AVERE urges the European Commission and in particular DG MOVE's Sustainable Transport Forum (STF) to speed up its work on harmonising accessibility requirements in terms of communication features, hardware and site design. While establishing a European standard might not be possible in a short space of time, it is essential that the European Commission publishes, as soon as possible, its guidelines promoting best practices ensuring the user-friendliness of charging infrastructure while offering flexibility to charging point operators and equipment manufacturers involved in achieving our charging point deployment targets.
POSITION PAPER
Charging for All - A Vision for an Accessible European Charging Infrastructure
Europe is currently undergoing a notable e-mobility revolution, characterised by a surge in electric vehicles (EVs) and a significant increase in charging infrastructure. The European Alternative Fuels Observatory (EAFO) reported a staggering 600,000 recharging stations across the continent in 2023, showcasing a dedicated move towards sustainable transportation. These figures are poised to rise further following the recent adoption of the Alternative Fuels Infrastructure Regulation (AFIR) and the upcoming Energy Performance of Buildings Directive (EPBD) by European lawmakers.
Beyond advocating for green alternatives, AVERE is committed to ensuring that e-mobility is accessible to all, with a particular focus on designing recharging points that cater to individuals with reduced mobility. However, the absence of a standardised approach to accessibility at the EU level poses a significant hurdle to the widespread deployment of inclusive recharging infrastructure across Europe. The lack of uniform guidelines not only complicates the user experience for individuals with reduced mobility, but also presents challenges for businesses striving to implement accessible recharging solutions as several countries may have different approaches or guidelines (see here for Sweden, here for Ireland, and here for the United Kingdom), while other countries already prepare legislations (see here for France and here for Germany).
Harmonisation of European accessibility requirements for the charging infrastructure will allow manufacturers of both automobile and charging equipment infrastructure to design and produce in compliance with the standards that are in force in all EU Member States. A standardised pan-European approach is essential to enhance user accessibility, harmonise the minimum requirements, simplify the manufacturing processes, streamline the deployment process, and encourage businesses to invest confidently in inclusive electric mobility infrastructure across Europe. A streamlined European approach to the accessibility of charging infrastructure will prevent a patchwork of regional regulations and guidelines as well as interpretation differences between different Member States, which will help the EU Member State governments to meet the charging infrastructure deployment targets set by the recently adopted the AFIR and the EPBD.
In this context, AVERE urges the European Commission and in particular DG MOVE's Sustainable Transport Forum (STF) to speed up its work on harmonising accessibility requirements in terms of communication features, hardware and site design. While establishing a European standard might not be possible in a short space of time, it is essential that the European Commission publishes, as soon as possible, its guidelines promoting best practices ensuring the user-friendliness of charging infrastructure while offering flexibility to charging point operators and equipment manufacturers involved in achieving our charging point deployment targets.
AVERE advocates for the following key components to be included in the Commission’s guidelines:
- General requirements that can apply to all types of charging points;
- Physical charging point design;
- Digital platforms and information provision for charging points;
- Charging point placement;
- Streetscape and the public realm around the charging point.
In this position paper, AVERE sets out recommendations on the accessibility of charging infrastructure and calls on the European Commission to adopt a proactive and balanced approach to charging point accessibility. A standardised pan-European approach is essential to harmonise the requirements related to ‘accessibility by persons with reduced mobility’ to:
- Ensure that people with reduced mobility can travel without barriers, plan their trip, and have similar charging experiences across European regions;
- Ensure equal Pan-European user experience, independent of the choice of operator;
- Avoid a patchwork of regional regulations and local guidelines;
- Avoid interpretation differences among Member States such as on cross-border operators;
- Ensure that original equipment manufacturers (OEMs) and charge point operators (CPOs) can optimize solutions;
- Enable scale of production and lower costs due to equal requirements, which will result in lower costs to all end-users.
AVERE’s Key Recommendations for an Accessible European Charging Infrastructure:
Non-exclusive priority charging is placeholder-based access to charging instead of exclusive charging or restrictive access to one single user group, with priority for all persons with reduced mobility.
1) Set European Accessibility Design Standards for Charging Points
Designs of charging points play a key role in ensuring that they can be accessed by anyone including people with reduced mobility. AFIR Recital 38 highlights the importance of creating transportation infrastructure that promotes seamless mobility and accessibility for all users, especially senior individuals and those with reduced mobility or disabilities. It advocates for designing the location and features of charging stations to be user-friendly and accessible to a broad public, with considerations such as avoiding kerbed surfaces, the appropriate height of buttons/screens, and manageable cable weights for individuals with limited strength. Furthermore, it recommends applying accessibility requirements outlined in Directive (EU) 2019/882 to recharging and refueling infrastructure, ensuring inclusivity in their design and user interfaces.
While the current European regulatory framework provides some insights on the design of both site and hardware of the charging points, AVERE recommends a standardised approach to be adopted at the European level to define which features should be included in charging points with non-exclusive priority charging for people with reduced mobility. Although EV chargers are commonly found in parking lots, it is essential to recognize the distinct use requirements that justify treating EV charging spaces for people with reduced mobility differently from ordinary parking spaces. To charge an EV, drivers with reduced mobility have to get out of their vehicle, go to the charger, and return with the connector, often to a charging socket on the opposite side to where they enter or exit their EV. Given the lack of a standardized location for EV charging sockets, it is necessary to be able to move around the vehicle. In addition, the evolution of cables, which are becoming heavier and shorter for faster charging, requires strategic parking alignment between the vehicle's charging inlet and the charger. However, this alignment may conflict with the orientation required for a disabled driver to use the access aisle. The accessibility of charging infrastructure can be ensured by implementing key mobility features around the design of the charging pool and hardware.
Site Design
The design of a charging site that takes into account the dimensions of the charging point and spaces within the charging site along with lowered kerbs, and marking of the charging points will ensure all EV users have a hassle-free EV charging experience. AVERE recommends that the European Commission specifies minimal site requirements for user accessibility to be complied by the CPO or location owner at the charging pools with non-exclusive priority charging for people with reduced mobility while CPOs are given ‘freedom of site design’ to optimise user experience. To begin, charging point components, which include a display, payment terminal, socket, connector, and grip holster, are to be placed within the range of 0.90 meters to 1.30 metres above ground level to service all users. Equally important, EV chargers must be located on an accessible route on a level floor or ground space on the same level as the vehicle charging space. An accessible charging station requires a charging bay of at least 3.50 metres wide and 5.00 metres long along with 1.20 metres of free moving space allocated between the EV and the charging station or any barriers, while the charging stations should ensure clear on-site indication in the charging pool via a mandated globally recognised symbol. Moreover, access aisles to the charging point should remain always clear from any curbs, wheel stops, bollards, or charging cable slack.
In addition to the right charging space size, adjacent movement areas are also important for enabling accessible mobility and easy use of the charging point. In this regard, barrier-free movement areas can be ensured by the following measures [1]:
- “In front of the charging station, an area of at least 150 x 150 cm should be left free to ensure that the charging cable can be easily plugged in and connected to the vehicle.
- There should also be a comparable area for side meter reading”.
Although a sweeping path of 120 cm wide should be included in the design of charging points to enable driving past [2], specifying footpaths and sidewalks since they are heavily location-dependent should be avoided.
The scarcity of available spaces dedicated to charging stations in the cities requires the implementation of on-street charging points and parallel parking areas. In this case, the EV chargers should be placed on the sidewalk adjacent to the on-street parallel parking space to ease entry to and exit from the vehicle for people with disabilities. Importantly, accessible routes must not be blocked when cables are connected to vehicles [3].
By implementing mobility features, the parking operators and CPOs can make the charging stations accessible for people with reduced mobility. Just as not all parking spaces are designed for disabled drivers, not all EV charging stations need to be designed for people with reduced mobility. However, to serve all users, a certain proportion at each location, or in each geographic area, should be designated as non-exclusive priority charging space for people with reduced mobility, elderly, pregnant women, etc. Non-exclusive priority charging for people with reduced mobility can be understood as placeholder-based access to charging instead of exclusive charging or restrictive access for single user groups, with priority for all persons with reduced mobility. Determination of the number of such charging points could be made at the local level, based on the number of disabled people in that community. Currently, the amount of charging pools designated as priority charging points for people with disabilities varies as there are no European standards on this aspect. AVERE advocates that at least 1 charging point is designated as a non-exclusive priority charging point for people with reduced mobility where the charging locations has more than 16 chargers whereas the maximal 5% of all charging stations per location should be equipped as accessible stations. Also, the number of EV charging spaces for people with reduced mobility should be commensurate with the percentage of parking spaces for handicapped people in that community, as determined at the local level. This target can be implemented for both charging stations and the on-street charging points with the designation of space on the sideway.
There are typologies of EV charging locations, yet in reality, each one is unique. CPOs and landowners need some flexibility to create accessible charging locations in a way that works at that specific location. In order to optimize the user experience to ensure that the best market-oriented accessibility solutions are implemented, AVERE urges European policymakers to avoid:
- Specifying total site layout/designs for all locations;
- Specifying individual components such as bollards, wheel stops, and curbs;
- Requiring the use of symbols on charging stations nor additional signing close to the charging station;
- Specifying number of accessible stations per region/geofenced area;
- Specifying percentages of charging station parks;
- Mandating restrictive dedicated charging stations for disabled persons.
Hardware Design
The accessibility of charging points cannot be fully ensured if certain requirements for the hardware are not addressed at the charging point. The design of hardware that takes into account the dimensions of the operable parts, as well as the display of vital information about the charging point and the charging session will provide EV users with a hassle-free EV charging experience.
In terms of the requirements for hardware design at the charging points with non-exclusive priority charging for people with reduced mobility, AVERE recommends that all user interface elements (operable parts) should be within the range of 0.90 metres to 1.30 metres long. However, if the charging station can be controlled by an App, then height dimensions for the user interface should not be applicable. Moreover, charging station handles should be ergonomic and easy to grip without slipping, using force or dexterity for both attached and unattached cables. Sockets should clearly indicate the type of plug and its orientation. Additionally, the vital information on the recharging session, payment information, and safety instructions must be easily readable to the user and remain accessible to all. In line with the AFIR, various user-friendly payment solutions without the need to physically pay in front of the hardware such as Plug & Charge, autocharge, and tap-and-go, should become available at the charging point as they significantly reduce the number of interactions on the screen interface and the payment device. Even though the AFIR does not obligate contactless payment systems and subscription services/app-based authentication & payment at the charging stations, their widespread adoption would ease the payment transactions for EV users with disabilities.
In order to enable user-friendly deployment of accessible charging infrastructure that goes hand in hand with the market incentives, AVERE recommends European policymakers to avoid:
- Mandating retroactive installation;
- Over-specifying hardware requirements to component level (those limit product usability which causes deployment burdens);
- Specifying cable length/reach requirements as they do not guarantee actual effect.
2) Ensure Dedicated Public Charging Points for People with Disabilities have Accessible Communication Features
As keeping EV users informed about all the processes of charging their EVs at a charging station is key for enhancing accessibility, the European regulatory framework should mandate a minimal level of core data elements for improving user experience. CPOs should provide clear feedback to the EV user so that the user knows if charging has started or stopped successfully, payment has been accepted, or the connector is ready to unplug. This will help to support customer confidence in the EV charging experience. In the example of public charging points with non-exclusive priority charging for people with reduced mobility, CPOs should make sure that the information on the accessibility of the charging point in addition to its connector type, output power, and availability, is easily and digitally available to the EV users. The implementation of AFIR and its delegated acts will help to standardize this process by making key information available online.
In order to make a charging point accessible to all users, display screens, labels and signs, when available, must be clearly visible and have support for at least two of the most spoken languages at the place of the charging point. In case the EV charger requires an NFC key-chain card or other physical token, then the key/card must provide a clear orientation to the user.
As technological advancements allow more charging stations to use websites and mobile applications to facilitate all steps in charging EVs varying from payment to start and stop charging, CPOs must conform to the standards for digital accessibility as set in the EU’s Web Accessibility Directive. Last but not least, all charging stations should have adequate broadband or mobile phone coverage to accommodate the use of mobile applications during the charging process in order to maintain accessibility for all EV users. This will be crucial for providing customer service, help support, or a similar mechanism to be always available to report and receive support for any malfunctions and issues with the EV chargers. In order to avoid any confusion at a charging point, all charging points should be linked to a network of support teams via a helpline that is available 24/7 to intervene to assist EV drivers in at least two of the most spoken languages at the place of the charging point. The support team should be able to be reached via voice, email, SMS, social media channels, and e-mobility apps. However, the CPOs should have the flexibility to decide which communication channel(s) to be accessible by the users at the charging station. Ideally, charging station locations should be available online to the users whilst over-specifying location details causes an overkill of site details as this does not serve to core user experience.
Overall, the hardware of charging stations should have communication features in the form of visual, and colour at all times to ensure accessibility, as well as the CPOs, should register if a charging station qualifies as ‘accessible’ and detail accessibility level via simple data elements based on the criteria set by the current European regulatory framework.
3) Support the Uptake of Accessible Charging Points in Buildings
In the EU, over 75% of charging sessions take place at buildings, either at home or in the office. Ensuring the accessibility of destination charging points will be key for a more inclusive e-mobility. However, there is a greater challenge in supporting the uptake of accessible charging points in the buildings due to the obstacles related to their design. First of all, it is costly to retrofit existing buildings to equip them with accessible charging points. Moreover, the existing buildings do not have spacious parking spaces in most cases which further makes it difficult to introduce a number of accessible charging points for people with reduced mobility. Allocating necessary space for accessible charging points should be considered at the time of the design of the new buildings. In that regard, European lawmakers should play a crucial role in setting off the uptake of accessible private charging in the existing and new buildings. Even though the Commission’s proposal for the revised Energy Performance of Buildings Directive (EPBD) misses the opportunity to set measures for easing the deployment of accessible private charging points, EU Member States, in their implementation of the EPBD, should ensure accessibility of public charging infrastructure in buildings.
AVERE recommends that if the EV charging point is located in a parking garage, then it must provide an accessible route that connects to the accessible pedestrian entrance of the parking garage. However, specifying footpaths and sidewalks since they are heavily location-dependent should be avoided as it may slow down the uptake of charging infrastructure in the buildings.
[1] Heidelberg Amperfied, Whitepaper, p. 12.
[2] Heidelberg Amperfied, ibid.
[3] The U.S. Access Board, Design Recommendations for Accessible Electric Vehicle Charging Stations, https://www.access-board.gov/tad/ev/.