EVC对AEMC草案决定的回应 通过灵活的交易释放CER收益

February2024 With reference to: Unlocking CER benefits through flexible trading (retail) | AEMC Prepared by: MichaelShaughnessy,ElectricVehicleInfrastructure Officer. With contribution from:Ross De Rango, Head of Energy and Infrastructure. Preamble 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. The Australian Energy Market Commission (AEMC) is the rule maker for Australian electricityand gas markets. They make and amend the National Electricity Rules, National Gas Rulesand National Energy Retail Rules. They also providemarket development advice togovernments. This consultation relates to a proposed amendment to enable consumers to separate out‘CER’–Consumer Energy Resources–from the balance of the loads in the home, for thepurpose of these ‘CER’ being able to participate in potential new services.Electric Vehicles (EVs), their charging apparatus (EVSE), and the future potential of vehicleto grid (V2G), are relevant to this proposed rule change. The EVC welcomes ongoing discussion on this matter, and can be reached atoffice@evc.org.au Our previous submissions to unlocking CER benefits through flexible trading are here EVC response to ERC0346–unlocking CER benefits through flexible trading directionspaper-Electric Vehicle Council Ross De Rango-Electric Vehicle Council Introduction The EVC sees a future where small customers with EVSE can participate in network servicemarkets however, the largest benefit available, participation in the wholesale market, canalready be enjoyed through currently existing frameworks, such as VPPs and retail offerslike Amber.Although theresults of the Energeia cost-benefit analysis show a small overallbenefit, a large proportion of it is assigned to network visibility from a secondary NMI. Thebenefits of this should not be overstated through the lens of the AEMC target of 100% smartmeter roll out by 2030, which will provide all of the visibility networks require. It may be ofuse to some in future to have secondary NMIs and in-built meters in devices but these arenot required in the short term and will benefit few. Large customerssuch as charge point operators (CPOs)trying to deploy high powerchargers in shopping complexes will likely benefit from the proposed rule change. Large customers The EVC supports the provision of a more appropriate and enduring framework to enable asecond national meter identifier (NMI) for large customers, rather than leveraging theembedded network (EN) framework.The EVC has been vocal in its support for ENs to remain an option in the car parks of apartment buildings due to the ease of EVSE installation, as you can readhere. Whilstsmall customers with EVSEs under an EN structure can take their EVs elsewhere to chargeif they’re not happy with the service, CPOs wishing to deploy chargers in shoppingcomplexes under an EN structure have no choice of retailer and therefore limited exposure to competitive retail offers.Secondary NMIs with the ability to have more than one FRMP will aid CPOs to deploy in this situation. The draft determinationmentions that large customers can engage multiple energy serviceproviders byestablishing two connection points to the distribution network. The AEMC willbe aware of theresistance from DNSPs in Qld andVicwhen a second connection is beingsought withina certain distance of the first.This is causing problems for CPOs wishing todeploy fast chargingto suitable retail outlets like petrol stations andretail premiseswithoutincurring high costs andinconvenience to the site owner in utilizing the existing connection.More informationon second lines of supplyhere. Small customers CER such asEVSE, particularlyV2Gcapable EVSE,could be an important contributor tothe grid of the futureandsecondary NMIs may be an enablerof the most efficient use of thatCER, however the EVC supportsthat the installation of EVSE with in-built metering will bevoluntary.Thelion’sshare ofbenefit can be derived frommechanisms already inuse in themarket todayie.a smart meter and an effective retail tariff, this is unpacked morehere,page5.This is the cheapest andeasiest way for consumers toderive benefit from their EV andsupport the network. Addinga pattern approved metertoa device will have a non-trivial impacton the priceonceresearch, design,development,testing and certification are taken into account.EVSEmanufacturers (OEMs)no doubt attempt to designate R&D costs of one productto the priceof that productonly, without smearingthe costacross other products in theirrange. Whenmultiple products are designed and developed by the same teamswithin an OEM, this ishard to do and will likely result in price increases across the range.Ifthemeterwere toalignwith international standards already in use by large multinational equipment