Takshashila Policy Advisory - Comments on NITI Aayog’s Draft Battery Swapping Policy
Executive Summary
The Draft Battery Swapping Policy (Policy) aims to create a framework for greater interoperability while safeguarding the innovation potential for the Electric Vehicles (EV) battery ecosystem. Our major recommendations are:
The Policy guidelines should expand its existing focus on safety by including SOPs on the shipping of batteries, fire safety etc.
The Policy should mandate that EVs, Batteries, Charging Stations and other related accessories are ISO26262 (or equivalent) compliant.
The Policy must specifically state that data privacy concerns will be factored in. Remote monitoring and tracking need to be done to ensure the privacy of the EV owner. The use of state of the art cryptographic mechanisms can help in ensuring that battery identity and battery data are trustworthy.
The mechanism for apportionment of liability between the Battery Provider, Original Equipment Manufacturer (OEM) and EV user is not clear and needs to be specified in the Policy.
The Policy should be suitably amended to remove reference to self-certification. While self-certification may appear as a simple process, it poses safety risks and concerns.
Increase capacity for inspection, testing, and certification (ITC) by using a marketplace model where ITC can be done by multiple private agencies which receive licenses from the relevant government bodies.
Introduction
The Government of India (GoI) has taken the lead in enabling sustainability and innovation with its new Policy which enables an innovative battery swapping ecosystem. At the outset, we welcome the Policy and the call for comments. However, we note that some aspects of the Policy demand further scrutiny. The comments below are compiled by a team that has analysed the draft from legal, technological, and policy angles.
Our Comments
Focus on safety
Position under the Policy
Paragraph 5.2 of the Policy which deals with Battery and Swapping Station Unique Identification Number (UIN) states that “To implement unique traceability across the battery lifecycle, a Unique Identification Number (UIN) shall be assigned at the manufacturing stage for tracking and monitoring EV batteries.”
Our comments
The Policy guidelines could expand its existing focus on safety by including the following aspects:
A fire hydrant to tackle safety issues stemming from fires caused by batteries.
Proposing a standard for fire retardation system.
Standard Operating Procedures to safely ship batteries to and from Battery Charging Stations and Battery Swapping Stations (eg. shipping them when discharged).
The Policy could also highlight other existing policies and guidelines which tackle safety, which might be applicable in the case of charging swappable batteries or running a Battery Charging Station.
Focus on standards setting
Position under the Policy
The second bullet in Paragraph 5.3 of the Policy states that the “BMS of the battery must be self-certified and open for testing to check its compatibility with various systems, and capability to meet safety requirements.”
Our Comments
The Policy should mandate that EVs, Batteries, Charging Stations and other related accessories are ISO26262 (or equivalent) compliant.
We are of the opinion that the Policy must specifically refer to the Indian Standards of Battery Swapping that the e-amrit website of the Niti Aayog refers to.
Standardizing the physical interface for electrical connection, communication interface and the communication protocol b/w the battery and its ecosystem, in addition to providing guidance on mechanical form factor - e.g. by classifying swappable batteries per top use cases, can potentially expedite economies of scale and affordability for the broad market that are in greatest need for clean, affordable mobility.
Technical and operational requirements
Position under the Policy
Paragraph 5.1 of the Policy states that “To ensure battery safety and security of assets, swappable batteries will be equipped with advanced features like IoT-based battery monitoring systems, remote monitoring & immobilization capabilities, and other required control features.”
Our comments
The Policy must specifically state that data privacy concerns will be factored in. Remote monitoring and tracking need to be done in a way which ensures the privacy of the EV owner.
Data is aptly recognized in the draft policy as a pillar of future business models around BaaS for first life vehicle applications. The Policy may also consider emphasizing the integrity of data for enabling robust market and efficient processes for managing batteries throughout their lifecycle, e.g. towards second life applications in energy storage. Appropriate processes and guidelines including e.g., the use of state of art cryptographic mechanisms may be suggested in ensuring that battery identity and battery data are trustworthy.
Convergence with 5G network rollout in India may be considered - e.g. by suggesting the use of NB-IoT for remote monitoring, which potentially enables monitoring of swappable batteries in remote locations and kirana stores, without depending on WiFi access points.
A centralized portal for assigning digitally signed certificates (DSC) similar to the mechanism employed in the case of ‘Digital Sky’ for drones, may be considered for digitizing approval and verification of approved battery vendors, that can enable OEMs to remotely check (for safety reasons) the provenance of swappable batteries before allowing the vehicle to operate.
The final aspect of our comments concerns the battery's intended second life post its initial intended usage. Guidelines should be issued to clarify an SOP for the safe disposal of batteries. Alternatively, the guidelines should also develop an SOP which enables batteries for specific use cases such as in Solar Farms.
Data Sharing and Communication
Position under the Policy
Paragraph 5.5 of the Policy states that “The information to be tracked by battery providers on an ongoing basis will be defined and the assigned nodal government authorities may access it at any time.”
Paragraph 5.5 of the Policy further states that “For the classification of collected data under the broad categories of proprietary, restricted-access, private and open-data, a non-restrictive detailed guideline will be developed for adherence by all industry players.”
Our comments
The Policy must state which organisation will be responsible for developing this non-restrictive detailed guideline.
Grievance redressal and compensation
Position under the Policy
Paragraph 7.1 of the Policy states that “On behalf of the ecosystem, the Battery Provider will also be responsible for channelling monetary compensation to the EV owners within a stipulated time, if necessary. The Battery Provider may not necessarily bear the cost of such compensation depending on the particulars of the case, and may recover these costs from other ecosystem players, for instance, the EV manufacturer, should there be a technical fault in its EV(s).”
Our Comments
The mechanism for apportionment of liability is not clear and needs to be specified in the Policy.
Further, the Policy must state how exactly the Battery Provider will channelise the monetary compensation to the EV owner.
Planning and provision of battery swapping networks
Position under the Policy
Paragraph 9.4 of the Policy refers to the “Charging infrastructure for electric vehicles – Guidelines and Standards” released by the Ministry of Power in January 2022.
Paragraph 9.4 of the Policy further states that Battery charging and swapping stations are required to be in accordance with the requirements specified for public charging infrastructure in Section 3 of January 2022, Ministry of Power Guidelines.
Our Comments
Section 3 of the January 2022 Ministry of Power Guidelines only refers to requirements that Public Charging Stations (PCS) are required to adhere to. A PCS is defined in the January 2022 Guidelines as “EV Charging station where any electric vehicle can get its battery charged.” There is no reference to the requirements that Battery Swapping Stations are required to adhere to.
While Paragraph 5.4 of the Policy states that “standards for BCS and BSS will be developed or approved by BIS/ Ministry of Power (MoP) or other competent authorities,” the January 2022 Guidelines are silent on the requirements for Battery Swapping Stations.
There must be specific reference as to which organisation will formulate the safety requirements to be followed by kirana shops and general stores. Further, the mechanism for the implementation of the same must also be specified.
Power supply connections for battery charging stations
Position under the Policy
Paragraph 9.6 of the Policy states that “Battery providers should be able to self-certify their installations for safety as per guidelines provided by the distribution utility.”
Our Comments:
The Policy should be suitably amended to remove reference to self-certification. While self-certification may appear as a simple process, it poses safety risks and concerns.
Further, in Paragraph 9.6 of the Policy, the term ‘Battery providers’ should be replaced with Battery Swapping Stations (BSS) / Battery Charging Stations (BCS) as the installations will be constructed by the BSS or the BCS as the case may be.
Creation of an informal council/apex organization
Position under the Policy
Paragraph 9.7 of the Policy states that “A single window portal should be set up to facilitate submission of all required documents by battery swapping providers, issue trade licenses for battery swapping businesses, approve allocation of public land for installation of battery swapping stations and to grant electricity supply connections for battery charging centres/ stations.”
Our comments
Given the multiplicity of regulatory institutions involved, there is a need for an organization/apex body which has a representative from each of the following stakeholder organizations:
Bureau of Indian Standards - Come up with standards for the industry
Bureau of Energy Efficiency - Central Nodal Agency responsible for the rollout of EV public charging infrastructure,
Ministry of Power - Play a coordinator’s role in the council/apex or7ganization
Ministry of Road, Transport and Highways - Dealing with challenges regarding registration of vehicles without batteries
Ministry of Environment, Forests and Climate Change - Implementing Draft Battery Waste Management Rules (2020).
Central Electricity Authority - Setting standards for safety and connectivity.
Automotive Research Association of India - Testing of vehicles
Industry representatives
Niti Aayog representative
Increasing capacity for Inspection, Testing and Certification (ITC)
Implementation of this policy requires multiple rounds of inspection, testing, and certifications (ITC) primarily to ensure safety and reliability. It is likely that GoI might face capacity constraints in implementing these checks. Non-availability of ITC providers might lead to unsafe and illegal charging and swapping installations. Hence we recommend that ITC be done by using a marketplace model. ITC can be done by multiple private agencies which receive licenses from the relevant government bodies. This mechanism will increase the ITC capacity.
Authors
