EVC对《国家建筑规范2025》公众意见草案的回应

July2024 With reference to: NationalConstruction Code 2025 Public Comment Draft-Australian Building Codes Board-Citizen Space (abcb.gov.au) Prepared by: MichaelShaughnessy,ElectricVehicleInfrastructure Officer With contribution from:Ross De Rango, Head of Energy and Infrastructure Introduction The ElectricVehicleCouncil (EVC) is the national body representing theelectric vehicleindustry in Australia. As the market is emergingin Australia, our work is particularly aimed atincreasing certainty for investment through policy, knowledge sharing and education. The EVC welcomes the opportunity to provide feedback to theAustralian Building CodesBoard (ABCB)on the NationalConstructionCode (NCC)2025 Public Comment Draft (PCD).A well thought out andclearly worded NCC ensuresbuilding owners and residentsenjoy thebenefitsthat good buildings provide, at least cost andminimal future investment. Broadly, the EVC strongly supports the changes to theprovisions forelectric vehicle (EV)charging in thePCDwithsomeminorrequests for adjustments as detailed below. The EVC would welcome the opportunity tobe involved in the development of theseprovisions and would be well placed to aid in the development of reference material tosupport those using the code to inform their planning and design work. Clarificationon ‘special hazard’ Therecommendationfromthe National Council forFire andEmergencyServices (AFAC)hasbeen thatbuilding surveyors/certifiers,fireauthorities,developers,building designers,engineers, legislative and regulatory consentauthoritiesandinsurersshouldconsiderclauseE1D17 and Clause E2D21 ofNCC2022on special hazardswith respect to EVs and EVcharging equipmentin the built environment.1 These clauses invokeadditional provisionsif“special problems of fighting firecould arise”oradditional smoke hazard management ifthere’s a“special function or use of the building”,amongst otherpossibilities.Although theopinion of AFAC does nothavethe weight of regulation, the effectofAFAC(to which thevariousjurisdictionalemergency service agencies aremembers)publishing variousguidelines2on the safety ofEVs,EV chargersandLithium-ionbatteries generally, is; •to influenceemergency service agencies who reference the guidelinesin their ownposition statements, eg. FRNSW3,QFES4,then,•therelevantposition statementsarereferenced by strata committees in formalcommunications withlot owners,(exampleletterinAppendix A)and•theEV chargerinstallationsareprevented. On occasion the lot owner’s right to parkanEV in the building car parkis challenged. In summary theAFACguidelines have aquasi-regulatoryimpact. The EVC was pleased to see clarification from the ChiefExecutiveOfficerof the ABCB, GaryRake on the intended interpretation of special hazard in the NCC,5whichis that thepresence of EVsandEV chargersis nowcommon,shouldnotbe consideredspecial andtherefore is not sufficientto invoke the‘special hazard’clauses. The EVC recommends thattheABCB provide clarificationto this effectin theNCCnormativetext, the online guidance materialsaround NCCthat reside on the ABCB website6and instandalone guidance relating to EV chargingeg.ABCB advisory note on EV charging | ABCB. Response(s) NCC Volume(s):☒One☐Two☐Three☐Housing Provisions☐Livable Housing DesignStandard Clause/Figure/Table:Clause J9D4 Recommended change to draft: It is recommendedJ9D4 have an additional sub-clause eg. (6) “(6)The presence ofelectric vehicles or electric vehicle chargersis not sufficient to invoke‘specialhazard’clauses.” Comment/reason for change: As above Carpark fire safety improvements The EVCrecognises the evidence-based approach toadjustments made to clauses E1D5,E1D9, S17C2, S5C19 and S5C22where consultation from a wide range of stakeholders hasresulted in the understanding thatmoderncarparks containvehiclesof an increased size,increased fuel loaddue to more plastic used in constructionand new energy sources andvehicleparking/storage methods.This warrants therevocation ofconcessionson sprinklersystemsforopen deckcarparks,implemented in the 1980s. Whendecisionsaremadeor consultations areheldthat arenot evidence-based,we seeoutcomes that arenot in the public’s bestinterests, such as that discussed in the topicabove. Individualsor companiesthatare denied permission to install EV chargers,due touncertainty aboutconsequences forbuilding occupancy certificates,expensive remediation,insurancepremiumsetc. brought about byimplicationsfrom fire authority publications,delaysEV uptake. Concomitantly,government emissions reduction targetsare jeopardisedas well as keepingpoor air quality,particulate pollutionlevels, noise/vibration levelsandexpenditure on foreign oil higherfor longer. Adjustmentsto J9D4 The EVC applauds the adjustments toclauseJ9D4 such as theaddition of busduct as acompliance pathway forsupplying EV chargers[J9D4 (1)(b)or(c)]and theinclusion of EVchargers in a proportion of car parks in buildingClasses3,5,6,7b,8 or 9[J9D4(3) and (4)]. Regarding buildingClass