National Electric Vehicle Strategy: consultation paper

Submission regarding the proposed National Electric Vehicle
Strategy. (Close for submissions 31 October 2022)
Introduction to Lighter footprints
Lighter Footprints1 is a community-based group that aims to influence Australian local, state and national decision makers to take the action necessary to halt global warming as a matter of urgency. For over a decade, we have educated, advocated and brought people together in Boroondara and surrounding suburbs to inform the community and promote a clean energy future. We have more than 3,300 people on our mailing list.

Lighter Footprints welcomes the opportunity to respond to Government’s Electric Vehicle Strategy.

Lighter Footprints’ view on the EV strategy and where it fits
Lighter Footprints is of the view that the electrification of transport is a critical part of Australia’s energy transition. There are key inter-dependencies with other sectors, but decarbonisation of all sectors needs to occur concurrently.

The following actions need to occur concurrently:
1. Decarbonise the electricity grid as fast as possible, with urgent focus on all measures required to accelerate the exit of coal while
minimising supply and security issues
2. Decarbonise the home through electrification of heating, water, cooking supported by stronger energy efficiency measures
3. Decarbonisation of transport (predominantly through direct electrification and BEV) with priority on road transport noting that
other solutions may be required for sea transport, aviation, and heavy vehicles.
4. Decarbonise commercial environments (space and water heating, cooking)
5. Decarbonise industry (especially industrial heat and carbon intensive processes)

1 https://lighterfootprints.org/
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Context
• This response focuses on electrification of licensed road vehicles and does not specifically address rail, maritime, aviation,
agriculture, or mining. These sectors require significant Government focus but are less advanced in availability of economic
solutions.
• The Australian vehicle market is small and right-hand drive so there is very limited opportunity for a domestic EV market to
influence to global markets and grow to viable vehicle exports. However, our ability to produce key components from green
materials with low cost, green electricity is good. Lighter Footprints encourage Government support of value adding industries
leveraging our abundance in both renewable energy resources and critical mineral ores that can be locally converted to high value
processed materials essential to support the energy transition.
• Electrification of transport will importantly reduce our petrol/diesel imports, assist in our trade balance, and further improve our
energy self-sufficiency and security.
• Most necessary technology already exists, strategies already well developed and mostly proven in other countries – we should not
waste valuable time on trials and research on technologies well proven elsewhere. Focus needs to be on accelerated transition
• The time for plug-in hybrid vehicles (PHEV) has passed in most transport sectors and only true ZEV should be included in any
Government support. Hydrogen Fuel Cell Vehicles (FCEV) are not mature and have very limited industry support so Government
should be very cautious in providing any support. Hybrid vehicles without plug-in charging should be fully excluded from any
zero/low emissions strategy.
• Biofuels will only play a small role in decarbonising transport and should not be used to perpetuate fuel burning vehicles

Lighter Footprints’ views on Governments’ paper
We are aligned with EV Council views that strict, monitored and enforced fuel efficiency standards aligned with leading
international peers form the base of Australia’s EV strategy.
We see the Government paper as a good start addressing most of the important questions required at this stage to get on with the
urgent electrification of transport. The key areas where further works are necessary are:
• More detail is required on demarcation between state and federal Governments, especially coordinated incentives to consumers and
industry.
• Much more transparently is required on support and subsidies to petroleum and traditional vehicle companies. Then low/zero
carbon vehicles need to be positioned on at least an equal but preferably better footing.
• Smart home charging will be critical – advanced EV markets suggest that 80% of private EV charging will be done at home. Smart
EV charging equipment with connectivity and awareness of solar, grid congestion and time of use tariffs must be mandated. The
Lighter Footprints Co-Convenor Michael Nolan [redacted]
Energy Transition Group Convenor: David Strang [redacted] | www.lighterfootprints.org
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Energy Security Board’s Electric Vehicle Smart Charging Issues Paper (July 2022) 2 has initiated industry engagement on
requirements for standards and compliance. We agree with industry responses proposing Australia’s adoption and adherence to
OCPP1.6J, ISO 15118 and IEEE 2030.5. The same approach that the PV industry used to standardise inverters could and should
be used – the personnel, process and tools could be readily leveraged. Opportunities for higher levels of Australian manufacturing
and content could be included.
• Connected EVs and smart chargers represent a cyber security risk allowing potential external parties to attack transport and
electric networks via these ingress points
• V2G and V2H have some potential in the residential sector in the future but currently provide minimal return to the user or the
grid on the significant investment, minimal manufacturer adoption and significant change to user behaviour. Fleet adoption of
V2H/V2G will make more technical and economic sense in some applications. Government should avoid perpetuating the hype on
this emerging technology but acknowledge it has some potential.

Lighter Footprints’ responses to specific questions raised in Government paper
1. Do you agree with the objectives and Yes, but additional consideration necessary on:
do you think they will achieve our • Demand needs to be accelerated across all sectors but prioritised on best environmental bang
proposed goals? Are there other for buck
objectives we should consider? • More overt mention of seeding the second-hand market
• Lead by example (e.g. government fleet transition prioritised)
• Should there be an objective to stop the importation of "gas guzzlers" by 2030? Vehicles
purchased then may still be in use after 2045.
• The immediate Australian market issue is supply (insufficient volume, model range) but once
this is addressed, demand-side needs attention
2. What are the implications if other • Balance of trade (if we are still importing petroleum products which has almost the same
countries accelerate EV uptake faster value as the unprocessed resources we export)
than Australia? • Australia will be left as dumping ground for outdated ICE/PHEV and will not access latest
models/technology that manufacturers direct to more advanced markets.

2 https://www.datocms-assets.com/32572/1658376992-esb-electric-vehicle-smart-charging-issues-paper-final-for-publication.pdf
Lighter Footprints Co-Convenor Michael Nolan [redacted]
Energy Transition Group Convenor: David Strang [redacted] | www.lighterfootprints.org
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• Less aggressive FES would allow manufacturers to offset their heavy PHEV development
investment by dumping these unwanted models in Australia as they are banned in European
markets.
• Australia would miss out on developing parts of the EV manufacture supply chain
• Australia would continue to export low value ores (e.g. Lithium) rather than evolving into
high value components (battery packs)
• Decarbonisation of other sectors may be impacted (agriculture, mining etc)
3. What are suitable indicators to • Tracking of fuel efficiency standards across all sectors, new and used. FES gCO 2/km must
measure if we are on track to achieve ramp down year by year
our goals and objectives? • Comparing fuel efficiency standards to those of other economies ensuring that we do not fall
behind
• EV vs ICE price points (for benchmarked capability sets and price points), sales, resale
values (as % of purchase price after 5, 10 years) across cars, LCVs, trucks/busses
• Transition progress of Government fleets (direct and indirect)
• EV km, tonnage travelled
• Electric Vehicle Supply Equipment (EVSE) infrastructure rollout (public, on-street,
apartments). EVSE/population per state. EVSE/highway km per state (metro, rural, remote
targets)
4. Are there other measures by • Drop luxury car tax on EVs below $100k.
governments and industry that could • Introduce a pollution tax on ICE (both new sales and registration based) to fund EV
increase affordability and incentives
accessibility of EVs to help drive • Remove state EV km taxes (but do not introduce a federal equivalent until EV penetration
demand? exceeds 50% of sales and administration inefficiencies and fraud risk are overcome)
• Assist financial institutions offer more favourable finance options to consumers and
businesses purchasing new and used EVs.
• Incentivise fleets (and lead by example on Government fleet) to accelerate transition to EVs
and turnover vehicles into the used market rapidly (3 years)
• Means-based subsidies and attractive finance options.
• Subsidies for renters and/or incentives for landlords to install domestic smart chargers
• Subsidies to ensure adequate street charging where required (areas with limited off-street
parking)
Lighter Footprints Co-Convenor Michael Nolan [redacted]
Energy Transition Group Convenor: David Strang [redacted] | www.lighterfootprints.org
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5. Over what timeframe should we be • We expect EV incentives would only be required until 2030 when new car price parity should
incentivising low emission vehicles as be achieved but increasing ICE pollution tax over time would further disincentivise ICE.
we transition to zero emission However, incentives may be required longer to encourage low socio-economic groups to
vehicles? transition from old ICE (direct EV subsidies may be less valuable than other targeted
welfare-oriented schemes)
• Any incentives for PHEV, hybrids should rapidly phase out (2025) – which may make them
attractive in the second -hand market
6. What information could help increase • Guides on how to easily access incentives and calculate lifecycle ROI for EV vs ICE
demand and is Government or • Independent benchmarking and comparison guides of EVs and ICE on lifecycle costs,
industry best placed to inform environmental impacts – enforce star rating on all vehicles showing emissions and costs per
Australians about EVs? km (as per consumer electrical appliance rating system)
• Provide charging infrastructure assistance (FAQ, tools/guides) to fleet operators / employers
7. Are vehicle fuel efficiency standards Fuel efficiency standards appear to be effective based on local studies and international
an effective mechanism to reduce implementations but needs to look as what has worked and not from overseas
passenger and light commercial fleet experience but this must not slow down the introduction of standards consistent with
emissions? US and EU (which guide most manufacturers)
• Ensure that the system incentivises more sales of low/zero emission vehicles and
disincentivises higher emissions vehicles (with disincentive growing year by year)
• Standards need to apply across all vehicle types (different standards for LCV/SUV vs light
trucks vs heavy trucks)
• Checks and balances must be included to ensure that loopholes are not exploited (ref US
market SUV sales flourishing as they were not applicable to low emissions car standards)
8. Would vehicle fuel efficiency • Based on European country experience, FES seems to work. If manufacturers/importers must
standards incentivise global meet a standard across all vehicles they import/sell, then they must offset any high emissions
manufacturers to send EVs and lower vehicle sales with many low/zero emissions vehicles
emission vehicles to Australia? • The standards could also place a cap on emissions for any single vehicle
• Some research may be required to determine which entity fuel emissions standards apply to:
manufacturers, importers, distributers. We would suggest that the entity that has control
over which countries have access to required volumes of ZEVs should have the fuel efficiency
obligation.

Lighter Footprints Co-Convenor Michael Nolan [redacted]
Energy Transition Group Convenor: David Strang [redacted]  www.lighterfootprints.org
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• Some consideration might be given to both a carrot and stick approach – rewarding
manufacturers who exceed the standard as well as penalising manufacturers who fail to meet
the standard
9. In addition to vehicle fuel efficiency • Yes (perhaps based on tonnage sold by manufacturers/importers rather than number of
standards for passenger and light vehicles sold) although it may be more complex to apply than to cars/LCVs.
commercial vehicles, would vehicle • Consideration also needs to be given to addressing fuel efficiency and emissions of existing
fuel efficiency standards be an fleet – improved enforcement of emissions – to retrofit or upgrade to lower emission
appropriate mechanism to increase alternatives
the supply of heavy vehicle classes to • Expect this is largely an issue of vehicle availability – transport companies and drivers
Australia? largely appreciate the economic and ergonomic advantages of EVs
• Truck dimension standards alignment with EU/US important (ref Grattan report s)
10. What design features should the • Alignment with US and European standards so manufacturers see Australian non-
Government consider in more detail compliance as equivalent risk/opportunity.
for vehicle fuel efficiency standards, • Emissions measurement and compliance should align with Europe/US to align testing and
including level of ambition, who they compliance tools/processes/reporting
should apply to, commencement • Financial penalties plus public/industry naming and shaming
date, penalties, and enforcement? • Providing tools and reporting techniques such that fleets can report their transport emissions
compliance and improvement
11. What policies and/or industry • Introduce operational standards (availability, reliability, utilisation) for any EV charging
could complement vehicle fuel
actions network that utilises Government subsidies/funding to provide better perceptions of EV
efficiency standards to help increase charging network capability– KPIs on availability, repair times
supply of EVs to Australia and • Incentivising faster rollout of public charging networks
electrify the Australian fleet? • Subsidising compliant smart home/business chargers (ref point above on standardisation)
• Consider any EV purchase incentive being provided to the importer/seller (not the
buyer/owner), coupled with fuel efficiency targets so that point of sale price parity achieved
sooner
12. Do we need different measures to • Bus fleets should be electrified ASAP (pollution concerns, easier business cases, existing
ensure all segments of the road manufacturers, local manufacturers, potential V2G opportunities)
transport sector are able to reduce

3 https://grattan.edu.au/report/grattan-truck-plan/
Lighter Footprints Co-Convenor Michael Nolan [redacted]
Energy Transition Group Convenor: David Strang [redacted]| www.lighterfootprints.org
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emissions and, if so, what government • Establish a plan / timetable for transitioning agriculture diesel rebates to an EV equivalent
and industry measures might well on purchase of EV and EVSE once heavy agricultural vehicles have a clear pathway forward
support the uptake of electric bikes, (including support to transition the sector if necessary)
micro-mobility and motorbikes? • More focus on taxis, rideshare, courier vehicles to transition high usage vehicles faster
• E-bike standards need to be enhanced and enforced
• E-scooter standards (safety, usage) need to be consistent across private ownership and hire
firms and need to be publicised and enforced
• Public charging associated with secure storage (cages/lockers) at train/bus stations would
encourage higher public transport utilisation.
13. How could we best increase the • More fleet incentives to electrify. Government lead by example on direct/indirect fleets
number of affordable second hand • Encourage independent certified EV mechanics. Transition TAFE (etc) training for
EVs? transitioning current motor mechanics (Geelong’s Gordon Institute appears to have a strong
offering)
• Independent EV mechanics may facilitate affordable battery swap/upgrade for older EVs
• Promote and incentivise more attractive EV novated lease options with shorter turnover
periods
• FBT exemption on fleet EVs
14. Should the Government consider • No incentives should be required– just remove disincentives.
ways to increase the supply of second • Encourage independent certified EV mechanics to roadworthy and service post-warranty
hand EVs independently imported to used EVs.
the Australian market? Could the • Engage with industry to streamline imports (although this would always be a small market
safety and consumer risks of this component)
approach be mitigated?
15. What actions can governments and • Encourage investment in development of value-added materials and components (processed
industry take to strengthen our advanced materials using abundant, inexpensive, renewable energy) rather than exporting
competitiveness and innovate across raw ores and fossil fuels for other countries to process/value-add
the full lifecycle of the EV value
chain?
16. How can we expand our existing • Encourage independent certified EV mechanics.
domestic heavy vehicle • Enforce workplace emissions standards (e.g. mines transitioning to EVs)

Lighter Footprints Co-Convenor Michael Nolan [redacted]
Energy Transition Group Convenor: David Strang [redacted] | www.lighterfootprints.org
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manufacturing and assembly • Align Australian heavy vehicle physical standards (height, width) with major markets so
capability? vehicles developed for local market have international relevance. Current Australian
standards differences provide a pseudo local trade protection for local manufacturers – if local
industry protection is necessary, then less oblique techniques should be used which do not
slow introduction of low carbon trucking.
• Further support for manufacturers who have already established capability (tax incentives,
low interest development loans, etc)
17. Is it viable to extend Australian • Australia does not have the domestic demand necessary to support a significant car/LCV
domestic manufacturing and production industry but should be able to support further growth in the existing
assembly capability to other vehicle commercial/industrial vehicle design and manufacture.
classes? • Whereas conversion of ICE to EV is usually not practical in car/LCV sector, conversion of
heavy vehicles is often economic and such industry should be supported.
• BZE “Deploy” report4 potential for 12,800 jobs in manufacturing 30% of Australia’s bus and
rigid truck fleet with a similar number in maintenance.
18. Are there other proposals that could • Work with CAMS etc to promote EV racing (e.g. bring Formulae-e to Australia) alongside
help drive demand for EVs and traditional events
provide a revenue source to help fund • Introduce inner city congestion tax based on emission levels
road infrastructure? • Introduce indirect incentives (reduced tolls, parking, congestion tax)
• Phased, increasing tax or levee on higher polluting ICE
• Tighten up the definition of Utes that can be claimed a business related (e.g. exclude twin
cabs)
• Cap the rate per kilometre that can be claimed as a tax deduction incentivising a move away
from ICE vehicles
• Restrict FBT exemptions to 2 door utes and no-side-window vans only (that is, only vehicles
actually used for commercial purposes, not private/personal use)
• The definition of "fuel efficient vehicle" in the Tax Act gives discounts on the Luxury Car Tax
to vehicles that are not fuel efficient by current global standards. The definition should be
reduced from 7 litres per 100 km to zero litres. This will make EV more competitive with ICE

4 https://bze.org.au/research_release/deploy/
Lighter Footprints Co-Convenor Michael Nolan [redacted]
Energy Transition Group Convenor: David Strang [redacted] | www.lighterfootprints.org
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vehicles in the luxury car bracket and will increase government revenue in the short to
medium term.
• EV trucks with their minimal noise and air pollution can be readily incentivised by excluding
them from night time curfews etc and eventually banning ICE trucks from inner city areas.
19. What more needs to be done • Work with states to sensibly introduce a national standard EV equivalent of fuel excise that
nationally to ensure we deliver a is easy and transparent to administer – Although it can be mooted now, its introduction
nationally comprehensive should be kept until significant EV penetration, otherwise would be an additional
framework for EVs? disincentive to transition to EV
• EV strategy must be integrated with related decarbonisation initiatives (perhaps only at high
level initially such that integration does not impede the implementation of sector
decarbonisation but ensuring that initiatives do not conflict or undermine each other) Support
• and accelerate Energy Security Boards work on standardisation of smart chargers and
associated tariff reforms
• Consideration of repairability legislation. EV manufacturers need to be encouraged (forced)
to enable 3rd party repair and upgrades. Just like changes to consumer electronics and
mobile phone repair, EV manufacturers should be required to provide parts and access to
allow 3rd party mechanics to repair and upgrade EVs, especially outside warranty. Software
locks that only allow manufacturer agents and genuine parts must be countered to allow
affordable, remote area repairs. Government (through TAFEs etc) should support the
transition and retraining of traditional mechanics to EV technicians.
• Introduce national fire rescue standards and procedures for dealing with EV road accidents
• Introduce standards for comprehensive charging infrastructure at major destinations –
airport carparks, city/suburban medium-long stay carparks
• Work with charging networks to improve charger reliability. Potentially introduce and
enforce reliability standards as charging networks become critical national infrastructure.
• Recognition that EV and ICE value chains are different – most ICE sales and distribution
channels rely heavily on after-sales service as a recuring revenue stream. With higher
reliability and fewer moving parts, EV maintenance revenue streams may make traditional
vendors unviable. Current shortage of supply has driven a sellers’ market where customers
are forced to buy on-line without test drive and engaging the dealer network. Many EV
importers have centralised sales with traditional distribution channels only having delivery
Lighter Footprints Co-Convenor Michael Nolan [redacted]
Energy Transition Group Convenor: David Strang [redacted] | www.lighterfootprints.org
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and maintenance involvement – consideration of how sales and service is handled in rural
and remote areas may require Government intervention.
• Work with states for building standards (house, apartments, commercial buildings) to
mandate EVSE readiness in new builds
20. How can we best make sure all • Ensure that charging facilities are available in the street for buildings without off-street
Australians get access to the parking (such as many inner suburbs and introduce schemes to support charging facilities for
opportunities and benefits from the apartment owners.
transition? • How to best address equity? Initial EV subsidies benefit wealthy home owners to the
detriment of low income, renters, and apartment dwellers. Lower socio-economic groups are
often dependent on low-cost vehicles to cover long distances (outer suburban, rural, remote)
for work, shopping, and services – these groups are potential the best candidates for EVs but
can least afford them. Government should consider means-tested subsidies or interest free
loans for lower socio-economic groups to purchase new and used EVs and charging
infrastructure.

Lighter Footprints thanks you for the opportunity to make this submission.

SUBMISSION BY:
Organisation name: Lighter Footprints Inc.

David Strang Russell Williams
Energy Transition Group Convenor Primary author
Lighter Footprints Energy Transition Group Lighter Footprints Energy Transition Group
Email: [redacted] Email: [redacted]

Lighter Footprints Co-Convenor Michael Nolan [redacted]
Energy Transition Group Convenor: David Strang [redacted] | www.lighterfootprints.org