EVC对《2002年昆士兰电气安全法案2021》最终报告的回应

Review of Queensland’s Electrical Safety Act 2002 August 2023 With reference to:https://www.oir.qld.gov.au/public-consultation/electrical-safety-act-2002-reviewhttps://www.oir.qld.gov.au/system/files/2023-05/ea-act-2002-review-final-report.pdf Prepared by: Ross De Rango Preamble: The Electric Vehicle Council (EVC) appreciates the opportunity to provide feedback on therecommendationsof the December 2021 final report on the review of Queensland’sElectrical Safety Act. Some of our feedback, particularly with respect to recommendation 8, is captured within ourresponse to the ESO Discussion Paper, which was published alongside the final report. Our submission to that document can be accessed here: https://electricvehiclecouncil.com.au/submissions/evc-response-to-eso-discussion-paper-on-review-of-queensland-electrical-safety-act-2002/ As Australia's national representative body for the EV industry, our primary goal is topromoteinvestment certainty through policy development,knowledge sharing,andeducational initiatives. Executive summary of EVC position: The report runs to 215 pages and contains 83 recommendations. We are providing a briefresponse to this report. Individual EVC members may have a range of views on thisproposal. We note that while there are recommendations in this report that are highly relevant to theelectricvehicle sector,no vehicle manufacturers,vehicle repairers,or peak bodiesrepresenting the interests of this sector were part of the industry reference group.We notefurther that no reference appears to be made in the final report to the existing AustralianStandardsrelevant to electric vehicle maintenance(AS5732)or the various trainingprograms covering the safe maintenance of electric vehicles (AURETH101 and similar),which have existed and been delivered in Australia by RTOs for many years. The framing of the report is in the context of fatality rates associated with electricity, whichidentifies on page 15 that the fatality rate (Nationally and in Queensland) is on the order ofone fatality per 2 million people per year. There are several hundred thousand vehicles in use in Australia today with battery systemsat voltages high enough to be hazardous.This dates back to the introduction of mild-hybridvehicles in the late 1990s. There are no recorded instances of a fatality associated with theirmaintenance that we are aware of. By contrast, recent work related to the consequences of tailpipe emissions from vehiclesindicates over11,000 premature deaths per year associated with this cause1,On apopulation base of 26 million, this is a fatality rate approximately 850 times higher than thatassociated with electricity. The transition to electric vehicles will address these 11,000 annual premature deaths.Theintroductionof ill-conceived regulation in Queensland,developed without adequateengagement with industry stakeholders, will likely inhibit the transition to EVs, maintainingthis level of loss of life associated with air pollution.We do not dispute the importance ofelectricalsafety,but in the absence of clear evidence that the existing regulatoryarrangements applying to electric vehicles are inadequate to provide for electrical safety, theintroductionof regulations that will inhibit or obstruct the transition to EVs appearsindefensible. We address requirements around competency to undertake maintenance work on electricvehicles in our response to the ESO discussion paper, linked in the preamble.In short, theexisting regulatory arrangements appear to be adequate, because there is no evidence ofnegative outcome, and ample evidence of systems delivering safe outcomes in place. If anyenhancementto proof of competency is required,the need for it should be robustlydemonstrated with data (given any increase in regulation will add cost, ultimately borne byconsumers), and it should be limited to at most a restricted electrical licence. We ask the parties reading this submission to also read and closely consider our submissionto the ESO discussion paper on this report. We note that this final report covers many additional matters that the ESO discussion paperdid not touch on, which we address below specifically. Specific comments to the items raised in the report Section 6.3 – core definitions: B. Electric vehicles and “electrical equipment” The document claims that electric vehicles were ‘yet to reappear’ in Australia in 2002, andthat “The first electric cars became available in Australia around 2010”.In truth, Toyota wassupplying vehicles with 200+ volt traction batteries in the year 2000.By 2010, Hybridelectric vehicles with traction batteries at voltages high enough to be potentially hazardouswere commonplace.They are now ubiquitous.The absence of representation from thevehicle sector in the Industry Reference Group is the likely cause for this level of error in thereport. This section notes the potential risks associated with vehicle electrification, but ignores thebenefitsin terms of av