The Electric Vehicle Council (EVC) of Australia provides feedback on the AEMC's consultation paper regarding the 'scheduled lite' rule change proposed by AEMO to integrate price-responsive resources like EV charging into the NEM. The EVC notes the extensive documentation and multiple consultations on the topic.
Executive Summary:
The EVC supports the creation of 'scheduled lite' as a voluntary mechanism for price-responsive resources, including EV charging, to participate in the NEM. However, based on existing data and trials, the EVC doubts that orchestrating domestic EV charging will yield meaningful outcomes beyond the cost of orchestration compared to simple incentivization. While consumer behavior tends to avoid peak charging times, there is limited additional benefit to extract through orchestration. The EVC remains open to the mechanism's potential value with other types of price-responsive resources and V2G implementations.
Key Points and Arguments:
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Limited Value of EV Charging Orchestration:
- Current unmanaged EV charging (approx. 2500 kWh/annum/vehicle, ~250 W/vehicle at peak) already contributes ~$250/annum to network costs and ~$25/annum to augmentation requirements, while consumers pay significantly more.
- ARENA trials (e.g., AGL) show the available benefit of orchestration is ~$33/annum/EV, with two-thirds achievable through incentivization.
- The 2023 IASR overestimates peak EV charging impact (EVC estimates a factor of 2 error), ignoring Australian studies and real-world data.
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Consumer Behavior and Incentivization:
- Baseline consumer behavior avoids peak charging; orchestration offers little additional benefit.
- Consumers readily respond to price signals without orchestration, and retail products incentivizing 'grid-friendly' charging are available.
- A wide-scale orchestration solution (scheduled lite + flexible trading) would likely deliver marginal benefits at high consumer costs.
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Justification for 'Scheduled Lite':
- AEMO's claims about reduced curtailment and system uncertainty are misleading, given solar deployment and the limited impact of EV orchestration (0.05 kW/vehicle).
- AEMO's forecast of rising peak demand due to unmanaged EV charging is not supported by data.
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Potential for Other Resources and Future Use:
- While EV participation in 'scheduled lite' is expected to be low, other loads (e.g., domestic hot water) may fit the mechanism.
- 'Scheduled lite' could aggregate solar export and develop VPPs, potentially aiding V2G in the future.
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Voluntary Nature and Uptake Concerns:
- The EVC supports a voluntary approach and does not oppose offering solutions to EV drivers on an opt-in basis.
- Limited driver uptake is expected due to negligible value, as better alternatives exist.
- If AEMO later mandates participation citing low uptake, the EVC will demand significantly better justification based on rigorous data analysis.
Conclusion:
The EVC is critical of the justification for 'scheduled lite' but remains open to its existence if it proves useful for other resources or V2G. The focus should be on providing attractive time-of-use tariffs to incentivize grid-friendly EV charging behavior without penalizing normal home use.
