Ever confusing Indian EV Charging Infrastructure Guidelines & Standards | MoP Notification on 08th June, 2020

On 08th June 2020, Government of India’s Ministry of Power - MoP has released an amendment (again!!) to its guidelines and standards for the charging infrastructure of electric vehicles (EVs). However, this release only creates new confusions, instead of clarifying the doubts of previous ones!. 

Confusions on tariff for buying / selling electricity in EV charging

The original guidelines were issued by the MoP in December 2018 and were revised in October 2019 – both left a lot of room for assumptions and confusions on the electricity tariff rates. Now, there’s one more amendment this week which again fails to give any clarity on the outstanding question.

Initial release by MoP on 14/12/2018

The Ministry of Power first released the guidelines for the EV charging Infrastructure on 14th Dec 2018. Notification 12/2/2018-EV | Charging Infrastructure for EV - Revised Guidelines & Standards (link) can be downloaded from the MoP website. 

Below is an excerpt from the document (section 2 & 7) which mentions the guidelines for the tariff for supply electricity to EV public charging stations.
 


Going strictly by the wordings of this guideline, the MoP was seen as working positively for capping the price at which electricity would be supplied to the EV Charging Stations. However, it was later left to confusion whether this regulation was to cap the cost of supply of power to the EV charging station OR to cap the price at which the EV charging asset owner could charge to the consumer.

There were not many present at that time, yet a few charge point operators (CPO) and electric mobility providers (EMSP) and industry experts raised the concern on the confusions to the Ministry of Power asking to clarify. The MoP heard them as well and released an amendment on the 01st Oct 2019. 

Amendment to Guidelines for EV Charging Infrastructure on 01/10/2019

Towards the end of 2019, there were many voices in the space of Indian electric mobility and the MoP tried to clarify the doubts on the 2018 original policy document on EV charging infrastructure. Complete release document : Notification 10/1/2019-EV | Charging Infrastructure for EV - Revised Guidelines & Standards (link) can be downloaded from the MoP website.

Below screenshot (section.7) specifies the guidelines for the tariff for supply electricity to EV public charging stations. 

 


This notification gave credence to the State wise ERCs (Electricity Regulation Committee) to define the tariff for EV charging supplies., whereas the previous 2018 release mentioned only the 15% cap on the electricity tariff. 

Amendment to Guidelines for EV Charging Infrastructure on 08/06/2020

This new amendment now specifies that the tariff for the supply of electricity to the EV public charging stations should not be more than 15% of the average cost of supply of power. This ceiling was not given in the earlier guidelines.

The complete document : Notification 12/2/2018-EV | Amendment in the revised Guidelines and Standards for Charging Infrastructure can be downloaded from the MoP website link here. Below is the excerpt on the electricity tariff.

 
In effect, the latest guideline (08th June, 2020) has brought back the 15% cap from the 14-Dec-2018. Is this 15% cap on the cost of supply of power to the EV charging station OR to cap the price at which the EV charging asset owner could charge to the consumer? What is the role of the State wise ERCs (Electricity Regulation Committee), if the CPO’s are free to set to tariff respecting the 15% cap? 

Confusion on PCS-CCS-BCS terminologies & technical requirements

Besides this, the amendment has added a few more important points to the existing guidelines. The amendment has now added a clause to say that for all practical purposes, the battery charging station (BCS) will be treated at par with the public charging station (PCS), and the applicable tariff for electricity supply will also be the same as for the PCS.

Here, PCS means any EV charging station, while BCS implies a station where the discharged or partially discharged batteries of EVs can be recharged electrically.

As per the amendment, the captive charging station (CCS) for EVs will be fully owned by the owner of the charging station, and it will not be used for commercial purposes. Captive Charging Station (CCS) shall mean an electric vehicle charging station exclusively for the electric vehicles owned or under the control of the owner of the charging station e.g. Government Departments, Corporate houses, Bus Depots, charging stations owned by the fleet owners etc.

This was a bit of surprise for many charge point operators who were building their business cases on captive charging, which will not be commercial anymore; but to be used only for self-use. This forces many charge point operators & EMSPs towards Public Charging Infrastructure (PCI).

But, note that the original (2018) requirements for Public Charging Infrastructure (PCI) were impractical even for the most deep-pocketed companies. Under this guideline, each charging station would need a dedicated transformer, plus 5 chargers each of a different protocol. This would amount to a minimum investment of Rs. 45 Lakhs!


 
Again, some of the charge point operators and e-Mobility providers promptly raised alarm to MoP and the ministry responded back with amendment on 1-Oct-2019. In this amendment, the MoP retracted and clarified the minimum requirements and also proposed Central and State nodal agencies for validating the PCI.



This relaxed the need to have 5 different chargers in one place, yet the costs can be very high with dedicated transformer. Also the process to approach and get approval from the Central and State nodal agencies still requires more clarity and direction.

In summary :

This new amendment raises more questions than clarifying on the situation! India with an ambitious goal of having 30% of EVs by 2030, it is highly imperative that MoP should give more liberty to the CPOs (Charge Point Operators), who are already under pressure to develop and deploy viable business models for different segments of customers. 

The intentions of the MoP guideline amendments are extremely forward looking, but the fundamental flaw is that they attempt to control and regulate the EV charging businesses rather than guide and direct!. Least that is expected in this scenario is a complete clarity from central government and various state governments on policy and regulatory aspects.