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Department of Transport and Planning1 Spring Street,MelbourneVictoria 3000ZEB-transition@transport.vic.gov.au EVCResponse toConsultation on Victoria’s ZEB Transition The Electric Vehicle Council(EVC)welcomes the opportunityto respondtothis consultation onVictoria’sZero-Emission Bus (ZEB)transition.The EVC is the national peak body for the electricvehicle (EV) industry in Australia. Our mission is to accelerate the electrification of transport for asustainable and prosperous future. We represent members across the EV value chain, includingcar, busand truck manufacturers,importers,operators, charging infrastructure suppliers andnetwork providers. Overview Transport makes up almost one-fifth of Australia’s emissionsand25% ofVictoria’semissions, withthe vast majority ofthisattributed tolight vehicles, followed by trucks.Unfortunately, transport isalso the greatest laggard when it comes to achieving our emissions reduction targets.Currentprojections suggest that without government action, Australia’s transport emissions will likely besignificantly higher than 2005-levels in 2030–undermining the economy-wide target of a 43%reduction. Thisplacesundue pressureonto Australian farmers, manufacturers, energy suppliers,and other local businessesto offset transport-related emissions. As the energy system rapidly decarbonises, it is likelythat the transport sector will becomeAustralia’s top emitting sector in the near future. While much of the technology is already availableto decarbonise transport, the challenge for this sector is time; specifically the amount of time it takesto turnover the vehicle fleet. As such,prioritisingdecarbonisation of this sector todaywill be crucialachievingnet zero emissions before 2050. Withinthis context,ZEBs are set to play a key role.Battery electric buses have alreadydemonstratedcost competitiveness compared to their diesel counterparts.Beyond economicbenefits, they offer substantial environmental and health advantages, curbing noise and air pollutionwhile providing affordable transit options that reduce private car dependency, which willalsobe keyto displacing transport related emissions. Despite this, Australia lags behind global counterparts in uptake of electric buses and deploymentof necessary infrastructure.Promptly electrifying bus fleets constitutes an initial, impactful step thatstate governments can take towards achieving net-zero objectives and decarbonising transport. Thisis particularly vital considering that othertransportsegments, like freight, will require extendedtimelines for decarbonisation.Accordingly, a proactiveapproach toelectrifyingbuses will becriticalinattaining Victoria’s net-zero target by 2045. Transitioning Victoria’s Bus Fleet The EVC is very supportive ofthe Victorian Government’scommitment to progress beyond trials toonlyprocureZEBs from 2025, as part of a broader strategy totransitionthe4,500-bus fleet. ThevariousZEB trials underway andMetropolitanBus Franchise contract will provide vital informationto inform the broader transition.We note that based onexpected timeframes for implementation,Victoria's ZEB transition iscurrentlypoised to outpace New South Wales, with the latter extendingits transition timeframe to 2040 and 2047 for metro and regional areas respectively. We understand that of 52 ZEBs being trialled,50 are battery electric and 2 hydrogen fuel cell.Studies from existing trials and bus deployments across the country have consistently shown thatbatteryelectric buses offer the most cost-competitive option when considering total cost ofownership, withlong-term benefits far outweighing costs of initial investment in vehicles andrequisite energy infrastructure at bus depots. Transitioning to electric buses will significantly reduceair pollution and contribute to a cleaner environment for Victorians, which will only improve withdecarbonisation of the Victorian energy system. Infrastructure Needs and Opportunities A key priorityfor the ZEB transition beyond procurement of vehicles, will involve effectively planninginfrastructure installationin a mannerthat appropriately considersthe range of different operatorsacross the industry. Whilesome operatelarge fleets across multiple depotswhere they are able todeploy charging infrastructureon their own properties, others, such as community and school busservices in regional Victoria, contend with limitedvehicles andrestrictedproperty resources.Formetropolitanbus services,insights from the operating trial at the Footscray Depot withEvenergi/BetterFleet will be able to inform future requirements. Energy requirements The EVC notes from the consultation papera very high level, and potentially misleading, powerrequirement description: Unpacking this in a little more detail is warranted, with the goal of identifying which sites should beprioritised, on the basis of being ‘lower hanging fruit’. The ‘1MW capacity per 20 buses’ figure implies50kW per bus. If we assume the buses are generallychargin