AFIR presents a crucial opportunity to enable the decarbonisation of the transport sector, the only sector whose emissions have risen since 1990. However, the deployment of infrastructure must occur in a manner which is consistent with the broader energy transition: by efficiently using limited resources in a targeted way, so that overall emissions can be reduced at a pace that is in line with the aims of the Paris Agreement. 

The core of our asks relate to the need to phase out the use of fossil fuels and build sufficient additional renewable power generation capacity, support fuels which are net-zero compatible and reinforce the grid for their production, without cannibalising the broader energy transition. This requires the elimination of the transition phase for fossil fuels as well as the introduction of mandates for the bunkering of hydrogen carriers in maritime ports, for use in ships, instead of LNG. 

1. Hydrogen needs to be targeted and produced with additional renewable

Ensuring that hydrogen-based fuels are produced in a way that does not increase emissions elsewhere in the system is crucial to ensure these fuels truly meet their emissions abatement potential. This includes the use of additional renewable electricity, produced from newly deployed renewable power generation capacity, as well as, where carbon is required, the use of carbon of atmospheric origin.  

Direct electrification through batteries, and not hydrogen, is the most viable option in the long term for heavy-duty vehicles. Moreover, fuel cell electric trucks are estimated to be market-ready only in the late 2020s. In other words, the targets in the regulation are currently too high and should therefore be indicative and be reassessed in the regulation’s revision foreseen in 2026. 

2. All chargers should be Smart-Charging ready 

Requiring all chargers to be smart ready will enable a roll-out of infrastructure that can both support the much-needed switch to direct electrification, and help the grid to cope with the integration of high penetration of non-dispatchable renewables. Only smart chargers can ensure that the batteries of the EV fleet become useful to the grid, by providing balancing services instead of creating a further demand peak, that will require power generation from fossil fuels. If the smart charging requirement is not extended to all chargers in AFIR, Europe will risk locking-in charging technologies that will be already outdated by the time they are deployed. 

3. LNG should be excluded from AFIR 

LNG is a fossil fuel and is not net-zero compatible. A phase out of LNG should be planned, rather than further deployment of LNG infrastructure. 

Setting mandatory targets for the supply of LNG means creating a fossil-fuel lock-in and is likely to result in either continued emissions or stranded assets, neither of which are desirable outcomes. Additionally, upstream emissions from LNG can often undermine the supposed emission reductions from its use. Alternative options are already being deployed. These include direct electrification and hydrogen-based carriers, such as hydrogen and ammonia for use in ships, that do not emit CO2 upon combustion.  

4. Make electrification user friendly 

The signal of this legislation must be that from 2025, every European citizen can reach any destination within the EU with an EV, thus requiring an even greater deployment of charging infrastructure, beyond the core network. 

All consumers, regardless of their residency arrangements, should have easily accessible public charging infrastructure available on a daily basis. This could be facilitated through uptake of charging at parking spaces on commercial properties like shopping malls, grocery stores and sports facilities.  

Card readers should be mandatory for all charging stations in order to remove unnecessary obstacles for users and prevent any delay in the shift to electrification. 

5. Extend support for heavy-duty vehicle charging 

Deploying chargers at safe and secure parking areas, urban nodes and logistic depots is crucial to speed up the uptake of electric heavy-duty vehicles.  

Battery electrification is already being deployed in trucks and is a more efficient use of limited renewable electricity than producing hydrogen and using it in a fuel cell—both of which have high efficiency losses.  

Enabling electrification by setting binding targets for chargers and indicative targets for hydrogen refuelling infrastructure will ensure that hydrogen does not form an obstacle when electrification is the better option. 

6. Shore-side electricity supply in maritime ports should be extended to all type of ships 

Shore-side electricity (SSE) is already being deployed today. Therefore, the mandates should increase the scope of its targeted use to include a broader range of ships, with a more ambitious timeline. Furthermore, smaller ships can more easily connect to SSE and should therefore be included.