EVC对AER的回应PLUS ES试验豁免咨询

November2024 With reference to: PLUS ES trial waiver application open for consultation | AER-Regulatory Sandbox Prepared by: MichaelShaughnessy,ElectricVehicleInfrastructure Officer With contribution from:Ross De Rango Preamble The Electric Vehicle Council (EVC) is the national body representing the electric vehicleindustry in Australia. As the market is emerging in Australia, our work is particularly aimed atincreasing certainty for investment through policy, knowledge sharingand education. The Australian Energy Regulator (AER) is the national regulator for electricity and gas supplyin Australia. The AER has responsibility for regulation of energy networks, protecting theinterests of consumers through theenforcement of the National Energy Retail Law. PLUS ES isa metering coordinator, part-owned by Ausgrid under ringfenced arrangements. Introduction The EVCsupports ‘regulatory sandboxing’tobolster innovation in a safe way and potentiallybringabout better and/or cheaper ways of doing things. The consultation note (the paper) describes PLUS ES’s primary objective is to trial aninnovative metering solution for pole mounted kerbside EV chargers that may improve thecost and efficiency of EV charger installation with minimal impacts on users. The EVC notes thatthistrial waiver couldbe in place for up to5years and involves theinstallation ofup to1000, 7-22kWpole mounted EV chargersin NSWand SA. The waiver The trial seeks toinstall EV chargers with in-built metering, whereas normally a type 4 meterwould need to be installed upstream of the device, within an enclosure. This may simplify,speed and reduce cost ofkerbside EVSEinstallations, but not the EVSE itself. EVC members noted the use of theacronym‘PUMS’ (permanently unmetered supply)inDiagram 2, p20of the paper,which implies that theremay beno retailerinvolved. The EVC sought clarification fromthe AERwho received confirmation from PLUS ES thattheinclusion of theacronymPUMS was in error, and there is in fact a retailer in theproposedprocess, in line with the rest of the paper. The EVC also soughtadvice from the AER as to whetherthe waiver could be extended toothercharge point operators(CPOs). The response was that waivers are specific to theapplicant,but the AER is happy to considerwaiver applications from otherCPOs and theirrelevantentity, such as the registeredmetering service provider. The requested waiver appears to specifically relate to the manner of deployment of the type4 meter associated with the connection. Transparency Another considerationfor the trial waiver is whether it would be reasonable to require thelicencing arrangement(commonly referred to as a facilities access agreement)between:Ausgridand PLUS ES,SAPN and PLUS ES,for the use of the poles to be made public. Our members tell usthey are interested in learning whatconstitutes fair and reasonablefacilities access agreements across jurisdictions.We expect transparencyon this matterwould support future deployments of EVchargingin settings like this, so we would ask thatthe detailsof the Facilities Access Agreement be made public as a condition of the waiverbeing provided. Conclusion The EVC is supportive of the trial, on the basis that the request is simply around metrologyarrangements and does not appear to create a meaningful risk of damage to the marketstructuresupporting public EV charging deployments. With the aboverequestofpublishingthe licencing arrangementconsidered, this can be avery useful trialwaiverinacceleratingthe transition. The EVC is happy to discuss any of the above andcontact can be made tooffice@evc.org.au