EVC向简化CER和EVSE的网络连接流程提交的文件

Attention: DCCEEW, Distributed Energy Policy Team. Via email:DEDM@dcceew.gov.au EVC response to: Streamlining network connection processes for consumer energy resources (CER) andelectric vehicle supply equipment (EVSE) With reference to: https://consult.dcceew.gov.au/streamlining-network-connection-processes-for-cer-and-evse Prepared by: Ross De Rango, September 2024. 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 aimedat increasing certainty for investment through policy, knowledge sharing and education.The accelerated uptake of electric vehicles enables a more sustainable and prosperousfuture. The DCCEEW team at a federal level have carriage of the National Electric VehicleStrategy, which incorporates elements addressed by this consultation – see page 27 of thisdocument: https://www.dcceew.gov.au/sites/default/files/documents/national-electric-vehicle-strategy.pdf The EVC looks forward to constructive engagement with DCCEEW and other stakeholdersto move these important matters forward. Executive summary: The consultation paper is well done, and demonstrates very clearly that extensive andeffective consultation with relevant stakeholders has been undertaken. We note that this work falls within the purview of the National CER Roadmap, under section5.4,subsection P.2.Critically,while this work has produced clear and usefulrecommendations, the National CER Roadmap has no clear timeline on when theserecommendations will be actioned. The implementation phase of sub section P.2 has boththe ‘start’ and ‘completion’ dates as TBC. The vast majority of other actions in the National CER roadmap have clear timelinesassociated with them.Implementation of the recommendations considered in this reportneeds a clear timeline as well, or we are at risk of public EV charging deployments failingto keep up with uptake of the cars, and consequent poor consumer outcomes for drivers,leading to delayed uptake of EVs. This has been covered in the press in recent times: https://www.afr.com/companies/energy/ampol-dials-back-ev-charging-target-slashes-dividend-20240812-p5k1q4 We note that securing the actual outcomes necessary in this domain is not entirely withinthe remit of the federal government – much of the work will need to be done at state level.This is addressed in the ‘next steps’ section at end of this submission. EVC comments on the specific recommendations: Recommendation 4.2.1:Establish baseline data The EVC agrees that this should be implemented by way of regulation. Ideally, there wouldbe consistency across the jurisdictions in the manner in which the data is presented, butthere is the risk of ‘perfect being the enemy of good’ if we seek consistency across DNSPson this matter. It is more important that those jurisdictions who do not publish this information, startpublishing this information, than to ensure that the information is consistently presentedacross jurisdictions. A sensible next step here would be an AEMC rule change, requiring the publication of theinformation described in this recommendation.This could be similar in nature to the rulechange 10 years ago that required publication of zone substation data: https://www.aemc.gov.au/rule-changes/publication-of-zone-substation-data Recommendation 4.2.2. Require DNSPs to provide tools or processes that allowproponents to easily assess the available capacity at prospective sites We note that multiple DNSPs have tools of various kinds, providing data to various levelsof granularity. The AEMC rule change noted above ensures that zone substation data is available, but fora proponent of public EV charging this is typically not sufficiently granular. What is neededis capacity data at the level of the feeder, or the level of the pole or pad mount transformer,depending on the nature of the charging equipment being deployed. It is important to note that this data does not need to be perfect in order to be extremelyuseful, and it does not replace the formal connection process.What it allows is the rapidassessment of a large number of locations by a project proponent, without the need forengagement with the DNSP staff, so that the applications they put in to the DNSP are farmore likely to be efficiently deliverable, with reduced requirement for augmentation of theupstream network. This should also be progressed by way of a rule change, in a manner fundamentally similarto the rule change noted above, but clearly identifying that where actual data is not availableat the level of granularity called for, an estimate is required to be made based on data thatis available. We note specifically that a ‘traffic light’ system to indicate availability of space capacity isnot sufficient.The proponent of a public EV charging project will require an estimate ofcapacity measured in kW or kVA, in order to determine whether or