| — | Addressing the technological development as follows: (a) within the framework of the Horizon 2020 programme, funding will be made available for research, demonstration or market-oriented projects for alternative fuels in all modes; (b) roadmaps will be developed under the Strategic Transport Technology Plan (COM(2012) 501 final); (c) private public partnerships should be further developed and partnerships such as the Smart Cities and Communities' initiative (COM(2012) 4701 final) should be used; (d) specific projects include the European Industry Bioenergy Initiative under the Strategic Energy Technology Plan, and new research facilities for Electric Vehicle/Smart Grid interoperability are planned in the EU Joint Research Centre. |
| --- | --- |

—

Addressing the technological development as follows: (a) within the framework of the Horizon 2020 programme, funding will be made available for research, demonstration or market-oriented projects for alternative fuels in all modes; (b) roadmaps will be developed under the Strategic Transport Technology Plan (COM(2012) 501 final); (c) private public partnerships should be further developed and partnerships such as the Smart Cities and Communities' initiative (COM(2012) 4701 final) should be used; (d) specific projects include the European Industry Bioenergy Initiative under the Strategic Energy Technology Plan, and new research facilities for Electric Vehicle/Smart Grid interoperability are planned in the EU Joint Research Centre.

| 2.5 | The proposal focuses on alternative fuels infrastructure, developing common technical specifications and consumer information. However, it also obliges the Member States to adopt a national policy framework for the market development of alternative fuels and their infrastructure. That framework is to include an information requirement, policy and regulatory measures to support infrastructure development, support measures, research and target setting and cooperation with other Member States: a) to ensure international coherence in the infrastructure; b) to make journeys across the entire EU possible. |
| --- | --- |

2.5

The proposal focuses on alternative fuels infrastructure, developing common technical specifications and consumer information. However, it also obliges the Member States to adopt a national policy framework for the market development of alternative fuels and their infrastructure. That framework is to include an information requirement, policy and regulatory measures to support infrastructure development, support measures, research and target setting and cooperation with other Member States: a) to ensure international coherence in the infrastructure; b) to make journeys across the entire EU possible.

| 2.6 | At the same time as the communication and the proposal, the Commission also made public the Working Document setting out an action plan towards a comprehensive EU framework on LNG for shipping. The Commission, in cooperation with EMSA, is planning to propose, by the end of 2014, a comprehensive set of rules, standards and guidelines for LNG provision, bunkering and use in shipping. |
| --- | --- |

2.6

At the same time as the communication and the proposal, the Commission also made public the Working Document setting out an action plan towards a comprehensive EU framework on LNG for shipping. The Commission, in cooperation with EMSA, is planning to propose, by the end of 2014, a comprehensive set of rules, standards and guidelines for LNG provision, bunkering and use in shipping.

3.   General comments

General comments

| 3.1 | As pointed out above, the EESC has on a number of occasions addressed the questions of the need for alternative fuels for transport and the urgency in developing an adequate infrastructure for a credible refuelling or recharging system, that supports cross-border mobility. It has also stressed the need to launch further measures to promote the market uptake of electric vehicles and to grant sufficient autonomy to Member States in implementing this policy. The EESC therefore welcomes this initiative. |
| --- | --- |

3.1

As pointed out above, the EESC has on a number of occasions addressed the questions of the need for alternative fuels for transport and the urgency in developing an adequate infrastructure for a credible refuelling or recharging system, that supports cross-border mobility. It has also stressed the need to launch further measures to promote the market uptake of electric vehicles and to grant sufficient autonomy to Member States in implementing this policy. The EESC therefore welcomes this initiative.

| 3.2 | The EESC supports the approach outlined in the communication and implemented in the proposal, to stipulate an obligation for Member States to adopt national policy frameworks for the market development of alternative fuels that fulfil a certain number of minimum requirements, subject to a notification and evaluation system managed by the Commission. |
| --- | --- |

3.2

The EESC supports the approach outlined in the communication and implemented in the proposal, to stipulate an obligation for Member States to adopt national policy frameworks for the market development of alternative fuels that fulfil a certain number of minimum requirements, subject to a notification and evaluation system managed by the Commission.

| 3.3 | In particular, the EESC approves the focus on refuelling/recharging infrastructure as a means to trigger market take-off for vehicles and ships using alternative fuels. It seems to be generally agreed that such measures are important for creating confidence in alternative fuels on the part of users which is an essential element for the market to take off. |
| --- | --- |

3.3

In particular, the EESC approves the focus on refuelling/recharging infrastructure as a means to trigger market take-off for vehicles and ships using alternative fuels. It seems to be generally agreed that such measures are important for creating confidence in alternative fuels on the part of users which is an essential element for the market to take off.

| 3.4 | The EESC also welcomes the establishment of technical standards valid within the EU for refuelling/recharging infrastructure. This measure is a decisive factor in inspiring confidence in alternative fuels as a viable alternative for cross-border transport. The EESC assumes that the Commission will make use of its power, as provided by the proposal, to adopt delegated acts to update the specifications, in order to ensure that they are always compatible with those applying on the world market. |
| --- | --- |

3.4

The EESC also welcomes the establishment of technical standards valid within the EU for refuelling/recharging infrastructure. This measure is a decisive factor in inspiring confidence in alternative fuels as a viable alternative for cross-border transport. The EESC assumes that the Commission will make use of its power, as provided by the proposal, to adopt delegated acts to update the specifications, in order to ensure that they are always compatible with those applying on the world market.

| 3.5 | The EESC observes that the proposal obliges Member States to adopt a national policy framework for alternative fuels. Article 3(3) however appears to authorise Member State to omit fuels from that policy, and the infrastructure obligations set out in Articles 4 to 6 only cover electricity, hydrogen and natural gas supply. However, the consumer information obligation in Article 7 seems to cover all alternative fuels on the market. It also appears from the communication that in particular the so called advanced biofuels are an important element in the future energy mix, at least as things now stand, also bearing in mind the minimum quotas foreseen for biofuels in the future energy mix. The EESC therefore thinks that Article 3 of the legislative proposal should indicate a core set of alternative fuels that must be addressed by national policy frameworks. |
| --- | --- |

3.5

The EESC observes that the proposal obliges Member States to adopt a national policy framework for alternative fuels. Article 3(3) however appears to authorise Member State to omit fuels from that policy, and the infrastructure obligations set out in Articles 4 to 6 only cover electricity, hydrogen and natural gas supply. However, the consumer information obligation in Article 7 seems to cover all alternative fuels on the market. It also appears from the communication that in particular the so called advanced biofuels are an important element in the future energy mix, at least as things now stand, also bearing in mind the minimum quotas foreseen for biofuels in the future energy mix. The EESC therefore thinks that Article 3 of the legislative proposal should indicate a core set of alternative fuels that must be addressed by national policy frameworks.

| 3.6 | According to Article 3 of the proposal, the Member States should assess the trans-border continuity of the infrastructure coverage for alternative fuels. It also provides that the Member States are to cooperate, through consultations or joint policy frameworks, to ensure that the measures to implement the Directive are coherent and coordinated. The only means of ensuring that this fundamental obligation is adequately implemented seems to be the reporting and evaluation mechanism laid down in Article 3(5) and (6). The EESC questions if this is enough and wonders if it might not be useful to create a permanent coordination function, on the lines of the coordinators for certain TEN-T projects under the TEN-T Guidelines. |
| --- | --- |

3.6

According to Article 3 of the proposal, the Member States should assess the trans-border continuity of the infrastructure coverage for alternative fuels. It also provides that the Member States are to cooperate, through consultations or joint policy frameworks, to ensure that the measures to implement the Directive are coherent and coordinated. The only means of ensuring that this fundamental obligation is adequately implemented seems to be the reporting and evaluation mechanism laid down in Article 3(5) and (6). The EESC questions if this is enough and wonders if it might not be useful to create a permanent coordination function, on the lines of the coordinators for certain TEN-T projects under the TEN-T Guidelines.

| 3.7 | The communication seems to assume that financing of alternative fuels infrastructure can be obtained without direct public funding and with the support exclusively of policy tools such as building permits, concessions, procurement regulations, access and charging regulations and non-financial incentives. In the EESC's view this may be true for non-public loading stations for electric vehicles, but it doubts whether this concept works as regards public loading stations for electric vehicles, where commercial operation is generally considered to be unfeasible and public financing the only realistic solution, at least during the build-up phase. (See, for instance, Fortschrittsbericht der Nationalen Plattform Elektromobilität (Dritter Bericht), Section 5.5 – a report prepared for the German Ministry of Transport in July 2012). |
| --- | --- |

3.7

The communication seems to assume that financing of alternative fuels infrastructure can be obtained without direct public funding and with the support exclusively of policy tools such as building permits, concessions, procurement regulations, access and charging regulations and non-financial incentives. In the EESC's view this may be true for non-public loading stations for electric vehicles, but it doubts whether this concept works as regards public loading stations for electric vehicles, where commercial operation is generally considered to be unfeasible and public financing the only realistic solution, at least during the build-up phase. (See, for instance, Fortschrittsbericht der Nationalen Plattform Elektromobilität (Dritter Bericht), Section 5.5 – a report prepared for the German Ministry of Transport in July 2012).

Fortschrittsbericht der Nationalen Plattform Elektromobilität (Dritter Bericht)

| 3.8 | Because of the level of investment costs and uncertainty of markets the EESC takes the view that there will be a general and long term need for public financing of dedicated refuelling/recharging infrastructure for alternative fuels. The EESC therefore feels that the assessment made in the communication on this point should be reconsidered. These financing needs have been considered in the Guidelines on Financial Incentives for Clean and Energy Efficient Vehicles (SWD(2013) 27), which have now been issued, and should also be considered when setting priorities, for instance, on TEN-T funding. |
| --- | --- |

3.8

Because of the level of investment costs and uncertainty of markets the EESC takes the view that there will be a general and long term need for public financing of dedicated refuelling/recharging infrastructure for alternative fuels. The EESC therefore feels that the assessment made in the communication on this point should be reconsidered. These financing needs have been considered in the Guidelines on Financial Incentives for Clean and Energy Efficient Vehicles (SWD(2013) 27), which have now been issued, and should also be considered when setting priorities, for instance, on TEN-T funding.

| 3.9 | The EESC also questions the number of loading stations per Member State foreseen for 2020 in Annex II to the proposal. Quoting one example, Germany, the Annex foresees 1 500 000 loading stations, of which 150 000 are to be public. The report on the implementation of the German electro mobility programme quoted under 3.7 above predicts a total of just fewer than one million loading stations for about the same number of cars. Of these loading stations, 150 000 are to be public, but there is a question mark over 50 % of these. The EESC would therefore suggest that the target figures in Annex II should be reconsidered and that a simple mechanism for revising the previsions in Annex II should be devised. |
| --- | --- |

3.9

The EESC also questions the number of loading stations per Member State foreseen for 2020 in Annex II to the proposal. Quoting one example, Germany, the Annex foresees 1 500 000 loading stations, of which 150 000 are to be public. The report on the implementation of the German electro mobility programme quoted under 3.7 above predicts a total of just fewer than one million loading stations for about the same number of cars. Of these loading stations, 150 000 are to be public, but there is a question mark over 50 % of these. The EESC would therefore suggest that the target figures in Annex II should be reconsidered and that a simple mechanism for revising the previsions in Annex II should be devised.

4.   Specific comments

Specific comments

| 4.1 | The EESC questions the criterion of cost effectiveness regarding shore electricity facilities set out in Article 4.4 of the proposal. It is not clear against what effectiveness criteria the cost is to be weighed. |
| --- | --- |

4.1

The EESC questions the criterion of cost effectiveness regarding shore electricity facilities set out in Article 4.4 of the proposal. It is not clear against what effectiveness criteria the cost is to be weighed.

| 4.2 | The EESC welcomes the requirement that all public loading stations should be equipped with intelligent metering systems. This will facilitate future development of functions such as selection of green energy for charging and electricity delivery from the vehicle at peak hours. The EESC wonders if this requirement might not be considered also for non-public charging points. |
| --- | --- |

4.2

The EESC welcomes the requirement that all public loading stations should be equipped with intelligent metering systems. This will facilitate future development of functions such as selection of green energy for charging and electricity delivery from the vehicle at peak hours. The EESC wonders if this requirement might not be considered also for non-public charging points.

| 4.3 | The EESC questions if the provisions of Article 4.8 of the proposal are sufficient to ensure a right to roaming when using an electric vehicle in cross-border travel. The EESC takes the view that serious consideration should be given to the alternative of imposing an obligation on the Member States to ensure that roaming can be carried out within the EU at a reasonable cost. |
| --- | --- |

4.3

The EESC questions if the provisions of Article 4.8 of the proposal are sufficient to ensure a right to roaming when using an electric vehicle in cross-border travel. The EESC takes the view that serious consideration should be given to the alternative of imposing an obligation on the Member States to ensure that roaming can be carried out within the EU at a reasonable cost.

| 4.4 | Comparing Article 6(1) and (2) with (4), the EESC questions whether the planned deadline for the availability of technical standards for LNG, set out in Annex III 3.1 to the proposal as ‘by 2014’ is really satisfactory, considering that the 0,1 % sulphur rule for marine fuels will apply in Sulphur Emission Control Areas as from 1 January 2015. This gives extremely short notice for actually carrying out the work, let alone for defining financing conditions. The EESC therefore suggests that measures be taken to ensure that ports, ship-owners and ship operators can make timely use of the possibility to adapt to the 0,1 % requirement by using LNG, without incurring the risk of non-compliance with EU rules according to Directive 1999/32/EU as amended through Directive 2012/33/EU Article 1(4). |
| --- | --- |

4.4

Comparing Article 6(1) and (2) with (4), the EESC questions whether the planned deadline for the availability of technical standards for LNG, set out in Annex III 3.1 to the proposal as ‘by 2014’ is really satisfactory, considering that the 0,1 % sulphur rule for marine fuels will apply in Sulphur Emission Control Areas as from 1 January 2015. This gives extremely short notice for actually carrying out the work, let alone for defining financing conditions. The EESC therefore suggests that measures be taken to ensure that ports, ship-owners and ship operators can make timely use of the possibility to adapt to the 0,1 % requirement by using LNG, without incurring the risk of non-compliance with EU rules according to Directive 1999/32/EU as amended through Directive 2012/33/EU Article 1(4).

| 4.5 | The EESC would welcome a reference in the proposal, possibly in Article 3, to the need to find appropriate solutions to ensure that adequate infrastructure is available in sparsely populated areas, where financing may be particularly difficult to obtain without public aid also after the end of a start-up period. |
| --- | --- |

4.5

The EESC would welcome a reference in the proposal, possibly in Article 3, to the need to find appropriate solutions to ensure that adequate infrastructure is available in sparsely populated areas, where financing may be particularly difficult to obtain without public aid also after the end of a start-up period.

| 4.6 | Lastly, the EESC notes that although LNG as such may be sourced from fossil fuels or biofuels, it appears from the Working Document (Section 1, last point), that the variety considered for maritime use currently seems to be of fossil origin, although with very good environmental characteristics. The EESC assumes that efforts will be made to promote the use of other LNG varieties or other propulsion systems. The possibly provisional character of the LNG solution again puts into question the high level of commitment to LNG facilities of the proposal. |
| --- | --- |

4.6

Lastly, the EESC notes that although LNG as such may be sourced from fossil fuels or biofuels, it appears from the Working Document (Section 1, last point), that the variety considered for maritime use currently seems to be of fossil origin, although with very good environmental characteristics. The EESC assumes that efforts will be made to promote the use of other LNG varieties or other propulsion systems. The possibly provisional character of the LNG solution again puts into question the high level of commitment to LNG facilities of the proposal.

Brussels, 22 May 2013.

The President of the European Economic and Social Committee

Henri MALOSSE

---

(1)  Communication on Clean Power for Transport: A European alternative fuels strategy (the Communication), the proposal for a Directive on the deployment of alternative fuels infrastructure (the Proposal) and the accompanying staff working document on LNG for shipping (the Working Document).

1

(2)  EESC opinion on the Roadmap to a Single European Transport Area – White Paper, OJ C 24, 28.1.2012, p. 146.

2

(3)  EESC opinion on Toward the Wider Uptake of Electric Vehicles, OJ C 44, 11.2.2011, p. 47.

3

(4)  EESC opinion on Sulphur Content of Marine Fuels, OJ C 68, 6.3.2012, p. 70.

4

(5)  EESC opinion on Guidelines for the Development of the Trans-European Transport Network, OJ C 143, 22.5.2012, p. 130.

5

---