EVC对澳大利亚新南威尔士州RFI-00211525的回应——漫游

Single interoperable and roaming Electric Vehicle (EV)charging payment solution - RFI-00211525 November 2023 With reference to: http://www.tenders.nsw.gov.au/?c=4B764952 Prepared by:Ross De Rango Preamble: The EVC is the national peak body for the EV industry. Our membership base includes organisationsfrom across the value and supply chain – vehicle OEMS, energy network operators, fleet managers,charging equipment manufacturers, vehicle rental businesses, public charging network operators,and more.We are well placed to comment and provide insight to this question, from a variety ofperspectives. It should be noted that industry does not have a unified position around this proposition, and thatthe global approaches to delivering roaming outcomes at scale are relatively nascent.Substantialwork is being done in overseas jurisdictions, particularly with respect to standards and regulatoryrequirements, but it’s not a ‘solved problem’. The objective from the EVC’s position is acceleration of EV uptake.The existence of seamlessroaming would be nice to have in this respect, but it’s not presently holding up EV uptake. The riskof poorly introduced roaming is that it can create challenges and increase costs for the organisationsselling the cars and deploying charging equipment, which may hold up EV uptake. EVC response to the RFI: Outline: The objective laid out in the RFI addresses driver frustration, framing it in a manner that could beread as applying to the general public. It also addresses fleet operation, framed specifically for theuse of NSW government fleet vehicles. We’ll consider these separately. The fleet operator has different considerations and motivations tothe private vehicle operator. NSW fleet operations will have some similarities to the vehicle rentalsector, and corporate vehicle fleets, for example. We exclude consideration of Tesla vehicles using Tesla Superchargers from this response. Tesla’ssolution works very well within its vertically integrated limits, but where non-Tesla vehicles areserved at Tesla superchargers, authentication is app-based, much like any other charge pointoperator (CPO). For private vehicle operators: The operator of a private electric vehicle, using public charging equipment today, will typically useeither the app provided by the CPO, or a credit card. The usage of physical RFID fobs as the solemeans for authentication at EV charging stations has largely been bypassed in Australia – it was triedin Canberra, and it was common in Europe for a time, but it was identified as delivering poorconsumer outcomes, and has given way to app/credit card approaches. This does not mean itshould not be permitted as an option for the CPO to include if they wish – merely that it should notbe the only option. NSW government grants for high power public charging have mandated for some time the inclusionof universal payment methods, such that a driver need not download an app for authentication andpayment at these locations. These methods include credit card readers and the Opal publictransport card. This effectively delivers a level of payment universality exceeding what would be possible with aroaming solution – to engage with a roaming solution, the consumer will need to have a relationshipwith that organisation. To use their credit card for payment, they require nothing beyond theirexisting banking arrangements – and credit card payment terminals are a 100% proven technology inmarket, we’ve been using them on parking meters for years. The perception that having multiple apps is actually a problem would be worth testing with a largecohort of drivers by way of a survey. Inevitably there will be a certain amount of noise along thelines of ‘wouldn’t it be nice if’, but the provision of roaming services of this nature co-ordinatingpayment and shared asset use between competitors via dedicated financial clearing housearrangements is the exception, rather than the rule, in most of the rest of the economy. We see it intelecommunications in the mobile phone network, and in ATMs, but we don’t require it of petrolstation operators, supermarkets, or retailing businesses in general. In the event that it can be shown that apps managed by each CPO for this purpose are demonstrablyinadequate, consideration could be given to requiring (potentially by way of regulations relating tothe licencing of sale of electricity for EV charging in each state) credit card payment facilities at all public EV charging locations above a certain power threshold, for example 50kW DC. As noted, thisis already a commonly deployed feature, because it’s a requirement for government co-funding attime of deployment. If taking this direction, consultation with industry about timeframes forcompliance and specific technical details of any new requirements would be necessary – basicquestions such as ‘do we need multiple credit card readers at a single location’ would need to beaddressed consultatively. The EVC wou