EVC提交给DEECA消费者能源资源（CER）消费者保护审查

Manager, Energy Consumer PolicyEnergy Consumer Policy BranchConsumer, Community and First Peoples’ Energy TransitionDepartment of Energy, Environment and Climate Action (Vic)PO Box 500East Melbourne VIC 8002 Via email:energyretail@deeca.vic.gov.au Regarding:Consumer energy resources (CER) consumer protections review | EngageVictoria Introduction The EVC welcomes the opportunity tocontribute to this important consultation.The EVC’smissionis to accelerate the electrification of road transport,supported by a strong,expansive ecosystem of EV charging infrastructure. We recognise there are certain criticalsectors in theCER industrythat may require expanded regulation. The EVC is asking for an exemption for behind the meterElectric Vehicle Supply Equipment(EVSE)as energy to vehicles is not an essential service and there is little evidence ofconsumer harm.Expanding regulation to encompass EV charging wouldstifle innovation,increase costs and slow the transition toEVs, withminimal improvement toconsumeroutcomes. Page15- Currently, energy for private transport (like petrol and diesel) isn't considered an essentialservice. Similarly, it's not necessary to treat EV energy with the same level of importanceas energy for homes.The AER agrees that Energy for EVs is not as essential service.1 Ifone cannot afford fuel from a petrol station, they are not entitled to it.As opposed toelectricity at ones home,if they could not afford it,they would begivena payment plan andwould not be cut off.Also, an EVismobile and can be taken tomany different electricitysources to be charged.Excessive consumer protection for EV charging could disruptinfrastructure deployment and hinder the adoption of EVs. Page22- Consideration should be given to how well the guiding principles and intended outcomesalign with the NationalEnergyObjectives.2 It is important toconsider the consumerandbalancethiswithAustralian government targets thathave long term benefits to all.It isdifficult to meet the mission without bringing consumers alongon the journey, butregulationin areas that are not causing harmcanhamper innovation, increase costsand slow thetransition. Page23-24- DEECAspreferred proposal incorporates an exemptions scheme.EV chargingwill requirean exemption due to its lower essentiality.This is in keeping withtheexemption for EVcharging that was granted bythe previous Department ofEnvironment, Land, Water andPlanning (DELWP)under the outcomes of the last Victoriangovernmentled consumerprotection review.3 Importantly,any conditions associated with the exemptions should beco-developed with industry. Page27- At the inception of this expansion of regulatory oversight and control, EVs and EV chargingshould be excluded on the basis that there is negligible evidence of any consumer harmoccurring with respect to EV owning consumers.If it comes to pass that consumer harmisoccurring, AND this new scheme is proven effectivewithother CER,thenconsideration ofexpanding the scheme to EV would be appropriate. The EVC has historically engaged withthe Energy and Water Ombudsman Victoria(EWOV)on the matter of EV owning consumers, and has found that (1) there is minimal evidenceof any actual problems of a CER / consumer protection type specifically relating to EV, andthat (2) where there were issues, the existing regulatory arrangements werein factadequate. If this new layer of regulation is going to be brought in, it should first be brought in againstestablished CER types where there is actual evidence of harm. Page29- The EVC is pleased to see that the intentof government is to focus first on solarinstallations, where the bulk of consumer complaints have come from, and exclude publicEV charging, which is low risk.We would like to see non-public EV charging similarlyexempted, in cases where the EV charging is wholly financially separable from the balanceof usage at the site-for example, EV charging in workplaces and apartment complexes,where EV charging is managed by the building owner or occupant. Page30- The table exemplifies theimportance of national consistency, in alignment with proven goodinternational approaches.If for example,Victoria goes it alone on EV charging technical requirements, the Australian market could befragmented, drivingup costs forVictorianconsumers. Page31- Vulnerability and Family Violence are likely well outside the capacity of CER providers (likesolar installersor electrical contractors) to address.It is not clear that it’s reasonable toinclude this here. Page 33- The fourth dot pointrelating to “detrimental impact” needs some context around it.Forexample-additional load in a home (such as electrification of gas appliances) has thepotential to tripthe supply breakerif the consumer uses several high load appliances atonce.Usually,thehomeownerwill be able to reset their supply breaker andadjust theirusage.Must the home supply be upgraded (at substantial cost) to avoid detriment in theform of outage?It should beacceptab