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The Regulatory Assistance Project

RAP

We are a global, non-profit team of experts focused on the long-term economic and environmental sustainability of the power and natural gas sectors, providing technical and policy assistance to policymakers and regulators on a broad range of energy and environmental issues.

Lobbying Activity

Meeting with Anne Katherina Weidenbach (Cabinet of Commissioner Dan Jørgensen)

22 Oct 2025 · Citizens Energy Package

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur)

13 Mar 2025 · Electricity grids

Meeting with Bruno Tobback (Member of the European Parliament)

17 Feb 2025 · Prioriteiten voor de komende legislatuur op vlak van industrieel beleid en onderzoek

Response to Technical specifications related to the format, frequency and quality of data on alternative fuels infrastructure

19 Dec 2024

We welcome the European Commissions continued efforts to creating a unified and harmonised EV charging market in Europe. Standardisation in view of creating a user-centered transparent ecosystem for (smart) EV charging, both for private and public charging, contributes significantly to this objective. With this in mind, our comments relate to two pieces of draft legislation (submitted in two parts): 1. In the proposed Annexes to Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2023/1804 of the EuropeanParliament and of the Council as regards specifications and procedures relating to the availability and accessibility of data on alternative fuels infrastructure, Table B, number 9 we suggest replacing the first two bullet points with the following three: - CPO provides user option for charging control to optimise on prices - CPO accepts MSP profiles for charging control - External charging control without user consent In the case of this third bullet point, a corresponding new data field in Table F (dynamic data) should be made available for this purpose, which, for the sake of transparency for the user, provides insight into historical, current and expected limitations in charging capacity beyond the user's control. Table B, number 10 we propose to extend this with the following optional values: - On-site generation of renewable electricity - Granularity of Guarantees of Origin used (location, time unit) Furthermore, we propose to make this value also optionally available as a forecast, which may be particularly relevant in the case of on-site generation, which also requires the availability of a corresponding new data field in Table F (dynamic data) (optional, only available if needed). With regard to Table F, number 3 (price), we note that - in line with the current exchange of price information between parties in the EV ecosystem - it is necessary to link each price element to a time element, so that it is clear from when and until when a price applies. This is particularly relevant also in view of smart charging and the proliferation of time-varying, including dynamic, prices at public charging locations. In the case of bi-directional charging, a price table with discharge prices (and relevant time elements) should also be published. This is not now clear from the current proposal.
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Response to Standards for wireless recharging, electric road system and vehicle-to grid-communication of recharging infrastructure

19 Dec 2024

We welcome the European Commissions continued efforts to creating a unified and harmonised EV charging market in Europe. Standardisation in view of creating a user-centered transparent ecosystem for (smart) EV charging, both for private and public charging, contributes significantly to this objective. With this in mind, our comments relate to two pieces of draft legislation (submitted in two parts): 2. Concerning the draft technical specifications regarding communication between the electric vehicle and the recharging point (vehicle-to-grid communication) in Annexes to COMMISSION DELEGATED REGULATION (EU) /... of XXX amending Regulation (EU) 2023/1804 of the European Parliament and of the Council as regards standards for wireless recharging, electric road system, vehicle-to-grid communication and hydrogen supply for road transport vehicles: While we welcome further standardisation, we also see that the proposed technical standard does not yet have full clarity with regard to conformity testing, among other things. We also see continuing need to address ambiguities and interoperability issues (as is done in IEA EV-TCP Task 53, among others). This means that at the moment of review, in December 2024, there is still uncertainty about possible adaptations, and in particular also market adoption (both in charging hardware and vehicles). We see no need to prescribing ISO 15118-2 as proposed in point 2.1.1, which could lead to higher costs with no clear added value. For point 2.1.2, we suggest removing the reference to ISO 15118-2 as well, so that it is not made mandatory, using the same argument. Regarding 2.1.3, requiring ISO 15118-20 for private charge points, we note that this creates an undesirable incentive to install Mode 2 charge points, which will, after all, be clearly cheaper. ISO 15118-20 in itself does not currently provide any concrete benefits for users of private charging points (residential/commercial). Our recent market research on smart charging [https://www.raponline.org/toolkit/strong-growth-in-tariffs-and-services-for-demand-side-flexibility-in-europe/] shows that, in addition, charger-centric smart charging plays an increasingly minor role; most providers use direct communication with the vehicle. This makes it unclear how mandating this standard, which leads to higher charging hardware costs and possibly also creates unwanted lock-in effects due to the certification structure and associated communication requirements, leads to user benefits. It is different with bidirectional charging. We therefore welcome, in the case of bidirectional charging points, the prescription of this ISO 15118-20 standard for that purpose. Here too, however, possible adaptations are to be expected making an entry date of 2027 uncertain, including with regard to grid code processing, and vehicle-hardware interoperability issues. The Commission reflects this progressive development in the explanatory memorandum, and it would be good to see this reflected accordingly in these annexes.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and Climate Action Network Europe and

4 Jul 2023 · Electricity Market Design Reform

Meeting with Ciarán Cuffe (Member of the European Parliament, Rapporteur) and Siemens Energy AG and European Building Automation and Controls Association

21 Jun 2023 · Energy Performance of Buildings Directive: opportunity for countries to unleash the potential for smart and cost-effective solutions (Staff level)

Meeting with Kathleen Van Brempt (Member of the European Parliament)

9 May 2023 · first exchange of views on the GDIP with focus on NZIA - APA

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Bureau Européen des Unions de Consommateurs and

20 Jan 2023 · U.S.-EU Task Force: Best practices in Energy Savings and Flexibility Other participants: Cleantech-Cluster Energy, ELVIA, EU DSO Entity, California Energy Commission, ASE, AEE, ComEd, Octopus Energy, OPower, Uplight

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Bureau Européen des Unions de Consommateurs and

17 Oct 2022 · US-EU Task Force Convening: energy efficiency and energy savings. The California Energy Commission, ACEEE, ASE, Advanced Energy Economy, Arcadia, ComEd, Octopus Energy, OhmConnect, OPower, Uplight and the Covenant of Mayors also participated.

Response to Greenhouse gas emissions savings methodology for recycled carbon fuels and renewable fuels of non-biological origin

17 Jun 2022

The Regulatory Assistance Project (RAP) appreciates the opportunity to comment on the European Commission’s draft delegated acts on the “Production of renewable transport fuels – share of renewable electricity (requirements)” [hereinafter “RFNBO Production DA”] and “Renewable energy – method for assessing greenhouse gas emission savings for certain fuels” [hereinafter RFNBO GHG Methodology DA”], issued pursuant to the Renewable Energy Directive. When comparing the ambition level for domestically produced green hydrogen included in the REPowerEU communication of 18 May 2022, we can’t but conclude that the commensurate level of renewable power production is not foreseen. This is concerning as the regulatory framework should lead to optimal outcomes and a level playing field. Renewable hydrogen producers are intended to only use electricity from new renewable power installations. RAP is not sure the Delegated Acts are sufficiently considering potential adverse impacts of electrolysers on the electricity system and consumer. To counter this concern regulators should consider expeditiously implementing locational energy pricing. The grandfathering provision introduces many unhelpful incentives, and it may therefore lead to better outcomes if it were removed. See the attached document for more detailed comments.
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Meeting with Claudia Gamon (Member of the European Parliament, Shadow rapporteur) and Energy Cities

25 Apr 2022 · Gas & Hydrogen Package

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

The Regulatory Assistance Project welcomes the opportunity to provide feedback on the changes to the EPBD. The introduction of MEPS is essential to kickstart renovation, but the design has several flaws. Targeting homes with EPC labels of G and F, combined with the proposed EPC reforms, would address 15-30% of the stock by 2030. The upper end of this range, 30%, is an appropriate and achievable ambition. However, no pathway for MEPS implementation beyond 2033 is set out. This should be rectified as clarity and certainty are vital. An opportunity to introduce trigger points — sale and rent — before 2027 to phase in the regulations and enable the supply chains to scale up is also missed. Requiring F&G buildings to achieve only EPC E is a larger missed opportunity. The MEPS should require buildings to meet a standard that enables heating system decarbonisation as the next step. This should be defined as the energy efficiency and heat distribution system requirements to enable homes to be heated using lower temperature water and for heating schedules to operate flexibly at different times of the day without compromising comfort. Heating with lower-flow temperature water is more efficient and important for the primary solutions: heat pumps and district heating. Enabling homes to be heated flexibly is essential, allowing new electric loads from heating to be absorbed efficiently by the electricity system. The new standard should be translated into an EPC label (eg D). By 2030-33, 30% of the stock should reach this standard. The inclusion of the social safeguards in Articles 9 and 15, and the requirement to monitor impacts on energy poor households, are very positive. The Social Climate Fund will not, however, be large enough to both provide compensation for the impact of the ETS2 price and the investments needed for low-income households, as several studies illustrate. New funding or ringfencing of existing sources is essential. The requirement for Member States to set out plans to decarbonise heating and cooling by 2040 in their NRPs is positive. However, this should be elevated from a reporting requirement to the main Directive. This element of the Directive must be coordinated with other elements of the Fit for 55 package. These include local and stronger heat planning, ‘efficient’ heat network requirements under the recast EED, and changes to Ecodesign. The end to fossil fuel boiler subsidies by 2027 should be brought forward to 2024 or sooner to, at a minimum, align with the EED. We welcome the focus on the smart EV charging. However, the minimum thresholds for new and renovated buildings to install charging stations, or pre-cabling, forgo the opportunity to target all properties. Article 12.4 on dimensioning for simultaneous use should reflect the ability of smart charging to manage power flows, both within the building and in interaction with the grid, to avoid over-dimensioning. For this, standards that allow EVs to communicate with other energy assets within the building and with external signals, such as dynamic energy pricing and demand-response services, are vital. In residential buildings, the provisions on pre-cabling should, where possible, be extended and/or combined with bike spaces to reflect the needs of e-bikes as well as possible modal shift. Building standards, supported by product standards, should mandate that building systems are smart-enabled when constructed or upgraded to future-proof investments. The EPBD should require Member States to integrate demand-side flexibility objectives into supply-chain capacity building and customer engagement strategies, such as one-stop-shops. Data sharing and interoperability provisions — an important addition to the EPBD — must operate seamlessly with those in the Electricity Directive and pending Demand-side Flexibility Network Code with coherent, robust governance.
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Response to Review of the CO2 emission standards for heavy-duty vehicles

14 Mar 2022

The Regulatory Assistance Project (RAP) welcomes the opportunity to give feedback on the revision of the CO₂ standards for heavy-duty vehicles (HDVs). RAP fully supports the overall aim of the revision in view of the EU’s ambition to reduce greenhouse gas emissions by 55% by 2030 and to reach climate neutrality in 2050. CO2 standards are a crucial tool to drive decarbonisation and electrification of the road freight sector. They should be an important focus because the electrification of freight transport is emerging in practice as the most cost-efficient and thus most effective method of decarbonisation. They can help address two of the main barriers of road freight electrification which are limited availability of electric models as well as high upfront cost of vehicles. When considering the upfront cost of zero-emission HDV, the current developments in fuel costs present an opportunity. The higher the costs for fossil fuels, the more important it is to maintain this price level and to use the resulting additional revenues to ensure a faster switch to ZEV. To encourage electrification of urban deliveries in particular, an extension of the scope of the regulation to all other groups of lorries, in particular small to medium-sized lorries below 16t is important. The speedy deployment of HDV charging infrastructure at commercial depots and logistics hubs, as well as charging hubs across main European highways (Trans-European Transport Network (TEN-T) corridors) is crucial and needs to be done in a well-planned, grid-optimal manner to encourage electrification of road freight at least cost. To support HDV charging infrastructure build-out, ambitious HDV charging infrastructure targets for 2025 in the currently negotiated Alternative Fuels Infrastructure Regulation (AFIR) proposal are important.
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Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson) and Transport and Environment (European Federation for Transport and Environment) and

2 Dec 2021 · EPBD - Energy efficiency - Minimum Energy Performance Standards

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

19 Mar 2021

The Regulatory Assistance Project welcomes the opportunity to provide feedback on the EPBD Roadmap. Significantly strengthening the EPBD and broader energy efficiency and decarbonisation policies, is key to significantly raise the rate and depth of renovation this decade. We support ambitious implementation of option 3. A robust framework of minimum energy performance standards (MEPS), supported by funding, finance and practical support (technical assistance and local one-stop shops), is the central tenet in the renovation framework. The framework of MEPS must set out the long-term trajectory for different building sectors, providing certainty. It must also swiftly ramp-up renovations this decade. As MEPS are introduced with a long lead time to enforcement, the design of the first-stage standard should focus on driving maximum voluntary renovations before compliance and ensuring the greatest benefits through choice of target buildings and standard to be met at a compliance date before 2030. Scale of energy savings is achieved through requiring a large number of buildings to meet a moderate standard or a smaller number of buildings to undertake deep renovations. Residential buildings should not be excluded this decade. They account for 75% of the stock (floor area) and renovating the worst-performing homes alleviates energy poverty. Public buildings, a very small percentage of the European stock, are addressed through (a strengthened) Article 5 of the EED. Synergies between the EPBD and Art 5 must be sought, but overlaps avoided. Transactional trigger points alone will not drive the scale of renovation needed, particularly in 2030, even if deep renovations are required. On average, each home in Europe will be sold once before 2050. At their next sale, every home would need to be fully decarbonised if relying on the trigger point alone. Reliance on transactional trigger points risks creating an underclass of buildings, as some buildings will not be sold. MEPS can guarantee renovations for the households most burdened by the impact of a new carbon price on heating fuels, as envisaged in the extension of the EU ETS. MEPS and the enabling framework of financial and practical support and outreach should deliver significant renovations, before the carbon price, to those who will be most burdened but have least ability to mitigate the impact. Robust verification of the design of national MEPS and compliance with the standards is essential given the flexibility needed for Member States to design nationally appropriate standards. Energy Performance Certificate data have potential to serve this function. The EPBD revision should improve the penetration of EPCs, the reliability and comparability of assessments and the transparency of data. Building tools like the EPC, building renovation passport (BRP) and deep renovation standard must serve the purpose of full decarbonisation. The cost-optimality calculation is out of step with this priority. The methodology must be revised to take into account the full costs (including of inaction) and multiple benefits, using an appropriate time horizon. These tools should encourage optimal solutions that combine the priorities of demand reduction, the switch to decarbonised heat sources and demand-side flexibility and storage – including electric vehicle charging - more holistically. BRPs are a very useful step to communicate this path to building owners and occupiers. Standards for smart communication - for systems like heat pumps and EV charging infrastructure - between the building and the energy system ensure optimal integration. These should be part of the ‘smart readiness. Smart vehicle charging allows for the optimal integration of EVs into the energy system. Minimum thresholds for residential and non-residential buildings on (ducting for) recharging infrastructure should be removed, fostering home and work charging. Given the scale of the essential changes, a full recast should be considered.
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Response to Revision of EU rules on Gas

10 Mar 2021

Please find comments from the Regulatory Assistance Project attached.
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Response to Review of Directive 2012/27/EU on energy efficiency

17 Sept 2020

Regulatory Assistance Project (RAP) welcomes the opportunity to give feedback on the EED roadmap. The Commission (EC) aims to ensure that energy efficiency (EE) sufficiently contributes to the achievement of a higher 2030 climate goal. While it is important to consider this pending target, the EED revision should also be geared towards the 2050 climate neutrality objective and aim at 1) tapping into all cost-effective energy savings potential; 2) avoiding locking in fossil fuel infrastructure. RAP recommends that the 2030 EE target be included in the scope of the revision. It should be increased to reach the 2030 and 2050 climate objectives while maximising benefits for society. Not increasing the target would send a negative signal about the importance of EE in meeting climate goals. The target should be made binding to provide more certainty. The fact that national targets do not add up to the EU 2030 target jeopardises its achievement – as experienced with the 2020 target. The review should consider introducing binding national targets or requiring Member States (MS) to revise targets upwards. It’s important that the EC reassess the role of Art. 7 in reaching an increased target. The credibility of energy savings delivered under Art. 7 should be reinforced by increasing transparency, e.g., by creating a public scrutiny board looking at MS’ measurement, verification and evaluation (MV&E) frameworks. The board could identify problems and best practices and aim to improve the accuracy and consistency of reported savings across MS. This would provide more confidence in policy measures and support the development of an EU-wide MV&E system. Revising Art. 5 offers the opportunity to align it with the Energy Performance of Buildings Directive objective — highly-energy-efficient and decarbonised building stock by 2050, facilitating the cost-effective transformation of existing buildings into nearly zero-energy buildings. The EC should consider i) extending the current scope of Art. 5 to additional buildings, e.g., those occupied by regional/local authorities, schools, universities, hospitals ii) ensuring that buildings are in scope whether public authorities own or rent the building, and iii) ensuring that sufficient technical and financial support is available to manage the transition. The EC should consider minimum energy performance requirements for these obligated buildings. It should look at how these requirements could be extended to other segments of the building stock, such as social housing and commercial buildings. Finally, it should consider requiring public authorities to adopt an energy management system and track operating performance. Art. 14 should be revised i) in light of the 2050 objective, reconsidering the role of cogeneration in a climate-neutral Europe, and ii) together with Art. 23-24 of the Renewable Energy Directive to fully decarbonise heating systems and enact the efficiency first principle. RAP recommends the EC mandate a phaseout of subsidies for fossil fuel based heating systems, incl. within Art 7. An integrated planning process for heating and cooling should be introduced, possibly requiring MS to do this at the appropriate geographic level (as determined by MS). The EC should i) explore whether amending Art. 15 could help recognise the value of EE and demand response in grid operation (impact on network loss, relieving local congestion) and grid development (avoided grid extension), and introduce an obligation for network operators to consider EE requirements in tariff design. Network companies should not be incentivised to invest into the physical grid, as opposed to non-wire solutions. To that end, National Regulatory Authorities should be mandated to revise remuneration schemes to move towards a total expenditure basis. Art. 20 should be reinforced with the creation of a dedicated EU financing facility for building renovation, funded by a share of EU Emissions Trading System revenues.
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Meeting with Maroš Šefčovič (Vice-President) and

23 May 2016 · Energy Union governance