Direct submissions to the institutions that write and review this regulation

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.

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.

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.