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April2024 With reference to: Have your say on the regulation of embedded networks (www.wa.gov.au) Prepared by: MichaelShaughnessy,ElectricVehicleInfrastructure Officer Preamble The Electric Vehicle Council (EVC) is the national body representing the electric vehicle(EV)industry in Australia. As theEVmarket is emerging in Australia, our work is particularlyaimed at increasing certainty for investment through policy, knowledge sharing andeducation. Energy Policy WA isa part of the Department of Mines, Industry Regulations and Safety.EPWA provides policy advice to government to facilitate the delivery of secure, reliable,sustainable and affordable energy services to Western Australians. Our previous submissions on the subject of embedded networks (ENs) can be found here: EVC response to the Review of the AER exemptions framework for embedded networks-Electric Vehicle Council Feedback on Victorian Government’s Embedded Networks Review: Draft RecommendationsReport-Electric Vehicle Council The EVC is submitting a brief response to theCRIS, reduced to whereEVs are concerned. Introduction The EVC supports the WAgovernment’s continued attention to the fair application of ENs inWA.Equality is an important cornerstone of a harmonious society. Equality in this instancemay mean increased regulatory oversight of ENs to apartments, but the same oversight isnot needed of ENs to car parks, as an EV driver is free tocharge their vehicle wherever theywish. This is explained at length in previous submissions noted above. Smallcustomers It is pleasing to see the potential benefits of ENs acknowledged and the proposed policyattempting to work with and improve upon the existing structure. As stated in previoussubmissions, the EN structure can be especially useful in providing the least cost, leastcomplexity method of introducing EV charging and renewable energy solutions to apartmentcomplexes and the like. This is because the metering requirements are less stringent andtherefore take up less space, are cheaper and the cable runs often reduced. Continuing the ability to use ENs supports the installation of EV chargers for apartmentdwellers and therefore enables accelerated EV uptake. Non-residentialcustomers The EVC supports the option for non-residential customers in ENs consuming more than50MWh per year, to obtain a separate master meter at their own cost in order to gain accessto competitive retail offers and other protections. In the example of a chargepoint operator(CPO) wishing to install EV chargers in a shopping complex car park under an ENframework, not having access to competitive retail electricity offers can be detrimental to thebusiness case and may result in the infrastructure not being deployed. This applies thehandbrake to the rollout of EV infrastructure and EV uptake more broadly. Therefore, we are glad to see this barrier will no longer be in place for this customer class. This approachshould also be considered for other customer classes that may be impacted by poor accessto the contestable market. Extension of licence exemptionfor electric vehicle charging stations The EVC understands that current settings are working. CPOs are able to deploy charginginfrastructure and EV drivers are pleased to see this and take advantage of the utility itprovides. This also enables increased EV uptake. Our member CPOs understand that whatis good for the industry, including consumer confidence, ultimately serves them throughhigher EV uptake, efficient utilisation of infrastructure and the resulting increased revenue. We note the department will be seekinginput from some of our members andreal-worldexamples to feed into the assessment over the next 3years, and the EVC stands ready toassist during thisconsultationperiod. Should you wish to discuss anything related to this, please contact us at office@evc.org.au.