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German bill requires CCS and L2 plugs at every new fast charge point.

ScepticMatt

Member
Nov 5, 2014
453
10
Austria
Short version: Under this bill, every new DC charger has to have CCS and every AC charger L2 plugs.
That would mean new superchargers would have to have CCS and destination chargers L2 plugs.
The government body has to be notified of construction 8 weeks in advance in written/email form,
and can forbid operation if those requirements aren't met and verified.

"Fast" chargers are defined as >22kW. Lower is called "normal" charging.
Only applies to publicly accessible locations (i.e. not inside homes or service centers)

Link to german TTF forum threads:
Handelsblatt: Bundesregierung standardisiert Ladesäulen
Online Petition gegen Ladesäulenverordnung

The bill (in german):

Ladesäulenverordnung (LSV) BSM e.V.

Key parts translated:
§ 3 Mindestanforderungen an den Aufbau und den Betrieb von Ladepunkten

Minimum requirement for the construction of operation of fast charging points

(1) Beim Aufbau von Normalladepunkten, an denen das Wechselstromladen möglich ist, muss aus Gründen der Interoperabilität jeder Ladepunkt mindestens mit Steckdosen oder Fahrzeugkupplungen des Typs 2 gemäß der Norm DIN EN 62196-2, Ausgabe Dezember 2014, ausgerüstet werden.

During the construction of normal charging points which enable alternating current charging every charge point, due to interoperability, must at least be equipped with plugs or adapters of Type 2 under norm DIN EN 62196-2, december 2014 issue.

(2) Beim Aufbau von Schnellladepunkten, an denen das Wechselstromladen möglich ist, muss aus Gründen der Interoperabilität jeder Ladepunkt mindestens mit Kupplungen des Typs 2 nach der Norm DIN EN 62196-2, Ausgabe Dezember 2014, ausgerüstet werden.

During the construction of fast charging points which enable alternating current charging every charge point, due to interoperability, must at least be equipped with plugs or adapters of Type 2 under norm DIN EN 62196-2, december 2014 issue.

(3) Beim Aufbau von Normal- und Schnellladepunkten, an denen das Gleichstromladen möglich ist, muss aus Gründen der Interoperabilität jeder Ladepunkt mindestens mit Kupplungen des Typs Combo 2 nach der Norm DIN EN 62196-3, Ausgabe Juli 2012, ausgerüstet werden.

During the construction of normal and fast charging points which enable direct current charging every charge point, due to interoperability, must at least be equipped with plugs or adapters of Type Combo 2 under norm DIN EN 62196-3, july 2012 issue.

§ 4 Anzeige- und Nachweispflichten

§ 4 Notification and verification obligations

(1) Betreiber von Normal- und Schnellladepunkten haben der Regulierungsbehörde schriftlich oder elektronisch anzuzeigen:

Fast charging operators have to notify the government body in written or electronic form:

1. mindestens acht Wochen vor dem geplanten Beginn den Aufbau von Ladepunkten und

At least 8 weeks in advance of planned construction of charge points and

2. unverzüglich die Außerbetriebnahme von Ladepunkten.

immediately after decommissioning of charge points.

(2) Betreiber von Schnellladepunkten haben der Regulierungsbehörde durch Beifügung geeigneter Unterlagen die Einhaltung der technischen Anforderungen gemäß § 3 Absatz 2 bis 4 nachzuweisen:

Operators of fast charge points have to verify by apposition of appropriate documents the compliance with the technical requirements listed in § 3 section 2 through 4

1. beim Aufbau von Schnellladepunkten und

During the construction of fast charging points and

2. auf Anforderung der Regulierungsbehörde während des Betriebs von Schnellladepunkten.

At the request of the government body during operation of fast charging points.

(3) Betreiber von Schnellladepunkten, welche vor Inkrafttreten dieser Verordnung in Betrieb genommen worden sind, haben der Regulierungsbehörde den Betrieb anzuzeigen und die Einhaltung der technischen Anforderungen gemäß § 3 Absatz 4 durch Beifügung geeigneter Unterlagen nachzuweisen.

Operators of fast charge points, which operate fast chargers before commencement of this regulation have to notify the government body of the operation and verify compliance with the technical requirements in line with § 3 section 4 by apposition of appropriate documents.

§ 5 Kompetenzen der Regulierungsbehörde

Responsibilities of the government body

(1) Die Regulierungsbehörde kann die Einhaltung der technischen Anforderungen gemäß § 3 Absatz 2 bis 4 an Schnellladepunkte regelmäßig überprüfen.

The government body can regularly review compliance with the technical requirements for fast charging points listed in § 3 section 2 to 4

(2) Die Regulierungsbehörde kann den Betrieb von Ladepunkten untersagen, wenn die technischen Anforderungen gemäß § 3 Absatz 1 bis 4 nicht eingehalten oder die Einhaltung der Anforderungen gemäß § 4 nicht nachgewiesen wird.

The government body can prohibit the operation of fast charging points if the technical requirements listed in § 3 section 1 to 4 are not met or the compliance with the requirements listed under § 3 cannot be verified.

§ 6 Übergangsregelung

Transitional arrangement

Ladepunkte, die vor dem [einsetzen: Datum drei Monate nach dem Inkrafttreten dieser Verordnung] in Betrieb genommen worden sind, sind von den Anforderungen nach § 3 Absatz 1 bis 3 ausgenommen.

Charging points which are in operation before [deployment: Date three months after commencement of this bill], are exempt from the requirements listed in § 3 section 1 to 3
 
Last edited:

hobbes

Active Member
Feb 11, 2013
2,798
16,252
Germany
This is a draft bill, not passed yet - still not a good direction things are going from a Tesla investors point of view. Wonder how Tesla will react, as they have said they want to push electric mobility as a whole, I think they could prove that by just complying and putting the new plugs in (given the bill is passed). One thing to also think about is that not any car plugging into a supercharger would be able to handle the same charging speed a Model S can, so Tesla customers would still have an advantage. To avoid having the SCs blocked by slow charging other cars, they could put dedicated spots. And seeing the Teslas charge much faster than their own cars might turn owners of other EVs into Tesla customers...

But I think it is important Tesla clarifies their strategy soon so potential new customers know what to expect as far as Supercharger buildout in Germany is concerned and don´t have to fear it stopping (which I don´t think will happen). Then again, on the short term that might lead to Tesla actually accelerating SC buildout as long as the bill is not passed yet...
 

jkirkebo

Model S P85+ VIN 14420 EU
Jun 13, 2010
961
13
Fredrikstad, Norway
This is a draft bill, not passed yet - still not a good direction things are going from a Tesla investors point of view. Wonder how Tesla will react, as they have said they want to push electric mobility as a whole, I think they could prove that by just complying and putting the new plugs in (given the bill is passed). One thing to also think about is that not any car plugging into a supercharger would be able to handle the same charging speed a Model S can, so Tesla customers would still have an advantage. To avoid having the SCs blocked by slow charging other cars, they could put dedicated spots. And seeing the Teslas charge much faster than their own cars might turn owners of other EVs into Tesla customers...

But I think it is important Tesla clarifies their strategy soon so potential new customers know what to expect as far as Supercharger buildout in Germany is concerned and don´t have to fear it stopping (which I don´t think will happen). Then again, on the short term that might lead to Tesla actually accelerating SC buildout as long as the bill is not passed yet...

If the requirement is per charging location and not per charger they can just put in a single CCS charger and set the price to use it to a reasonable level (better yet, farm it out). If it is per charger they have a real problem as they have no system in place to charge for the CCS outlets and would also risk blockage by other EVs. The smart thing would then be to make the payment credit card by call only and manual activation by operator. Set the price to €10.000,- per charge or so to assure no-one uses them. The only extra cost is then more cables and a remote-controlled switching relay.

But "per charger" requirement is stupid as that means one can not put in a separate CHAdeMO and CCS charger either, but has to use the multi-standard ones.
 

hobbes

Active Member
Feb 11, 2013
2,798
16,252
Germany
Set the price to €10.000,- per charge or so to assure no-one uses them.

I think the lawmakers would think of avoiding that. Also, Elon would lose a lot of credibility doing this after saying explicitly they´d be happy to share the SC network with other makers. Maybe a good compromise would be charging others the same S60 owners are charged ($2000 with car/$2500 after delivery) which would seem high to people to keep some out but couldn´t be argued against if your own customers have to pay the same.
 

jkirkebo

Model S P85+ VIN 14420 EU
Jun 13, 2010
961
13
Fredrikstad, Norway
I think the lawmakers would think of avoiding that. Also, Elon would lose a lot of credibility doing this after saying explicitly they´d be happy to share the SC network with other makers. Maybe a good compromise would be charging others the same S60 owners are charged ($2000 with car/$2500 after delivery) which would seem high to people to keep some out but couldn´t be argued against if your own customers have to pay the same.

I'd like to see them try to regulate what a private company can charge for people using their chargers, located on private property and built with private money. That would be in direct violation of EU free competition rules.

And yes, Elon wants to share the SC network. Not a slower CCS network blocking faster SC charging.
 

kbrandes

Member
Mar 8, 2014
18
12
If the requirement is per charging location and not per charger they can just put in a single CCS charger and set the price to use it to a reasonable level (better yet, farm it out). If it is per charger they have a real problem as they have no system in place to charge for the CCS outlets and would also risk blockage by other EVs. The smart thing would then be to make the payment credit card by call only and manual activation by operator. Set the price to €10.000,- per charge or so to assure no-one uses them. The only extra cost is then more cables and a remote-controlled switching relay.

But "per charger" requirement is stupid as that means one can not put in a separate CHAdeMO and CCS charger either, but has to use the multi-standard ones.

In my opinion the bill wants a CCS per Charger not per Charging Point - minimum the same number CCS !!!
 

ScepticMatt

Member
Nov 5, 2014
453
10
Austria
Any idea what ever happened with this ridiculous draft bill?
EU to Ban CHAdeMO EV Chargers by 2018
The german bill is a implementation of this EU bill, with some extra requirements on top.
It seems like a L2/CCS per stall will be an EU-wide requirement for AC/DC chargers by the end of 2017.

Edit: here it is:
Alternating current (AC) high power recharging points for electric vehicles shall be equipped, for interoperability purposes,
at least with connectors of Type 2 as described in standard EN 62196-2.

Direct current (DC) high power recharging points for electric vehicles shall be equipped, for interoperability purposes,
at least with connectors of the combined charging system ‘Combo 2’ as described in standard EN 62196-3.
Member States shall ensure that normal power recharging points for electric vehicles, excluding wireless or inductive
units, deployed or renewed as from 18 November 2017, comply at least with the technical specifications set out in
point 1.1 of Annex II and with specific safety requirements in force at national level.

Member States shall ensure that high power recharging points for electric vehicles, excluding wireless or inductive units,
deployed or renewed as from 18 November 2017, comply at least with the technical specifications set out in point 1.2
of Annex II.
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014L0094&from=DE
 

ItsNotAboutTheMoney

Well-Known Member
Jul 12, 2012
11,216
9,100
Maine
So, Tesla would have to add generic plugs, but wouldn't have to open up their Superchargers to all and sundry, so they'd basically have a bunch of redundant plugs.

What this really hits is their destination charging program, which, without an adapter, is Model S only. They'd just have to get agreement for priority for Tesla owners for any donated HPWC.
 

widodh

Model S 85 and 100D
Moderator
Jan 23, 2011
6,860
2,825
Venlo, NL
So, Tesla would have to add generic plugs, but wouldn't have to open up their Superchargers to all and sundry, so they'd basically have a bunch of redundant plugs.

What this really hits is their destination charging program, which, without an adapter, is Model S only. They'd just have to get agreement for priority for Tesla owners for any donated HPWC.
Keep in mind that the European Model S has a Type 2 chargeport. So chargers at destinations already have a Type 2 connector and fir on any EV which has a Type 2 inlet.
 

jhm

Well-Known Member
May 23, 2014
9,898
37,334
Atlanta, GA
IDK, such a law is going to look pretty ridiculous in ten years. What they need is a standard like China's that supports charging upto 120 kW. In ten years no one will be charging at low power.

Regarding Tesla I don't think this is contrary at all. Look at their destination charging program. At suitable destinations like hotels, Tesla is providing a match number of HPWCs and J1776s for free to destination operators. Obviously, they are under no obligation to provide the Js for nonTesla cars, but it is really smart business. Offering such "charging hospitality" generates a ton of goodwill and welcomes the drivers of LEAFs and other EVs to consider upgrading to a Tesla on their next auto purchase. This is really classy marketing.

I would expect Tesla to express the same attitude if pressed by such a law. This is an opportunity to provide hospitality, build EV acceptance, and cultivate a positive connection with future Tesla owners. Charging ridiculously high rates for nonTesla would be very stupid from a marketing point of view. If you approach this as a marketing opportunity, you see that you want the prospect to have a very good experience and use the opportunity to increase Tesla awareness. Think of it as a mini Tesla store. Put touch screens out there so that prospects can see videos of lovely Tesla, expore features and options, even build their own Model S/X/3, and provide contact info to Tesla. Sure, charge for free and your next car just might be a Tesla. And guess what, in the time you took to charge your i3, you would have added 211km of range to your Model S 85. Press here for more informatiom.
 

jkirkebo

Model S P85+ VIN 14420 EU
Jun 13, 2010
961
13
Fredrikstad, Norway
Charging ridiculously high rates for nonTesla would be very stupid from a marketing point of view. If you approach this as a marketing opportunity, you see that you want the prospect to have a very good experience and use the opportunity to increase Tesla awareness. Think of it as a mini Tesla store. Put touch screens out there so that prospects can see videos of lovely Tesla, expore features and options, even build their own Model S/X/3, and provide contact info to Tesla. Sure, charge for free and your next car just might be a Tesla. And guess what, in the time you took to charge your i3, you would have added 211km of range to your Model S 85. Press here for more informatiom.

That sounds lovely in theory but what will you say if you arrive with your Tesla at the SC and find all 8 stalls taken by low-range EVs charging at 20-40kW?
 

Yggdrasill

Active Member
Feb 29, 2012
4,107
7,192
Kongsberg, Norway
That sounds lovely in theory but what will you say if you arrive with your Tesla at the SC and find all 8 stalls taken by low-range EVs charging at 20-40kW?
Yeah. The only way it would work is if Tesla massively increased the number of chargers. And I really don't think it's in Tesla's business to roll out a massive CCS charging network.

If they are forced to add CCS plugs, they should price the access high, but not so high as to cause complete outrage. Maybe around 2$/minute.
 

trils0n

2013 P85
Feb 12, 2013
1,527
1,979
Earth
If you want to build your charge network, you have to build ours too! (We didn't believe in electric cars or fast charge networks, so we didn't build it, but now that Tesla built it, and demonstrated it works, we'll get them to pay for it!) Great idea for the incumbents. No risk for them, and lots of upside, and no need to actually commit to building anything (status quo). Shows they've finally realized how much of an advantage Tesla's Supercharger network is.

As to the destination charging program, I thought Tesla was already installing a HPWC and Clipper Creek J1772 at least in newer sites in the USA, so not much of a change there.
 

Yggdrasill

Active Member
Feb 29, 2012
4,107
7,192
Kongsberg, Norway
Since the batteries are smaller, the fill time will still be about the same as the Model S.
The issue is primarily that there are/will be a lot more vehicles compatible with CCS than there will be vehicles compatible with Tesla Type 2. Tesla is building enough charging locations for it's own customers, they're not building enough charging locations for all EVs. And that's not their responsibility either, Tesla is primarily a car company, not a charging infrastructure company. To force Tesla to offer CCS to the cars of other car makers is to sabotage them, just as NADA is trying to sabotage Teslas sales strategy.
 
What they need is a standard like China's that supports charging upto 120 kW. In ten years no one will be charging at low power..
The chinese standard is limited to ~187 kW. The stations they are building are 4x120kW.
CCS currently goes up to ~170 kW if I remember correctly. The fastest one built are the kia 100 kW ones I believe.
Since the batteries are smaller, the fill time will still be about the same as the Model S.
But they will need to charge more often.
this is not for Tesla, because Superchargers are privat and only for customers, it's like a charger in own house. Tesla would do not put CCS.
Not how the german bill is worded. Doesn't matter if it's privately owned.
 

RobStark

Well-Known Member
Jul 2, 2013
10,934
57,626
Los Angeles, USA
Tesla charges $2.5k here if you buy after taking delivery.

German electricity is more expensive. What do they charge after taking delivery there?

BTW Still need to see how Tesla reacts after their German lawyers advise how this applies to Tesla after reading the law in its totality not just a sentence here and there.
 

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