EVC向NT Power&Water EVSE技术规范提交的文件

AddresseeNT Power & Water Via email:Networksevents.PWC@powerwater.com.au Regarding:Electric Vehicle Supply Equipment Technical Specification | Power and WaterCorporation | Have your say Introduction The EVCappreciates the opportunity to consult on this important document which willoutline the way in which EV supply equipment may be installed and operated in the NT. EVs aregood for networks and EV uptake should be encouraged.When EV chargingload comes onto the network is most efficientlymanaged through pricing.Time-of-usetariffs encourageconsumers to charge EVs in the middle of the day or off-peak anddisincentivise charging during peak periods.Other methods of orchestrating EV chargingis via VPPs, HEMS, CPO deployed load management systemsand other proprietarysystems eg. Origin, ChargeHQ.In all of these instances, the network and the system arethere to serveconsumers and are paid for by consumers.It follows thatconsumers mustbe able to opt-out of any management, the AER agrees.1 Opting-outwill usually meanthe consumeris informed that limitation iscoming andhas access to a button that willoverride any limitationif they need to charge at thecharger’scapacity, there may be feesaccompanyingopt-out. We have some concerns with the contentandthese are explored in some detail below. 3.Obligations of Proponents 3.b. EVSE 3.7–400kW are in scope meaning that installation of standard 7kWper phaseACEVSE would be required to apply to NT P&Wfor connection.It is not apparent from theService andInstallationRules (NP018)that this is required for other appliances of similarpotential current draw such asOvens,Cooktops, AirConditioners etc.This is discriminatory towards EVowners, difficult to police and the objectivescan be achieved inother ways. The objective of knowing where EV charging is occurring can be met frompostcodelevelEVsales dataora checkbox on an electrical certificate ofcompliancethat an EV chargerhas been installed.There is also analysis that can be done from smart meter data todetermine when and where EV charging is occurring.Objectives of system managementbyprescribing what size EVSE or whether limitationwill be implemented can be metthrough automatic pre-approvals up to a certainsize, TOU tariffs, education campaignsetc. 4.1Definition Maximum rate of charge-This definition is good because it allows for control by limitation(as per AS/NZS3000) and internal settings which reflects the work the EVSE willbedoing, rather than nameplate rating. 4.2 Abbreviations EVSDE–The EVChas become aware that thisabbreviationmay have come from the SAjurisdiction. It is not commonly used in other jurisdictions.It is important for industry touseconsistent terminology, such as from the IEA.In other parts of the document,‘bidirectional EVSE’is used, which is appropriate. 6. Technical requirements 6.3 Demand response The percentage of EVs on Australian roads is around 2%, the percentage in NT is0.6%.2There is time for NT to observe global trends andassess whether demand response isrequired in future. 6.4Verification of demand response AS/NZS4755was not designed for EVSEand globally,product is nottypicallymanufactured to support it. If a demand response system is deemed necessary,mandatinga version ofOCPPcould be considered, though this incurs extra cost3.Whatmust be considered here is to what extentthe requirement limits the availability ofequipment able to be installed. The final paragraph states, “..shall be capable of being tested..”. It is not clear whatstandard it would be tested to.If there’s nostandard then there’s no test.Demandresponse via AS/NZS4755 DRMs is one waycommunication, the OCPProtocols are twoway and tests can be carried out remotely. 6.5 Electrical vehicle energy management system The wording may need to be tightened up here. If the intention is to relay thattheEVSEfinalsub-circuitshall be capable of carrying the full rated current, thenthe intention isgood,however, it could be interpreted to mean thatthe entireelectrical installationneedsto be capable of runningseveral EVSE at full current.This is consistent withAS/NZS3000maximum demand method A–Calculation, where 100% of capacity isused.It is not consistent with maximum demand methods B–Assessment, C–MeasurementorD–Limitation.Inshort,the paragraph needs to allow for diversityafforded by controlsystems. Suggest todelete or re-word the final sentence.“Energy management is the remotemonitoring and control of the EVSE connections to the grid network.The proponent mayinstall an energy management system to ensure that site import and export limits are notexceeded, particularly in instances where the installed EV capacity exceeds thecontracted maximum demand.Single EVSEfinalsub-circuitcablesshall be installed tocarryfull nameplate current rating.” 6.5.2EVSDE/Bidirectional charging Vehicle-to-any(V2X) can also mean Vehicle-to-load which does not use invertersthatintegrate withthe grid (AS/NZS4777.2).A fuel-driven generator that is connected to