EVC向财政部提交的现金承兑委托书

DirectorRetail Banking and Currency UnitBanking and Credit BranchThe TreasuryLangton CrescentPARKESACT2600 Via email:CashAcceptanceConsultation@treasury.gov.au Mandating cash acceptance | Treasury.gov.au Introduction The EVC appreciates the opportunity to contribute tothis important consultation.TheEVC’s mission is toaccelerate the electrification of road transport, supported bya strong,expansive ecosystem of EV charginginfrastructure.We recognisethere arecertaincriticalsectorsin the economywhereacceptance of cash payments should bemandatory,but theEVC is concerned thatany such mandate could inadvertently affect paymentsat EVcharging stations. For the sake of clarity,the EVC is calling fora carve outfromanycashacceptancemandatesforEV chargingand Charge Point Operators (CPOs).Imposing cash payments forwhat is aninherently digital infrastructure would have the effect of materially slowing the EVtransition,jeopardising the Government’s legislated emissions reduction targets andfrustrating the decarbonisation of the Australian economy. EV charging has always been cashless As a relatively new industry, EV charging has not undergone the typical transition from cashto online payments; it is and has always been cashless.Given the nature of EV charging,deployments need to be operational anywhere, available 24/7 and at lowest cost.Systemsare digital,charging stations areunmannedand payments typicallyapp-based or ‘tap-and-go’. In fact, the Energy and Climate Ministerial Council has published a set of “Minimumoperatingstandards for government-supported public electric vehicle charginginfrastructure”.1The ‘Payment’sectionproactivelyencourages options of “smart phone orwebsite applications, or over-the-phone credit or debit card payment systems” which areoptions the vast majority of Australians are very familiar with. Not only areEV charging stationsunattended,employeeswouldtypicallyvisit thecharginglocationonlyfor periodic inspections, maintenance and repairs.Mandating in-personcashcollectionwould bemuch more expensiveand introduce unacceptably high labour costs tothis critical fledgling industry. Alternatively,cash acceptance mandateswithoutface-to-faceinteractionswould likelypushCharge Point Operatorsto install machines to accept the cash. These machineshavehistorically been unreliable, not accepting particular coins and notesand would themselvesneed periodic repairs and maintenance. A spokesperson for Evie provided the example of an installationwith two fast chargersinaCouncil car park. The site is safe,well-litand has 24/7 accessbut is not integrated witha shopfront.They noted a cashbox on site would encourage criminal activity and theCouncil would no longer support hosting of the infrastructure. They went on to say the EVchargingindustry is already facing headwinds from globally unique Australianrequirements,2on top“A cash payment requirement wouldseverely hampertheroll out.” Furthermore,EV drivers areby definitiondigitally literateand will continue to be.Asuptake ramps up to 100% by 2050,3the cohort of people driving EVswill all be‘digitalnatives’capable ofinitiating a charge digitally; indeed they will have never known anyother payment method.We also notethat systems willlikelyget simplerto useand moreautomated with time. Stickingglobal The EV charging industry is nascent in Australia and working hard to stay abreast of EVuptake. It has based the rollout of EV charging systems on global technology proven towork, following international best practice. No other country in the world has mandated cash transactions for EV charging and thereis no reason to do it in Australia. A requirement of this nature would setback the industryconsiderably and jeopardise government targets for the broader EV transition. In some respects, Australia’s EV transition is alreadybeinghampered by divergence frominternational standards. The higher costs and regulatory burden from unique requirements are well known.4Charge Point Operators (CPOs) are not large companies, nor do they havelarge capital reserves to facilitate cash transactions. They have all their capital invested inaccelerating the rollout of EV chargers and charging sites.A cash acceptance mandatewould compromise CPOs’ entire business model, diverge from global best practiceandcripple the deployment of more charging sites in Australia-a real and perceived barrier toEV uptake. If there is a desire toregulate payment requirements for EV charging, close considerationshould be given toAFIRin the EU, particularly article 5. Recommendations Given the adverseeffects that a cash mandate would have on Australia’s EV chargingindustry, theEVCrecommends that: •EVs becarved out of anycash acceptance mandate,should it be introduced.•Requirements on Australian Charge Point Operators remain consistent with globalbest practice and refrain from introducingbespoke,unaligned standards. If you have any questions on this submission, please contact Michael, atoffice@evc.org.au.