EVC对Energex 2025-2030计划草案的回应

October 2023 With reference to:https://www.talkingenergy.com.au/rdp2025draftplanshttps://www.talkingenergy.com.au/88810/widgets/416637/documents/268786 Prepared by: Ross De Rango Preamble: The Electric Vehicle Council (EVC), Australia's national representative body for the EVindustry, appreciates the opportunity to provide feedback on the Energex’s draft plan for the2025-2030 regulatory reset period. We note from the draft QECM published in July that Energy Queensland: •Is inclined towards setting requirements for consumers to yield control of their EV chargingat home to their energy network (Ergon or Energex),•Is opposed to measures that would assist in the acceleration of deployment of public EVcharging facilities, such as providing flexibility around second lines of supply to commercialpremises for public EV charging stations,•Is seeking to apply unique state-level requirements to vehicle to grid implementations. The EVC and other stakeholders continue to engage with Energy Queensland on these matters. Wenote that the tariff setting process is separate, but parallel, and in some ways linked with elementscovered in the QECM. Executive summary of EVC position: Energy Queensland has invested significant effort in understanding the impacts of EV charging intheir networks, and in seeking to understand EV driver behaviour. For example: https://qhes.com.au/queensland-household-energy-survey-2023/electric-vehicles-2023/ https://www.energex.com.au/manage-your-energy/smarter-energy/electric-vehicles-ev/ev-insights Regrettably, in its approach to setting technical requirements and tariffs, Energy Queensland tendsto treat EVs as a threat to be managed, rather than as an enabler of a more robust, lower cost-to-operate energy system. We address this in the ‘clarifications’ section below. On tariff reform specifically, we draw distinction between residential tariffs (applicable whenconsumers are charging their cars at home, which will be about 80% of EV energy required), andcommercial tariffs, applicable to the operators of high power public charging stations (CPOs) For residential, there will be a need to ensure that the planned reward for peak time grid export issufficiently available, such that the overall retail offer to the consumer stacks up. Pairing this rewardwith a monthly demand charge, for example, would be a poor choice.This will be key to theenablement of V2G in Queensland through the 2025-2030 regulatory period. For commercial, the EVC would like to see the volumetric threshold below which consumers can optout of demand/capacity charges lifted from the current 100MWh/annum to 160MWh/annum. Thiswould be in keeping with the settings in WA, Vic, Tas, ACT, and NSW. Finally, we touch on arrangements for the integration of batteries in public charging infrastructure. Clarifications Page 45 indicates the potential for up to 640,000 EVs on the road in South-East QLD by 2030. TheQueensland State Government has a target in place of 50% of new vehicle sales being EV by 2030,which will correspond to roughly 10% of the on-road fleet.Achieving this target will require theeffective implementation of a robust fuel efficiency standard at a federal level, which is beingworked towards, but which is not yet in place. It will also require that efforts being made to hamper the uptake of EVs in apartment complexes byQFES, and efforts to complicate the regulatory environment for maintenance of EVs in Queenslandby Queensland’s ESO, to be successfully resolved.Finally, we’ll need to see a shift in approach byEnergy Queensland in the QECM, to something which is supportive of consumers charging theirvehicles when and how they wish to.Assuming these matters are effectively sorted out, and thestate government’s target is actually achieved: •Queensland has a total of about 4.3 million registered road vehicles.o10% of this is 430,000 vehicles.•SEQ as defined by Energex contains about three quarters of the population of Queensland.oSo, likely about three quarters of the vehicles.•Three quarters of 430,000 is roughly 320,000 – about half of the Energex estimate provided. Pages 63 and 86 represent EV load as occurring at peak time.Multiple Australian data sets existwhich consistently indicate that while some EV charging happens at peak time (about 250W per EV),the majority of EV load turns up outside peak time, with consumers preferring to charge their carsfrom their own solar, or to charge over night in order to secure off-peak rates. Energy Queensland’s own research into EVs conclusively demonstrates this as well. The presentation of EV charging being a significant contributor at peak time can be used to helpjustify a build-out of the RAB (per page 79, from $15.6B to $17.9B, a 15% uplift over 5 years), and itcan be used to justify taking control of home EV charging away from consumers (as attempted in therecent QECM), but it is not grounded in fact. Contribution of EVs to peak system demand is likely to be <1%