1. INTRODUCTION

As the world increasingly struggles from a global climate change crisis, the push towards adoption of sustainable modes of transportation, especially the electric vehicles ("EV"), over traditional modes of transportation, has been a significant driver in the global fight against climate change. In the Indian context, the adoption of EVs has witnessed remarkable momentum, strengthened by the government's ambitious plans to achieve a substantial transition to EVs.

The successful switch from internal combustion engine vehicles to EVs relies heavily on the development of a robust and accessible EV charging infrastructure and network in India. As per Government of India ("GoI") data, currently there exist only about 6500 public charging stations1 ("PCS") to cater to over 2.8 million EVs in the country.2 Thus, one can argue that infrastructure development to support the growing number of EVs may be on a different trajectory.

This lack of adequate charging infrastructure in India, may be a good reason for consumer scepticism owing to range anxiety and concerns regarding charging accessibility. Therefore, it can be said that comparable development of an efficient and widespread charging infrastructure holds the key to overcoming concerns relating to EVs, ultimately encouraging mass adoption of EVs across urban and rural areas alike.

In this article, we delve into the legal landscape surrounding the EV charging infrastructure in India including a brief overview of the emerging business models, current trends and key stakeholders. Further, in this endeavour we aim to provide a comprehensive analysis of the various consents and authorisations required for establishing and operating a PCS, including the standards to be followed. We also undertake a comparative analysis of the EV charging infrastructure industry in India vis-à-vis the industry in China, Japan, Norway and United States of America. Thereafter, we finally aim to shed light on the potential hurdles in realising an adequate EV charging infrastructure in India, and possible solutions to the same.

2. OVERVIEW OF EV CHARGING INFRASTRUCTURE MARKET IN INDIA

To understand the legal structure surrounding the EV charging infrastructure industry (the "EV Charging Industry"), it is crucial to understand the market dynamics around it. This section identifies the key stakeholders driving its growth and examines the evolving business models within the EV Charging Industry.

2.1 Key Stakeholders

The following table provides a depiction of the key stakeholders in the EV Charging Industry, highlighting the various interactions within the ecosystem:

Stakeholder Role
Site-owners Site-owners refer to the owner of the real estate on which the PCS is built.
Charge point operators A charge point operator installs, manages, maintains, and operates PCSs.
Power distribution companies ("DISCOMs") DISCOMs are utility companies that typically purchase power from electricity generation companies and sell it to consumers (in this case, to charge point operators).
Network service providers Network service providers' act as service providers whose primary responsibility is to help EV drivers find PCSs by offering mobile apps with labelled maps, assist connectivity with the PCS, as well as billing and payment functionalities.
Charging management software companies Charging management software companies assist charging stations in providing back-end services such as energy management, hardware and load monitoring, payment processing, fleet management, etc.
EV manufacturers EV manufacturers collaborate and partner with charge point operators to ensure the availability and accessibility of PCSs for their EV customers
Governmental ministries The government assists the EV Charging Industry in developing and implementing policies, regulations, and incentives that support the growth, accessibility, and sustainability of EV charging infrastructure.
End consumers End consumers are the primary users of EV charging infrastructure by utilising PCSs, providing feedback for improvement, and influencing demand through their choices and preferences.


It is important to note that these stakeholders may be interconnected and interdependent. Charge point operators rely on collaboration with site owners to gain access to suitable locations for PCSs. Site owners, on the other hand, rely on charge point operators to provide the necessary expertise. These stakeholders may also coincide with one another, such as when an EV manufacturer owns its PCSs as well as the real estate it is on. Ultimately, it is the consumer who benefits from these efforts and utilises them. These interactions give growth to diverse business models within the sector. We have discussed these interactions in detail further below.

2.2 Business Models

The EV Charging Industry encompasses a diverse range of business models, each offering unique value propositions from the varied perspectives of key stakeholders. From the perspective of a charge point operator, several interactions take place within the EV Charging Industry, including with site-owners, end consumers, and utility companies, among others. We have highlighted some common business models in the EV Charging Industry relevant to each of these interactions from the point of view of a charge point operator –

Interaction

Model

Description

Interactions with site-owners

Owned and operated

The charge point operator owns the real estate on which it sets up a PCS.

Renting and leasing

The charge point operator rents or leases real estate from the siteowner to set up a PCS.

Revenue Sharing

The charge point operator collaborates with a site-owner for installing PCSs at commercial establishments, wherein the revenue is shared between the charge point operator and the siteowner.

Interactions with end consumers

Parking-based

Where the charge point operator is also a site-owner, it may offer a combination of charging and parking facilities to attract more customers. For example, a mall may offer bundled EV charging with its parking facility to attract more footfall

Subscription services

Charge point operators offer its users the option to pay a recurring fee for access to charging. They may often bundle other benefits such as discounted charging rates, priority access, or faster charging speeds.

Pay-per-use

Charge point operators charge their users on the basis of amount of electricity consumed or the duration of their charging on a persession basis.

Bundled charging

Some charge point operators are empanelled with EV manufacturers such as Audi and BMW, to offer free bundled charging for a fixed period.

Interactions with utility companies

DISCOM connections

In India, power distribution is carried out mostly through publicsector DISCOMs and is a highly regulated activity. Charge point operators generally have to apply for electricity connections with DISCOMs for their electricity needs

Open Access Energy

Charge point operators may obtain electricity through open access from any power generation company directly.

Interactions with other industry stakeholders

Partnership revenue model

Charge point operators often partner with EV manufacturers to offer charging solutions for the EV manufacturer's customers. For example, Mahindra has tied up with Jio-bp to offer charging solutions by using Mahindra's channel locations to set up Jio-bp Mobility Stations.3

Franchise model

Charge point operators such as Statiq offer franchisee opportunities to set up an EV PCS. This allows the market entrant to take advantage of a unified charging app and brand name, while strengthening the franchiser's PCS network.


Other stakeholders in the EV Charging Industry such as fleet operators, cab aggregators, manufacturers of charging infrastructure, or software companies may interact with the ecosystem through other business models. Some examples of these are highlighted below –

(a) Mobility-as-a-Service

Mobility as a service ("MaaS") refers to services which enable users to plan, book, and pay for multiple types of mobility services, typically characterised by a shift from personally-owned modes of transportation. MaaS companies can take many forms including cab aggregators like Uber and Ola, monthly car subscriptions such as those offered by Revv, and bicycle-sharing systems such as Santander cycles. Charge point operators typically interact with these companies by offering charging solutions on a B2B basis dedicated to their operation.

(b) Micro-mobility

Micro-mobility entails the use of low-speed, small vehicles such as cycles, scooters, skateboards, etc. for travelling short distances, typically for first-mile and last-mile connectivity. Micro-mobility generally goes hand-in-hand with the growth of public transit, since public transit typically doesn't offer last-mile connectivity. Companies such as Bounce and Yulu are operating in this space in India. Charge point operators' solutions to these small vehicles requires a combination of public charging and battery swapping (and consequent charging of these swapped batteries).

(c) E-roaming services

Apart from charging management software and network service providers, charge point operators are now also subscribing to e-roaming services. E-roaming services connect several charge point operators and their networks over a single digital platform. This allows consumers to charge their EVs at any PCS, irrespective of the network service provider they are subscribed to or enrolled with. Essentially, e-roaming services promise a "charge-anywhere" experience. Companies such as Numocity and Deepfleet are currently operating in this space in India.

(d) Battery Swapping Stations

Battery swapping technology allows EVs to quickly exchange a discharged battery pack for a fully charged new one, as an alternative to recharging the vehicle via a charging station. Battery swapping is generally used for E2Ws and E3Ws. Companies operating in this space such as Sun Mobility also use a "battery-as-a-service" model, allowing customers to subscribe to batteries, such that they do not have to purchase the battery upfront along with the EV. We have previously analysed India's draft battery swapping policy in an article titled 'Battery Swapping: A Promising Future for Electric Vehicles' accessible here.

In addition to those discussed above, we have described several pioneering business models in the EV industry such as infrastructure-as-a-service and virtual power plants in a previous report titled 'Electric Mobility in India' accessible here.

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Footnotes

1. Please refer https://pib.gov.in/PressReleasePage.aspx?PRID=1910392

2. Please refer https://vahan.parivahan.gov.in/vahan4dashboard/

3. Please refer https://www.mahindra.com/node/3435

Originally published September 2020

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.