COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT Accompanying the document Proposal for a Directive on the deployment of alternative fuels infrastructure
Date: 2013-01-24
Institutions: European Commission
Subjects: electric vehicle, hydrogen production, import (EU), international road transport, natural gas, substitute fuel, technical standard, trans-European network, transport infrastructure, waterway transport

EUROPEAN 
COMMISSION 

Brussels, 24.1.2013  
SWD(2013) 6 final 

COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

Proposal for a Directive  

on the deployment of alternative fuels infrastructure 

{COM(2013) 18 final} 
{SWD(2013) 5 final} 

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COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

Proposal for a Directive  

on the deployment of alternative fuels infrastructure 

1. 

1. 

2. 

3. 

4. 

5. 

6. 

2. 

7. 

GENERAL CONTEXT 

The  White  Paper  “Roadmap  to  a  Single  European  Transport  Area  –  Towards  a 
Competitive  and  Resource  Efficient  Transport  System”1  found  that  without  the 
significant  uptake  of  alternative  fuels,  we  cannot  achieve  the  targets  of  the  Europe 
2020  strategy  and  our  climate  goals  for  2050.  It  therefore  announces  that  the 
Commission will develop “a sustainable alternative fuels strategy including also the 
appropriate  infrastructure”  (Initiative  24)  and  ensure  “guidelines  and  standards  for 
refuelling infrastructures” (Initiative 26). 

Based  on  the  consultation  of  stakeholders  and  expertise  gathered,  the  Commission 
has  identified  the  alternative  fuels  which  have  already  shown  a  potential  for  long-
term oil substitution.  

Deployment  of  alternative  fuels  is  hampered  by  (1)  the  high  price  of  vehicles,  (2) 
poor  consumer  acceptance,  and  (3)  lack  of  recharging  /refuelling  infrastructure, 
caused by multiple market failures. 

Previous  initiatives  have  addressed  fuel  production,  vehicle  technology,  and 
marketing, but neglected the build-up of the necessary infrastructure. 

Ex-post  analyses  of  projects  and  policy  actions  have  pointed  out  the  lack  of 
recharging/refuelling infrastructure, and the inability of market forces to fill this gap, 
as  a  fundamental  barrier.  Without  removing  this  barrier,  all  other  efforts  risk  to 
remain ineffective. 

Three alternative transport  fuels are particularly affected: electricity, hydrogen, and 
natural  gas  (LNG  and  CNG).  The  other  main  alternatives  to  oil  –  biofuels  and 
liquefied petroleum gas (LPG) – are less concerned.  

PROBLEM DEFINITION 

The Impact Assessment finds that on the basis of projected market developments, the 
infrastructure  for  electric,  hydrogen  and  natural  gas  (LNG  and  CNG)  vehicles  is 
likely  to  remain  insufficient  for  what  broad  market  take-up  would  require.  This 
‘minimum’ network is defined below. 

Electric vehicles (EVs) 

8. 

A minimum network for EVs should ensure: 

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COM(2011) 144 final  

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9. 

10. 

11. 

12. 

3. 

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4. 

14. 

15. 

16. 

•  the critical mass of production needed to achieve economies of scale; 
•  the projected deployment of EVs of approximately 6-8% of vehicle sales in 2020.  

The above criteria suggest a benchmark number of 4 million EVs on the road in the 
EU by 2020, less than half of the sum of the targets announced by Member States. 

EVs will be mostly deployed in urban areas, and therefore be distributed across the 
EU  according  to  the  urbanisation  of  Member  States.  Market  tests  have  shown  that 
each EV needs two recharging points (at home and at work), and about 10% of all 
should be publicly accessible to address range anxiety. 

Hydrogen vehicles 

For hydrogen, a first step towards market opening would require linking existing and 
planned refuelling stations. 

LNG in vessels and CNG and LNG in vehicles 

The 83 maritime ports of the TEN-T Core Network are the primary locations for the 
use  of  LNG  in  shipping.  Equipping  with  LNG  also  the  inland  waterway  and  road 
transport  corridors  and  assuring  enough  number  of  refuelling  stations  for  CNG 
vehicles would provide sufficient coverage in these transport modes as well.  

ROOT CAUSES 

The Commission has identified two main root causes: 

•  Existing  recharging/refuelling  equipment  cannot  be  connected  and  is  not 
interoperable  in  all  related  alternative  fuel  vehicles/vessels.  The  technology 
necessary  for  the  construction  of  a  network  is  substantially  mature.  However, 
currently  the  standards  are  not  common  EU-wide,  thereby  discouraging 
potential  infrastructure  investors,  car  manufacturers  and  consumers.  This 
leads to the fragmentation of the internal market. 

•  Investment  uncertainty  hinders 

the  deployment  of 

recharging/refuelling 
infrastructure  for  electricity,  hydrogen  and  natural  gas  (LNG  and  CNG).  The 
business case for providers of alternative fuels infrastructure is not yet established. 
The  co-ordination  failure  among  vehicle  manufactures,  infrastructure 
providers, national authorities and final users must be addressed. Initiatives 
that are specifically addressed at promoting infrastructure appear necessary 
to break this deadlock.  

ANALYSIS OF SUBSIDIARITY 

The right for the EU to act in the field of transport is set out in Articles 90-91 of the 
TFEU, in Title VI. 

An EU initiative in this field would be necessary since Member States do not have 
the  instruments  to  achieve  pan-European  coordination  in  terms  of  technical 
specifications of infrastructure and timing of investments.  

Vehicle and equipment manufacturers need to produce on a large scale for a single 
EU  market,  and  they  need  to  be  able  to  rely  on  consistent  developments  across 
Member  States.  Similarly,  consumers  and  transport  users  are  interested  in  pan-
European mobility.  

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17. 

5. 

18. 

19. 

The proposed action only addresses two transport modes (road and waterborne) for 
which the development of a minimum necessary network cannot be achieved without 
EU support. These sectors represent more than 80% of the modal split in freight and 
passenger transport. In these sectors, alternative fuels are functional to the reduction 
of oil dependence, GHG and pollutant emissions.  

OBJECTIVES OF EU INITIATIVE 

The EU has agreed on binding targets on the share of renewable energy in transport 
fuels (10% by 2020), and on a reduction of the CO2 intensity of the road transport 
fuels (-6% by 2020). The 2011 White Paper announced a reduction of 60% of CO2 
emissions by 2050 requiring also a significant uptake of alternative fuels. 

The  general  objective  of  this  initiative  is  to  ensure,  within  the  current  economic 
climate, the provision of a sufficient infrastructure network, contributing thereby to 
achieve the take-up of the alternative fuel vehicles’ and vessels’ market announced in 
the White Paper. 

20. 

The general objective can be translated into more specific goals (Table 1) 

Table 1: Problem tree: mapping problems and objectives 

Problem 

General objective 

the  alternative 

Based  on  planned  investments  of  Member  States 
and, 
for 
electricity,  hydrogen  and  natural  gas  (LNG  and 
CNG)  is  likely  to  remain  insufficient  to  enable  the 
uptake of alternative fuels. 

infrastructure 

fuel 

The  general  objective  of  this  initiative  is  to  ensure, 
within the current economic  climate, the provision of 
a  sufficient  infrastructure  network  for  alternative 
fuels,  contributing  thereby  to  achieve  the  take-up  of 
the  alternative  fuel  vehicles’  and  vessels’  market 
announced in the White Paper. 

Problem driver 1 

Specific objective 1 

Existing recharging/refuelling equipment cannot be 
connected and is not interoperable  

To  make  sure  that  recharging/refuelling  equipment 
can be connected and are interoperable  

Problem driver 2 

Specific objective 2 

Investment  uncertainty  hinders  the  deployment  of 
recharging/refuelling  infrastructure  for  electricity, 
hydrogen and natural gas (LNG and CNG) 

To ensure that investment uncertainty is reduced to a 
level  breaking  up  the  existing  ‘wait  and  see’  attitude 
amongst market participants 

21. 

The following operational objectives have been defined: 

(1)  All  recharging  stations  for  EVs,  hydrogen  and  natural  gas  (LNG  and  CNG) 
refuelling  for  road  transport  vehicles,  and  LNG  refuelling  facilities  for 
waterborne vessels can be connected, and are interoperable. 

(2)  The number of recharging points for EVs reaches the values set out in Table 1, 

with at least 10% publicly accessible.  

Table 2: Minimum number of EVs charging points in each Member State (in thousands) 

MS 

BE 

BG 

CZ 

Number of 
charging points 

Number of 
publicly accessible 
charging points 

21 

7 

13 

207 

69 

129 

4 

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DK 

DE 

EE 

IE 

EL 

ES 

FR 

IT 

CY 

LV 

LT 

LU 

HU 

MT 

NL 

AT 

PL 

PT 

RO 

SI 

SK 

FI 

SE 

UK 

HR 

54 

1503 

12 

22 

128 

824 

969 

1255 

20 

17 

41 

14 

68 

10 

321 

116 

460 

123 

101 

26 

36 

71 

145 

1221 

38 

5 

150 

1 

2 

13 

82 

97 

125 

2 

2 

4 

1 

7 

1 

32 

12 

46 

12 

10 

3 

4 

7 

14 

122 

4 

(3)  Existing  hydrogen  refuelling  stations  are  connected  via  the  TEN-T  Core 
Network with a maximum distance of 300 km between stations by 2020. 

(4)  LNG  refuelling  facilities  for  waterborne  vessels  are  available  in  all  maritime 

ports of the TEN-T Core Network by 2020. 

(5)  LNG refuelling facilities for waterborne vessels are available in all inland ports 

of the TEN-T Core Network by 2020. 

(6)  LNG  refuelling  stations  for  road  transport  vehicles  are  available  along  the 
TEN-T Core Network with a maximum distance of 400 km between stations by 
2020. 

(7)  CNG  publicly  accessible  refuelling  points  are  available,  with  maximum 
distances of 150 km, to allow the circulation of CNG vehicles Union-wide by 
2020. 

POLICY OPTIONS 

The  Commission  undertook  an  extensive  consultation  of  stakeholders  on  various 
policy  options.  A  pre-screening  of  possible  options  was  carried  out  on  the  basis  of 

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6.1. 

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6.2. 

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6.3. 

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6.4. 

27. 

28. 

the following criteria: consistency with general, specific and operational objectives, 
technology neutrality and feasibility. 

The  Commission  has  identified  three  policy  options  besides  the  ‘no  policy  change’ 
baseline scenario and analised them in-depth. 

Policy Option 1 

Policy  Option  1  represents  the  future  without  any  additional  policy  intervention  to 
change current trends (‘no policy change’ scenario). It takes into account all current 
legislative  and  policy  initiatives,  national  announcements  for  the  deployment  of 
infrastructure, and the continuation of previous EU and Member States’ programmes 
and incentives.  

Policy Option 2 

The  EU  will  issue  recommendations  on  the  application  of  standards  for  alternative 
fuels  infrastructure.  It  will  issue  recommendations  setting  out  basic  criteria  and 
indicative  targets  for  the  deployment  of  infrastructure  for  electricity,  hydrogen  and 
natural gas (LNG and CNG). 

Policy Option 3  

The  EU  will  set  out  requirements  for  alternative  fuels  infrastructure  for  Member 
States.  It  will  also  set  out  basic  criteria  for  minimum  infrastructure  coverage, 
together with binding targets for the most mature fuel technologies (electricity, and 
LNG  for  waterborne  transport).  For  hydrogen  and  natural  gas  (LNG  and  CNG)  for 
road transport, the targets would be indicative.  

Policy Option 4  

The  EU  will  set  out  requirements  for  alternative  fuels  infrastructure  for  Member 
States.  At  the  same  time  it  will  set  out  basic  criteria  for  minimum  infrastructure 
coverage, together with binding targets for electricity, hydrogen, LNG and CNG in 
road and LNG in waterborne transport. 

Under any Policy Option, EU legislation would not specify requirements beyond the 
minimum number and the technical standards. Member States would thus decide on 
the  regulatory  framework, 
implementation 
measures. 

localisation,  and  other 

territorial 

7. 

ASSESSMENT OF IMPACTS 

Economic impacts 

29. 

30. 

These Policy Options aim to provide a fundamental condition for market up-take of 
alternative  fuel  vehicles  and  vessels,  but  cannot  ensure  it  without  the  concourse  of 
the other initiatives that are part of the overall strategy. 

The assessment is based on modelling results quantifying the ‘direct’ or ‘stand-alone’ 
benefits  of  the  policy  proposal,  and  on  evidence  from  other  studies  on  the  wider 
impact, when it is seen in combination with other existing and forthcoming initiatives 
to promote alternative fuel vehicles. 

31. 

The ‘stand-alone’ costs of the infrastructure deployment are shown on Table 3.  

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Table 3: Estimated investments costs under each Policy Option2 

Number of 
additional 
charging 
points/fuelling 
stations 
thousands 

8,000 
7,200 

800 
0.143 
0.139 
0.144 
0.654 

Policy Option 
2 

Policy Option 
3 

Policy 
Option 4 

3,984 
1,872 

2,112 

1,140 

Million € 

7,968  
3,744  

4,224  

2,085 

- 

- 
- 

7,968 
3,744 

4,224 
230 
2,085 
58 
164 

5,124 

10,053 

10,505 

45 – 50 

90 –100 

5,124 

10,103 

10,605 

- 

- 
- 

- 

Electricity  

(Total)  

of 90% private  
of 10% publicly 
accessible  

Hydrogen 
LNG for vessels 
LNG for trucks 
CNG for vehicles 
Estimated investment 
costs of infrastructure 
deployment 

Estimated retrofitting 
costs  

Estimated total 
investments costs 

32. 

33. 

34. 

Member States could ensure implementation through a variety of measures (e.g. 
building codes, conditions for parking lots permits, certification of the environmental 
performance  of  businesses,  facilitating  cooperation  between  LNG  companies  and 
port authorities) without necessarily involving public spending. 

The approach for the cost-benefit analysis does not take into account the benefits of 
reduced  oil  dependency,  increased  competitiveness  and  better  functioning  of  the 
internal market. Nonetheless, even under the Policy Option 4, comparing the benefits 
of choosing infrastructure deployment to the costs of other possible policies results in 
higher than 1.5 ratios in all Member States. 

The main macroeconomic effect would be on reduced oil consumption and avoided 
fuel  expenditure.  Avoided  fuel  use  increases  progressively  over  the  decades  2010-
2030 from about 610 million € per year in  2020 to about 2.3 bn € per year in 2030 
under Policy Option 2, 1.7 bn € per year in 2020 to 4.6 bn € per year in 2030 under 
Policy Option 3, and 4.2 bn € per year in  2020 to 9.3 bn € per year in 2030 under 
Policy  Option  4.  The  estimated  aggregate  energy  security  benefit  also  increases 
gradually. 

35. 

The  main  difference  in  macroeconomic  impacts  between  Policy  Option  2  and  3 
consists  in  the  different  probability  of  achieving  the  same  results  through 

2 

The unit cost per smart private charging point can be estimated to be around 520 €; while for a publicly 
accessible  charging  point  it  is  approximately  5,280  €.   The  cost  of  hydrogen  refuelling  station  is  1.6 
million €. The unit cost of a small-scale bunkering f acility is 15 million €, while the cost estimate used 
for LNG fuelling station is 400,000 €. 

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recommendations or mandates. Policy Option 2 is considered much less effective for 
the following reasons: 

•  Many  Member  States  have  ambitious  plans  but  have  not  undergone  obligations. 
This leaves consumers and investors with uncertainties and holds back market up-
take; 

•  The deadlock between the various market players needs to be removed. This can 
only be done if there is a credible commitment, which Member States’ plans, 
voluntary industry agreements and EU recommendations are not providing. 
Market  participants  are  aware  of  past  non-binding  initiatives  in  this  field 
that failed to produce the intended result (e.g. Biofuels Directive3). 

The  difference  between  Policy  Option  3  and  4  is  the  smaller  likelihood  of 
deployment of a hydrogen refuelling network in Policy Option 3. The high potential 
gains  of  Policy  option  4  should  be  assessed  against  the  relatively  small  additional 
investment costs. 

Social impacts 

The  Impact  Assessment  finds  that  investment  into  the  build-up  of  infrastructure 
would  be  mostly  placed  in  Europe,  with  direct  economic  benefits  for  the  sectors 
involved in the infrastructure build-up. 

Additional  employment,  with  a  wide  range  of  job  qualifications,  will  be  created 
through  investment  into  the  areas  of  construction,  manufacturing,  electricity, 
technology,  advanced  materials,  computer 
information  and  communication 
applications.  In  automotive  and  refining  sectors,  shift  to  new  qualifications  will 
preserve employment on the long term. 

Environmental impacts 

Large  environmental  benefits  can  be  realised  from  deploying  alternative  fuels.  The 
reduction  is  marginally  higher  in  Policy  Option  3  relative  to  4,  due  to  increased 
emissions from LNG trucks in Policy Option 4 in the medium-run.  

Under Policy Option 2, NOx emissions decrease by 1.4% by 2020, by 2.0% in Policy 
Option  3,  and  in  Policy  Option  4  by  2.8%.  Particulate  matter  emissions  follow  a 
similar pattern. External costs for noise are reduced as well.  

Conclusions of the assessment of impacts 

The  analysis  of  impacts  shows  that  investing  in  a  minimum  recharging/refuelling 
network  is  the  most  efficient  way  to  promote  alternative  fuel  vehicles.  While 
infrastructure  alone  has  no  major  direct 
the 
refuelling/recharging  network  can  have  large  positive  effect  in  combination  with 
other initiatives targeted at the introduction of cleaner vehicles.  

intervention  on 

impact,  an 

The  Biofuels Directive 2003/30/EC  established  a reference  value of  a 2%  share  for biofuels  in petrol 
and  diesel  consumptions  in  2005  and  5.75%  in  2010.  Member  States  were  required  to  set  indicative 
targets  for  2005,  taking  this  reference  value  into  account.  The  reports  issued  in  2009  as  well  as  the 
Renewable  Energy  Roadmap  (COM/2006/848)  highlighted  “the  slow  progress  Member  States  were 
making  and  the  likelihood  that  the  EU  as  a  whole  would  fail  to  reach  its  2010  target.  The  Roadmap 
explained possible reasons for this, which included the merely indicative nature of the national targets 
and the uncertain investment environment provided by the existing legal framework.” The Commission 
therefore  proposed  a  more  rigorous  framework  and  legally  binding  targets  for  2020,  as  part  of  the 
Climate and Renewable Energy Package. 

36. 

37. 

38. 

39. 

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41. 

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53. 

54. 

Under  Policy  Option  4,  the  benefits  in  terms  of  lower  oil  consumption  amount  to 
about 84.9 bn €, and lower impact on the environment to around 15.4 bn €. Hence, 
the benefits clearly outweigh the approx. 10 bn € needed for a minimum network.  

COMPARISON OF OPTIONS 

Effectiveness:  The  objectives  are  fully  achieved  under  Policy  Option  4  for  all 
alternative fuels considered in the IA. Policy Option 3 differs only in the coverage of 
fuels. Policy Option 2 has the greatest risk of not satisfactorily delivering. 

Efficiency: The least cost can be associated to Policy Option 2, which is however a 
result  of  lower  effectiveness  in  the  achievement  of  objectives.  While  the  costs  of 
Policy  Option  4  are  higher  than  of  Policy  Option  3,  the  potential  benefits  can 
outweigh this difference. 

Coherence: Policy Option 2 would likely result in lower investments. This outcome 
would  particularly  penalise  the  environmental  dimension.  Policy  Option  3  achieves 
the  most  comprehensive  limitation  of  trade-offs  across  the  economic,  social  and 
environmental  fields.  Policy  Option  4  would  represent  a  more  risky  option,  which 
can  be  considered  to  place  more  emphasis  on  the  environmental  dimension  with 
respect to the economic one. 

CONCLUSION 

Policy  Option  2  is  discarded,  since  it  compares  unfavourably  with  both  Policy 
Options 3 and 4. 

Policy  Options  3  and  4  have  many  elements  in  common.  Preference  is  given  to 
Policy Option 3 which better takes into account the present economic constraints. 

However, Policy Option 4 is not discarded as its suitability is mostly influenced by 
existing  technological  prospects  that  can  change  rapidly.  This  would  increase  its 
efficiency. 

The overriding necessity of giving clear signals to the markets would rather give 
larger merits to Policy Option 4. If chosen, such a decisive step on EU level could 
accelerate  the  market  development  of  alternative  fuels  in  general  and  ensure  that 
investments have a larger impact on economic growth in Europe. 

Rapid implementation of the necessary actions, with market comforting targets, can 
also strongly enhance the momentum for the EU 2020 strategy. 

MONITORING AND EVALUATION 

Monitoring and reporting will be needed, building on existing reporting channels and 
additional  information  collection  through  existing  Joint  Undertakings,  Technology 
Platforms, and expert groups. 

Member  States  would  most  likely  need  to  set  up  national  plans  on  the  build-up  of 
alternative fuels infrastructure. 

The  Commission  would  submit  reports  on  the  implementation  and  impacts  of  this 
Directive to the European Parliament and the Council. 

The reports would also review the requirements in view of the technical, economic 
and market developments, and propose adjustments as appropriate. 

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