Fit-for-55: Fit for industry?
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The obligation to assess the utilisation of waste heat on-site and off-site (Art. 24 para. 4 letter (b)) should not be mandatory in case an industrial installation is not running the entire year but seasonally only.
10. Proposal for a revised Alternative Fuels Infrastructure Deployment Regulation (AFIR) and Strategic Roll-Out Plan The regulation lays down binding requirements for the comprehensive development and expansion of an EU-wide network for charging and refuelling infrastructure for all relevant drives and fuels and for all modes of transport: road, airports, sea and inland ports. By presenting a regulation to replace the directive, the Commission is sending an important signal to its member states, because the comprehensive expansion of charging and refuelling infrastructures is a basic prerequisite for achieving the national and European climate protection targets in transport. With concrete targets for the different modes of transport, charging points and refuelling stations are to be expanded along the TEN-T network, differentiated according to core and comprehensive network. A positive aspect is, that the regulation is fundamentally open to all technologies: electric mobility, charging infrastructures for passenger cars, light and heavy commercial vehicles, alternative fuels, refuelling infrastructures for hydrogen and natural gas and onshore electricity supply on airports and ports. However, recitals 5, 6, 7 and 8 state that in the passenger car sector, the EU Commission is primarily focusing on BEVs and PHEVs, the further use of natural gas must be linked to a clear decarbonisation path, LNG will play a continued role in maritime transport, while only limited use is expected for inland waterways and roads. Regarding roads, the Commission’s view is too short-sighted, at least in terms of the contribution LNG can make to decarbonisation, especially in road freight transport in this decade, as long as marketready ZEVs are not available in long-haul transport. The same applies to biofuels, even if they do not require a separate tank infrastructure. The EU Commission should also recognise these bridging solutions by setting binding targets for the deployment of LNG refuelling infrastructure without creating lock-in effects. It is also right that the EU Commission puts a strong focus on road transport and changes the system to the installed charging capacity instead of the number of charging points. However, it should be noted that the specifications of 1kW per BEV/ 0.66 kW for PHEVs are insufficient for the necessary EU-wide EV ramp-up. In addition, it is important to keep in mind that the AFIR has a central role to play with regard to the EU CO2 Fleet Regulation: in order to effectively support the required ramp up of electromobility and to achieve the ambitious fleet limits, a binding, rapid and comprehensive expansion of the EU wide charging infrastructure is indispensable. For air and maritime transport, the EU Commission is presenting tight schedules. In order to avoid additional burdens on the industries, subsidies will be needed - where the regulation at least allows for the possibility of subsidies in Art. 13, para. 5.
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