Article
citation information:
Kałuża, M., Sierpiński, G. Procedures for the actions required to
build electric car charging stations against the polish legal framework. Scientific Journal of Silesian University of Technology. Series
Transport. 2019, 105, 91-100.
ISSN: 0209-3324. DOI: https://doi.org/10.20858/sjsutst.2019.105.8.
Marta KAŁUŻA[1],
Grzegorz SIERPIŃSKI[2]
PROCEDURES FOR THE
ACTIONS REQUIRED TO BUILD ELECTRIC CAR CHARGING STATIONS AGAINST THE POLISH
LEGAL FRAMEWORK
Summary. The article is an attempt to review the requirements
and procedures which an investor who intends to build and commission an
electric car charging station must follow. What has been highlighted is the
conditions and restrictions associated with the siting of such facilities, the
relevant safety requirements and the technical inspection procedures prior to
the commissioning of a charging station.
Keywords: electromobility,
charging station, urban planning
1. INTRODUCTION
In the recent years, one
could observe certain changes in how the automotive industry has been
developing towards electric cars. Despite initial scepticism, vehicle
manufacturers operating all around the world started manufacturing individual
electric models, while some of them have already declared significant expansion
in the production of such vehicles in the years to come [1,2]. Electric cars
offer numerous advantages, some of which are primarily the reduction of
external costs [3-5], including those related to noise, as well as
environmental costs.
The momentum of electromobility
development is determined by a number of external factors. Among them, the
price barrier and the anxiety about the limited operating range of electric
cars are the most topical ones [6]. With regard to the latter, special attention
should be paid to the development of the charging infrastructure as well as the
message sent by stakeholders. Proper promotion of electromobility
may significantly contribute to the increase in the number of users of these
vehicles. This is one of the main problems in focus of the research performed
under the international project titled “Electric travelling –
platform to support the implementation of electromobility
in Smart Cities based on ICT applications (7)” implemented under the ERANET CoFund EMEurope
programme co-financed, among other entities, by the National Centre for
Research and Development.
The infrastructure
development must proceed in line with the local legal regulations of the
country concerned. With regard to charging stations, ensuring the capacity for
connection to the power grid is not without significance. The article discusses
selected legal requirements and procedures associated with construction of
charging stations in Poland. The respective problems consecutively addressed in
the paper include the following:
- additional factors to be
taken into account in the process of siting of charging stations, related to
land development and access to the power grid,
- requirements towards
charging stations and their surroundings,
- procedures for the
commencement of works,
- connection and acceptance
procedures pertaining to the Distribution Network Operator and the Office of
Technical Inspection.
The procedures described
in the article provide the grounds for building a charging station, and then signing
contracts for the station operation.
2. SITING
OF CHARGING STATIONS AND ACCESS TO THE POWER GRID
One of the main problems raised in the literature of the subject
with regard to the development of electromobility is
the proper siting of charging stations. One can speak of a number of methods
which take such factors into account as population density, coefficient of
motorisation, charging station cost, distance between stations, volume of
traffic streams, etc. [8-15]. However, the choice of a location is also determined by the land
use. Important information that the investor must have before making the final
decision to build a charging station is the intended use of the given plot of
land on which construction works are to be conducted. It is established in the
local land development plan, defining not only the plot’s intended use,
but also the conditions for land and building development, as well as the
siting of public utility projects. With regard to a charging station, the land
where the investment is to be implemented should be categorised as service
development area, and as for the point of service connection to the power grid,
it should belong to the technical infrastructure. In both these cases, there
may be no exclusions, as they are formally referred to, established on such
plots, preventing either the erection of a charging station or a service
connection.
Another limitation is obtaining a legal title which provides for
the right to perform construction works.
In
accordance with article 3(11) of the construction law [16], a legal title
should result from the right of ownership or joint ownership, or from the right
of use or perpetual usufruct. An investor can also be a lessee, provided that
the lessor holding the relevant legal title to the real estate in question has
authorised the other party to the agreement to perform construction works under
the lease agreement.
The siting of a charging station also depends on the capacity to
connect it to the power grid. In this respect, one is required to submit a
request to the chosen Distribution Network Operator for determining the terms
and conditions of connection to the distribution network, and upon their
settlement, to sign an agreement and develop the actual connection to the
network. In order to choose optimum locations for the installation of electric car
charging points, both in terms of the investor’s requirements and the
distribution network capabilities, one is advised to contact the Distribution
Network Operator in advance.
3. LEGAL REQUIREMENTS TOWARDS THE TECHNICAL DOCUMENTATION
3.1. Compliance with legal regulations
In accordance with article 13 of the act on electromobility
and alternative fuels [17], charging stations should comply with the technical
and operating requirements specified in particular in Polish Standards, which
will ensure their safe operation, including fire safety, safe functioning of
power supply systems and access to charging stations for the disabled. Detailed
information on the technical requirements to be met by charging stations is
provided in the Regulation of the Minister of Energy on the technical
requirements for charging stations and charging points being parts of the
charging infrastructure for public road transport [18]. The act in question
[17] approves and defines (article 15, items 1 and 2) the procedure for
obtaining an opinion on the conformity of the technical documentation of the
station designed with the applicable technical requirements. Therefore, before
proceeding with the construction of the charging station, one can file a
request to the President of the Office of Technical Inspection for issuing upon
payment an opinion on the conformity of the technical documentation of the
station designed with the technical requirements specified in the act [17]
(article 13) and the regulation [18] in question.
3.2.
Requirements towards basic technical means of protection
The most important technical requirements are those pertaining to
fire protection of the facility, as stipulated in article 5 of the said
Regulation [18]. It stipulates that the equipment comprising the charging
station must feature at least one of the following safeguards:
-
a main
switch cutting off power supply from all circuits of the facility,
-
a
residual-current circuit breaker in cases where the facility is powered from an
AC network,
-
overcurrent protection.
Moreover, in accordance with article 6 of the Regulation, the
facility must be functionally based on the principle of selectivity of
protection devices.
The manufacturer of the equipment admitted to the given market is
obliged to guarantee the compliance of the facility with the relevant
standards, and particularly with the standards harmonised with the LVD and EMC directives, as well as compliance with all the
infrastructural requirements concerning, among other aspects, means of electric
shock protection (both basic protection and protection in case of damage), fire
protection, capacity to operate at specific temperatures or adequate
ventilation.
In
terms of the compliance of charging stations with Polish standards, it is
recommended that the devices installed at the station meet the guidelines
provided in respective industry-specific standards, such as the following:
- PN-EN 61851-1 Electric vehicle
conductive charging system – Part 1: General requirements.
- PN-EN 61851-21 Electric vehicle
conductive charging system – Part 21: Electric vehicle on-board charger
EMC requirements for conductive connection to an AC/DC supply,
- PN-EN 61851-23:2014-11 Electric
vehicle conductive charging system – Part 23: DC electric vehicle
charging station,
- PN-EN 61851-24:2014-11 Electric
vehicle conductive charging system – Part 24: Digital communication
between a DC EV charging station and an electric vehicle for control of DC
charging,
- PN-EN ISO 15118-1:2015-09 Road
vehicles – Vehicle to grid communication interface – Part 1:
General information and use-case definition,
- PN-EN ISO 15118-2:2016-09 Road
vehicles – Vehicle to grid communication interface – Part 2:
Network and application protocol requirements,
- PN-EN ISO 15118-3:2016-06 Road
vehicles – Vehicle to grid communication interface – Part 3:
Physical and data link layer requirements,
- PN-EN 50620:2017-07 Electric cables
– Charging cables for electric vehicles,
- PN-EN 62752:2016-2 In-cable control
and protection device for mode 2 charging of electric road vehicles (IC-CPD),
- PN-HD 60364-7-722 Low-voltage
electrical installations – Part 7-722: Requirements for special
installations or locations – Supplies for electric vehicles,
- standards of the PN-EN 62196 family,
setting guidelines for sockets and plugs for electric vehicle conductive
charging points,
- standards of the PN-EN
ISO 15118 family, concerning vehicle to grid communication.
The building requirements towards charging stations, as stipulated
in article 8 of the Regulation [18], concern protection of the facility against
mechanical damage. This kind of protection should be provided by:
-
siting
the facility in such a way as to avoid damage caused by a vehicle running over
it (equipment installed on an elevated platform), or
-
using
additional mechanical means of protection, such as bumpers, posts or barriers.
Furthermore, ensuring compliance with the
above requirements must not hinder access to the charging point for people with
disabilities (article 8(2) of the Regulation [18]).
The location of the charging station and its accessibility to
users must be planned in such a way that there is no need to engage any
charging cable extensions while using the facility (article 10 of the
Regulation [18]).
The applicable Polish guidelines also provide for the sockets
which enable charging of electric cars. In this respect, section 3 of the
Regulation [18] specifies in detail the requirements to be met by vehicle
sockets or connectors. Depending on the nominal power, charging points must
feature either type 2 output sockets or vehicle connectors, as defined in the PN-EN 62196-2 standard [19] (for alternating current), or
universal Combo 2 connectors, as per PN-EN 62196-3
[20] (for direct current).
Where any additional parking spaces are provided within the
charging station, the provisions of the Regulation of the Minister of
Infrastructure and Construction on technical conditions to be met by buildings
and their location [21] should be
followed.
In accordance with article 21,
sections 1, 2 and 3 of the Regulation [21], the following minimum dimensions
are defined:
a) separate parking spaces
for cars:
- 2.5 m in width and 5 m
in length for passenger cars,
- 3.6 m in width and 5 m
in length for passenger cars used by disabled persons,
- 3.5 m in width and 8 m
in length for heavy commercial vehicles,
- 4 m in width and 10 m in
length for buses;
b) parking spaces arranged
along the carriageway:
- 3.6 m in width, with
optional reduction to 2.5 m, for cases where it is possible to use an adjacent
access route or a pedestrian and vehicle route, and 6 m in length for passenger
cars,
- 3.6 m in width and 6 m
in length for passenger cars used by disabled persons,
- 3 m in width and 15 m in
length for heavy commercial vehicles,
-
3 m in width and 19 m in length for buses.
3.3. Notification on the intend to
build a charging station submitted to the architectural and construction
administration body
Within the meaning of the construction law [16], building of both
charging stations and charging points does not require the investor to procure
a planning permission (article 29(1)(8a)). Under article 29(1)(20)
[16], neither is it required in the case of construction of a power supply
service connection.
In accordance with article 29a(1) [16],
construction of service connections and charging stations requires a layout
plan to be developed on a copy of an up-to-date master map or unit map entered
into the state surveying and cartographic records.
Additionally, article 30(1) of the Regulation [16] obligates the
investor to notify the architectural and construction administration body about
the intent to build the service connection as well as the charging station.
Depending on the station location, the competent authority is either a district
governor (Polish starosta)
or a mayor (Polish prezydent)
in municipalities with the rights of an administrative district (Polish powiat), or a
province governor (Polish wojewoda), e.g. in railway areas.
The construction law stipulates in detail what it should contain,
and what other documents should be attached to such a notification of the
intent to conduct construction works. In accordance with article 30(2) [16],
the notification should state the type, scope and manner of performing the
construction works as well as their commencement date. The notification should
be accompanied with a declaration on being entitled to use the property for
construction purposes, relevant sketches and drawings, as well as permits or
arrangements required by separate regulations (e.g. service connection
requirements, permit to occupy a roadway lane, arrangements with the competent
conservation officer, if the facility is to be located within the area subject
to such conservation officer’s supervision). Where a service connection
with the power grid is to be built, the plot or land development plan should be
additionally enclosed along with a technical description of the installation.
This plan must be prepared by a designer holding an adequate building license.
The notification of construction works should be submitted before
the date of the intended commencement of the construction works (article 30(5)
[16]). The architectural and construction administration body may file an
objection within 21 days from the date of receipt of the notification. In
accordance with article 30(1a) [16], instead
notifying the intent to perform construction works, the investor may submit a
request for a planning permission.
As per
article 41(1) [16], the construction project formally commences upon beginning
preparatory works at the construction site. The preparatory works (as per
article 41(2) [16]) include staking out in the field, terrain levelling,
developing the required service lines or fencing of the construction site.
4. SERVICE CONNECTION
AND ACCEPTANCE PROCEDURES
4.1. Notification to the
Distribution Network Operator
Upon completion of the construction works, the investor is required to
notify the chosen Distribution Network Operator of the readiness of the user
wiring system to be connected to the power grid.
The electric vehicle charging points to be connected to the
distribution network must meet the requirements provided in the relevant
standards and regulations, such as those pertaining to operating safety and
quality parameters, including not causing any disturbance in the power grid,
etc.
When connecting fast EV charging points to the power grid, or a
set of charging stations which require more capacity, it is also possible that
these installations are connected to a medium-voltage network through a
transformer substation owned by the investor, also referred to as an end-user
transformer substation.
In accordance with the regulations in force, electric car charging
points, as any other facility connected to the network, must be equipped with
an appropriate measuring and billing system delivered and installed by the
competent Distribution Network Operator.
4.2. Notification to the Office
of Technical Inspection
Before a public charging station is commissioned and put into service,
its operator is obliged to file a request to the Office of Technical Inspection
for a preliminary technical inspection for operating safety of the station. The
manner in which the inspection is performed is defined in the applicable
Regulation of the Minister of Energy [18].
The inspection consists of checking the completeness of the
documentation, verifying the compliance with the relevant requirements, visual
inspections, random measurements and functional or load tests. Only equipment
that has been completely assembled, which is fully operational and ready for
use qualifies for the testing, which is performed by an inspector representing
the Office of Technical Inspection in the presence of the operator (or a person
authorised by the operator) within 30 days of the submission of a complete
request for performing the tests.
In article 22, the Regulation in question [18] also lists the
documents which must accompany the request for testing:
a) technical description of the facility:
- name, address, telephone number and e-mail address of the
operator;
- information whether the facility is a charging station, a public
charging station or a charging point being a part of the public road transport
charging infrastructure;
- technical details of the facility: type, factory number, number of
charging points within the charging station;
- electrical input parameters: input power, mains voltage, and mains
system, if applicable;
- electrical output parameters: ranges and types of output voltages
for individual charging points, maximum charging currents for individual
charging points, IP protection of the facility;
- facility dimensions:
- height above the ground level at which the user interface has been
installed, if present;
- connector type for each charging point;
- ambient temperature range within which the facility can be
operated;
- station’s longitude and latitude as per the WGS84 system;
b) a declaration of conformity, as referred to in article 5(10) of
the act of 30 August 2002 on the conformity assessment system [22], i.e. a declaration
by the manufacturer or their authorised representative stating to their sole
responsibility that the given product complies with the relevant essential
requirements;
c) operating instructions in Polish provided by the manufacturer of
the facility equipment or their authorised representative;
d) a certificate of correct installation, as per a template provided
in the annex to the Regulation;
e) records of electrical measurements approved by a person qualified
to perform duties of an supervision inspector, referred to in the regulations
issued pursuant to article 54(6) of the energy law [23] along with a copy of
the qualification certificate held by the person in question, certified by the
same person for conformity with the original;
f) a drawing along with a description of the place where the facility
has been installed, showing in particular its location against areas of road
traffic, pedestrian traffic, vehicle charging stations, explosion hazard zones,
as well as a description of the measures applied to protect the facility
against mechanical damage and of the rainwater drainage method;
g) a diagram of the facility’s power supply system, indicating
in particular the charging point equipment enabling the vehicle to be connected
to the charging point and feeding the connected vehicle with energy (power
supply equipment), the size and type of safeguards, as well as the type and
category of power supply lines;
h) a copy of the technical acceptance protocol for the installation
or the power supply service connection;
i) an opinion on meeting the
relevant fire protection requirements, issued by a fire protection expert.
5. CONCLUSION
Full implementation of electromobility
requires actions integrated on many levels of the transport systems currently
in operation. The efforts undertaken so far by the manufacturers of electric
cars, aimed to extend the distance they can cover on single charging, have
recently been substituted by their urge to design urban cars that can be
recharged as quickly as possible. In light of the insufficient charging
infrastructure, this constitutes a clear barrier hampering the development of electromobility in Poland. The procedures discussed in the
article are envisaged to allow for the formal requirements pertaining to
construction of electric car charging stations to be fulfilled. It should be
noted that with regard to charging stations 2020 will be a particularly
important year for Poland, since the act on electromobility
and alternative fuels [17] imposes an obligation on municipalities to prepare
plans for the construction of charging stations, followed by their actual
installation and commissioning in a specific minimum number by 31 December
2020.
Acknowledgements
The present research has
been financed from the means of the National Centre for Research and
Development as a part of the international project within the scope of ERA-NET CoFund Electric Mobility Europe Programme “Electric
travelling - platform to support the implementation of electromobility
in Smart Cities based on ICT applications”.
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