"In order to further accelerate the expansion of charging infrastructure for electric vehicles, increase user-friendliness, and ensure affordable charging prices, a coherent, cross-departmental 'Overall Charging Strategy' is essential. Against this background, the VDA fundamentally assesses the draft of the 2030 Charging Infrastructure Master Plan as positive.

The draft contains a number of proposals suitable to increase the attractiveness of e-mobility. These include, above all, simpler and faster approval procedures, accelerated grid expansion and grid connections, lower charging prices through greater transparency and competition, a greater focus on charging infrastructure for electric trucks and buses on highways and at depots, and adjusted framework conditions for bidirectional charging. However, there is still room for improvement.

In detail:

The draft rightly provides for targeted support measures for charging infrastructure in multi-unit buildings. However, it is also important to implement the requirements of the EU Building Directive (EPBD) regarding the expansion of charging infrastructure at parking spaces of buildings into national law without delay and as ambitiously as possible. Flexibility of the EU minimum requirements should only be provided where appropriate and necessary. The bundling of charging points across multiple locations, referred to in the draft under the term 'pooling', would significantly weaken the EU requirements and contradict the goal of a comprehensive charging infrastructure. It must therefore be rejected categorically.

The expansion of the charging infrastructure for heavy commercial vehicles and buses must be pushed forward urgently, as the still completely inadequate availability of charging points represents the main obstacle to the ramp-up of electric commercial vehicles and buses. The commitment to further expanding the charging network for electric trucks along the motorway at serviced and unserviced rest areas is therefore expressly to be welcomed. The additional funding for charging infrastructure at depots and work yards, including the necessary grid connections, is sensible but must be provided with sufficient resources. The charging network for commercial vehicles should definitely incorporate the foreseeable trend toward autonomous vehicles. The draft still requires improvement in this regard.

Unfortunately, the current draft does not adequately address the growing segment of light electric commercial vehicles. Dedicated measures to support the development of specific charging infrastructure, particularly in urban areas, are urgently needed. In this regard, the draft falls short of expectations.

Power grids play a key role in the further expansion of the charging infrastructure. Currently, Germany's power grids are not equipped for the energy transition and the ramp-up of e-mobility. Particularly in view of the high performance requirements of the truck charging network, the expansion must be forward-looking, i.e., oriented towards future demand. The right path will be further forward-looking development of grid expansion based on improved demand forecasts, as envisaged in the draft master plan. Furthermore, applications for grid connection must be submitted within the framework of a nationwide, uniform, digital process. The draft sets the right focus here by expanding digitalization and standardization to include medium-voltage grid connection procedures. Furthermore, better transparency, standardization, and bindingness of grid connection procedures are required—there can be no compromises here.

The draft sets the right focus with the planned 'innovation bonus' for bidirectional charging facilities, but falls short when it comes to the crucial issue of double taxation: electricity tax, network charges, and concession fees must now be eliminated quickly in the vehicle-to-grid application, i.e., when feeding back into the general supply network, so that bidirectional charging can establish itself in the market.

The fact is: Affordable charging prices are crucial for the market ramp-up of e-mobility. To relieve the burden on consumers and increase the attractiveness of electric vehicles, reducing charging prices through greater transparency, competition, and technology is crucial. With the abolition of disproportionate fees, i.e. for nighttime parking and blocking, as well as the creation of a transparency office for ad hoc charging prices, the draft contains good proposals toward affordable and user-friendly charging prices. However, when it comes to electricity tax, the draft falls short of the coalition agreement. This must now be swiftly improved, and the electricity tax for e-mobility must be reduced to make charging electricity significantly cheaper.

Furthermore, the German government must advocate for more ambitious targets in the Alternative Fuels Infrastructure Regulation (AFIR) at the European level. The current AFIR minimum targets are not ambitious enough and don't do justice to the market ramp-up of e-mobility in Europe. Higher density and performance targets, earlier intermediate stages, and uniform specifications along the entire TEN-T network are necessary to accelerate the expansion of charging infrastructure across the EU and thus create an important prerequisite for the success of e-mobility in Europe."