AI智能总结
EVCSubmission to: Enhancing the integrated system plan to support the energy transitionImproving consideration of demand-side factors in the ISPERC0396 With reference to: https://www.aemc.gov.au/rule-changes/improving-consideration-demand-side-factors-isp Prepared by: Ross De Rango, Head ofEnergy andInfrastructure Premable: 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 forinvestment through policy, knowledge sharing and education. Theaccelerated uptake of electric vehicles enables a more sustainable and prosperous future. This submission focusses specifically on ERC0396, Improving consideration of demand-sidefactors in the ISP. The EVC is broadly supportive of theother rule change requestsmade that are bundled withthis one, but is not commenting specifically to them at this time. Executive summary: The EVC supports the intent of the rule change request from Minister Bowen: https://www.aemc.gov.au/sites/default/files/2024-06/erc0396_0.pdf In particulartheEVC strongly agrees with this statement: “That assumptions about electrification, and the uptake and orchestration of CER anddistributed resources should be improved” It is the view of the EVC thatAEMO definitely needs to improve the accuracy ofassumptionsrelating toEV forecasting, both with respect to EV numbers, and with respect to consumerbehaviourrelating to EV charging and discharging (V2G).The EVC has provideddetailedfeedback of this nature multiple times: https://electricvehiclecouncil.com.au/?s=aemo The proposedsolutionfrom the AEMCis well intentionedand in keeping with the intent ofMinister Bowen’s request, but, in the EVC’s view,not likely to deliver the desired result,primarily becausethe proposed solutionassumes that the DNSPs have the best data availableto aid AEMO in doing a better job of forecasting the impact of EVs, when in fact they do not. To improve EV forecasting, AEMO will need to seek out data sources from stakeholders otherthan DNSPs, and then use that data well.In the EVC’s view, the clearest short term pathwayto improvementwillbethe retention of independent consultants with transport sector(andspecifically EV sector)expertise.Longer term,to support the convergence of the transportsector and the electricity sector,AEMO shouldprobablyhirepersonnel into their forecastingteamfrom the transport sector. Additionally, consideration is given to the availability of more granular data relating to networkcapacity.The EVC is of the view that whether or not AEMO needs this datato improveforecasting, the EV industry definitely needs it to support the efficient deployment of publiccharging infrastructure, on which the transition to EVs (and hence achievement of the NEO)depend.So, the proposed solution should lead towards this data being publicly available,rather than just available to AEMO. Detailed responses to questions: 6(a): Yes. Seediscussion below relating to point 3.1.1 6(b): Yes. See discussion below relating to point 3.1.2. With respect to this question, the issue is that many DNSPs are notpublishingdata at asufficiently granular level to support the transition, because they are not required to. This has been coveredmany times in a variety of forums, most recently here: https://www.aer.gov.au/industry/registers/resources/reviews/network-visibility https://electricvehiclecouncil.com.au/submissions/evc-response-to-esb-aer-benefits-of-increased-visibility-of-networks-consultation-paper/ If DNSPs madesufficiently granular estimates of network capacity publicly available (per theexcellent example provided by Essential Energy), AEMO could use that data, as could all ofthe businesses seeking toaccelerateand lower the cost of deployment of publicEVcharginginfrastructure. AEMO forecasts EV uptake andbehaviour in significant detail, due to the forward outlook ofhow significant EV-related energy use will be over the forward period of the ISP. The forecasting of EV uptake by AEMO has been badly misaligned with government policy atstate and federal level forseveralyears. It remainsbadly misaligned withgovernment policy,and also withthe objective reality of the vehicle market,in the most recent forecastingassumptions update in 2024. For example, the current assumptions workbook expects that approximately 50% of new lightvehicle salesin the NEMwill be BEV in 2026, and 85% BEV in 2030.Government targetsand policies are aimed at 50%ofnewlightvehicle sales being a combination of BEV andPHEV in 2030. While over-forecasting BEVs, AEMO significantly under-forecasts PHEVs. AEMO’s forecastfor the period 2024-2030 assumes approximately 8000 PHEVs sold in total in the NEMoverthat period.Australians haveactuallypurchasedabout 8000 PHEVs in the first half of 2024,and PHEV sales are growing. Assumptions around EV charging behaviour are similarly out of step with real world cons