EASE Reply to the European Commission Public Consultation on the Revision of the Directive on Intelligent Transport Systems

EASE took part on the public consultation on Directive 2010/40/EU (The ITS Directive). The directive aims to accelerate and coordinate the deployment and use of Intelligent Transport Systems applied to road transport and its interfaces with other transport modes. EASE, as voice of the energy storage industry, argues that Intelligent Transport Systems and energy storage go hand in hand and they can contribute to decarbonisation.

It is key to elaborate a legislation able to link the transport and energy sectors and related infrastructure: Vehicle-to-Grid technologies are crucial assets to manage the future energy system and decarbonise the transport sector, while also empowering customers. Sector integration is a key pillar of the EU decarbonisation strategy.

• Awareness. Citizens concerns about range or availability of their vehicles if engaged in Vehicle-to-Grid schemes is a significant barrier. Customers need to be well informed and incentivised to participate with fair reward in Vehicle-Grid Integration schemes.
• Added value for consumers. Electric vehicles must be equipped with the capability to allow for bidirectional flows of electricity between the vehicle and the grid. The Vehicle-to-Grid system’s price, set by both the vehicle and charger manufacturers, should be affordable enough to better attract customers. The EV owner must be remunerated by the aggregator for providing grid services to the grid operator and must be assured that the vehicle will be available for personal use when needed. Similarly, the aggregator must derive enough benefit from the availability of vehicles to compensate for the additional cost of monitoring and controlling the vehicle-grid interactions, remunerating EV owners, and administering the system.
• Harmonisation of the market. EU legislation is key to avoid a fragmented EU market where Member States have different levels of ambition. It is paramount to ensure and simplify/harmonise market compliance at EU level, and ensure clarity on business models. It is important to set up standards and protocols that apply across the EU and ensure interoperability, continuity of applications, systems and services across different Member States.
• Interoperability, harmonised protocols, and standards among infrastructures and systems should be implemented to enable seamless communication. Technical standards for charging processes are mostly defined but there is currently no formal procedure to ensure the compliance between these standards and the vehicles coming into the EU market from abroad. These standards are crucial to ensure consumer engagement and the provision of vehicle-grid integration services over Europe while avoiding overinvestment.
• Data. Access to energy consumption data should be ensured. Availability of charging patterns to the electric vehicles energy supplier or electric vehicles aggregator is crucial for consumers to be offered the right tariffs. This should include protection of consumer privacy and security and the consumers’ access to their own data, notably in case of switching of service provider. It is key to avoid technical barriers: technical costs (AC/DC, software, hardware) could hamper EV/V2G deployment.