EVC对Energex 2025-30号决定的回应

May2024 With reference to: Energex-Determination 2025–30 | Australian Energy Regulator (AER) Prepared by: MichaelShaughnessy,ElectricVehicleInfrastructure Officer With contribution from:Ross De Rango, Head of energy and infrastructure Introduction 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.Theaccelerated uptake of electric vehicles enables a more sustainable and prosperous future. The EVC welcomes the opportunity toprovide feedback to the AER on the Energexregulatory proposal.1 We commendEnergexfor cleaning up legacy tariffs in the interest ofstreamlining current process and improving efficiency.It is also pleasing to seepreferencesfor time-of-use (TOU) tariffs recognisedand various structures and timelines presented.Unfortunately,someareasremainwhere the AER need to considerexercising theirregulatorypowers. TheEVC recommends theAERto: •ProhibitEnergexfromimplementingimport controlwithout consentovera.c.32A/phaseEVSE.•Mandate thatEnergexoffer tariff structures that do notinextricably linkpeak exportrewards (peak periods, kW)withexport charges (minimum demand periods, kWh).•EnsureEnergexform a firm position on whether they are investing in measures toavoid network augmentation or investing innetwork augmentation.•InformEnergexthat there is nolegislative barrier to creating a tariff that allows opt-out of capacity charges for connectionsover 100kVA and under 160MWh/annum. These requests are discussed in more detail below. Demand management Energy Queensland (EQL) andtheir subsidiaries Ergon Energy Networksand Energex writethe Queensland electricity connections manual (QECM)for how electricity installations are tobe carried out in the state.The latest version 4requires that for installations under 100A perphase, an a.c.single phase 32A EVSE may only be installed if an acceptable method ofcontrolis given over to the DNSP for use in peak demand periods.This change to theQECMwillaffect the uptake of EVs, TOU tariffs andsmart meters, and therefore feeds intotheregulatory2025-30proposal(the proposal). Queensland is the only jurisdiction in Australia mandating such a controland the AER hasstated their opposition to measures whichcontrol or constrain the flow of electrons to apremises.2 Queensland has ahistory in demand management of consumer loads such ashot water, pool pumps and air conditioners. These loads are discretionaryin this contextasa brief interruptionor constraintduring a peak demand event will usually not inconveniencethe consumer, as the service can be providedlater that day.EVs are different, a consumercould have need at any time to charge their vehicle as rapidly as possible.Controlwithoutconsentin this context, as proposed in QECM V4, falls short of industry and consumer expectations, and runs counter to the consumer protection advice given to Energy Ministersby the AER. There are costs associatedwith standingup such a control regime, further costs are incurredin theoperation,maintenance,compliance and policingof it,as well as keeping it secure. Regarding theexistingdemand controlstohot water etc. DNSPs have argued that thelimitation isjustified as it helps in efficiently managing the network to keep the lights onandprices down for everyone.They have also argued thatshould a consumer not wish to havetheir EVSE controlled, they can just plug their car into apower point(slow charging) orupgrade their connection to 3-phase so that they can install a 3-phase EVSE,where therequirementfor controldoes not exist.The EVC does not accept this methodology, slowcharging may not be suitable for certain would-be EV owners and others may notbe able toafford upgrading their connection and EVSE for that purpose and may forgo making thechange to an EV. Instead of control without consent, there are other more cost-effective solutions that do notreduce customer amenity, such as TOU tariffs and control options preceded by a consumerconsent process, such as the Peaksmart program.There is more information on this in theEVC’sresponse to the QCA.Energexstatetheirinvestment prioritiesin the overview“..uphold reliability, resilience, service and safety.“for this reason, the AER shouldstep in torequire aconsent process, so that should the consumerneed their vehicle charged, they canopt-out of any rewards for not charging the car and opt-out ofDNSPimport limits. TOU tariffs and two-waytariffs The EVC is pleased to see TOU tariffsbeing offered across a range of customer groupsinthe proposal.TOU tariffs have been shown in many studies toreduce EV contribution topeak demand toabout100W/EV.3 TOU tariffs are good for the gridand keep prices downfor everyone.However,uptake of TOU tariffs hashistorically been poor,probably due totheway they have been structured.The benefit to the consumer oflow