How the proposed amendments in Guidelines and Standards for Public EV Charging Infrastructure better enable EV adoption in India

Charging infrastructure is a lifeline for battery-driven electric vehicles (EVs). Taking cognizance of the importance of scaling up charging station rollout, about five and half years ago, in 2018, Ministry of Power issued the first set of guidelines and standards for implementation of this new-age electrical infrastructure. Since then, the EV charging market has evolved and so has the understanding of the complexities and challenges in on-ground deployment. The guidelines and standards trying to stay relevant have also undergone revisions, from light touch changes to major amendments, five times (yes, in five years). The process is still on!

About a month back, Bureau of Energy Efficiency (BEE), the Central Nodal Agency (CNA) for development of public charging infrastructure, floated a draft version of a new set of revisions. This time public feedback has been sought on the proposed amendments which is a welcome step by BEE. Taking this opportunity, I spent some quality time in going through the existing provisions and the proposed revisions. I find several changes are more for bringing clarity and some to effect system improvements. Ease of installation and ease of access along with affordability seem to be the primary guiding principles for shaping the proposed amendments. While studying through the lens of the stakeholders who will be directly impacted by the guidelines, I find that the proposed amendments may benefit from more nuanced thinking. Also, taking a longer-term view of realizing a matured charging ecosystem may be useful and some provisions to this end can be explored which are within the scope of this guideline document. Hence, I considered it my responsibility to highlight these and went on to submit my suggestions for improving the upcoming amended guidelines and standards (views and comments expressed were personal).

To learn from the community of professionals who are in the thick of actions, and gauge my present understanding of the issues, I thought of sharing some of my suggestions here.

(There is a time lag of ~ one month between the submission of my comments and making some of them public here, in order to avoid influencing possible feedback from fellow commentators.)

Let me start with the suggestions that are not addressed sufficiently by the existing guidelines or the proposed changes. Instead of a laundry list of to-dos, I preferred to make three key suggestions.

• Decarbonization of motorized road transport is a key driver for the transition to electric. Therefore, enough effort should be made to realize deeper GHG emission cuts from vehicle electrification. The only way to achieve this is optimally using renewable energy. Following is my suggestion:

The amended guidelines should emphasize integration of charging infrastructure with renewable energy. To do so, the guideline document can lay out the different regulatory mechanisms available through which renewable energy can be cost-effectively integrated with EV charging, such as net metering, net billing, Group Net Metering and Virtual Net Metering, Green Energy Open Access, etc. The guideline document should also urge State Electricity Regulatory Commissions to take progressive outlook toward innovative instruments based on energy-as-a-service model.

• Emergence of electric mobility has potential implications, in the form of opportunities as well as challenges, for the power system at multiple levels, from electricity generation to distribution. In this context, smart or managed charging is a potential lever to futureproof EV charging. Hence, my humble submission is:

The amended guidelines should recognize the importance of smart or managed charging. The guideline document should define what it entails and stipulate certain building blocks to achieve that. It is important to highlight that communication architecture plays a key role in implementing smart charging that is responsive to grid requirements. It is strongly recommended that the market players adopt open-source protocols for communication like the Open Charge Point Protocol (OCPP) for communication between EVSEs and Charger Management System, Open Charge Point Interface (OCPI) protocol to offer e-roaming to EV users, and Open Automated Demand Response (OpenADR) protocol for demand response-related communication exchange between a distribution licensee and charge-point operators/ EV users. The “Handbook of Electric Vehicle Charging Infrastructure Implementation” published by NITI Aayog advocates adoption of these communication protocols. The guidelines should also encourage the relevant authority to develop open-source communication protocol for low-power AC charging (equivalent to OCPP) since adoption of OCPP for communication with these charging points is found to be cumbersome and not cost-effective. Open Charge Alliance is believed to be developing a light version of OCPP for low-power AC charging points.

• As the human world is increasingly getting digitalized and becoming a connected system, there is looming threat to our cyber security. Charging infrastructure which draws strength from its digital core is not immune to these risks. That's why, my strong suggestion is:

Guidelines should be developed to address cyber security concerns since EV charging relies on interconnectedness and data flows. One may take cues from similar efforts in advanced EV markets like the formulation of Cybersecurity Framework Profile for Electric Vehicle Extreme Fast Charging Infrastructure by the National Cybersecurity Center of Excellence in the US.

There is more room to recommend in order to orient the guideline document towards the future, but I find these can be taken up at an opportune time later instead of hurrying up now.

Coming to the specific guidelines, existing or proposed, there is enough scope to improve without going overboard.

• The existing Guideline 2 brushed up by some proposed clarificatory changes highlights the right of an individual or an entity to set up public EV charging stations provided the system is compliant with the technical and safety norms, performance standards and protocols. I feel, this leaves a room to misinterpret, especially the legality aspect. My suggestion, therefore, is:

The guideline seems to overlook the aspect of legal access to land and electricity connection. The guideline should stipulate that the individual/ entity should have a legal right or arrangement to use the land or floor-space where it wishes to set up a public charging station. Similarly, the individual/ entity should have a legal right or arrangement to use an existing electricity connection or apply for a new connection to energize its public charging station.

• Guideline 3.1, viii rightly stipulates tie up with at least one online Network Service Provider (NSP) to enable advance remote/online booking of charging slots by EV owners. My recommendation here is:

The guideline should mandate adoption of Open Charge Point Interface (OCPI) or an equivalent protocol as recognised by the CNA that supports information exchange between multiple network service providers (NSPs) and charge point operators to enable automated roaming (also known as e-roaming [1]) between charging networks for the ease of charging. This is critical to provide hassle-free charging experience to EV users that will help promote EV adoption.

[1] e-roaming refers to an EV user's ability to take service of different charging networks even if it is a customer of only one charging service provider. In practice, it means that an EV user can have access to thousands of charging points of different operators with just one customer account.

• Guideline 3.1, xi prescribes that public charging stations should have the feature of prepaid collection of service charges with the time of the day rates and discount for solar hour. I wonder how this can be practically effected without having clarity on pricing structure. Hence, my observation here is:

Time-of-day rates for EV charging and discounted rate during solar hours are extremely important to align charging sessions with the greenness of grid electricity. However, it is not clear how this pricing structure is linked to prepaid collection of service charges and the mechanism to make the collection.

• Guideline 4 is a key amendment proposed in this round of revision. Recognizing the importance of access to charging in a community set-up, it rightly specifies a set of Resident Welfare Association (RWA) community charging requirements. However, I feel the guideline should also highlight the right of an individual EV user to have the option of installing one's own charging unit. Therefore, my suggestion is:

In addition to the proposed amendments, it is recommended that the RWA should allow an individual EV user to install private charging point at his/ her dedicated vehicle parking spot, if any, for which the cable can be drawn from his/ her meter or from the RWA’s trunkline (that caters to common area power requirements) through appropriate sub-metering and billing. Electricity tariff would be as per the rate applicable to the RWA’s common area electricity consumption.

• The existing Guideline 6.1 (brushed up with few proposed changes) lays down certain key requirements with regard to density of charging points. However, I find, this merits a fundamental relook as far as the approach is concerned. My recommendation in this regard is:

The amendment should encourage state and city authorities to carry out periodic mapping (at least once in 5 years) of the geographic distribution of potential EV charging demand through a spatial analysis methodology. Geospatial analysis helps map the relative EV charging demand at different locations. This can then be used to distribute public charging infrastructure in different areas, in proportion to the charging demand. Typically, such an analysis is useful to assess charging demand distribution across a city or region. Detailed step-by-step methodology for geospatial analysis of charging demand distribution is laid down in the Handbook of Electric Vehicle Charging Infrastructure Implementation (version - 1) issued by NITI Aayog. Such planning is helpful in the long run. It is time the administration takes a holistic approach toward charging infrastructure planning and does not rely only on rule of thumb.

• Guideline 7.1, ii prescribes public charging station operators to register on “EV Yatra” portal and regularly update the public charging station data. In order to emphasize, I suggest:

In addition, all public EV Charging Station Operators should be mandated to share through “EV Yatra” portal all the incidences of downtime of a charger and durations of charger downtime on a regular basis. Frequent incidences of downtime are found to be a major widespread issue with the existing public charging stations that is hurting charging experience of EV users and is becoming a barrier to EV adoption.

• The existing Guideline 8.3 lays down requirement for separate metering arrangement a public charging station so that consumption is recorded and billed as per applicable tariff. What about the cases of submetering which is often done when a charging station is set up inside a host facility like a mall? This is a gray area that needs immediate attention. Guidelines should not be designed considering standalone public charging stations only. I tried to highlight this issue, but the solution lies with the State Electricity Regulatory Commissions.

Although no amendment has been done here, it is recommended that the guideline clarifies the tariff applicability in case of sub-metered connection for EV charging which is usually done in a mall, workplace, or any host-facility.

• Guideline 9.4 is a recent amendment coming into effect since the latest revision was notified in April 2023. It stipulates certain ceiling limits on the service charges for serving the capital expenditure as recommended by a committee under Central Electricity Authority. In my view, this potentially has some far-reaching consequences. Although I fully appreciate the intent of this provision which is to make public charging affordable and avoid profiteering by charging service providers, I have some reservations regarding its implementation and effectiveness. My observations are:

o?? It is not clear from the amendment how the ceiling limit for charging fee rate will be based on the fixed ceiling limit for the service charges for serving the capital expenditure. Does the guideline imply that the limit on charging fee will be as follows?

Cap on charging fee rate = Applicable electricity tariff + Ceiling limit for service charges for serving capital expenditure + GST ????

This should be clearly stated in the guideline.

o?? It is important to bear in mind that the service charges (Rs./ kWh) for serving the capital expenditure depends on the capacity utilization of a charger/ charging-point. Rate of cost recovery will be lower if the utilization is high and vice-versa. In view of the current limited capacity utilization of the existing charging stations and lack of data to evaluate, it is not clear how the committee under CEA has accounted the utilization factor in determining the ceiling rate. If wrongly estimated, this may potentially impact the viability of an investment in charging infrastructure.

o?? Considering that differentiated electricity tariffs have been proposed as per solar and non-solar hours of a day, it is not clear why different ceiling rates have been proposed for service charges for serving capital expenditure which is in fact not linked with availability of solar energy. It appears that time-of-day aspect has been factored twice in considering the charging fee rate. A clarity on the appropriate formula for setting charging fee rate will be helpful (refer to the first comment on Guideline 9.4).

o?? The guideline should clarify under which conditions the set service charging ceilings are applicable to a public charging station. Will the ceilings be applicable to only those public charging stations that benefit from central capital subsidies and/ or concessional land rentals offered by a central public entity? Will the public charging stations set up under state initiatives such as the ones tendered by state authorities have to follow the ceiling rates? Will a public charging station installed by a private chare point operator without taking financial support from the government have to comply with the ceiling limits? The guideline should clearly state the conditions under which these caps are applicable.

o ??One should be mindful of the downsides of price capping practice. It has distortionary effect on the market dynamics, especially when the market like charging service is still evolving and has uncertainty in its business viability. It is preferable that the market players, i.e., charging service providers get conducive environment to realize profitability in their investments, where the watchdog’s responsibility is to identify and penalize malpractices like cartel formation among charging service providers.

These apart, I raised some more points, largely clarificatory in nature.

Regarding the proposed "definitions", I find there is scope to spell clearly what Community Charging Station means considering it is an important element of providing access to charging. My take on this is two-fold.

o?? The proposed amendment refers to a Community Charging Station as “public charging station”. As per the definition given in the guidelines, a public charging station means “EV charging station where any electric vehicle can get its battery recharged” i.e., it has no restriction to access. This implies that a community charging station will also have unrestricted access to any EV user which means it is not necessary that the user has to be a resident of or authorized visitor to the RWA or the residential accommodation. Is this the intended meaning of the given definition? If not, it is suggested that a community charging station should not be referred to as a public charging station. As a matter of fact, guidelines in some countries have a distinct category for charging stations called semi-public which is neither purely private/ captive nor entirely public. A community charging station can be treated as a semi-public facility. Currently, the guidelines for charging infrastructure in India do not have such a category.

o? ?As per the proposed definition, it seems only an owner of a flat or an authorized visitor is allowed to charge at a community charging station. Is this the intent of the proposed amendment? The guideline should take into consideration the charging requirement of any resident of a RWA or residential accommodation who may not be necessarily an owner of a flat or a visitor there. A tenant of a flat who is residing there is essentially a resident of the RWA. That is why, a tenant is allowed to use the vehicle parking spot allotted to the flat or its owner. Based on this logic or practice, the tenant should also have the right to charge at a community charging station. Therefore, it is recommended that the definition of a community charging station should not discriminate against tenants residing at a RWA or residential accommodation.

I hope the concerned authority finds my suggestions meaningful. Would be interested in understanding views from my knowledgeable colleagues here. Feel free to share your take.

Disclaimer: Views and comments expressed are personal. The author does not have any direct commercial interest in anything related to EV charging. This article is in the context of the draft version of proposed amendments in Guidelines and Standards for Public EV charging Infrastructure which was uploaded for eliciting public feedback on https://beeindia.gov.in/en . The purpose is to initiate a dialogue on improving the EV charging ecosystem in India.

Awadhesh Kumar Jha Akshit Bansal Maxson Lewis Varun Chaturvedi Paras Shah Jyotiranjan Harichandan Ramkrishna Singh Sandeep Bangia N MOHAN Imthias Mohamed Kasturi Gomatham Srujana Raghupatruni Patnaik Akhil Jp Pravin Kumar Ravi Teja Kuchibhatla Gargi Singh Sumit Dhanuka Kartikey Hariyani