EVC对2025-2030年SAPN监管提案草案的回应

SAPN Draft regulatory proposal 2025-2030 August 2023 With reference to: https://www.talkingpower.com.au/draft-proposal 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 South Australia PowerNetwork’s (SAPN’s) draft regulatory proposal for the 2025-2030 period. The EVC notes that SAPN has undertaken substantial stakeholder engagement in theleadup to this point, which has included consultation with the EVC. We also note that SAPNare members of the EVC and are actively engaged in the EV space. In this response, the EVC will principally address issues relating to electric vehicles and thearrangements supporting their recharging that are likely to be impacted by the approachdescribed in the draft regulatory proposal in South Australia. Executive summary of EVC position: Australia is currently lagging much of the rest of the world in EV uptake.Within Australia,South Australia is performing the least well of all the states in terms of percentage of newvehicle sales that are electric, at approximately 6%1year to date. In this context, it’s clear that obstacles to EV uptake in South Australia need to be removedwhere possible.Given SAPN’s function as the operator of the electrical distribution networkin South Australia, there are some supportive actions which cannot be readily implementedby anyone other than SAPN. The draft proposal from SAPN identifies in section 6.2.3 of Part B that the status quo,whereby all business connections >120kVA attract demand or capacity charges, will remainin place.We note that this position will entrench South Australia as having the leastsupportive tariff arrangements in the country for high power public EV charging.Thisapproach can be expected to limit the deployment and capacity of public EV charging inSouth Australia, particularly in regional areas, slowing down an already lagging state-leveltransition to EVs.A better approach in this respect would be for SAPN to align with the restof the country, as outlined in the detail below. The EVC notes the inclusion in the draft proposal of a $97.8 million program around CERintegration.Within this program, $15 million is allocated to ‘demand flexibility’.Thisproposal aims to create the capacity for centralised control of consumer loads, such as EVcharging in homes, with one of the goals being to “minimise costs to integrate ElectricVehicle (EV) charging”. Data from multiple ARENA trials indicates that centralised control of EV charging is unlikelytobe economically efficient.Generalconsumer behaviour around EV charging isdemonstrably already ‘grid friendly’, and can easily be made more so through incentivisation,without the need for centralised control solutions. Read in combination with the first item, it appears to the EVC that SAPN’s draft regulatoryproposal will have the effect of driving up the cost and limiting the capability of public EVcharging, while at the same time progressing efforts towards controlling EV charging inSouth Australian homes. On residential tariff reform, we note the design of the ‘Residential Electrify Export’ tariff,intended to be paired with the ‘Residential Electrify’ consumption tariff.The intent of thecombination is to encourage consumption and export patterns that support the energysystem, with the goal of rewarding the EV owning consumer for behaviour that helps drivedown costs for everyone. Conceptuallythis is excellent,and should serve to support V2G,subject to technicalrequirements from the Office of the Technical Regulator being brought into step with the restof the country.One of the crucial details which will need attention is the degree to whichconsumption at peak time is priced, which we address below. Finally, we address visibility of information related to network capacity, and how this mightbe improved to aid the transition to EVs. Specific commentary kVA-based demand charges for business customers at connections greater than 120kVA The rest of the country provides volumetric thresholds for business customers, so that low-energy use sites are able to opt out of kVA or kW based demand and capacity charges.This is either enabled via state government order-in-council (Victoria) or via the DNSPs tariffstructures as approved by ERAWA (Western Australia) or via the DNSP tariff structures asapproved by the AER (the rest of the country). In Western Australia, Victoria, NSW, Tasmania, and the ACT this volumetric threshold iseither set today, or soon to become by way of the 2024-2029 regulatory reset process,160MWh/annum.In QLD the threshold is currently set at 100MWh/annum.In NT thethresholdis soon to become,by way of the 2024-2029 regulatory reset process,100MWh/annum. In terms of quantitative impact, if we consider a 500kVA EV charging location (a typicalsupply for a site with 4 x ultrafast charging bays) delivering 100MWh/annum, the networkcomponen