EVC向CER数据交换行业共同设计咨询文件提交的文件

November 2024 With reference to:cer-data-exchange---consultation-paper---oct-2024.pdf Prepared by:Umair Afzal Preamble: The Electric Vehicle Council (EVC) is the national body representing the electric vehicle industry inAustralia. As the market is emerging in Australia, our work is particularly aimed at increasingcertainty for investment through policy, knowledge sharingand education. The EVC welcomes ongoing discussion on these matters, and can be reached viaoffice@evc.org.au EVC’sresponse, andposition: The EVC has previously commented on adjacent work to this project that wasledby theEnergySecurity Board (ESB), and then progressed byAustralian Energy MarketOperator (AEMO)untilrelatively recently, relating toElectricVehicleSupplyEquipment (EVSE)standing data: https://electricvehiclecouncil.com.au/wp-content/uploads/2023/02/Electric-Vehicle-Council-ESB-EVSE-Standing-Data-Register-Consultation-Paper.pdf We note that priorityuse case 3in the CER data exchange proposal is adjacent to this proposal. With respect to standing data relating to EV charging equipment, we suggest that the data besourced from electrical safety regulators in each state, using existing frameworks such asCertificatesof Electrical Safety (COES)in Victoria,Certificateof testing and compliance,Certificate of Complianceof Electrical Work (CCEW)in New South Wales, andequivalent in theother respective jurisdictions. We note that many EV drivers will choose to charge their EVs without installing dedicated EVcharging equipment,which means there will be no triggering event by which the energy sectorparticipants will become aware that a particular residence has acquired an EV. We note from page 43:“Allow organisations such as OEMs to access testing and certificationenvironments for CER devices such as Solar and Battery inverters and Electric Vehicles via a common,authenticated data platform” This could be read to imply that vehicle OEMs will berequiredto test/certify road registered vehiclesagainst AEMO/DNSP requirements.For the avoidance of doubt, this would not be appropriate, and ifimplemented wouldlikelyrestrict vehicle options available to Australianconsumers.Road registeredvehicles in Australia are regulated by way of the Australian Design Rules, which are aligned whereverpracticable with international requirements. The EVC’s positionif that if the intent is to stand up local capabilities to support interoperabilitytesting of EVs on a strictly opt-in basis, that would be fine.