The Electric Vehicle Council (EVC) provides feedback on Energex's regulatory proposal to the Australian Energy Regulator (AER), focusing on demand management, time-of-use (TOU) tariffs, two-way tariffs, Energex's investment plans, vehicle-to-grid (V2G) technology, and capacity charges.
Demand management: The EVC opposes Queensland's requirement for consentless demand control of EVSE under 100A per phase, arguing it inconveniences consumers and contradicts AER's consumer protection advice. Alternative solutions like TOU tariffs and consent-based control programs (e.g., Peaksmart) are proposed as more cost-effective.
TOU and two-way tariffs: While supporting TOU tariffs, the EVC criticizes the proposal's two-way tariffs for inextricably linking peak export rewards with export charges, which will deter participation and V2G deployment. The EVC recommends separate reward and charge structures and short-term flat tariffs with peak export rewards.
Energex investment: The EVC questions Energex's justification for simultaneous investments in control mechanisms, tariff adjustments, and network augmentation, given the potential for TOU tariffs to defer network upgrades. The EVC calls for a breakdown of Energex's investment plans to justify the need for further network spending.
V2G: The EVC expects V2G barriers to be removed by mid-2024 and anticipates significant consumer adoption by late 2024, mirroring the rapid growth of rooftop solar. The EVC urges AER to compel Energex to incorporate updated V2G forecasts into its proposal.
Capacity charges: The EVC highlights the negative impact of capacity charges on public fast chargers in regional areas. It proposes a new tariff for customers consuming 100-160MWh annually, allowing opt-out of demand charges, benefiting irrigation and sports facilities. The EVC also advocates for public charger battery integration with wholesale spot market participation.
The EVC recommends the AER prohibit Energex from implementing import control without consent, mandate non-intrinsically linked two-way tariffs, ensure Energex clarifies its investment in network augmentation, and allow opt-out of capacity charges for connections over 100kVA and under 160MWh/annum.
