EVC对AEMC的回应 定价审核

December2024 With reference to: https://www.aemc.gov.au/market-reviews-advice/pricing-review-electricity-pricing-consumer-driven-future Prepared by: MichaelShaughnessy,ElectricVehicleInfrastructure Officer With contribution from:Ross De Rango Preamble The Electric Vehicle Council (EVC) is the national body representing the electric vehicleindustry in Australia. As the market is emerging in Australia, our work is particularly aimed atincreasing certainty for investment through policy, knowledge sharingand education. The Australian Energy MarketCommission(AEMC)reports to the energy ministers. Theyhave two functions; to make and amend the national electricity, gas and energy retail rulesandconduct independent reviews for the energy ministers. TheEVC has responded to manyconsultations regarding retail and network electricity tariffs,which can be found here. Submissions-Electric Vehicle Council Introduction The topics in this pricing review are broadandthe effects may befar reaching.As ourelectricity market continues to evolve, driven by technological advancements and shiftingconsumer expectations, it is imperative to re-evaluate and refine our pricingmechanisms.The Australian Energy Market Commission (AEMC) is undertaking a crucial review aimed atshaping a future where electricity pricing aligns more closely with consumer needs, fostersinnovation, and supports sustainable practices. This submission aims to provide recommendations on both retail and distribution aspects ofelectricity pricing, focusing on customer protections, the integration of emergingtechnologies, and the establishment of fair tariff structures. By addressing thesekey areas,we can create a more resilient, efficient, and consumer-centric electricity market that is well-equipped to meet the challenges and opportunities of the future. Retail Customer Protections for Tariff Changes Retailers must ensure robust customer protections are in place to prevent the unauthorisedtransfer of customers to different tariff types.Clear and transparent communication isessential to safeguard consumers from unexpected changes that could impact theirelectricity bills.This includes prior notice and consent from the customer before any tariffmodifications areapplied, regardless of whether a DNSP changes the tariff. The EVCnotes approvingly of developments from the AER requiring explicit consent for a2-yearperiod after installation of a smart meter, beforea tariff can be mandatorily changed.We are also pleased to see that consumers retain thechoiceto go ontoaTOU tariffiftheywishto, as it will benefit most consumers with an EV. Improvement of TOU Tariffs in Qld and WA Time-of-Use (TOU) tariffs offer significant benefits, yet accessibility remains limited inWestern Australiaandregional Queenslandwith peak prices being too high. Efforts should be made to broaden the availability and adoption of TOU tariffs, ensuring that consumerscan benefit from cost savings,efficientuse ofnetworkassetsand renewable energy. Market Access for Public Charger Deployments Commercial sites with embedded networkspresent barriers to charge point operators(CPOs) wishing to deploy high powerchargers,as they may be faced with pass through ofdemand/capacity tariffs.While in some cases it is possibleto access the market for theenergy component of the bill, there is no way to split outthe network component at theparent meter.It’s important that this becomes possible becauseEV charging may be arelatively small load at a shopping complex for example, and the EV charging loads may notcontribute to the thresholds that triggerthedemand or capacity charges. Members report thatthere are no rules governing what prices the embedded networkoperator will pass on in response to the network charges they pay.Also,thatsomeembedded network operators will make it a condition of the lease that CPOs forego accessto theretail market. One possible solution is flexible metering.If a CPO could have arecognisedcheck meterupstream of their equipment, then contribution to the network component of the embeddednetworkbill could be subtracted, making sure the CPO only pays their fair share.A rulechange is likely required to allowthis. The power ofchoice reforms in 2017 aimed toallowcommercial and industrial customers inembeddednetworksto accessthe retail marketbutwasultimately insufficientin somecircumstances(Source:AEMC, see particularly section 9). Areviewconducted in 2019identified potential changes to regulatory frameworks which could fix the shortfalls, but thesechanges have not yet beenimplemented.It’s now 2024, and access to on-market offers forcommercial consumers at locations served by embedded networks remains inadequate to adegree that is impacting public EV charging deployment.These changesor any otherchangesthat will solvefor these issuesshould be implementedas soon as possible. Metrology and Billing Standards for EV Chargers The current approach to metrologyfor EVsupply equipment (EVSE)