EVC对AER的回应——CPU围栏豁免申请

AER Via email:AERringfencing@aer.gov.au. Electric Vehicle Council’s response to the AER consultation on CPU’s ring-fencingwaiver application for providing kerbside EV charging infrastructure The Electric Vehicle Council (EVC) welcomes the opportunity to provide feedback to theAustralian Energy Regulator(AER)on theconsultation paper. The EVC is the national peakbody for the electric vehicle (EV) industry in Australia. Our mission is to accelerate theelectrificationof transport for a sustainable and prosperous future.We representbusinesses acrossthe EV value chain,including car, bus and truck manufacturers,importers,operators,charging infrastructure suppliers,battery reuse and recyclingcompanies, financiers, and network providers. Growing Australia’s Charging Infrastructure Expanding EV charging infrastructure is critical to meeting the target of 1 million EVs onAustralian roads by 2027.Governments and regulators havekeydecisionsto make aboutthe best model for Australia to roll out kerbsidecharging infrastructure.Additionally, thetransport electrification contributes significantly to the National Electricity Objective (NEO)“topromoteefficientinvestment inoperation and use of, electricity services forthe longterm interests of consumers of electricity with respect to….reducing Australia’s greenhousegas emissions,”which means that it is incumbent upon the AER to considercarefullymarketmeasures which may affect thetimelymeeting of this objective.However,more data andanalysis are needed to assess the current state of the charging market, to inform whichmodel will bestdeliver rapid, consumer-centric and cost-efficientexpansion. Before government and regulators support any proposed models for kerbsidechargingthatrequireschanges to the roles and responsibilities of market participants, including thecurrent proposal put forward by DNSPs, we call forregulators to run a thorough andconsultative inquiryto ensure the avoidance of creating any real or perceived marketdistortions through the precedent of this waiver. This processshouldconsiderwhich modelwillbestserve Australia’s EV transition acrossseveral criteria includingspeedof rollout, cost to government, customercosts andimpacts,thecompetition issuesarising from regulated monopolies competing with privatecompanies,relevant international experiences amongst other issues.Via ongoingconsultationwithour members who have providedus theirinputs into this process, weurge the AER to consider specifically what additional analysis is requiredtoachieve the mostholisticenergy market outcome, which may include targeted mapping for EV chargerdemand, cost-benefit analyses or other economic reviews, options fortariffreform tailoredto EV charging,and a clear assessment of the barriers to EV charging installation underthe current marketarrangements. TheEVCdoesnot put forwarda position for or againstthespecificCPU’s ring-fencingwaiver applicationtrial,butthe AER should give close consideration to the following focusareas: Speed of Rollout: Is there evidence ofmarket failure? EVs play an important role in the energy transition,andthe policy and regulatorylandscapeishighly complex.We support improved data demonstrating the status of the chargingrollout and the current charging market locally and consider this a key input into theregulatorydecision-makingprocess. When assessingthisproposal, the AER shouldconsiderexisting dataon the current statusof theEVrollout andevidence ofmarket health, where available, and be guided bythisevidence wherever it exists. The AER should look at how this proposal uses that data andaddressesany gaps-likecoverageor future needs. Where evidence is lacking, the assessment should seek to establish it to inform sounddecision-making. Competition Issues: Is there innovation? There are several existing kerbside charging infrastructure providers inan establishedmarket offering in Australia.Competition in the EV charging market is desirable forconsumer benefits throughmarket growthand product innovation. Departuresfrom thecurrent market roles and responsibilities should be based onevidence-based policy thatdemonstrablygets more people into EVssooner, at the lowestexisting and ongoingcost tocustomers. Costs:Is there transparency on costs, their impact togovernment and consumers? In the case of kerbside EV charging market expansion,thereislimited evidenceof howmuch this will cost consumers andgovernment. If the costscan be demonstrably shown tobesubstantially lower than any other mechanism,the AER should considerhow can thisbe deliveredwithout givingthe regulated network businessesan advantage aboveothermarket participants.An evidence-based assessment is needed to present areas of costsavings through changes to market arrangements and any impacts to reduced competition. Customer Impacts:Is there customer benefit? To reach a goal of50% of new car salesbeing electricby 2030, consumers mustcontinueto see benefits from the role of EVs in the energy transi