EVC对ERC0352的回应——计划精简版规则变更提案

September2023 With reference to: https://www.aemc.gov.au/rule-changes/integrating-price-responsive-resources-nem 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 onthe AEMC’s consultation paperin response to the ‘scheduled lite’a rule change request from AEMO. We note that the consultation paper runs to 63 pages, with a further 27 pages summarisinginternational mechanisms-and that AEMO’s rule change proposal runs to 200.We notefurther the multiplicity of open consultations in this domain.Our response will berelativelybrief. Executive summary of EVC position: ‘Scheduled Lite’ is proposed as a means by which price responsive resources (such asconsumer EV charging) can participate in the NEM. Based on 3 x ARENA smart charging trials, data collected by C4NET in Victoria form smartmetersat homes that have recently acquired EVs,studies undertaken by EnergyQueensland, and data the EVC has seen from Tesla, it is doubtful that orchestration of EVcharging in domestic homes will deliver meaningful outcomes worth more than the cost oforchestration, by comparison to simple incentivisation approaches. Despite AEMO’s assertions to the contraryby way of the IASR, the baseline consumerbehaviour tends towards avoidance of EV charging at peak time.There isn’t actually muchadditional benefit available to extractthroughorchestration. We address this here: https://thedriven.io/2023/07/11/what-does-well-behaved-ev-charging-look-like/ This said,providedscheduled literemainsa voluntary mechanism, we do not object toits creation, because there is the possibility thatit will create valuevia othertypes of priceresponsiveresources,and it may prove useful with respect to vehicle to gridimplementations. Specific commentary Responses toselectedquestions: Electric Vehicles will need to charge.EV charging does not need to be centrally orchestrated inorder to avoidsignificantnegative outcomes. Refer: https://electricvehiclecouncil.com.au/wp-content/uploads/2022/08/Home-EV-charging-2030.pdf On current behaviour (ie, unmanaged, and with incentivisationapproachesrelatively nascent), homeEV charging accounts for ~2500kWh/annum of energy use per vehicle, with contribution at peaktime of ~250W/vehicle.If we consider the typical contribution to DNSPs from the retail bill to be~10c/kWh, and the typical LRMC to be $100/kVA/annum,then we see that the contribution by theconsumer to network cost from car charging is about $250/annum, while the degree to which theycreate network augmentation requirements amounts to $25/annum.They’re already payinganorder of magnitude more than they’re actually costingthe energy systemon this front. It's a similar story with respect to the wholesale market and energy costs–EVs are already biasingtowards consuming energy at off-peak times, so there’s very little value in orchestrating to shift thebehaviour further.AGL’s final report form their ARENA smart charging trial identifies the availablebenefit as being at~$33/annum/EV…. Two thirds of which can likely be achieved throughincentivisation. https://arena.gov.au/knowledge-bank/agl-electric-vehicle-orchestration-trial-final-report-pdf-678kb/ The possibility exists that Vehicle to Grid implementations may benefit from the mechanismsdescribed, so the EVC is not opposed in principleto Scheduled Lite being brought into existence,provided the mechanism remains entirely voluntary. Electric Vehicle charging in the context of the home does not need to be separable from the mainmetered supply in order to be ‘well-behaved’ with respect to the energy system, or to deliverconsumer benefits associated with consumers electing to modify their behaviour with respect to EVcharging.The consumer can derive the bulk of available benefit on a simple ToU retail product. If it proves necessary to create separation behind the connection point in order to make thescheduled litemechanism work, that can be expected to add cost and complexity, which wouldmake it a less attractive way tomanage (for example) vehicle to grid. With respect to efficient integration ofhomeEV charginginto the energy system, ensuring theavailabilityofattractivetime-of-useretail tariffproductsto consumers, whicheffectivelyincentivise‘grid-friendly’EVcharging behaviourwithoutpenalisingnormal‘balance of home’use,shouldbe afocus. TheEVC is active in this area: https://electricvehiclecouncil.com.au/about-ev/charging/ Notes with respect to the AEMO paper: https://www.aemc.gov.au/sites/default/files/2023-01/ERC0352_Rule%20Change%20Request_Scheduled%20Lite%20-%20including%20Appendix.pdf Appendix A of AEMO’s work deals with the justification for the mechanism. To the extent that EVs are used as part of the justification, the work is deeply flawed. Someexamples are provided below. Appendix A, Page 9: “To reduce operational risk arising from the additional uncertainty in the