Shaping new mobility efficiently and intelligently

Political demands of the BEM

Policies in Germany for environmental protection in society, the economy and mobility fall short of their potential. The majority of actors across the political spectrum are in favour of greater compatibility between the requirements of modern industrial societies and the need to preserve and care for the environment. As a result, however, Germany achieves at best a middling result in terms of actual implementation.

Politics in Germany is not setting the pace for reform. Previous decisions in transport policy have neither led to a reduction in the climate impact of our mobility nor triggered a change in social behaviour. Changes are already failing due to a lack of concepts, a lack of detailed knowledge on the part of those responsible, a lack of interdisciplinary interfaces and a high level of interest on the part of administrative staff in maintaining tried-and-tested working methods and the usual framework of influence by maintaining existing contacts, relationships and advisors.

The Bundesverband eMobilität e.V. (BEM) has been promoting electric mobility based on renewable energies as the most efficient drive solution for 15 years. With the help of political decisions already taken in Brussels and the tentative, initial beginnings of reform in German road transport, the BEM believes that the groundwork has been laid to restructure transport policy efficiently and intelligently and to reorganise the New Mobility in a meaningful way with fresh forces.

The following recommendations of the Bundesverband eMobilität are based on the technical advice of the BEM working groups, which work openly and differentiated according to individual topics and include the knowledge and expertise of relevant pioneering companies in electromobility. It is not uncommon for them to belong to the reform wing of the German SME sector, for whom feasibility and affordability are a matter close to their hearts. They are all united by the awareness that new technologies and smart connections form the basis for creating jobs and added value and for combining prosperity and environmental protection.

Creating more clarity in politics and legislation

The BEM urgently recommends a separate legal framework for electromobility and a new specialist organisation with appropriate experts.

To date, electromobility has been an unloved additional topic in the ministries’ areas of responsibility.
There are neither interdepartmental working groups in the federal ministries nor a separate legal framework.

Status Quo

  • 25 different laws, regulations and ordinances from various ministries govern the eMobility sector
  • Various, sometimes contradictory third-party laws
  • technical support and advice is the responsibility of a federal organisation that was originally responsible for hydrogen

Electric Mobility Act (EmoG)

• only 8 paragraphs
• without a clear legal mandate
• does not cover all eMobiles
• expires in 2026

1. Create more clarity in politics & legislation

To date, electromobility has been an unloved additional topic in the ministries’ areas of responsibility. There are neither interdepartmental working groups in the federal ministries nor a separate legal framework. Although an Electric Mobility Act (EmoG) has been created, the mere eight paragraphs are a far cry from a suitable set of regulations. The law does not have a clear legal mandate, nor does it cover all electric vehicles. The pinnacle of the caveat is made clear by the law’s expiry date – it is dated 31 December 2026, which means that companies and investors have virtually no legal certainty.

According to research by the German eMobility Association, more than 25 different laws, regulations and ordinances from different departments currently govern issues relating to the specialised field of electromobility. If you want to know how electromobility is organised in Germany, you have to wade through a wide variety of sometimes contradictory third-party laws. What’s more, technical support and advice is the responsibility of a federal organisation that was originally responsible for hydrogen. This energy source has since been widely defined as a champagne solution for private transport and has rightly been rejected. Nevertheless, the supervision of electromobility is still located there; we do not see a general understanding and the necessary depth of expertise in electromobility – proof of the lack of understanding of the novelty of the subject area on the part of the previous decision-makers. The BEM urgently recommends a separate legal framework for electromobility and a new specialist organisation with appropriate experts.

In order to strengthen the expertise in this area, the association recommends the use of staff specifically assigned to the topic, who also maintain regular dialogue between the ministries, do not shy away from conflicts of interest, share findings, work on joint papers and help shape the regulatory framework – not just in the coordination rounds.

The dialogue and working groups of the National Platforms for Electromobility have proven to be unproductive or even obstructive. Instead of making new decisions, the meeting of selected participants turned out to be a club of worriers and fossil-fuelled preservationists. The BEM is not aware of a single relevant reform that can be traced back to these committees. The new drive requires new organisational anchoring that already has the courage to change and dares to look ahead.

Building in more acceptance for interoperable systems

The transport transition is largely dependent on energy supply issues. Systems, technologies and organisations must be enabled to cooperate and connect with each other.

  • Exempt all CO2-free energy sources from the EEG levy
  • Consider the potential of mobile storage systems through charging and discharging compared to stationary storage systems

Charging infrastructure

  • Standardise charging infrastructure
  • Drive-through DC charging points
  • Enable network operators to make charging infrastructure affordable
  • Operation should be subject to the free market economy
  • Speed up bureaucratic processes

The battery

  • Produce and recycle batteries regionally
  • Introduce a transparency register for raw materials
  • Ensure general humanitarian compatibility

Security

  • Personnel qualification
  • Training and generating new skilled labour
  • Establishing new safety standards for transport, rescue, recovery and construction
  • Cybersecurity and interoperable systems, utilisation of the Mobility Data Space area

2. Building more acceptance for interoperable systems

Electromobility stands for new connections: Charging electric energy instead of filling up with petrol and diesel – sharing instead of ownership – digital instead of analogue – electric drive instead of combustion engine – regionally available energy instead of fuel imports – resource efficiency instead of scrapping – renewable energies instead of fossil fuels.

The new drive and new mobility solutions are associated with changes: for systems, technologies and organisations that need to be enabled to cooperate and connect with each other. This applies in particular to the transport, energy and digital sectors.

The transport transition is largely dependent on energy supply issues. So it is not only CO2 free mobility, but also the value and use of primary energy, which must be reduced = efficiency.

Imbalances in the organisation of the energy transition for mobility must be rectified. One example of this is the different treatment of the EEG levy. While the use of hydrogen is exempt from the EEG levy, users of electromobility currently have to pay the levy for charging electricity, even though they contribute directly to reducing the burden on the environment. It would be logical to exempt all CO2-free energy sources from the EEG levy.

New forms of battery utilisation should be included in the regulation at an early stage. Traction batteries from electric vehicles will play a significant role as storage capacity in the energy grid. The potential of mobile storage through charging and discharging must be recognised in the same way as stationary storage.

In order to utilise this potential in a targeted and environmentally conscious manner, batteries should be produced and recycled regionally, a general transparency register for raw materials should be introduced and humanitarian compatibility should be ensured.

Standardised interfaces should be created in order to use batteries in a variety of ways and increase their interoperability.

The charging infrastructure also needs to be standardised. Standardisation has already been completed in the automotive sector, but not in the other mobility sectors. It is currently conceivable that a 40-tonne lorry could charge at a fast-charging point and block the entire charging park due to the length of the vehicle. The BEM is calling for drive-through charging points for the logistics sector, for articulated lorries and also for people with disabilities. This includes all vehicles that cannot be manoeuvred into a parking pocket. As before, the charging point becomes a dead end.

Standardisation also applies to payment: uniform access, price transparency and price reduction across Europe are top priorities here. Network operators should be empowered to make charging infrastructure affordable, and operation should be subject to the free market economy.

The aim of the reforms must be to make charging simpler, safer and more reliable.

When it comes to safety, there are still many things lacking in electromobility: in the qualification of existing personnel, in the training of new specialists, there is a lack of robust safety standards across all forms of mobility through to transport, recovery and construction regulations. New standards need to be defined here.

Realise consistent implementation

If you want to reduce greenhouse gases, you have to make decisions and agree on measures.

Maritime sector

  • Favour or promote the purchase of electrically powered watercraft or conversion to e-drive in the same way as for road transport

Lightweight vehicles

  • Promote classes L1e-L7e
  • Adjust maximum speed to 59 km/h

eAviation

  • Promote with research and development funds

Construction, agricultural and special machinery

  • Acquisition and conversion analogous to other conversion programmes
  • Link public tenders to zero-emission requirements
  • 2-stroke engine registration ban from 2024

Plug-in hybrids for cars are merely a bridging solution

The BEM has presented a three-stage model for the reform of the PHEV vehicle subsidy: Stagger the payment of the environmental bonus and stagger it according to environmental impact; push the use of vehicles as e-cars and reward actual gains in positive environmental impact.

3. Realise consistent implementation

The organisational weaknesses in the political apparatus mean that there is a lack of consistency in the content of administrative measures. This has an impact on the lack of or weak regulation. The allocation of state subsidies, the creation of parking space or the consideration of infrastructural necessities is extremely selective, mostly car-driven and without meaningful coordination.

From the BEM’s perspective, the purchase of electrically powered watercraft or the conversion to e-drive in the maritime sector should be favoured or subsidised in the same way as road traffic. The improvement in the area of noise emissions is considerable in addition to the CO2 reduction. The expansion of the charging infrastructure on water (inland and sea) is absolutely essential.

A similar equalisation must be achieved for light vehicles. Vehicles that achieve high savings, particularly in the area of primary energy, have so far been completely ignored by German politicians, despite their enormous potential for reducing emissions. Light vehicles in the L1e-L7e classes should also be promoted. In the interests of smooth and safe transport, the maximum speed of classes L1e, L2e and L6e should be adjusted to 59 km/h in order to be able to integrate into the traffic flow.

Construction, agricultural and special machinery can now also be powered by electricity. Their purchase or conversion should be promoted in the same way as other conversion programmes. Public tenders should be linked to the requirement of zero emissions. There should be a ban on the registration of 2-stroke engines for special-purpose machines and all other vehicles from 2024.

The eAviation sector should be supported with funds from research and development. Following the lack of international emissions trading in aviation, there is a lack of incentives for a market-side, environmentally orientated repositioning. At the same time, air transport is already achieving high emission savings – for example in noise emissions. This development can be accelerated.

The German Federal Association for eMobility is aware that many changes in the transport and energy transition could mean deep cuts for existing business models and concepts. This is right and necessary in the interests of the environment and value creation. Nevertheless, there is not just black and white. Smart solutions build transitions. It is important to actively take responsibility for the social impact through reorganisation processes, retraining, rebuilding and strategically sensible investments.

Responsibility also includes unbiased communication: if you want to reduce greenhouse gases by 65% by 2030, you have to make decisions and take measures that go against previous habits. These are political decisions, such as the closure of combustion technology – for the last petrol and diesel car off the production line and the last combustion engine on the road.

Plug-in hybrids are merely a bridging solution for passenger cars. If you use these vehicles predominantly in combustion mode, they are more harmful to the environment than a pure combustion car. Unfortunately, the vehicles are hardly ever charged in practice and are therefore not used as electric cars. Granting tax benefits for this is counterproductive. The BEM has presented a three-stage model for the reform of the PHEV vehicle subsidy. The payment of the environmental bonus is staggered and staggered according to environmental impact. Customers should be encouraged to use the vehicles as e-cars and the actual gain in positive environmental impact should be honoured.

Remove bullshit

Funding programmes for combustion vehicles must be stopped.

All privileges and benefits for the combustion engine must be discontinued immediately.

Germany does not recognise its own real electromobility. There is a lack of data collection and official recording. Calculations provide a blind flight into the future.

Federal Motor Transport Authority

  • Record battery capacities, storage potential, energy requirements, load and demand peaks of e-vehicles on the market

eTrailer

  • Use enables considerable CO2 savings, but the Federal Ministry of Transport does not recognise any environmental effect

With an expiry date of 31 December 2026, the current Electric Mobility Act does not provide any perspective.
Electric mobility players have no legal certainty in Germany, which urgently needs to be changed.
Every day without a concept weakens companies ready for reform. Mobility companies need planning and investment security.

4. Remove bullshit

It is undisputed that the transformation towards greater sustainability is only just beginning. Neither is the fact that a lot of expertise first needs to be developed and disseminated. However, when parallel structures emerge or are knowingly maintained and work against each other, it is justified to speak of bullshit politics because it lacks leadership and clarity.

Electromobility is being promoted with taxpayers’ money – at the same time, the use of diesel vehicles is being incentivised through tax reductions or exemptions. Such parallel structures are not understandable for people involved in the reorganisation of economic processes – especially when there is no exit scenario. All privileges and benefits for the combustion engine must be discontinued immediately.

While the federal government is promoting the purchase and now also the conversion of buses and lorries to alternative drive systems, the same players have failed to provide companies, cities and municipalities with clear guidelines for action. A wide range of subsidy programmes continues to reward the purchase of diesel vehicles – in various programmes – without stopping. One example of this is the scrappage scheme for commercial vehicles, which has the nice title of ‘promoting the renewal of the commercial vehicle fleet’. Support programmes for combustion vehicles must be stopped.

The Federal Motor Transport Authority collects all data on vehicles of the previous type: This includes power output, engine capacity, weight figures and even fuel type. In the case of electric mobility vehicles, however, the KBA cannot make any statements about charging performance, charging standards or battery capacities of registered vehicles because these are not recorded. Due to these information gaps, the Federal Government is unable to provide any overview, e.g. of battery capacities, storage potential, energy requirements, load and demand peaks of e-vehicles on the market – and therefore cannot provide any real data for the provision of renewable energy in the transport sector. Germany does not know its real electromobility, which is like a lack of scaling and therefore like flying blind into the future.

And the shortcomings continue: In the trailer sector, considerable CO2 savings are possible through the use of eTrailers. Electrically powered trailers have their own drive and reduce the load on the towing vehicle. The Federal Ministry of Transport does not want to recognise any environmental effect here. Recognising this would reduce revenue in the toll system, a process which, incidentally, cannot be carried out in practice as the toll system does not differentiate between the different emission classes of trailers.

The list could be extended at will. The fact that different federal authorities provide different information on the data situation is more of a minor lapse. There is also miscommunication on the part of users. While the energy industry, for example, speaks out against the Schuko plug in order to make charging safe, manufacturers equip vehicles with this cable as standard. The only thing missing here is a common dialogue and a common understanding. Nothing more. The installation of a charging point must also be reported to the grid operator in accordance with the Low Voltage Connection Ordinance: However, there is still no uniform, nationwide standardised reporting form.

In the end, this all has to do with the lack of specifications and the destructive signals for the overall process. The current Electric Mobility Act does not provide any perspective with its expiry date either. It ends on 31 December 2026, which means that electromobility stakeholders in Germany have no legal certainty and this urgently needs to be changed.

With every day of bullshit and further procrastination on upcoming decisions, politicians are weakening the very companies that are actively investing in the transport transition. If companies knew today what the legislator envisages by 2030 and beyond, the market would have clear framework conditions and companies would have the necessary planning and investment security. The EU provides clear backing for this, and the market in Germany is

Simple & digital expansion

The electromobility system requires networked players and faster action, which can be achieved with the help of digitalisation.

The BEM is urgently calling for the creation of digital identities in order to standardise basic processes in the vehicle trade and allow for new business models.

Germany does not recognise its own real electromobility. There is a lack of data collection and official recording. Calculations provide a blind flight into the future.

Use of data

  • Create standards that are in line with European data protection
  • Operate on platforms that are accessible to all interested parties and provide the right interfaces
  • Devices must be able to communicate with each other

At this interface, it will then be all the easier to combine different forms of transport and promote intermodality in cities and the countryside.

Speeding limit

The BEM supports the calls for a speed limit of 130 km/h and welcomes the scientific promotion of AI projects, especially in the mobility transition.

5. Simple & digital expansion

In Norway, it takes 15 minutes to register a car. Online, from home. Simple & digital is the least common option, especially in German offices. This is where things urgently need to change. Last year, the vehicle registration offices provided an impressive example of working methods that have completely fallen out of time, registering and deregistering vehicles depending on the municipality, official sick leave and corona regulations, without finally resorting to nationwide online registration with a digital vehicle file and digital identities. The BEM is urgently calling for the creation of digital identities in order to standardise basic processes in the vehicle trade and allow new business models. If the players network their actions with the help of digital data, they can speed them up enormously. The BEM therefore supports the German government in shaping the framework conditions.

Word has got around that it is not the end device that will generate the turnover in the transport sector of tomorrow, but rather the data of the drivers using it that will create the business models of tomorrow. Those who know how customers act and how their lives can be supported are close to the revenue. Standards must therefore be created for the use of data that are in line with European data protection, are operated on platforms that are accessible to all interested parties and provide the right interfaces. For example, data is not the fundamental property of vehicle manufacturers

At this interface, it will then be all the easier to combine different forms of transport and promote intermodality in cities and in the countryside.

With digital help, it is also possible to develop artificial intelligence in the transport sector. Manufacturers are currently experimenting with self-driving vehicles for public and private transport. These vehicles are equipped with sensors, control units and software. A speed limit is necessary to ensure their long-term functioning, in order to guarantee safety and enable technical progress. The BEM therefore supports the calls for a speed limit of 130 km/h and welcomes the scientific funding of AI projects, especially in the mobility transition.

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