The Electric Vehicle Council (EVC) responds to the AER consultation on CPU's ring-fencing waiver application for providing kerbside EV charging infrastructure. The EVC emphasizes the importance of expanding EV charging infrastructure to meet the target of 1 million EVs on Australian roads by 2027 and highlights that transport electrification contributes significantly to the National Electricity Objective (NEO) of reducing greenhouse gas emissions. The EVC calls for a thorough and consultative inquiry to assess the current state of the charging market and determine the best model for kerbside charging, considering criteria such as speed of rollout, cost to government, customer costs, competition issues, and international experiences.
The EVC does not take a position on the specific CPU waiver application but urges the AER to consider the following focus areas:
- Speed of Rollout: Assess whether there is evidence of market failure and use existing data on EV rollout and market health to inform decision-making.
- Competition Issues: Ensure the proposal promotes innovation and benefits consumers through market growth, avoiding distortions caused by regulated monopolies competing with private companies.
- Costs: Provide transparency on costs to consumers and government, demonstrating that the proposed model is cost-efficient compared to alternatives.
- Customer Impacts: Evaluate whether the proposal balances utilisation, user pays, cross-subsidizing of EVSE deployment, and the overall cost of energy for EVs, while mitigating risks of backlash from non-EV drivers.
The EVC recommends additional analysis, such as targeted mapping for EV charger demand, cost-benefit analyses, tariff reform options, and assessments of barriers to EV charging installation under current market arrangements. The submission concludes by acknowledging that different EVC members may have varying views and encourages them to submit directly to the consultation process.
