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

[Yggdrasill]

What I meant is that they should have gone with the type 2 combo (CCS) plug from the beginning in europe instead of the type 2.
Anyway, an adapter could easily solve the problem you describe.

Hindsight is 20/20. And by "easily" you mean "inconveniently".

 

[brianman]

Woah, there is a lot in that Letter. Someone mind running it through a translator?

From the google:

The current draft regulation charging stations hindered investment and innovation in charging technologies for electric vehicles
The European Directive 2014/94 / EU on the construction of infrastructure for alternative fuels has until 18 November 2016 the EU - Member States be implemented. From November 18, 2017, the conditions laid down in the Directive requirements must apply. As one of the first Member States that take steps Germany has submitted to the charging stations Ordinance (LSV) a draft implementing Directive. Tesla Motors welcomed Germany's efforts to play a leading role on this issue and the declared by the Federal Government aimed at bringing up to 2020 one million electric vehicles on German roads. However, we are deeply concerned that the current draft of the LSV is liable to hinder the development of electric mobility. In addition, the design is significantly different from the zugrunde-- this Directive and infringes European and German constitutional law Primär--. For years, Tesla has invested in developing charging technologies for electric vehicles, as well as a Europe-wide integrated network of charging points. The batteries of the Tesla Model S and Tesla Supercharger - network are optimally matched to one another in order to allow a fully electric driving over long distances; they allow a 50% charge within 20 minutes, enough for a distance of over 250 kilometers. In Europe, there are more than 186 so-called Tesla Supercharger - stations and therefore has more than 1020 individual charging points that ensure a fully electric driving from Oslo to Barcelona or from London to Vienna. This means that more than 20 million kilometers throughout Europe driven with 100% renewable energy in JULY and 2015th Including more than 3.7 million kilometers loaded to the 48 Supercharger-- stations in Germany. 60% of the loads derived from foreign customers and demonstrate that cross-border electric mobility is already possible today. This would be without adequate private investment in battery technology and the Supercharger - stations have been impossible. Here is the Supercharger - technology open to others and Tesla remains open to cooperation with other companies to use the Supercharger - network. If the LSV is implemented in its current form, however, operators of charging points 'also in privately financed and privately-held as the Tesla' would be forced to invest in additional connections at all new charging points and all other electric cars to grant access to the Superchargers , This not only hinders the expansion of the charging infrastructure in general, but also leads to a limitation of the necessary free space for private investment in innovative technologies and business models for charging services. x The LSV requires the establishment of type 2-- or Combo 2 - terminals and in future a third party access for all ͣƂĨĨĞŶƚůŝĐŚ njƵŐćŶŐůŝĐŚĞŶ͞> ĂĚĞƉƵŶŬƚĞ?. After LSV certainly so on the basis of accessibility in the spatial sense. After that would hardly be a loading point in Germany to be regarded as private charging point, even if it is privately funded 100% to 100% is privately owned and located on privately owned land. This also the EU - Commission recognized in its opinion on the LSV and speaks of obvious contradictions related to pe ?? ĞŐƌŝĨĨ ͣƂĨĨĞŶƚůŝĐŚ njƵŐćŶŐůŝĐŚ͞; Apparent inconsistenĐŝĞƐ ƌĞůĂƚĞĚ ƚŽ ƚŚĞ ĐŽŶĐĞƉƚ Zi Accessible to the ƉƵďůŝĐ͛͞Ϳ???????? , According to the Commission, the definition of publicly available charging point according to the LSV would imply that there are no privately accessible charging points [...], ie that all charging points are available to the public ultimately (ͣǁŽƵůĚ?ŝŵƉůLJ?ƚŚĂƚ?ƚŚĞƌĞ?ĂƌĞ?ŶŽ?ƉƌŝǀĂƚĞůLJ?ĂĐĐĞƐƐŝďůĞ?ƌĞĐŚĂƌŐŝŶŐ?ƉŽŝŶƚƐ?΀͙΁?ŝ͘Ğ͘? That ultimaƚĞůLJ?Ăůů?ƌĞĐŚĂƌŐŝŶŐ?ƉŽŝŶƚƐ?ĂƌĞ?ƉƵďůŝĐůLJ?ĂĐĐĞƐƐŝďůĞ͟Ϳ. According to the Directive, however, a charging point is available to the public if it functionally EU for all - users njƵŐćŶŐůŝĐŚ?ŝƐƚ͗?ͣĞŝŶ?>ĂĚĞƉƵŶŬƚ?ŽĚĞƌ?ĞŝŶĞ?dĂŶŬƐƚĞůůĞ͕?ĂŶ?ĚĞƌ?ĞŝŶ?ĂůƚĞƌŶĂƚŝǀĞƌ?<ƌĂĨƚƐƚŽĨĨ?angeboten and is njƵ?ĚĞƌ?ĂůůĞ?EƵƚnjĞƌ?ĂƵƐ?ĚĞƌ?hŶŝŽŶ?ŶŝĐŚƚĚŝƐŬƌŝŵŝŶŝĞƌĞŶĚ??ƵŐĂŶŐ?ŚĂďĞŶ͞?;?ƌƚ͘?Ϯ͘ϱ the Directive). These charging points are to ensure technical compatibility and non-discriminatory access for all users. However, the Directive does not provide any comparable obligations for public

accessible before charging points so as not to be private investment in innovative technologies and business models in the way. As the United Kingdom and Finland require in their recently the Commission sent statements, the LSV should take to ensure their compatibility with the Directive laid down in the Directive definition of public accessibility.
x Furthermore, the amounts laid down in the LSV transition period for compliance with these requirements, three months after the entry into force thereof. Such a period, however, would make the adaptations to be carried out by the industry extremely complex and costly (a production change takes after rough estimate for at least 24 months to complete). This could lead to an immediate termination of successful requests initiated initiatives. This may not be in the interest of German expansion targets for e - mobility are; the EU - Commission has emphasized in its observations on the LSV that the period until 18 November 2017 is a transition period that allows the relevant economic operators, to matters arising from the Directive sĞƌƉĨůŝĐŚƚƵŶŐĞŶ ĞŝŶnjƵƐƚĞůůĞŶ; The period until? 18 November 2017 is a transition period Allowing the CORRESPONDING economic operators to adapt to the obligations derived from Directive 2014/94 / EU͟Ϳ͘? The obligation to transpose the LSV should therefore apply only after the conditions laid down by the directive appropriate transitional period 'namely from November 2017 ( as the Commission confirmed in its observations on the LSV). x According to the directive, the agreed commitment to the standards of the type 2-- 2-- and Combo ports should not adversely affect existing investments in the expansion of other standard technologies for charging points affect (recital no. 33). Even if existing charging points would not be affected by the LSV, the LSV would already jeopardize planned investments of Tesla and other companies in Germany and thus also to an end of the expansion of Supercharger - lead network in Germany. The LSV should reflect the relevant clear statement of intent of the Directive. apart from the non-observance of the underlying EU - - Policy - x Finally, the LSV violates EU - primary law, especially against the entrepreneurial freedom, property rights, freedom to provide services and free movement of goods, as well as to German constitutional law, ie. to Art. 80 para. 1 GG (issuance of regulations), Art. 12 GG (freedom of enterprise) and Art. 14 of the Basic Law in conjunction with Art. 19 para. 3 (corporate ownership).
Tesla understood the objective of standardization of charging points in Europe. Since the electric mobility but is still in its early stages, it requires a balanced development between standardization and innovation in order to create more incentives for private investment in better products and services. This achieves a higher market acceptance and a more sustainable mobility. Tesla is therefore of the opinion that the applicability of that in the LSV technical obligations on private networks of charging points and the shortened transition period the previously well-functioning initiatives seriously damage and thus possible further investments with high additional costs would burden. This would result in a significant delay of progress in the German E-- mobility industry. Tesla is convinced that Germany of all EU - Member States is best suited to become the leading market for e - ascend mobility in Europe and a pioneer in the establishment of necessary standards. However, this objective can not be realized by the current LSV, are hampered by the innovations in the important area of ​​the charging infrastructure. Best regards,

Jelle Vastert Lead EU Supercharger Program

 

[bwa]

A nice fence would have been my idea too, but the regulators foresaw that.
In the current draft it explicitly says that if an operator installs measures that are only (or mainly) intended to restrict access, the charging point still counts as public. This is just unbelievable.

"a charging point is available to the public when it is either in the publicIs road space or on private land, provided that the loading point for
Their passenger car park of an undetermined or only after general
Features identifiable group of people can actually drive on;
different types of authentication, use and payment as well as all
Measures which are intended exclusively or predominantly to
other drivers of electric vehicles to the loading point to access
refuse to stay for the allocation of a charging point when public"

Hmm. Tesla could put a flyer on every supercharger telling each person about the inferiority of the ICE-backed EV charging standards and the proposed law, and contact information for every politician. They can post QR codes on fixed signs that people could scan to read more while they wait in their car. The government wants a buyout, so go ahead and let the citizens buy them out on their own time in their own way; Tesla doesn't have to impose its foreign ideas on the locals -- it can inform them and let them take their own actions.

P.S., in my experience, multinationals ruin local chains whenever the multinational takes over. Myspace, Safeway, Trader Joe's -- the first two were bought by foreign interests and tanked. Beautiful when bought, garbage now. I suspect the same of TJ. My point is that Tesla already is a foreign multinational with respect to Germany, so let me recommend to Tesla not to do the foreign multinational failure mode: they need to have local interest in local terms do the local work. That is to say, they need to have sort of a diplomatic core that positions in each country and does the local negotiation. This is multilevel: there's the Tesla <-> Diplomat level, and the Diplomat <-> local politician level. In each case, there is a local counterpart: there would be a local German in Germany who works for Tesla, that interacts with a German counterpart at Tesla HQ, and negotiates carefully with them, who then negotiates with the rest of Tesla HQ. When necessary, the local German (in Germany) would do local political work there in their own way. It's a lot of money and work, but isn't that the cost of success?

So, if Telsa balks at my QR code with signs everywhere idea (not necessarily the specifics but the generalities) because it is "too much work to do in someplace that is too far away", then my opinion is that Tesla is taking the failure mode for all of Germany and is happy to just fail anywhere it meets the least amount of resistance.

 

[stopcrazypp]

As Matbl rightly points out Tesla are using bone stock Type-2 (but high quality) in current EU cars, and just playing fast and loose with DC-Mid (of which AFAIK Tesla are the only adopters) IMO.

I'm mainly responding to his point that the standard allows it. The standard only allows 200A max (same as CHAdeMO), it doesn't allow higher current than that. There is speculation that a new draft will do so, but it is unknown if it will still keep the same physical connector.

 

[smac]

Hindsight is 20/20.

I'm not sure it was just hindsight, they were on the standards committee, and when it looked like the CCS would usurp DC-Mid (with greater tolerances AKA EU Supercharger connector) Tesla walked away.

Now it certainly would have been inconvenient (read expensive) to redesign the sheet metal presses for Tesla to accommodate CCS, so Tesla did the Tesla thing and fought it via their PR machine and made a big fuss of publicly ridiculing the standards body.

My personal view is for a standard (which we all should look for) is unfortunately a regime of high tolerances need building in to the spec, we can moan about this, but it's a pragmatic reflection on current business/economic practices, where material and QC slip over time.

This is where Tesla's proprietary approach is IMV a little short sighted, because CCS is physically superior. But yes we know DC mid is capable outside spec with good QC and materials of delivering higher currents (especially over shortened duty cycles due to tapering), in a CONTROLLED SYSTEM. But we don't know if it would become a limitation in 10 years if battery sizes grew significantly, or quality slipped.

We are where we are, and in my mind there is no doubt if CCS had been ratified pre-EU Model S's that's what the cars would have. Tesla were too far down the line, and had no choice but to take this course of action rather than delay the cars and involved significant re-tooling and development costs.

BTW I'm not being down on Tesla here, it's a big testament to Tesla's engineers to work through this problem, and it's very clever technically how they have done so. Will it stand 10 years, or will Tesla have to fall back to CCS, time will tell.

 

[stopcrazypp]

BTW I'm not being down on Tesla here, it's a big testament to Tesla's engineers to work through this problem, and it's very clever technically how they have done so. Will it stand 10 years, or will Tesla have to fall back to CCS, time will tell.

I suspect Tesla will wait for the standard after CCS to adopt (that standard may not necessarily have the same physical compatibility). 200A is way too little current carrying capacity to make sense as a long term standard to adopt.

 

[Model 3]

Btw, a charging provider here in Norway is now starting to give CCS/ChaDemo a boost. 120 kW CCS and 70 kW ChaDemo:
Google Oversetter

Now you can charge electric cars more than twice as fast

The first super-quick charger that does not have Tesla logo on itself opened in Vestby.

Norway's first super quick charger was opened Tuesday in Vestby. This can deliver an output of up to 120 kilowatts with 94 percent efficiency, and is the first of its kind in Scandinavia. Unless you look away from Tesla Supercharger stations, of course, but they are not widely available for all elbilister.
The new charger is manufactured by Delta Electronics and is the first commercially available charger of this caliber from producer. There may be a lot more such finding around the country eventually.
The charging stations operated by charging operator Arctic Roads. They have plans to build out a Norwegian network with 388 such chargers the next three years, if they win support funds for the development of fast chargers for six transport corridors in 2016.

 

[matbl]

Btw, a charging provider here in Norway is now starting to give CCS/ChaDemo a boost. 120 kW CCS and 70 kW ChaDemo:
Google Oversetter

Anything more specific? Such as volts/amps for those 120 KW?

- - - Updated - - -

I'm not sure it was just hindsight, they were on the standards committee, and when it looked like the CCS would usurp DC-Mid (with greater tolerances AKA EU Supercharger connector) Tesla walked away.

This ^ was going to be my answer as well. Thanks smac.

Now it certainly would have been inconvenient (read expensive) to redesign the sheet metal presses for Tesla to accommodate CCS, so Tesla did the Tesla thing and fought it via their PR machine and made a big fuss of publicly ridiculing the standards body.

My personal view is for a standard (which we all should look for) is unfortunately a regime of high tolerances need building in to the spec, we can moan about this, but it's a pragmatic reflection on current business/economic practices, where material and QC slip over time.

This is where Tesla's proprietary approach is IMV a little short sighted, because CCS is physically superior. But yes we know DC mid is capable outside spec with good QC and materials of delivering higher currents (especially over shortened duty cycles due to tapering), in a CONTROLLED SYSTEM. But we don't know if it would become a limitation in 10 years if battery sizes grew significantly, or quality slipped.

We are where we are, and in my mind there is no doubt if CCS had been ratified pre-EU Model S's that's what the cars would have. Tesla were too far down the line, and had no choice but to take this course of action rather than delay the cars and involved significant re-tooling and development costs.

BTW I'm not being down on Tesla here, it's a big testament to Tesla's engineers to work through this problem, and it's very clever technically how they have done so. Will it stand 10 years, or will Tesla have to fall back to CCS, time will tell.

Couldn't agree more.

 

[Model 3]

Anything more specific? Such as volts/amps for those 120 KW?

I don't know anything more then what's in that article I linked to:

The charger is supplied with 400 volts, have an efficiency of 94 percent, and can operate in temperatures ranging from 25 degrees below zero to 45 degrees and a relative humidity of up to 95 percent.

 

[mgemmell]

Awesome news!!....

Yesterday the Spanish government officially announced an exception for Tesla through to Nov 2017 to allow them to deploy superchargers without a CCS for every (yes it was EVERY) supercharger connection.

This is great news for us down here who have been waiting 2 years for them to deploy. Spain had been the first country in the EU to implement this law obliging CCS for each supercharger connection. Hard to understand why the Spanish rush until you realise we are the #2 car manufacturer in Europe but all the car plants are owned by non-Spanish companies who are "less motivated" to see Tesla succeed. Hence the Spanish government's enthusiasm to please these car plant owners by imposing strict "anti-Tesla" laws.

And why the sudden change? Good question. I have been involved in talking to the government previously about this but the actions leading to this about-turn are unknown to me. I'm just enjoying the thought that my third drive from Madrid to the Alps is going to be purely on superchargers

As Matbl rightly points out Tesla are using bone stock Type-2 (but high quality) in current EU cars, and just playing fast and loose with DC-Mid (of which AFAIK Tesla are the only adopters) IMO.

The _only_ reason I can see for this is Tesla own liability on both the car and the charging.

...

A good example would be the UK 13 pin plug.

Early examples (i.e. MK's from 25 years ago), when matched with an early 13A socket could deliver sustained 13A pretty much indefinitely. As time has moved on, manufacturers drive down costs, the quality has dropped significantly, but they still meet the testing regime. They can still deliver 13A, but basically only as long as the test regime states they must. Try and run one overnight at max capacity and it will melt around the fuse carrier as over time the thickness in those holders have been penny pinched away.... (btw one fix is to solder the fuse into the holder :wink: )

This is why the UMC in the UK is capped at 10A when run on a 13A socket.

...

Tesla's modus operandi is fast & loose! Thank god it is... otherwise we'd not have the Model S nor the supercharger network.

You clearly know your stuff smac and you are absolutely right about the compromises standards impose as well as the justifications for having them. In the IT World I've seen both sides... TCP/IP was the fast & loose version of the ISO stack, but GSM was the EU standard version of others like CDMA. In the first case TCP/IP won out, and on the other GSM won out. Standards need to compete against pragmatic work arounds, and then the market will decide which needs to dominate. Standards are vital to protect the public from danger and to build in future-proofing, but where possible governments should not impose one over the other. The choice should still be influenced by the market.


BTW I've melted several UK 13A plugs running them at 13A all night when on tour and charging the Model S (via a portable wallbox). Aluminum foil around the fuse was the best workaround there. Interestingly with the EU plugs (also rated at 13A) I can run them at 16A without things melting. No fuse helps I suppose.

 

[hobbes]

Awesome news!!....

Yesterday the Spanish government officially announced an exception for Tesla through to Nov 2017 to allow them to deploy superchargers without a CCS for every (yes it was EVERY) supercharger connection.

That´s really great, thanks for reporting! Maybe an example for other EU countries to consider...

And why the sudden change? Good question. I have been involved in talking to the government previously about this but the actions leading to this about-turn are unknown to me.

Dieselgate? Interest in hosting a future Tesla factory?

 

[GSP]

I suspect Tesla will wait for the standard after CCS to adopt (that standard may not necessarily have the same physical compatibility). 200A is way too little current carrying capacity to make sense as a long term standard to adopt.

Tesla was involved in the development of the CCS standard, but was not happy how it turned out. JB Straubel has publicly stated that Tesla gave up on the CCS standard when it became clear that it was not going to have enough ampacity for high power charging. He rightly said that standards must have room for future growth in capability. CCS was not even enough to handle the first Model S.

Of course, Elon was not happy with the bulky, industrial, design of the CCS plug.

Expanding the capability of Type 2 DC-mid, like Tesla did, is a much, much, better solution for the general public.

I hope Tesla is allowed to continue to provide their superior technical solution, and superior business model (pre-pay to auto OEM, and just plug in as soon as you arrive) in Europe. Other OEMs can join Tesla, build their own network, or band together to offer a generic competing network. Relying on government or third party installed standardized chargers should not be the only legal option, since it will make EV much less practical for many people.

GSP

 

[smac]

Tesla's modus operandi is fast & loose! Thank god it is... otherwise we'd not have the Model S nor the supercharger network.

Fast & loose, but well engineered, would be my view on the current SpC situation. But you are right

You clearly know your stuff smac and you are absolutely right about the compromises standards impose as well as the justifications for having them. In the IT World I've seen both sides... TCP/IP was the fast & loose version of the ISO stack, but GSM was the EU standard version of others like CDMA. In the first case TCP/IP won out, and on the other GSM won out. Standards need to compete against pragmatic work arounds, and then the market will decide which needs to dominate. Standards are vital to protect the public from danger and to build in future-proofing, but where possible governments should not impose one over the other. The choice should still be influenced by the market.

I'm torn. Professionally I'm in IT so I see the benefits of pushing the specs, especially when it's only dropped packets at stake. Heck I've run cat 5/6 at home well outside what the book says, next to cables when it should be shielded, excessive bend radii etc. etc. Written HTTP and IMAP services to how the clients work, done crazy stuff with COM vtable rewriting (sorry showing my age), etc. etc. Amazingly it all works

However historically I'm from an electrical engineering family, so I'm not surprised how much "surplus" copper things like building code require, to ensure personal safety. I've seen the results of electrical fires, and it's far more serious than the odd "Method ~ of object ~ not found" pop up dialog

As ever it's risk probability vs. impact analysis.

BTW I've melted several UK 13A plugs running them at 13A all night when on tour and charging the Model S (via a portable wallbox). Aluminum foil around the fuse was the best workaround there. Interestingly with the EU plugs (also rated at 13A) I can run them at 16A without things melting. No fuse helps I suppose.

Yep the big build up of heat is around the fuse/ fuse carrier interface which is little more than a pressure fit. This creates resistance across the fuse / fuse holder boundary as the cross surface of poorly pressed holders, and slightly out of round fuses reduces surface contact. Wrapping them in foil increases the clamping pressure and reduces resistance. Other options are using a bolt of a wider diameter, soldering (better option), or ideally swapping the socket with hardwired outlets or unfused sockets like the commando (aka BS EN 60309) where the circuit is designed upfront to support load at a continuous rating all the way back to the board, where it is ultimately protected by distribution board fusing based on fixed wire cable sizing including (de-rating for running through insulation, and is best option ).

 

[pegs]

One note. The destination charger is not operated by Tesla. I guess this means that the hotels restaurants etc will have to add a similar number of ccs chargers. (Maybe Volkswagen will provide them for free?)

 

[Panu]

Do we have destination chargers in Europe? Anyway destination charging is AC and Tesla connector is already the one that EU wants (Type2).

 

[mgemmell]

One note. The destination charger is not operated by Tesla. I guess this means that the hotels restaurants etc will have to add a similar number of ccs chargers. (Maybe Volkswagen will provide them for free?)

Do we have destination chargers in Europe? Anyway destination charging is AC and Tesla connector is already the one that EU wants (Type2).

As destination chargers are <100kW where is no need to offer a Combo/CCS. I am not aware of any destination chargers in the EU, but we don't need Tesla to do that for us... I've already set up over 35 22kW outlets in hotels around Spain and all you need to do is call them to book a room or a meal. True, you need to carry a portable wallbox, but then that is just good sense when you are on the road in the EU.

 

[FlasherZ]

TCP/IP was the fast & loose version of the ISO stack

For what it's worth (albeit slightly tangential), anyone who ever had to implement or work with an ISO-based network implementation knows why TCP/IP was successful. It was far easier to work with and was more practical.

That's the situation we find ourselves in with regard to CCS as well... it's an academic standard, defined by a committee who didn't care about the owner experience but rather the slide-rule details. It took Apple to introduce the Lightning connector before the USB folks "woke up" to the bad experience that was the USB micro connector.

- - - Updated - - -

This is where Tesla's proprietary approach is IMV a little short sighted, because CCS is physically superior.

You need to define "physically superior". Perhaps in heft and bulk, but in practicality? It's a Frankenstein disaster!

 

[matbl]

You need to define "physically superior". Perhaps in heft and bulk, but in practicality? It's a Frankenstein disaster!

You do realize that we are comparing the european CCS to the european type 2 (which is in european teslas) right? And not the US CCS to the US tesla plug which is a much much bigger difference.

 

[GSP]

You do realize that we are comparing the european CCS to the european type 2 (which is in european teslas) right? And not the US CCS to the US tesla plug which is a much much bigger difference.

CCS in Europe is not just the Type 2 inlet, but includes the two extra large pins for "DC-High" level 3 charging. Tesla's approach to extend Tyoe 2 "DC-mid" to higher power and current does not have the bulk of the industrial looking CCS plug. I think FlasherZ's comment applies well to both North America and European CCS charging standards.

GSP

 

[FlasherZ]

You do realize that we are comparing the european CCS to the european type 2 (which is in european teslas) right? And not the US CCS to the US tesla plug which is a much much bigger difference.

Yes. In my opinion, the connector doesn't need to be as large as it is - whether J1772-DC or EU CCS. The adapted type 2 connector (and the TSL02 in the US) are both far more elegant than the frankenplugs (whether J1772-DC or EU CCS).

There are also some psychological reasons for this as well -- the perception is that the bigger the connector, the more anxious and nervous people will be in using it - it's scary and dangerous when it's a bigger connector! Just as a simple example, my wife has no problems whatsoever plugging in the TSL02 at home and she does it daily. Ask her to plug the CHAdeMO connector from the level 3 station into the CHAdeMO adapter? "You can do it."

This makes a big difference for a good amount of the driving public, and will be a big issue for Model X users.