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Australian Energy Market OperatorLevel 12, 171 Collins Street, Melbourne VIC 3000Via email:Forecasting.Planning@aemo.com.au EVC Submission to2025 Inputs Assumptions andScenarios Report (IASR) consultation With reference to this consultation, we ask that in addition to considering the feedback theEVC has provided to past IASR and ISP processes, the AEMO team consider the EVC’ssubmission to the current AEMC rule change request prompted by Minister Bowen, withrespect to forecasting around EVs and EV charging behaviour: https://electricvehiclecouncil.com.au/submissions/evc-submission-to-enhancing-the-integrated-system-plan-to-support-the-energy-transition-improving-consideration-of-demand-side-factors-in-the-isp-erc0396/ With relation to the specific questions in the 2025 IASR consultation: Since the 2023 IASR publication, what changes (such as environment, social, policy)do you consider most impact scenario development for the 2025 IASR scenarios? NVESlegislation relating to light vehicle efficiency has been passed.Significant analysishas been done relating to this, projecting credible numbers of BEVs and PHEVs in thevehicle mix over the near term.Further detail here: https://electricvehiclecouncil.com.au/wp-content/uploads/2024/03/Electric-Vehicle-Councils-Response-to-New-Vehicle-Efficiency-Standard-Impact-Analysis-2024.pdf V2G is part of the public narrative now, with Minister Bowen openly engaging on this topicin the media, ARENA support for domestic uptake of V2G through Amber announced, andexplicit support for V2G in the immediate term in the National CER Roadmap.It’snotcredible to suggest that V2G will be insignificant until post-2030, per current AEMOforecasts, when it’s clear that we’ll haveV2G in market in 2025 and that we havegovernment highly supportive of it.A more plausible scenario analysis would include avariety of levels of V2G at 2030, with an upper bound of perhaps 10% of electric vehicleson road participating in V2G at that time. Consumer behaviour around home EV charging is going to be heavily influenced byavailability of retail tariff products that encourage and reward grid-friendly charging.Rapiduptake of retail offers designed specifically for EV drivers over the last 12 months (Ovo,Engie, AGL night saver, Origin EV plan, Powershop) demonstrates this.Scenario analysisshould consider a high degree of consumers avoiding peak time charging at home, withouthanding over control, being a plausible outcome–because it’s the probable outcome,based on the behaviour we’re already seeing today. Is AEMO’s proposal as described above a suitable evolution of each scenario’sparameters that will effectively support AEMO’s functions in planning the transition? What additional changes should be considered? With respect to table 3: “Consumer energy resource investments (batteries, PV and EVs)” We note that ‘step change’ is generally treated as ‘central case’.With this in mind, it wouldbe appropriate to align forecast consumer investment in EVs in the step change scenariowith existing state and federal government policy, which is generally designed to achieve50% of light vehicle sales being a combination of BEV and PHEV at 2030.The currenttreatment of the “step change” scenario overstates expected EV uptake to an implausibleextent. Per our submission to the ERC0396 process, we specifically recommend that AEMOengage with a consultant or consultants competent in the transport sector to developcredible forecasts with respect to EV uptake. “Coordination of CER (VPP and V2G)” It’s a consistent theme from AEMO that consumer loads must be orchestrated to securesystem benefits. With EVs, this is simply not the case.The bulk of the available benefit of associated withtime shifting loadcan be achieved through simple ToU incentivisation.It’s perfectlyplausible that a proportion of V2G might operate in a similar mode, exporting in theafternoons, and recharging during off-peak periods, without engaging in a VPP.We notethat >80% of home batteries operate this way today, charging during the day, dischargingin the afternoon peak, without participating in a VPP–because the majority of consumersdo not want to participate in a VPP, and do not need to in order to derive acceptable valuefrom the investment they’ve made. Many consumers will be reluctant to hand over control, because they do not trust that theirinterests will be prioritised.It is not difficult to see why, in a context where prices have goneup, and thousands of consumers have been pushed onto higher costbilling arrangementswithout advance notice.Per the AER’s advice to ministers late last year, the right place tostart with respect to orchestration is consent, before control.We note that the word“orchestration” appears in the ISP nine times, whilethe word “consent” does not appearonce.It might be useful for some additional social science perspectives to be brought intothe AEMO process. The reason for noting this is that an assumption around “low