The Electric Vehicle Council (EVC) welcomes the opportunity to contribute to the consumer energy resources (CER) consumer protections review, emphasizing its mission to accelerate the electrification of road transport through robust EV charging infrastructure. The EVC acknowledges the need for expanded regulation in certain critical sectors of the CER industry but argues for an exemption for behind-the-meter Electric Vehicle Supply Equipment (EVSE).
Core Arguments:
- Essentiality of EV Energy: Similar to private transport (petrol/diesel), energy for EVs is not an essential service. Unlike home electricity, inability to afford EV charging does not warrant special treatment or protection.
- Impact on Innovation and Costs: Expanding regulation to EV charging would stifle innovation, increase costs, and slow the transition to EVs with minimal improvement in consumer outcomes.
- Alignment with National Energy Objectives: The guiding principles and intended outcomes should align with the National Energy Objectives, balancing consumer needs with long-term government targets.
- Exemptions Scheme: The EVC supports DEECAs preferred proposal of an exemptions scheme, similar to the previous DELWP exemption for EV charging, with conditions co-developed with industry.
- Evidence of Consumer Harm: There is negligible evidence of consumer harm specifically related to EV ownership, and regulation should first be introduced where actual harm exists.
Key Recommendations:
- Exclude EVs from expanded regulation, recognizing energy for EVs as a non-essential service.
- Focus regulatory efforts on established CER types with actual evidence of harm, such as solar installations, while excluding public and non-public EV charging.
- Ensure national consistency to avoid market fragmentation and increased costs for consumers.
- Avoid including vulnerability and family violence in the regulatory framework, as these are beyond the capacity of CER providers.
- Apply existing wiring rules for load management and ensure consumers have prior consent before their assets are controlled.
- Delay stewardship requirements until they are finalized and avoid imposing future decommissioning costs on installers.
- Recognize that the current protection for household energy supply already exceeds that for domestic petrol/diesel supply.
Data and Evidence:
- EWOV received 11,000 CER complaints from 2017 to 2024, with more than half related to solar.
- Very few complaints (likely less than 5%) have been specifically related to EVs.
- The EVC suggests publishing a breakdown of EWOV complaints by technology type and year for transparency.
Conclusion: The EVC recommends exempting EVs from expanded regulation and continuing to recognize energy for EVs as a non-essential service, while focusing regulatory efforts on areas with proven consumer harm.
