Deployment of alternative fuels infrastructure

As Europe’s largest renewable energy producer, Statkraft is committed to contributing to the EU becoming climate-neutral by 2050. Together with Mer Group, fully owned by Statkraft, our ambition is to become a leading European e-mobility company by providing innovative and renewable solutions and contribute to the European shift towards electric mobility.

Comments from CNG-Club eV on Alternative Fuels Infrastructure Regulation (AFIR) The non-profit consumer protection association CNG-Club eV strongly supports the EU’s ambition to become the first climate-neutral continent by 2050 through the Fit for 55 package. This is in line with our climate and environmental objectives in mobility and de-fossilisation of fuels CNG and LNG. However, CNG-Club e.V.

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Hydrogen Europe recommends the following key points to improve to truly unlock the synergies of the new Alternative Fuels Infrastructure Regulation (AFIR): 1. Ensure that the proposal acts in unison with other proposals of the Green Deal that drive demand for clean solutions in road, waterborne, and aviation sectors. 2.

Enedis welcomes the provisions on the deployment of electric recharging infrastructure in the proposal. It will be key for transport electrification, which must ultimately lead to reduced EU GHG emissions. In accordance with the principles established under Directive (EU) 2019/944, Enedis, France’s main electricity DSO, is committed to cooperating on a non-discriminatory basis with any person establishing or…

Italgas welcomes the adoption of the Fit 4 55 package, both in spirit and in substance. We firmly believe in the EU’s climate targets and believe the decarbonisation of transport is a fundamental part of the energy transition. We also believe one of the key values of the EU is consumer choice and free competition.

Air Liquide welcomes the obligation for Member States to ensure a minimum number of publicly accessible Hydrogen stations are put in place by 2030. However, we believe the European Union should increase this ambition by indicating minimum targets.

The Association of the Automotive Suppliers’ industry in Europe is pleased to provide feedback on the proposed regulation setting a framework for the deployment of alternative fuels infrastructure in the EU. CLEPA represents over 3.000 companies supplying state-of-the-art components and innovative technology for safe, smart and sustainable mobility, investing over 30 billion euros yearly in research and development…

UFE, the association representing the French Electricity industry, thanks the European Commission for the opportunity to react to its proposal for a new Regulation on the Alternative Fuels Infrastructure (AFIR). UFE supports the proposal made by the European Commission as it sends positive signals regarding the electrification of transport, a necessity to decarbonise this sector.

AFGNV welcomes the revision of the current Alternative Fuels Infrastructure Directive, which should align with the GHG emission reduction targets of the EU. AFGNV is convinced that the only way of achieving a quick decarbonisation of road transport is to support all existing solutions, including biomethane (both in compressed and liquified forms – bioCNG and bioLNG).

The Initiative Deutsche Payment Systems e.V. welcomes the EU Commission’s proposal for a Regulation on the development of an Alternative Fuels Infrastructure (AFIR) to ensure a coherent and consumer-friendly charging infrastructure in Europe. The transport sector and the electrification of the individual transport are crucial for achieving the Paris climate goals.

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Liquid Wind welcomes the European Commission’s initiative to revise the Alternative Fuels Infrastructure Directive as a part of the Fit-for-55 legislative package. Liquid Wind is a Swedish Power-to-Fuel Development Company committed to reducing carbon emissions.

EPHA welcomes the European Commission’s proposal to improve the EU’s refuelling and recharging infrastructure for zero emission new vehicles. Better refuelling and recharging infrastructure are crucial to get to 100% zero emissions mobility. This proposal should ensure that European Union can meet its own Green Deal goals and improve air quality.

WKÖ supports the European Green Deal and stands by the climate neutrality goal by 2050. Now a concrete set of measures for a sustainable, ecological change in the EU, in line with a new growth strategy, is necessary. WKÖ will contribute to a legislative package that meets the requirements of effective climate protection and at the same time is practicable and compatible with economic prosperity.

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

Aena supports the objectives of supplying electricity to aircraft in assisted and autonomous positions, and would propose the following slight change in the text: Article 12 Targets for supply of electricity to stationary aircraft 1.

Access to an extensive, convenient and reliable fast-charging network is critical for large-scale electric vehicle (EV) adoption. That’s why, since opening our first Superchargers in 2012, we have been committed to rapid expansion of the network. Today, we have more than 30,000 Superchargers (high power chargers) worldwide.

Fuelling infrastructure plays a critical role on the decarbonisation pathway of the transportation sector. Further emission reduction will require a decisive participation of all technologies from today towards 2050, where renewable and low-carbon fuels are called to play an increasingly relevant role.

GRTgaz welcomes the revision of the current AFID, which will contribute to the decarbonisation of the transport sector. In order to ensure the coherence of the Fit for 55 package, the definitions of the types of fuels produced and used for vehicles should be harmonised.

Indaver Ireland welcomes the proposals for a Regulation regarding mandatory minimum targets for hydrogen refuelling infrastructure. As stated in the recitals to the proposal, they will provide important policy signals and complement national policy frameworks to facilitate the roll out of alternative fuel infrastructure.

The European LPG industry is fully committed to reaching carbon neutrality in road transport by 2050 at the latest. LPG is the number one alternative fuel in Europe and with its clean burning properties, it has provided more environmental benefits to date than any other alternative fuel. Moreover, LPG can be readily replaced with its defossilised version BioLPG and be increasingly blended with rDME.

Teréga welcomes the "Fit for 55" package presented by the European Commission (EC), and wishes to propose several recommendations and areas for improvement to make the Fit for 55 package even more effective. The attached document shortly highlights Teréga’s main attention points in order to make sure that the net-zero objective set by the EC is reached as swiftly as possible and at the lowest-possible cost for the…

We, FinCo Fuel Group, appreciate the EU’s efforts in leading the energy transition and tackling GHG emissions in the maritime sector. Given the cross-border nature of this sector, it is the right approach to address its GHG impact on EU level and thereby set an example for the international shipping sector to follow. An important aspect of reducing GHG emissions is the availability of alternative fuels.

Fluxys welcomes the opportunity provided by the Commission through this feedback period for stakeholders to provide views on the Commission’s adaption regarding Alternative Fuels Infrastructure Regulation (AFIR) back in the summer of 2021 with the aim of feeding into the legislative debate at the European Parliament and Council.

We, GoodFuels, appreciate the EU’s efforts in leading the energy transition and tackling GHG emissions in the maritime sector. Given the cross-border nature of this sector, it is the right approach to address its GHG impact on EU level and thereby set an example for the international shipping sector to follow. An important aspect of reducing GHG emissions is the availability of alternative fuels.

NGVA Europe welcomes the revision of the current Alternative Fuels Infrastructure Directive, which should align with the increased GHG emission reduction targets of the EU. NGVA Europe is convinced that the only way of achieving a quick decarbonisation of road transport is to support all existing solutions, including biomethane (both in compressed and liquified forms – bioCNG and bioLNG).

The revision of the AFIR offers the opportunity to set an important course for a change of engines towards a sustainable transport sector. We support the rapid development of the infrastructure in order to enable a faster conversion to electric motor operation.

The International DME Association (IDA) is the global voice of the Dimethyl Ether (DME) industry, promoting its use as a clean alternative fuel worldwide. DME produced from renewable feedstocks (rDME) is a safe, clean, sustainable fuel that can support de-fossilisation of transport, domestic and industrial heating and cooking.

The Swedish Gas Association welcomes an ambitious expansion of infrastructure for electric and hydrogen vehicles, but we believe that biomethane should be addressed with the same level of ambition. This is not the case with the Commission’s proposed regulations, even though biomethane is one of the market’s most sustainable and cost-effective alternative fuels.

1. General Comment: Τhe AFIR’s revision should be based on the principle of infrastructure neutrality taking also under consideration that infrastructure is one of the key factors which will further promote the use of renewable fuels thus allowing for the decarbonisation of the transport sectors (both road and maritime).

“Fitfor55” – Proposal for a new regulation on alternative fuel infrastructures Proposal for a Regulation of the European Parliament and 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 Position paper Representing the Italian automotive supply chain, which is responsible – as well as the entire EU automotive…

In our view, AFID is an appropriate regulatory instrument to help achieve the climate change objectives set out in the Green Deal in the transport sector. The Directive should be used to incentivise the use of climate-friendly energy and innovative climate-neutral fuels for road, rail, waterborne and ground transport at airports and to support their market uptake.

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The Renewable Fuels Platform (PEK) welcomes the promotion of alternative fuels, but in particular the increased blending of sustainable biofuels and the replacement of fossil fuels with renewable fuels. In our view, particular attention should be paid to ways of effectively reducing greenhouse gas emissions in the existing fleet and using existing infrastructure.

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NABU recognizes the European Commission’s initiative for further action on the decarbonisation of transport through the proposal of the Alternative Fuel Infrastructure Regulation (AFIR) ‘Low-emission vehicles – improving the EU’s refueling/ recharging infrastructure’.

MOL Group has a strong ambition to make improvements in its operations that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030.

E.ON appreciates the opportunity to participate in the consultation process on the Alternative Fuels Infrastructure Regulation (AFIR) and sees potential to spur the action required for the transition towards cleaner mobility. E.ON welcomes an ambitious, legally binding approach and all efforts leading to EU-wide consistency of technologies, whilst ensuring more transparent offers for customers.

The transport and mobility sector has huge potential for transformation. It has a tremendous opportunity to reduce GHG emissions as well as improve Noise and Traffic Congestion throughout the EU. ANEC, therefore, welcomes the Commission’s proposal for a regulation on the deployment of alternative fuels infrastructure (AFIR) that aims to enable widespread uptake of low- and zero-emission vehicles.

Volvo Group has reviewed the EU Commission's proposal to amend Directive (2014/94 / EU) on the deployment of infrastructure for alternative fuels, and considers it to be a step in the right direction. For the goal of an EU free of fossil fuels to become a reality, the requirements must however be set considerably higher than in the current proposal.

GENERAL COMMENTS • Defining compressed natural gas (CNG) and liquefied natural gas (LNG) as transition phase fuels and limiting infrastructure commitments only to LNG and until 1 January 2025 may result in a time-limited support for these technologies and hamper the development not only of the bioLNG and bioCNG sector, but also projects developed for mixtures of hydrogen and natural gas.

ECI supports the EU’s climate ambitions for 2030 and 2050 and welcomes the proposed regulations on CO2 emission standards for light-duty vehicles and Alternative Fuels Infrastructure (AFIR) as important steps forward in accelerating the transition to e-mobility. Copper is one of the materials that makes this transition possible.

Reganosa, as Transmission System Operator, is committed to play an active role in the energy transition process framed within the European Green Deal, the National Energy and Climate Plan 2021-2030 (NECP) and the EU Energy System Integration and Hydrogen strategies.

CEPM wishes to transmit its comments on various texts proposed in the “fit for 55” package. In general, CEPM regrets that the contribution of crop based biofuels, including corn bioethanol, is not better supported. CEPM requests that the role of these biofuels be improved, and that it is reflected systematically in the various texts. Please find attached our comments.

Transport & Environment (T&E) welcomes the Commission’s (EC) proposal for a regulation on the deployment of alternative fuels infrastructure. In particular the change of the legislative instrument from directive to a regulation T&E considers an important step in the right direction. (detailed feedback in attachment).

Dear Madam or Sir Please find attached GAMA’s feedback on low-emission vehicles – improving the EU’s refuelling/recharging infrastructure. Please feel free to contact me, should you require any additional information or have any questions. Best regards [name removed] R. FABIAN Director, European Affairs

On 14 July 2021, the European Commission adopted its proposal for a Regulation on the deployment of Alternative Fuels Infrastructure (AFIR) with the intention of repealing Directive 2014/94/EU. The European emissions control industry that the Association for Emissions Control by Catalyst (AECC) represents, welcomes the opportunity to comment on the new regulation proposal.

PLINOVODI d.o.o. as a TSO of gas infrastructure would like to highlight full support for further expanding deployment of alternative fuels infrastructure, since certain limited gaps in the network and infrastructure remain and prevent some member states to reach the objective. We are of opinion that by 2025 or at least by 2030 member states should fill the remaining gaps.

Although the Regulation on Alternative Fuels Infrastructure (AFIR) refers to directives like the Clean Vehicle Directive (CVD) and suggests to be in consistency with it, the German Biogas Association sees some contradictions or omissions. Whilst the CVD explicitly states the necessity of (Bio-) C/LNG infrastructure, this is not properly reflected in the AFIR.

In principle, the orientation of the ETD towards climate protection is welcomed, as it puts an end to the preferential treatment of fossil energy sources. However, there are some details to address in more clarity. 1. Definitions of categories There are no clear definitions within the Directive.

The BDEW supports in principle the adaptation of AFID in order to create the necessary framework conditions for the sustainable development of recharging and refuelling infrastructure for alternative fuels. In particular, the strengthening of the National Strategic Frameworks, the dynamic approach to the targets for charging infrastructure and the concrete targets for the development of hydrogen tankers…

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EDF welcomes the European Commission proposal for a Regulation on the deployment of alternative fuels, as part of the “fit for 55” package. The transport sector should indeed decrease its GHG emissions drastically to reach the renewed climate objectives enshrined within the EU Green Deal and carbon neutrality by 2050.

Alfaport Voka is the platform by and for companies and professional associations in the port of Antwerp, Belgium. Alfaport Voka is aiming for an accessible, facilitative, cost-competitive and sustainable port of Antwerp with a view to embedding sustainable employment and added value at the port.

In general, we applaud the regulation's intention of facilitating the adoption, deployment, and development of charging infrastructure across Europe, as well as improving interoperability and transparency for the benefit of both customers and the green transition in transportation.

Aerospace and Defence Industries Associations of Europe (ASD) thanks the European Commission for this opportunity to comment on the proposal. ASD is committed to the ultimate objective to reach a net-zero emissions aviation ecosystem in Europe by 2050, and to strongly contribute to the EU’s 2030 ambition.

CONFEBUS represents a sector compromised with sustainable development in road passenger transport and committed to making its fleets and operations as sustainable and energy efficient as possible. Spain has the most modern fleet of buses and coaches in the European Union. Thanks to the efforts of the operators who invest more than 600 million euros every year in renewing their fleets.

Hubject welcomes the Commission’s proposal for the AFIR and sees it as an opportunity for the EU to establish the right legal framework to create the best market conditions for a technologically interoperable EV charging infrastructure (EVCI) ecosystem to equip end consumers across the EU with a seamless EV charging experience.

As one of the most environmentally friendly solutions, public transport has a key role to play in the environmental and energy transition. Beyond the benefits of modal shift, public transport also contributes to the development of new forms of sustainable mobility using alternative energy sources (electricity, hydrogen, natural gas, etc.).

The ‘Fit for 55’ package paves the way for the implementation of the EU Green Deal, this set of legislative revisions represents a unique opportunity for Europe to take a step forward and win the climate race. That is why now it is the time to show steadfast commitment and prioritize the most efficient, sustainable and cost-effective pathways to decarbonize the economy.

Worldline, as the European leader in payment & transactional services industry and #4 player worldwide, welcomes the EU Commission’s initiative to revise Directive 2014/94/EU on the deployment of alternative fuel infrastructure (AFID). We are seeing a tremendous development of the EV Charging sector with more and more citizens, governments and businesses moving to BEV / PHEV vehicles.

RAG Austria welcomes the opportunity to comment on the legislative proposals regarding AFIR/CO2 standards. However, there is need for improvement in the following topics: • Technology openness of the drafts not given: With the focus on e-mobility in the transport sector, the existing potentials regarding rapid CO2 savings through the use of gaseous energy sources are massively misjudged.

Fleet Cards Europe (FCE) is a not-for-profit association (ASBL) established in Belgium in 2021 with the aim of representing the independent fleet/fuel card sector in Europe and facilitating fuel transactions for millions of commercial users across Europe. Our growing membership base includes key players in this market which are headquartered and operate across the continent.

I) Continuing the acknowledgment of the potential of all alternative fuels in the AFIR proposal is crucial The full potential of all alternative fuels must be included into the range of tools to reduce CO2 emissions efficiently.

REPSOL appreciates the efforts and the approach of the Commission on further improving the deployment of the alternative fuels in the transport sector. We appreciate the opportunity to provide our feedback to this Proposal and remain at EC’s disposal for any further clarification needed.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

NLA welcomes the aim of the AFIR proposal to spread out infrastructure for alternative fuels in Europe by setting binding minimum targets and changing the Directive to a Regulation. This is an important step in enabling the green transition of the transport sector. We note that the minimum requirements covering the TEN-T network is a starting point.

Region Kalmar County welcomes the fit for 55 package, as our county has a target to be completely fossil fuel free by 2030. Our regional development strategy builds on the following principles: Our work should contribute to less fossil CO2 emissions, more efficient use of energy and a growing business sector contributing to a sustainable development. The public sector should be a frontrunner for this development.

CHAdeMO Association calls for a truly transparent, open and inclusive process for the development of technical specifications and advise against prematurely mandating standards that would stifle innovation. *** CHAdeMO Association embraces the Commission’s enthusiasm and ambition for accelerating zero-emission transport.

Einride strongly believes that nearly half of heavy freight transport can be electrified immediately. Technically speaking, it is already feasible. But to get there, we need to challenge the status quo and in some ways start from scratch. Electrification of the transport sector will require a whole new ecosystem when it comes to logistics.

Gas Networks Ireland (GNI) welcomes the opportunity to provide feedback on the European Commission consultation on the Alternative Fuels Infrastructure regulation (AFIR) proposal. Decarbonising road transport is particularly challenging, given its energy intensity, with its energy use both growing and currently almost completely dependent upon imported oil.

Elia Group encompasses two electricity Transmission System Operators, Elia Transmission Belgium, and 50Hertz in the northeast of Germany. Contributing achieving the Green Deal's objectives is at the heart of our company's strategy. As such, we welcome the European Commission's "Fit for 55" package to align key legislation with the goal of reducing greenhouse gas emissions by at least 55% by 2030.

The process of amending the European Directive on the deployment of alternative fuels infrastructure (2014/94/EU, AFI Directive, AFID) is necessary to follow technical progress in the development of charging infrastructure and vehicle technologies.

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Please find attached the Norwegian Ministry of Transport's comments on the proposal for a new EU regulation on the deployment of alternative fuels infrastructure, In addition, technical remarks on the proposal is included in the appendix of the letter.

Danish Shipping welcomes the proposal on an Alternative Fuel Infrastructure Regulation (AFIR) as the infrastructure will be the backbone for using renewable and low-carbon fuels paving the way for climate neutrality by 2050. However Danish Shipping has strong concerns regarding the proposal’s focus on LNG due to the slip of the greenhouse gas (GHG) methane.

The European Commission’s “Fit for 55” legislation package also includes proposals for amendments to the Directive on the deployment of alternative fuels infrastructure, which will now take the form of a regulation.

The European Biogas Association (EBA) has been an active member of the Commission’s Sustainable Transport Forum assisting in implementing and fostering the deployment of alternative fuels infrastructure. We have likewise supported the Alternative Fuels Infrastructure Directive as a technology-neutral piece of legislation helping the EU to reduce its oil dependence.

Motus-e strongly welcomes the European Commission’s Proposal for a Regulation and fully supports the measures that aim to deploy alternative fuels infrastructure as a necessary instrument to reduce emissions from the transport sector in the long term in the European Union.

The transport sector requires fundamental changes to become more sustainable. Clean Air Task Force (CATF) welcomes the Commission’s proposal for a regulation on the deployment of alternative fuels infrastructure (AFIR) that aims to enable a widespread uptake of low- and zero-emission vehicles. It is a major step in the right direction. We believe, however, that the proposal can be improved.

In order to achieve the more stringent fleet targets and the necessary scaling-up of e-mobility, a binding, rapid and comprehensive expansion of the charging infrastructure (CI) across Europe is essential. We welcome the fact that the COM plans to use the legal instrument of a regulation to provide a firm legal basis for the accelerated expansion of the CI for EVs in the member states.

The European Sea Ports Organisation (ESPO) fully supports the European Green Deal ambition and the 2030 and 2050 goals enshrined in the EU Climate Law. The transport sector as a whole has an important role in helping to lower EU greenhouse gas emissions, which should be achieved whilst guaranteeing a level playing field with other modes and avoiding a modal shift. The greening of the shipping sector is a priority.

Although the Commission contemplates the use of various alternative fuels, with AFIR the Commission recognises the specific contribution of electricity in the transport sector and notably of smart charging to enable EVs to contribute to the flexibility of the energy system and to the further absorption of renewable electricity.

Please find JAMA feedback comments on a proposal for a regulation on the deployment of alternative fuels infrastructure and a strategic rollout plan to outline a set of supplementary actions to support the rapid deployment of alternative fuels infrastructure.

The Fédération Internationale de Motocyclisme (FIM) welcomes the opportunity to comment on the European Commission’s proposal for a revision of the Alternative Fuels Infrastructure Directive (AFID), published on 14 July 2021. As the global advocate of motorcycling and riders, the FIM welcomes the Commission’s initiative to revise the AFID and transform it into a regulation.

PGE Polska Grupa Energetyczna S.A. (hereinafter: “PGE S.A.”) welcomes the draft Regulation of the European Parliament and of the Council on the deployment of alternative fuels infrastructure, and repealing Directive 2014/94/EU (hereinafter: "AFIR proposal") as an important element of the “Fit for 55” legislative package and one of the key milestones to achieve climate neutrality by 2050.

The Baltic Ports Organization (BPO) welcomes "Fit for 55" proposal. However; there are a number of points that need to be addressed in order to make the "Fit for 55" package fit for purpose and assure the continuous competitiveness of the European port sector.

Gas Distributors for Sustainability (GD4S) welcomes the European Commission's proposal to invest in infrastructure to facilitate the decarbonisation of transport and deliver on energy transition objectives. GD4S believes that a technology-neutral approach is essential in the context of designing infrastructure models, adapted to a decarbonised energy system.

Fit for-55 package: Transport policy aspects The Bavarian Crafts Day (BHT) supports efforts to curb climate change. Crafts and trades are the engine of key climate policy concepts such as energy renovation of buildings, development of renewable energy concepts or pan-European charging infrastructure.

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We welcome the ambition to enable consumers to recharge or refuel their vehicles anywhere in the EU and as easily as is currently the case for conventionally fuelled vehicles, recognising that the broad mass of consumers will only switch to zero- and low-emission vehicles once they are sure they can easily charge and refuel them.

SEA-LNG Feedback on the Proposed Revision of Directive on Deployment of Alternative Fuel Infrastructure (AFIR) SEA-LNG Founded in 2016, with numerous high-profile members including shipping companies, ports, LNG suppliers, bunkering companies, infrastructure providers and OEMs (Original Equipment Manufacturers), classification societies, banks and brokers, SEA-LNG is a multi-sector industry coalition whose members…

ACEM welcomes the efforts of the European Commission in strengthening the provisions on the deployment of alternative fuel infrastructures across Europe. ACEM however regrets that the EC proposal 2021/0223 (COD) does not include express references or targets for the swift deployment of L-category vehicles charging stations.

France Hydrogène welcomes the new ambitions from the EU with the Alternative Fuels Infrastructure Regulation. The new Regulation will support the uptake of hydrogen refuelling stations (HRS), whose deployment will now become mandatory for Member States, instead of being optional as it was with the AFID.

The Methanol Institute welcomes the opportunity submit feedback concerning the Alternative Fuel Infrastructure Regulation. We support the spirit of the regulation, but suggest it be refined to reflect the plurality of solutions capable of delivering the necessary climate benefits to attain the Union's climate ambition.

• The proposal for the revision of Directive (EU) 2014/94 of the European Parliament and of the Council on the deployment of alternative fuels infrastructure under Article 2(3) introduces a new classification of the alternative fuels in sub-paragraphs (a), (b) and (c) on the basis of sub-definitions.

E.DSO welcomes the revision of the EU’s approach to Alternative Fuels Infrastructure and the FF55 package as a tool to equip the EU’s economy for climate neutrality. DSOs will be key actors for the achievement of the objectives of the regulation (AFIR) as the charging infrastructure for electric vehicles (EVs) as well as for other modes of transport will be connected to their distribution grids.

UNIFE, the association of European trains-metros-trams builders and rail equipment manufacturers, would like to bring to the attention of the European Commission our comments and reccomendations on the Regulation (AFIR) proposal. You will find our Position Paper attached. For all information and questions, please contact Mr. [name removed]: [email removed]

Helen Ltd. thanks the European Commission for the opportunity to give feedback Commission’s 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. Helen Ltd.

ElaadNL is the knowledge and innovation centre in the field of Smart Charging and the charging infrastructure in the Netherlands and is an initiative of the Dutch grid operators. ElaadNL welcomes the revision of the AFID into a regulation. The binding character of a regulation is essential to guarantee the roll-out of sufficient recharging infrastructure across all member states.

Regarding Article 6, clause 1: "To that end Member States shall ensure that by 31 December 2030 publicly accessible hydrogen refuelling stations with a minimum capacity of 2 t/day and equipped with at least a 700 bars dispenser are deployed with a maximum distance of 150 km in-between them along the TEN-T core and the TEN-T comprehensive network." It is not clear if the requirement for a 700 bar dispenser is for…

The European Commission’s Fit for 55 package sets important new goals for emissions reduction in transport. Giving a prominent role to renewable liquid fuels would create a solid foundation for reaching them. To that end, the EU should fully maximise the tools it has on hand for decarbonisation and de-fossilisation.

Please find attached the feedback of the Federation of German Consumer Organisations (Verbraucherzentrale Bundesverband e.V. – vzbv). vzbv is the umbrella organisation for more than 40 consumer organisations throughout Germany and represents the interests of German consumers vis-à-vis policymakers, the private sector and in public. vzbv is also a founding member of BEUC, the European Consumer Organisation.

DEKRA is an international independent testing, inspection and certification company with almost 44,000 employees in 50 countries and offers a broad portfolio of services. DEKRA is also specialized in various services connected to charging stations for electrical vehicles (EV).

Easycharger welcomes the European Commission’s initiative to revise Directive 2014/94/EU on the deployment of alternative fuel infrastructure (AFID) One of the key objectives set in the European Green Deal is to provide efficient, safe and environmentally friendly transport. All this because transport currently represents around 25% of total greenhouse gas emissions in the EU.

The German Banking Industry Committee welcomes the proposal of the Alternative Fuels Infrastructure Regulation. If users are to purchase or to use vehicles powered by alternative fuels, it is essential to recharge the cars without difficulties and to pay without unwelcome surprises. In this regard, uniform payment options and convenient ways to pay are essential.

This is a very good and ambitious proposal. Some remarks: - ISO 14687, ISO TS 21000 and ISO 19880-1 mentionned in the annex for hydrogen technical specification have been replaced by EN 17127 and EN 17124, in the 2019/1745/EU. These ENs were prepared by the CEN to address the exact need of the AFID.

General remarks Tesla welcomes the European Commission’s initiative to revise Directive 2014/94/EU on the deployment of alternative fuel infrastructure (AFID) in line with the objective to make the EU climate-neutral by 2050, for which rapid uptake of zero-emission vehicles is a key cornerstone.

Snam welcomes the opportunity provide feedbacks on the potential AFID revision, being a key instrument for the development of markets for alternative fuels, and would like to provide the following comments and suggestions: 1. A long term and stable regulatory framework as well as a clear long-term plan for each fuel is key to invest in alternative fuels infrastructure. 2.

In the context of the initial impact assessment of the revision of Directive 2014/94/EU on the deployment of alternative fuels infrastructure, the Spanish Association of Automobile and Lorry Manufacturers (‘ANFAC’), has attached a document with its comments on the subject, which can be summarised as follows: Mandatory registration of recharging and delivery points accessible to the public Setting targets and…

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Nelfo represents the electrical contractors in Norway. As member of the EuropeOn, representing the European electrical contracting sector, we welcomes the review of the AFID – directive, and supports the full decarbonization of the transport sector in view of climate neutrality objectives, through electrification as the most efficient pathway to clean mobility.

Transport is the only sector in Europe in which emissions have increased in the last decades. Today, transport emissions are nearly 20% higher than in 1990 , representing more than a quarter of Europe's greenhouse gas emissions.

GreenWay welcomes the opportunity to give input into the IIA of the AFID. GreenWay is a member of ChargeUp Europe. Priority: Instrument Replace Directive with Regulation. Replacing the Directive with a Regulation will deliver an accelerated rollout of harmonised infrastructure, enlarged in scope for all types of EV charging across the EU.

Revision of the Alternative Fuels Infrastructure Directive (AFID) Contribution by FEBIAC – the Belgian & Luxembourg Federation of Automobile & Two-wheeler Industry www.febiac.be 1. Cornerstone of the European Green Deal The European Union has set clear objectives to reduce emissions of greenhouse gases and pollutants from road transport.

We agree with the choice of the four problems identified in the inception Impact Assessment and the way they are to be tackled. We would however point out a fifth line of enquiry which concerns the range of fuels covered by the Directive.

Electrification of transport can be a game changer for the transport sector, still responsible for a quarter of greenhouse gases emissions in the EU. With falling technology costs, electric mobility can allow for the fast and efficient decarbonisation of road transport, while reducing air and noise pollution and improving health conditions in cities.

The Platform for Electromobility welcomes the initiative of the EC to revise the Directive 2014/94/EU and agrees in general with the proposed Impact Assessment (IA). The Platform would nevertheless like to call the EC to assess the following elements.

As the pioneer and global leader in zero-emission electric vehicles, the Alliance Renault-Nissan welcomes the revision of the Directive 2014/94/EU. It supports and recognizes the priorities flagged by the European Commission for this Initial Impact Assessment. It agrees the primary problem is an insufficient amount and coverage of charging stations.

Hydrogen Europe welcomes the upcoming revision of the Directive 2014/94/EU on the Deployment of Alternative Fuel Infrastructure, especially in light of the European Green Deal and its aim of becoming carbon neutral by 2050.

EVBox Group welcomes the opportunity to provide input into the IIA of the Directive on the Deployment of Alternative Fuels Infrastructure. Priority: Instrument Replace Directive with Regulation: Replacing the Directive with a Regulation will deliver an accelerated rollout of harmonised infrastructure, enlarged in scope for all types of EV charging across the EU.

ChargePoint welcomes the opportunity to provide input into the IIA of the AFID. Our input has been consolidated within ChargeUp Europe which we are member of. Priority:Instrument Replace Directive with Regulation. Replacing the Directive with a Regulation will deliver an accelerated rollout of harmonised infrastructure, enlarged in scope for all types of EV charging across the EU.

The Keolis Group is a global leader in shared mobility located in 16 countries (including 4 European countries + United Kingdom + Norway). As an expert in multimodality, the Group is the partner of public decision-makers who wish to make mobility a lever for the attractiveness and vitality of their territory.

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ChargeUp Europe welcomes the opportunity to provide input into the IIA of the Directive on the Deployment of Alternative Fuels Infrastructure. Priority: Instrument Replace Directive with Regulation. Replacing the Directive with a Regulation will deliver an accelerated rollout of harmonised infrastructure, enlarged in scope for all types of EV charging across the EU.

T&D Europe, the European grid technology providers association, welcomes the review of the Alternative Fuels Infrastructure Directive (AFID) in the spirit of the European Green Deal and the climate-neutrality objective of the EU. Our contribution touches upon the following concerns identified in the roadmap document: 1.

The Directive 2014/94/EU has created a significant basis to promote the deployment of alt. fuels in Austria. The implementation of the directive has also led to some beneficial measures and to future development. In combination with the renewable target in RED II and the CO2 reduction target in FQD the directive enabled many areas around alt. fuels to be expanded and optimized.

GIE welcomes EU’s ambition for low-emission, climate-neutral transport sector. Already today, LNG as a fuel can meet EU’s climate and air quality targets and lays the ground for carbon neutral liquified biomethane (LBM) and liquified synthetic methane (LSM) with very limited additional infrastructure investment.

The Bioenergy Association of Finland welcomes the opportunity to provide feedback to this initiative. We believe regulation should be first and foremost technology-neutral by defining the target but not the technical means to achieve it. Alternative fuels are clearly an important means to reduce harmful effects of transport.

EnBW Energie Baden-Württemberg AG supports the revision of Directive 2014/94/EU on the Deployment of Alternative Fuel Infrastructure to encourage the use of low- and zero-emission vehicles. To successfully contribute to the European Green Deal, we suggest the revision to highlight the following aspects: 1.

Using Biomethane for Transport Improves air quality and can lead to carbon neutrality. In Sweden, the share of Biomethane in Gas used for transport is 94 %. Renewable methane is already produced in incremental revolution in most European countries; The technology is ature and Biomethane Profits derived from the existing natural gas infrastructure in Europe. This means that we do not have to wait for the future.

Filed in Swedish · English published by the European Commission

EUROCITIES welcomes the proposal to revise the Alternative Fuels Infrastructure Directive. Given that the move towards electromobility and other alternative fuels is likely to be strongest at first in urban areas, it is important that the Directive reinforces the alternative fuels infrastructure strategies of city authorities, who are at different stages of deployment.

Leaseurope, the European Federation representing the leasing and automotive rental industries, supports the Commission’s aim to improve the EU’s network of recharging and refuelling stations for alternative fuel vehicles through the Alternative Fuels Infrastructure Directive (AFID).

UFE welcomes the revision of the Directive 2014/94/EU and supports the Inception Impact Assessment (IIA) proposed by the EC to adapt the Directive to the EU Green Deal. The AFID revision is needed to address a fragmented European charging infrastructure market, to support investment and remove market barriers, with the aim to allow a smooth uptake of e-mobility and a seamless driver experience for EU citizens.

“Striving to be the first climate-neutral continent” , this mission statement is the goal of the European Green Deal, which pursues the long-term establishing of a climate-neutral economy by 2050. One step to fulfill this aim is the establishment of a well-functioning, high-quality alternative fuels infrastructure.

The development of the electric vehicle market depends directly on the availability of charging infrastructure. The current wording of the AFID Directive dates back to the times when battery technology used in electric vehicles did not allow the replacement of combustion engine vehicles with electric vehicles.

EuropeOn welcomes the review of the directive on the deployment of alternative fuel infrastructure (AFID) and supports the full decarbonization of the transport sector in view of climate neutrality objectives, through electrification as the most efficient pathway to clean mobility.

The impact of the Alternative Fuel Infrastructre Directive (AFI) on the reduction of emissions from maritime transport is so far very small or not measurable. Maritime transport is subject to legislation other than road transport. The assumption that the mere provision of pre-defined technologies such as shore-side electricity or LNG bunkering infrastructure to reduce emissions in the maritime sector is not correct!

Filed in German · English published by the European Commission

The European Copper Institute welcomes the initiative of the European Commission to revise the Directive 2014/94/EU (AFID) and suggests to include the following elements in its Impact Assessment: * Binding targets for Member States regarding charging infrastructure for light duty vehicles on roads: at least 150 kW on the Core Network every 60 km both ways, within 18 months after the revised directive / regulation is…

GENERAL COMMENTS • Currently, transport sector accounts for a quarter of the UE’s greenhouse gas (GHG) emissions and this value continues to grow. • Natural gas (LNG/CNG) powered vehicles reduce GHG emissions of approximately 20-22% (sum of CO2, CH4 and N2O) and produce three times less NOx compared to gasoline or diesel vehicles. LNG-fuelled ships emit up to 100% less PM, up to 80% less NOX and up to 100% less SOX.

ECOS supports the Commission’s initiative to review the Alternative Fuel Infrastructure (AFI) Directive 2014/94/EU. Strengthening this policy framework is key for the increase of EVs on European roads, as envisioned by the European Green Deal, to become a reality. Overall, we welcome the objectives and policy options outlined in the Inception Impact Assessment (IIA).

AVERE believes a revised Directive must be improved to address the current barriers within the market today & to meet the objectives of the Green Deal. To improve coherence with long-term EU climate and energy policy, the revised Directive should be brought in line with the National Energy and Climate Plans.

E-mobility will not take off without charging infrastructure. Vattenfall therefore welcomes the initiative of the European Commission to evaluate the Directive 2014/94/EU on the deployment of Alternative Fuels Infrastructure. Vattenfall is convinced that e-mobility will play a key role to help the EU economy to reach carbon neutrality by 2050, by progressively reducing GHG emissions.

Fastned’s mission is to accelerate the transition to electric mobility, by giving freedom to electric drivers. Our goal is to develop and operate a European network of fast chargers for EVs along high traffic corridors. The main barriers we face with the roll-out of our network have to do with regulations and policies. A proper revision of the AFID is therefore crucial for the transition to e-mobility.

The AFID is of great importance since it sets reference targets for Member states as an indication of a given density of infrastructure that should be achieved. In this regard, the AFID has been fundamental in the development of the CNG and LNG market. Financial incentives have helped to improve the number of refuelling points, especially in Western Europe.

ANEC, the European consumer voice in standardisation, welcomes the opportunity to express its views on the European Commission Evaluation Roadmap/Impact Assessment published April. The EU urgently requires a new framework to work towards reduced emissions (zero emissions) and support the development of infrastructure for electric vehicles on European roads.

Representing the 450 e-mobility players around the world including 142 European members, CHAdeMO Association is the provider of CHAdeMO, the world’s first DC fast charging protocol (IEC/EN 61851-23, -24, IEC/EN 62196-3). To date, there are over 10,000 CHAdeMO charge points publicly available and which can serve over half a million across Europe.

Mr Kallista Energy wanted the revision of the FID to take into account the following issues: The charging infrastructure must contribute to the environmental objectives of the EU: It is not sufficient to move the emissions and the nuisances of the exhaust cylinders to remote power plants.

Filed in French · English published by the European Commission

Neste Corp. (neste.com) fully supports the Green Deal’s ambition for climate neutrality in 2050 and measures to encourage greater use of low-emission fuels. General remarks Any future review of the AFID Directive should seek to provide coherence and alignment of legislation with EU decarbonisation ambitions, and acknowledge all fuels that have a proven environmental record, including all alternative and renewable…

Please find attached the response of ESPO to the consultation. Please find below a summary of the main points. The greening of the shipping sector is a priority for European ports and Europe’s ports are committed to playing their part in helping the shipping sector to make this transition. Close cooperation between ports and shipping lines is required.

ASFE – the voice of paraffinic fuels in Europe – welcomes the initiative to revise the Directive on Alternative Fuel Infrastructure, as this piece of legislation has the potential to be the regulatory cornerstone for the deployment of alternative fuels in Europe.

The German Association of the Automotive Industry (VDA), representing 630 German based, mostly fully in the EU-internal market integrated and globally acting members across the whole automotive value chain, welcomes the opportunity to provide feedback on the inception impact assessment for an EU revision of the Alternative Fuels Infrastructure Directive (AFID).

The Federation of Enterprises (VBO FEB) welcomes the review of the Directive for Alternative Fuels Infrastructure (DAFI), which should consider the following priorities: 1. Cornerstone of the European Green Deal The European Union has set and clear objectives to reduce emissions of greenhouse gas emissions from road transport.

Filed in French · English published by the European Commission

Repsol shares the world’s ambition to reach climate neutrality in the framework of the Paris Agreement as well as the EU’s 2050 carbon neutrality objective. In this sense, on December 2nd, 2019, Repsol published its aim to become a net zero emissions company by 2050, making it the first oil & gas company in the world to assume this ambition.

smartEn welcomes the launch of a consultation phase with stakeholders in view of the revision of the Alternative Fuels Infrastructure Directive (AFID). We would like to highlight the following inputs on the published Roadmap/Inception Impact Assessment: • the scope of the identified Objectives and Policy Options to tackle Problems n.

Review of the “alternative fuel” definition Given the difficulty of reducing emissions of aviation and shipping, it is necessary to focus efforts on the decarbonisation of road transport to achieve carbon neutral economy by 2050.

MOTUS-E welcomes the initiative of the Commission to evaluate the Directive 2014/94/EU. We believe the current provisions fail to support the goals of establishing a common framework of measures to mitigate the environmental impact of transport, since many of the alternative fuels allowed in the present release emit CO2 and some of them are pure or derivate fossil fuels.

The current directive fails to mitigate the environmental impact of transport, since many of the alternative fuels currently allowed emit CO2 since some of them are pure or derivate fossil fuels. The current directive does not set the adequate framework to achieve long-term EU CO2 emissions reduction objective, as it does not adequately support the deployment of zero emission mobility.

The American Chamber of Commerce to the EU (AmCham EU) supports the EU’s ambition for low-emission mobility. The review of the Alternative Fuels Infrastructure Directive (AFID) as part of the Green Deal will be instrumental in meeting this goal. AmCham EU recognises that the current level of deployment of alternative fuels infrastructure in the EU is uneven across Member States.

Gas Networks Ireland (GNI) welcomes the opportunity to feedback to the European Commission’s initiative concerning Low-emission vehicles – improving the EU’s refuelling/recharging infrastructure. GNI is involved in two areas which will benefit Ireland and the EU from both an environmental and economic perspective: - Development of biomethane (Ref:1) injection infrastructure.

The International Motorcycling Federation (FIM), welcomes the opportunity to express its views on the European Commission Evaluation Roadmap/Impact Assessment published on 6th April. It is commonly accepted that electric vehicles are the future, especially if the European Commission’s ambitious climate targets, as set out in the European Green Deal, are to be met by 2050.

The EU urgently needs a new and robust legislative framework on zero emission infrastructure to support the 33-44 million electric cars (battery and plug-in hybrid) expected on the road in 2030 to align with transport decarbonisation goals. Consumers should have access to the EU single market for chargers.

To achieve the objectives set out in the Green Deal, all EU policies and sectors will need to make their contribution – notably the transport sector. As E.ON explicitly advocates for electric mobility in road traffic, we welcome the Commission’s commitment to spur the action needed to keep the transition towards cleaner mobility and the EU on the path in meeting its Paris climate commitments.

To achieve the objectives set out in the Green Deal, all EU policies and sectors will need to make their contribution – notably the transport sector. As innogy, part of the E.ON group, explicitly advocates for electric mobility in road traffic, we welcome the Commission’s commitment to spur the action needed to keep the transition towards cleaner mobility and the EU on the path in meeting its Paris climate…

The Alternative Fuels Infrastructure Directive (AFID) is of great importance since it sets reference targets for Member states as an indication of a given density of infrastructure that should be achieved. In this regard, the AFID has been fundamental in the development of the CNG and LNG market.

The combined experience of our numerous accession scooters leads us to make the following observations and proposals regarding the improvement of charging structures with a view to the Green Pact for Europe. We note that there are 3 types of charging applied: At destination, occasionally, roaming. 1 Achieve affordable and safe energy for recharging at destination.

Filed in French · English published by the European Commission

Please find enclosed the opinion of the Verbraucherzentrale Bundesverband (vzbv) on the European Commission’s Combined Evaluation Roadmap with our requests for the revision of Directive 2014/94/EU on the deployment of alternative fuels infrastructure (AFID).

Filed in German · English published by the European Commission

Due to national measures to promote alternative fuels, the number of hydrogen refuelling points in Germany has increased from 20 in 2016 to 83 at the beginning of 2020. The existing network focuses on agglomerations and main transport routes and also makes it possible to reach every location in Germany. The national objective is to achieve the competitiveness of hydrogen mobility by 2025.

Filed in German · English published by the European Commission

Europe’s inland ports, as Enablers of Green Logistics, welcome the chance to evaluate the Alternative Fuels Infrastructure Directive. As the unique representative of inland ports in Europe since 1994 – constituting of nearly 200 inland ports located in 18 Member States of the EU and Switzerland, Serbia and Ukraine – EFIP underlines that this Directive is a key piece of the green transition, which will be hugely…

In line with the overall contribution to the Green Deal implementation published by ACEA on 22 January (https://www.acea.be/publications/article/paving-the-way-to-carbon-neutral-transport-10-point-plan-to-help-imple), automobile industry considers investment into alternative fuels infrastructure absolutely essential and the proposal on the AFID review should be presented by the Commission even sooner than foreseen…

Eurelectric agrees with the identified problems in this Inception Impact Assessment (IIA) and generally supports the objectives, direction and policy options put forward by the Commission. Electrification of transport within an increasingly cleaner electricity mix is the most effective, efficient and sustainable way to decarbonise the sector, reduce its dependence on fossil fuels imports from outside Europe and…

CONFEBUS welcomes the European Commission's initiative to review the fulfilment of the objectives of Directive 2014/94/EU. The Directive established clear and non-binding national targets for the deployment of refuelling points and refuelling stations for alternative fuels in a general way for road transport without focusing on particular transport modes.

Suggestions the undertakings which are members of the European Confederation of Small Enterprises — CEPI — together with the participating undertakings engaged in the carriage of goods by road and the carriage of passengers, as well as of the undertakings operating with the means used for their own account, invite the Commission for Transport and Tourism to consider, assess and include in the motion for a…

Filed in Italian · English published by the European Commission

Especially the accessibility of charging stations for electric vehicles and mobility devices will become more important in the coming years, also in the light of the EU Green Deal. The key thing to consider is the direct interaction between an individual and the electric vehicle charging point.