EVC向QCA提交的关于昆士兰州地区电价的意见书

QCAGPO Box 2257, Brisbane QLD 4001Tel 07 3222 0555 With reference to:Regulated electricity prices for regional Queensland 2025–26 Viathe website:www.qca.org.au/submissions/ Introduction The EVC is writing to the QCAin reference to electricity pricing in regional Queensland. We havemadeaprevioussubmissionto thisannualconsultationin 2024. The EVC finds that theTerms of Reference from the Minister are too rigidin specifyingtheN+R(network plus retail)cost buildup methodologyfor the modern market.We are callingfor the QCAto go back to the Minister and ask formore flexibilityinarriving at tariffs forregional Queensland, as theN+Rmethodis no longer fit for purpose.Instead or in additionto this, the EVCasks the QCAto recommend a change of legislation to arrive at a methodthat can meet the uniform tariff policy. QCA deservethe flexibility to do their job properlyfor the good of regionalQueensland. TOU tariffs Time-of-use tariffs are the single most effective and cheapest way to shiftEV and otherconsumer load out of peak times, saving consumers money andsupporting the network.Our updatedreport–Home EV charging and the grid: Impact to 2030 in Australia1, showsthe effectiveness of TOU tariffs, even in extreme temperatures.Page11exploresthebehaviour ofQldOvoenergycustomerson January 22nd,2024a day which saw record peak electricity demand.Those customers on EV TOUtariffs consumed on average 70%lesselectricity during thepeakthancustomers on other tariffs. Attractive TOU tariffscan benefit the network in regional Qld as well as consumers.Anetwork supported in this way can offer more reliable supply, less risk of sparking fires,lessinvestment in augmentation and a cheaper more efficient service for allQueenslanders. Too few TOU tariff types In our2024 response, we called formore TOU tariff options, to mirror those available toconsumers in SE Qld, such as the Ovoenergy plan which features$0.08/kWh midnight-6amand $0/kWh from 11am-2pm.Other EV plans from AGL,Amber, Engie,Origin,andPowershopare detailed in thereport.The TOU tariff option availableinregionalQldistoo expensiveand receives little buy in. If we consider the example of an Uber driver operating an EV inToowoomba, doingovernight charging at their home; they do 60,000kms a year, assumingan efficiency of20kWh/100kms,thisequates to feeding12,000kWh into the vehicle per year. Ataround30c/kwhon tariff 12B,it costs them$3600. Compare this to an Uber driverdoing the samekms aroundBrisbanewho’s with Ovoenergy payingon average 8c/kwh,powering theirvehiclecould cost as little as$960 for the year.This is devastatingto services inthe regions. Thevalue of EVs to an economy are well understood, providing both emissions and costsavings.2There remain too few TOU tariff optionsin Ergon EnergyNetwork areastorealisethe EV uptake rate that is possible and QCA say they are unable to help. QCA unable to help QCAacknowledged our calls in their responsestating “However, this approach would notbe consistent with the N+R framework, which involves us using the network tariffstructures as a basis for the retailtariffswe set. This includes using the same time-of-usecharging windows and customer eligibility conditions as those applied at the network-level.”3This requires a reassessment of the suitability of the N+R cost buildupframeworkfor the modern market.TheEnergex andErgonEnergyNetwork charging window are currently9am-4pm, 4pm-9pm and 9pm to9am4.These, coupled with the network prices5do not form an appropriate base to buildan EV TOU tariff. Networks understandably want to keep their tariff offerings simpleand none toonumerous.Retailers are finding more innovative ways toget market share by creatingclevertariff structures.RegionalQueenslanders should be able to benefit fromsome ofthat innovation,as EVs increase in number andother loadsbecome more easily shifted.We cannot rely uponDNSP tariff structures to appropriately underpin retail tariffstructureswhen regulatory resets occur once every 5 years.The N+R cost buildupmethodology needs an overhaul. Recommendations The EVCcalls on; •theQCA to go back to the Minister and ask for aless rigid method of arriving attariffsfor regional Qld.N+R is no longer fit for purpose, or•TheQCAtorecommendachange of legislation to arrive at a method that can meetthe uniform tariff policy.QCA deserve the flexibility to do their job properlyfor thegood of regional Qld. The EVC also notes thatIn 2024 the QCA received 5 responses to its interim consultation,due to the timing over the summer holidays.6There are many more bodies concerned withelectricity pricing in regional Queensland,that were taking a much-needed break.Theconsultation will be more meaningful ifconducted outside of the holiday period. If you have any questions on this submission, pleasecontact Michael, atoffice@evc.org.au. Thank you for yourconsideration of our submission. Yours sincerely, Michael Shaughnessy Electric Vehicle Infrastructure Officer Electric Vehicle Council