EVC响应Ergon能源测定2025-30

May2024 With reference to: Ergon Energy-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 Ergonregulatoryproposal.1 We commendErgonfor cleaning up legacy tariffs in the interest of streamliningcurrent process and improving efficiency.It is also pleasing to seepreferences for time-of-use (TOU) tariffs recognisedand various structures and timelines presented.Unfortunately,someareasremainwhere the AER need to considerexercising theirregulatorypowers. TheEVC recommendsAERto: •ProhibitErgonfromimplementingimport controlwithout consentovera.c.32A/phaseEVSE.•Mandate thatErgonoffer tariff structures that do notinextricably linkexport rewards(peak periods, kW)withexport charges (minimum demand periods, kWh).•EnsureErgonform a firm position on whether they are investing in measures toavoid network augmentation orareinvesting in augmenting the network.•InformErgonthat there is nolegislative barrier to creating a tariff that allows opt-outof capacity charges for connectionsover 100kVA and under 160MWh/annum. These requests are discussed in more detail below. Demand management Energy Queensland (EQL) andtheir subsidiariesErgonand Energex write the Queenslandelectricity connections manual (QECM)for how electricity installations are to be carried outin the state.The latest version 4requires that for installations under 100A per phase, an a.c.single phase 32A EVSE may only be installed if an acceptable method of controlis givenover to the DNSP for use in peak demand periods.This change to the QECMwillaffect theuptake of EVs, TOU tariffs andsmart meters, and therefore feeds into theregulatory2025-30proposal(the proposal).Queensland is the only jurisdiction in Australia mandating such acontroland the AER has stated their opposition to measures whichcontrol or constrain theflow of electrons to a premises.2 Queensland has ahistory in demand management ofconsumer loads such ashot water, pool pumps and air conditioners. These loads arediscretionaryin this contextasa brief interruptionor constraintduring a peak demand eventwill usually not inconvenience the consumer, as the service can be providedlater that day.EVs are different, a consumer could have need at any time to charge their vehicle asrapidlyas possible.Control without consent in this context, as proposed in QECM V4, falls short ofindustry and consumer expectations, and runs counter to the consumer protection advicegiven to Energy Ministers by 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 besuitable 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 ofcontrolwithout consent,there are other morecost-effectivesolutions that do notreducecustomer amenity, such as TOU tariffsand control options preceded by a consumerconsent process, such as the Peaksmart program.There is more information on this in theEVC’sresponse to the QCA.Ergonstatein their overviewthat to achieve their objectivesthey must“..support increased demand, enable customer choice for distributed energyresources, such as rooftop solar systems, battery storage systems and electric vehicles, andcontinue to keep the lights onefficiently and cost-effectively.“for this reason, the AER shouldstep in torequire aconsent process, so that should the consumerneed their vehiclecharged, they can opt-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 down