The Electric Vehicle Council (EVC) provides feedback to the Australian Energy Regulator (AER) on Ergon's regulatory proposal for 2025–30, highlighting both positive aspects and areas requiring regulatory intervention.
Demand management
Queensland's electricity connections manual (QECM) version 4 mandates control over a.c. single phase 32A EVSE for installations under 100A per phase, requiring DNSP consent during peak demand periods. The EVC opposes this mandatory control, arguing it inconveniences consumers and contradicts AER's consumer protection advice. Alternative solutions like TOU tariffs and consent-based control programs (e.g., Peaksmart) are proposed as more cost-effective and customer-friendly. The EVC recommends the AER mandate a consent process allowing consumers to opt-out of import limits if needed.
TOU tariffs and two-way tariffs
The EVC welcomes the proposal's inclusion of TOU tariffs but criticizes their current structure, where low off-peak prices are offset by high peak prices, leading to poor uptake. Two-way tariffs linking peak export rewards with midday export charges are also deemed problematic, discouraging V2G participation. The EVC suggests separating export rewards and charges and offering short-term flat tariffs with peak export rewards to incentivize prosumer behavior.
Ergon investment
Ergon forecasts a 20% increase in capital expenditure to address minimum operational demand power quality issues and peak demand capacity shortfalls, while also investing in control mechanisms and tariff adjustments. The EVC questions the necessity of further network augmentation, advocating for clearer breakdowns of investments in control and tariff development to justify the additional ~$900 million expenditure.
V2G
The EVC expects V2G regulatory barriers to be removed by mid-2024, with capable vehicles and EVSE arriving late 2024. Highlighting the success of rooftop solar, the EVC anticipates V2G adoption could mirror its growth, supporting the grid through diverse consumer participation. The EVC challenges Ergon's V2G forecast based on AEMO's draft assumptions and urges the AER to compel Ergon to incorporate updated forecasts into their proposal.
Capacity charges
Ergon's capacity charges starting at 100MWh per annum negatively impact regional public fast chargers. The EVC proposes a new tariff for consumption between 100 and 160MWh per annum, allowing opt-out of demand charges under 160MWh, benefiting large consumers, irrigators, and sporting stadiums. The EVC also suggests public charger providers with battery coupling should be able to participate in the wholesale spot market to avoid capacity charges.
The EVC recommends the AER prohibit Ergon from implementing import control without consent, mandate non-intrinsically linked export rewards and charges in two-way tariffs, ensure Ergon clarifies its network investment strategy, and develop tariffs allowing opt-out of capacity charges for eligible customers.
