Direct submissions to the institutions that write and review this regulation
These are not opinion pieces. Each entry below started as research, went to the European Commission or ENTSO-E as a formal submission, and got a reply on the institutional record. That is the difference between writing about regulation and being read by the people who write it.
AFIR mandatory review, public consultation
The Cross-Border Compliance Stack, built on operator-level evidence across the Netherlands, Germany, Spain, and Portugal. The submission documents the four-layer compliance stack a charge point operator meets when it expands from one AFIR-compliant member state into the next, and puts three fixes to the Commission:
- Consolidate the 33 non-binding Article 5 Q&As into one binding technical standard.
- Create a single EU-level EVSE type-approval registry with mutual recognition across member states.
- Mandate an OCPP version baseline with forward compatibility to ISO 15118-20, phased in rather than forced at once.
Acknowledged by the Commission's AFIR policy team. Direct contact established with the officials handling the review, including a follow-up flagging the submission ahead of implementation discussions. Full paper linked below.
DESAP D4.1 roadmap, distributed energy storage and aggregation platform
Direct input to the D4.1 roadmap, drawing on the CPO-aggregator financing and regulatory framework set out in Charging Without Subsidy, the paper that designs a subsidy-free path to community-scale distributed energy investment in an existing EU market.
Sent directly to the ENTSO-E JTF members handling the D4.1 roadmap, following the Digital Twins seminar on 2 April 2026 where the underlying gap was raised in person. ENTSO-E confirmed receipt and said the input is under consideration. Availability offered for Advisory Board or D4.1 cluster calls on the technical or regulatory workstreams.
ENTSO-E Ten-Year Network Development Plan 2026, consultation response
A response applying the distribution congestion and sequencing framework from the Urban Blind Spot and Sequencing Electrification papers to the network development plan under consultation, on record with ENTSO-E under the reference above.
Response acknowledged under ID ANON-VZG4-FCQ3-R. Submission followed the ENTSO-E stakeholder workshop on 27 March 2026, held during the consultation window.