National Electric Vehicle Strategy: consultation paper

National
Electric
Vehicle
Strategy:
Electric
Vehicle
Council's
Submission

Emergency

Police
Contents
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Why do we need a fuel efficiency standard? 11

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The Electric Vehicle Council (EVC) is the national peak body representing the electric vehicle industry in Australia.

The Electric Vehicle Council represents companies involved in providing, powering and supporting electric vehicles. Our mission is to accelerate the electrification of transport for a sustainable and prosperous Australia.

As the world’s largest vehicle markets and companies set their course for a future where transport is powered by zero emissions vehicles, the Electric
Vehicle Council works to highlight the important role and opportunities for Australia in this global transition.

Working to overcome the current challenges in
Australia’s electric vehicle market through policy and advocacy, industry development, and market facilitation, the Electric Vehicle Council recognises electrification is a key milestone in the future mobility ecosystem, enabling advances in sharing, connectivity and autonomy.

By bringing the Australian market up to speed with the global transition in transport, we firmly believe
Australian consumers and industry can be leaders in the future of electric mobility.

Note: This submission does not claim to represent the views of, or be specifically endorsed by any individual industry member of the Electric Vehicle Council of
Australia. The broad range of views across our membership have been taken into account in the development of these responses to the Federal
Government's discussion paper on a National Electric
Vehicle Strategy, with the aim of providing recommendations that advance Australia's electric vehicle industry as whole.

3
The importance of a
National Electric Vehicle Strategy
The Electric Vehicle Council welcomes the Federal Government's consultation on the
development of a National Electric Vehicle Strategy (NEVS). This strategy presents an
important opportunity to introduce national policy initiatives that will significantly reduce
emissions from the transport sector, principally through an increase in electric vehicles.

The Electric Vehicle Council (EVC) recognises that all industries have a critical role to play in
achieving Australia's emissions reduction targets of 43% by 2030 and net zero by 2050.

The transport sector is currently responsible for 19% of Australia’s emissions.
Transport emissions have already increased by 22% between 2005 and 2019, and without
strong policy action are currently on track to still be higher than 2005-levels by 2030. This
risks taking Australia further away from our 43% and net zero emissions reduction targets.

The reality is that without strong action to reduce transport emissions, a disproportionate burden
will be placed on other sectors, including agriculture, manufacturing, construction, mining and
energy, to reduce emissions even further in order to achieve
Australia's emissions reduction targets.

By accelerating adoption today, and having a clear national strategy, EVs can be efficiently
integrated, and put downward pressure on costs for consumers, industry and governments.

The Electric Vehicle Council welcomes the Federal Government’s prioritisation
of developing a strong and serious National EV Strategy for Australia.

Priority action: introducing a robust fuel efficiency standard for light vehicles
For too long Australia has been a dumping ground for some of the world’s most inefficient
vehicles. The time has come for a strong signal to be sent to the market that Australia is making
the switch to a net zero transport system, and that Australians want clean vehicles that do not fill
our communities with carcinogenic pollution, that don’t cost tens of thousands of dollars to
service and fuel over their lifetime, and that can be powered using cheap, Australian-made
energy.

The United States, New Zealand, Canada, the European Union and most of the OECD have gotten
on with the job. Now, it’s Australia’s turn.

To catch up to comparable countries around the world, Australia must introduce an
ambitious and robust fuel efficiency standard to provide all Australian households and
businesses with greater choice in EV models, reduce fuel bills, and reduce emissions. A weak
fuel efficiency standard would be worse than doing nothing, and would not increase the supply
of EVs to our country.

The Electric Vehicle Council strongly supports the Federal Government in introducing
an ambitious and robust fuel efficiency standard by the 1st of January, 2024 - at the latest -
to accelerate the supply of EVs to Australia.

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
Recommended key initiatives for the Federal Government's National Electric Vehicle Strategy
There are six key initiatives the Electric Vehicle Council recommends are included in the Federal
Government's upcoming National Electric Vehicle Strategy:

1. 2. 3.
Setting clear targets Introduce an ambitious and Provide temporary
For example: robust fuel efficiency incentives to reduce
• 1 million light EVs by 2027 standard upfront costs of EVs of all
• >60% light EV sales by 2030 that increases the efficiency of all shapes and sizes
• 30% heavy EV sales by 2030 new cars sold in Australia, and that accelerate the adoption of
• Multi-bay fast charging
ensures our market is prioritised electric cars, buses and trucks,
locations every approx. 70 km
on arterial roads and 5 km in for the introduction of affordable and supports the development
urban areas by 2027 and efficient EV models. of a second-hand EV market to
• 1 EV (electric car, bus or truck) provide equitable access to EVs
manufactured using
for all Australians.
Australian batteries by 2030

4. 5. 6.
Support the roll-out of a Accelerate the adoption of Create a national EV
national charging electric trucks, buses, two- industry development plan
infrastructure network wheelers and other EVs that includes funding to
and its integration into the including the revision of stimulate investment across
electricity grid Australian Design Rules on the full EV value chain,
with advanced planning for vehicle width and weight, as well including: critical mineral
the energy system that will as incentive programs to mining, processing & refining,
enable the efficient accelerate the adoption of these component and vehicle
charging of electric cars, vehicles in both urban and manufacturing, reuse and
buses, trucks and other regional locations. recycling - capturing this once
vehicles, with a particular in a lifetime economic
focus on regional areas, and opportunity to create
in suburbs with high-density, thousands of new jobs.
multi-storey buildings.

Economic opportunities
While Australia still has a long way to go to catch up to leading EV countries, with every
federal, state and territory government now actively supporting the uptake of this innovative, zero
emission technology, we have the opportunity to not only make this switch, but economically benefit
from the transition.
The Electric Vehicle Council encourages governments to refocus their efforts on ensuring Australia
not only transforms its own vehicle fleet, but economically benefits from the key role we have to
play in supporting the decarbonisation of the world’s vehicle fleet using Australian minerals,
batteries, components, chargers and potentially even vehicles one day. This is a once in a lifetime
opportunity that can support the creation of thousands of jobs for Australians.

Next Steps
We welcome the introduction of a National EV Strategy as soon as possible, so industry can have certainty
in moving forward to electrify the nation's transport fleet, and preparing the energy sector for this
transition. We encourage the Federal Government to commit to undertaking regular, annual reviews
of this strategy to ensure suitable adjustments can be made to policy initiatives in response to
prevailing market conditions, and progress against Australia's emission reduction targets.

National Electric Vehicle Strategy: 5
Electric Vehicle Council's Submission
The Electric Vehicle Council's
vision of an electric future

2030
Taxi
>60 %

Taxi

At least 60% of all new light Electric micro-mobility devices
vehicles in Australia are electric, are prevalent across most urban
with an increasing number of areas, with dedicated
these used as shared vehicles, and infrastructure separating
available through affordable taxi, rideable devices from
car-sharing and ride-sharing An increasing number of
pedestrians and vehicles,
services to reduce the number of electric vehicles are built creating a safer environment for
private car trips in our cities and/or assembled in
everyone. This has enabled a
during congested periods. This Australia, leveraging third of all commuting trips to
affordability is achieved since our nation's rich mineral
involve some form of active
electric vehicles are now cheaper resources and cheap transport, including micro-
to purchase than an equivalent renewable energy to mobility.
petrol/diesel model and remain employ thousands of
much cheaper to operate and Australians across the
maintain. EV value chain.

Biofuel production has also
expanded locally, with the fuel
Short-range electric primarily blended with
planes and boats have aviation fuel for medium and
been deployed. In long-haul aircraft, as well as
At the same time, the particular, many urban targeted at inland road freight.
electrification and ferries have been
decarbonisation of heavy vehicles electrified. Some larger-
is well underway. All new heavy boats have also started
vehicles sold in urban areas are to transition to ammonia
100% electric, 30% of all new heavy produced from
vehicles are electric, and renewable, green
most major cities have hydrogen.
removed curfews for the
Finally, the electrification of
operation of these quieter
construction, farming and
vehicles, while introducing
mining vehicles, and associated
emissions limits for vehicles that
equipment is well underway,
are allowed to enter city
with many cities introducing zero
boundaries to minimise
emission construction
carcinogenic fumes being
requirements for urban areas.
produced in urban areas.

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
2040

A quarter of all new vehicles sold Electric aircraft are now
in Australia will be made locally. operating between some major
75% of the light vehicle fleet is cities on the east coast of
now electric, and 100% of new Australia, and on medium and
heavy vehicles are electric and/or long-haul flights synthetic jet fuel
run on renewable fuel. Autonomous vehicles made from renewable hydrogen,
have emerged in major blended with renewable biofuels
cities, primarily in the is increasingly being used.
form of shuttles to/from
public transport, and
accessible transport for
young children, the
elderly and persons with
disabilities. These vehicles
provide complimentary
All of Australia’s seaports have services to other public,
now been electrified, running shared and active
boats/ships off onshore power transport modes.
when docked. Australia’s
renewable ammonia industry has
rapidly expanded, with an
The majority of Australian EV
increasing number of
batteries are also being recycled
international ships now powered
locally and used to produce new
using this zero-carbon fuel,
batteries for locally-
including some exporting
manufactured EVs.
renewable hydrogen or ammonia
to international trading partners.

2050

Australia achieves a net zero transport system,
with a third of all new vehicles sold being made
and assembled locally, and all scrapped
vehicles being recycled and/or repurposed to
achieve a true, circular economy.

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
What are electric vehicles?

An electric vehicle (EV) is any vehicle that is fully or partially driven by an electric
motor and can be plugged in to charge. This includes: scooters, bikes, cars, buses,
trucks, tractors, excavators, cranes, trains, trams, boats and even planes. There are two
types of electric vehicles: battery electric vehicles (BEVs) and plug-in hybrid electric
vehicles (PHEVs).

Battery electric vehicles (BEVs) –
are powered exclusively by electric motors, using energy stored in a battery that can
be plugged in to be charged.

BEVs are a zero emission vehicle that present the greatest opportunity to reduce
emissions, provide fuel independence, and deliver lower ongoing costs.

Plug-in hybrid electric vehicles (PHEVs) –
are powered by electric motors and usually also a combustion engine, with the ability
to travel for shorter trips exclusively using energy stored in a battery that can
be plugged-in to be charged.

PHEVs can play an important role in the short-term as a transitionary technology for
those vehicle segments where fit-for-purpose BEVs are not yet available, or where
public charging infrastructure is not yet adequate.

PHEVs have the potential to reduce emissions if they are regularly charged
e.g. charged often enough to drive 75% or more on the battery alone (on average).

PHEVs that are not regularly charged do not significantly reduce emissions and
therefore should not be actively supported.

Governments and industry need to work collaboratively to ensure the right
incentives and programs are in place to encourage the regular charging of PHEVs.

PHEVs will not require the same level of support as BEVs because the upfront cost
difference between petrol/diesel vehicles and PHEVs is lower than the upfront cost
difference between petrol/diesel vehicles and BEVs.

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
Why are electric vehicles important?

1. 2.
Improve air quality Reduce transport costs
Petrol and diesel fumes and particulates from Running vehicles off electricity is
Australia’s existing vehicle fleet are having a significantly cheaper than using petrol or
significant and detrimental impact on our diesel. In some cases charging an electric
health. It is estimated that there are hundreds vehicle can be as cheap as paying the
more premature deaths from vehicle equivalent of less than $0.20 per litre.
pollution each year in Australia than
deaths from road accidents. Electric vehicles also have far lower
maintenance requirements, further
Electric vehicles provide a great opportunity for reducing the ongoing costs of using these
removing these noxious fumes from our cities vehicles. These reduced costs not only
and reducing public health costs by billions of benefit vehicle owners, but also can reduce
dollars over the coming decades – whether that the cost of taxis, ride-sharing, and car-
be in the form of electric scooters, bikes, cars, sharing programs.
buses, trucks, or even construction vehicles.

3. 4.
Support uptake of renewable energy Improve electricity grid utilisation and
stability
Given all electric vehicles are effectively
“batteries-on-wheels”, and are often parked A shift to electric vehicles will lead to an
during the day and overnight, they provide increase in electricity consumption. If
the opportunity to soak up renewable energy managed successfully, this will not only
from solar, wind and hydro, and in the process improve grid utilisation and stability, but has
create demand for the additional deployment the potential to put downward pressure on
of renewable energy generation. increasing electricity prices for all consumers,
including local businesses and industry.

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
5. 6.
Reduce dependency on imported oil Create new green jobs and industries
Tens of billions of dollars are spent each year on The electrification of transport presents
buying imported fossil fuels to power Australia’s enormous job growth potential for Australia. This
transport sector. By electrifying our vehicles, includes through the scaling of local critical
some of this money can be redirected into the mineral extraction, and the on-shoring of
local energy system, supporting Australian jobs refining; the potential to launch a domestic
while increasing the nation’s energy battery manufacturing industry, and as an end
independence. goal, increasing advanced domestic
manufacturing in the form of locally-made
and assembled electric cars, buses, trucks, boats
and more.

7. 8.
Reduce greenhouse gas emissions Increase climate resilience
Studies around the world have demonstrated The electrification of transport opens new
that even in nations with a grid emissions opportunities for making renewable energy
intensity similar to Australia, electric vehicles storable, and portable. Through new capabilities,
will deliver around a 35% reduction in lifecycle such as vehicle-to-load, vehicle-to-home and
emissions compared to a petrol/diesel vehicle. vehicle-to-grid, electric vehicles of all shapes and
The electrification of transport has a key role to sizes have the potential to provide power during
play in achieving the nation’s target of net zero natural disasters – whether that be in the form of
emissions by 2050. tropical cyclones, local floods or even bushfires.

9. 10.
Provide alternative modes of transport Reduce noise
Rapidly falling battery prices has enabled the Next time you stand next to a road, take a
electrification of a whole range of new transport minute to listen to the environment around you.
modes that previously did not exist. Electric It is incredibly noisy, and in large part this is due
rideables are providing an alternative to sitting to the hundreds of vehicles swirling around you.
in road congestion that help to overcome some Electric vehicles provide the opportunity
of the challenges of using active transport in to significantly reduce this noise.
Australia’s hot climate.
Of course, some noise must remain to protect
pedestrians and other vulnerable persons, but
electric vehicles provide us with the opportunity
to make the choice about what that sound
should be and deliver it in a way that creates a
much more pleasant environment, with the
potential to further increase the adoption of
active transport modes as a consequence.

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
Why do we need a fuel efficiency standard?
The number one barrier to transport electrification in Australia today is the low supply of electric vehicles.
Only a fraction of EV models available globally are being supplied to Australia since we do not
have a mandatory fuel efficiency standard. In order to achieve our emission reduction targets, EV uptake
needs to accelerate significantly. This can only be achieved with the introduction of an ambitious and
robust fuel efficiency standard that will ensure Australia becomes a priority market for supplying
affordable EVs.

Fuel Efficiency Standards Vehicle emissions standards
(environment) (health) need them?
Why do we

Supply of electric 43% Net-zero Cleaner air Reduced health
vehicles by 2030 by 2050 impacts

C
What?

noxious particulate
g/km fumes matter

A fuel efficiency standard consists of annual Vehicle emissions standards measure the
tailpipe emissions targets for new vehicles. These noxious fumes and particulate matter emitted
targets are measured in grams of CO 2 per km. from an exhaust pipe.

A fuel efficiency standard does not limit or The aim of Euro 6 emissions standards is to
ban any particular vehicle or types of vehicles . reduce the levels of harmful exhaust
emissions, chiefly:
Car-makers need to meet the annual target,
based on the average of the new vehicles they sell.

If a car-maker misses the target, they pay a
penalty to the government that can then be used
NOx HC
to fund incentives, infrastructure, etc.
Nitrogen CO Hydrocarbons PM
An ambitious fuel efficiency standard oxides
encourages car-makers to supply more fuel- Carbon Particulate
efficient and electric vehicles to the market, in monoxide matter
order to avoid paying any penalties.

Australia currently does not have a
Australian context

mandatory fuel efficiency standard. Euro 6

The average emissions 180.5 g/km
intensity of new cars in Euro 5
2019 was 180.5 g/km.
Australia’s minimum emission standard for
new light vehicles is ADR 79/04, which is
A voluntary target scheme has been introduced based on the Euro 5 standards and is codified
by the FCAI for its car-maker members in under the Australian Design Rules.
Australia. Unfortunately, under this
voluntary scheme, Australia is on a pathway The current plan is for Australia to move to
that is 5 to 10 years behind comparable Euro 6 standards as soon as fuel quality
markets. standards are met - possibly as early as 2024.

Australia, Indonesia, Turkey, and Russia are the
only G20 countries that do not have fuel
Global context

efficiency targets.

Fuel efficiency targets have been introduced Euro 6 Euro 7
around the world, including (using NEDC
test cycle; passenger car targets): Europe introduced Europe will
the Euro 6 introduce Euro 7
standard in 2014. standards in 2025.
EU US New
81g/km 91g/km Zealand
by 2025 by 2025 102g/km
by 2025

1 Priority for electric vehicle supply
2
National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
The Electric Vehicle Value Chain:
A once in a lifetime economic opportunity

1. 2.
Raw material extraction and processing Component and vehicle manufacturing
Our abundance of critical minerals, and our The market for battery cells is expected to
proximity to fast-growing markets in the Asia- grow by over 20% a year to 2030 to be worth
Pacific region, combined with our stable over $500 billion. By investing in
regulatory environment will allow Australia to downstream processes, including
be a reliable supplier across the global manufacturing of battery cells and other
EV supply chain. components, Australia can attain significant
economic gains from diversified battery
Global demand for lithium and other minerals products.
is set to drastically increase as
manufacturers introduce new models to Opportunities exist in the
gain EV market share. The International development of onshore manufacturing
Energy Agency projects lithium across vehicle segments, with several local
demand to be between 13 and 50 times companies already involved in the
higher than today’s levels, with similar manufacturing of electric trucks and buses.
trajectories for cobalt, nickel and graphite - all
of which Australia has an abundance of. By establishing downstream demand in the
Australian market and the provision of
Innovating across more of the EV value chain government support to bring down total
will increase demand to refine and process production costs, Australia can also
raw materials onshore, creating new jobs and leverage an existing skilled workforce to
delivering significant economic develop an electric passenger vehicle
dividends for Australia, given the industry.
value of processed commodities is
substantially higher than raw minerals.

3. 4.
Vehicle operation Second-life and recycling
The global charging station industry is EVs provide considerable value even after a
expected to scale to reach over $300 billion by lifetime on the road. Because EV batteries
2031. Tritium, a Brisbane-founded and can retain more than two-thirds of their
NASDAQ listed company, has expanded usable energy storage after 12+ years of use,
manufacturing to the US to take advantage of as the market share of EVs increases, there
increased demand for EV chargers overseas. are opportunities to extend their utility in a
range of secondary applications, such as
The transition to EVs will result in home stationary storage.
substantial consumer cost savings, reducing
exposure to global fuel prices and Australia can also take the opportunity to
enhancing national security through further develop a domestic battery recycling
increased energy independence, with the industry for valuable critical minerals, as
transport system run on Australian energy. manufacturers seek to reduce lifecycle
emissions and environmental impacts
involved in product manufacturing.

In the future, retrofitting existing EVs with
new batteries may also serve to extend
vehicle life by another 10 to 15 years.

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
Thailand:
Aiming to be an EV super power
Thailand is the largest automotive manufacturer in Southeast Asia, and the 10th largest in the world,
with an annual output of more than two million vehicles. It is no surprise then that many of the new
cars in Australia, in particular utes, are made in Thailand.
Questions have been raised about Australia's ability to electrify some segments of our vehicle
market over the coming decade due to our heavy reliance on Thailand for vehicles. Yet significant
efforts are being undertaken by the Thai Government to transition its automotive
manufacturing sector to EVs.
In March, 2022, the Thai Government announced a suite of measures to encourage both the local
adoption of EVs, as well secure international investment in EV and battery manufacturing.
These investment incentives include 3 to 11 year tax holidays for the production of EVs.
Early signs suggest these measures are delivering results. During the first quarter of 2022,
investment pledges in Thailand's automotive and parts sector more than quadrupled from a year
earlier to the equivalent of $US 1.2 billion.
Mercedes-Benz has chosen Thailand as one of only seven locations globally to manufacture their
fully-electric EQS. The first Thai-built EQS is expected to roll off the production line by the end of 2022.
In September, 2022, the leading EV manufacturer BYD purchased land in Thailand to build a new
plant that will produce more than 150,000 EVs annually from 2024. BYD are not alone, with more
than 20 electric car projects recently approved by the Thai Government, thanks to its generous
incentives. These projects will support Thailand's goals of producing at least 750,000 EVs and
hybrid vehicles annually by 2030, and selling only electric cars from 2035 onwards.
Popular brands on the Australian market are also signaling the significant transition taking place in
Thailand. Ford Motor Company's Chief Financial Officer, John Lawler, recently outlined his view that
Thailand will become a hub for the manufacturing of zero emission vehicles, including the possibility
of an electrified Ford Ranger ute:

“Thailand is going to be a hub for manufacturing zero emission vehicles. As these changes
come around the world, we’re going to be part of that."

“(The) Ranger is a huge opportunity for us and it’s a cornerstone for us … there are great
possibilities, and so whether it’s Ranger or it’s other possibilities to bring in and expand,
perhaps globally, we will do that."

With around 1 million new vehicles sold in Australia each year, and almost a quarter of these coming
from Thailand, Australia cannot afford to ignore the transition occurring on our doorstep.
Encouragingly, this proactive approach taken by the Thai Government puts Australia in a strong
position to adopt ambitious fuel efficiency standards, and be a major buyer of EVs made in Thailand.
We would encourage the Federal Government to engage with Thailand and explore opportunities
to support and collaborate on achieving this transition.
Australia should also take note of the significant efforts undertaken by the Thai Government to
secure investment in their EV value chain. We must consider how we could follow a similar path so
that one day we too can make electric vehicles locally, while also supplying critical minerals, and
batteries for Thai-built EVs, and other EVs built around the world.

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
National Electric Vehicle Strategy:
The Gold Standard

Set goals and objectives that can be measured against different targets

Increase supply Fuel Efficiency Standard active by 2024 100 EV models by 2025 <60 g/km CO2 by 2030

Increase demand 1 million EVs by 2027 >60% EV sales by 2030 30% heavy EV sales by 2030

Increase demand
Establish systems Multi-bay fast charging station every 70 km on arterial roads and 5 km in urban areas by 2027

Capture opportunity 25% of all new vehicles domestically manufactured/assembled by 2040

Policies to support upstream of the EV market
• Provide incentives, tax breaks, fast-track approvals, operational certainty and guaranteed
orders to secure investment across EV value chain
• Expand renewable electricity generation, including appropriate investment in transmission and
distribution
• Consumer-focussed reform of the energy sector to support EV uptake while supporting whole-
of-system benefits from the transition

Policies to support the EV Market

Supply Demand Infrastructure Awareness

• Ambitious and • Temporary tax • National public EV • Publication of
robust fuel exemptions charging network, vehicle sales and
efficiency including rest stops, charging
• Zero interest loans
standard tourist locations, infrastructure data
• Consideration of a regional towns, cities
• Government • Support for EV
future feebate scheme and airports
EV fleet rentals

• Sales targets • Temporary rebate • Consideration of • Support for fleet
program, zero interest heavy vehicle data collection,
• Changes to
loans , or other access to public including
ADRs for width
incentives charging telematics
and mass
• Curfew exemptions, • Funding for
• EURO VI
emissions zones infrastructure

• R&D funding • Zero interest loans • Co-fund active • Promotion of
for non-road and other transport alternatives to
transport incentives infrastructure private vehicle
travel, including
• Electrify ports and
Mobility-as-a-
airports
Service

Policies to support downstream of the EV Market
• Plan and support the grid integration of • Skills and training support
EVs, including vehicle-to-grid (V2G)
• Future road tax reform for all vehicles
• Consistent national charging standards
• Plan for second/end-of-life opportunities
• Reliable public charging infrastructure

Annual public review of progress against targets

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
Responses to the Discussion Paper

Question 1:
Do you agree with the objectives and do you think they will achieve our
proposed goals?

• We commend the Federal Government’s prioritisation of this important policy issue, recognising the
key role electric vehicle technology has to play in unlocking future economic opportunities for our
nation, and importantly for supporting the achievement of a 43% reduction in emissions by 2030,
and net zero emissions by 2050.
• The government’s priority should be to support the uptake of electric vehicles (EVs), which we
define as battery electric vehicles (BEVs) and plug-in hybrid electric vehicles (PHEVs). The
costs of these technologies, and related infrastructure, are known, and can be deployed today.
• Other technologies, such as hydrogen fuel cell vehicles, may have a role to play in heavier vehicle
segments in the future, but globally do not yet have a significant presence. The government should
maintain a watching brief on other technologies, but not let this delay the significant need to act
today to support the uptake of EV technology, and related infrastructure – for both light and heavy
vehicles.
• We support the government’s three stated objectives to:
o Encourage rapid increase in demand for EVs
o Increase supply of affordable and accessible EVs
o Establish the systems and infrastructure to enable the rapid uptake of EVs.
• The number one priority for enabling greater uptake of EVs in Australia is increasing the supply of
EVs across all segments.
• The key policy measure to achieve increased supply of light EVs in Australia is to introduce an
ambitious and robust fuel efficiency standard for new vehicles, in addition to harmonising local design
rules and regulations with international standards to reduce the burden to import new EV models.
• A significant package of temporary incentives valued at up to $10,000 (when combined with state/
territory incentives) will also be required to drive the adoption of electric vehicles until at least 25-30%
market share is achieved, initially with a focus on fleets to establish a second-hand EV market as soon
as possible.
• Accelerating EV uptake will also require the coordinated roll-out of public charging infrastructure
along urban and regional arterial roads that support electric cars, buses, trucks and other types of
EVs, and that is appropriately integrated with the electricity grid.
• Additionally, a fourth objective should be adopted by the government to make Australia an EV
superpower on the world stage by investing domestically across the EV value chain.
• With the right policy settings, these four objectives can help the government to achieve its five goals:
o Make EVs more affordable
o Expand EV uptake and choice
o Reduce emissions
o Save Australians money on fuel
o Increase local manufacturing.

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
Question 2:
What are the implications if other countries accelerate uptake faster than
Australia?
• Australia is already at a disadvantage to countries that have a higher uptake of EVs, and therefore a
lower cost of transport operations for passenger and freight movements.
• Since lower operating costs of EVs help to reduce transport costs, without increased EV adoption the
cost of transport (and cost of goods) will remain higher in our market than in comparable markets,
affecting the overall competiveness of the Australian economy.
• Australia risks remaining a dumping ground for some of the world's most inefficient vehicles as some
manufacturers offload high-emission vehicles in markets without an ambitious fuel efficiency standard.
• Failing to accelerate the uptake of electric vehicles in Australia will not only jeopardise our ability to
meet emissions reduction targets, but will entrench our nation's reliance on imported fuel, and
continue to lead to premature deaths and air pollution-related illnesses from noxious vehicle emissions.
• Failing to reduce transport emissions through the accelerated uptake of EVs will also put more
pressure on other sectors of the economy, including farming, manufacturing, construction, mining,
and energy providers, which will need to cut their emissions even further to make up for transport
not doing its fair share on the journey first towards our legislated 43% emission reduction target, and
then to net zero by 2050.

Question 3:
What are suitable indicators to measure if we are on track to achieve our goals and
objectives?
• We recommend the Federal Government consider the adoption of the following (or similar) targets:

Supply:
• At least 100 electric car (light vehicle) models by 2025
• An average fuel efficiency target of less than 60 grams of CO2 per kilometre for new light vehicles
by 2030 (NEDC test cycle)

Demand:
• 1 million electric cars (light vehicles) in the Australian fleet by 2027
• At least 60% of all new car (light vehicle) sales being EVs by 2030
• 30% of new truck and bus sales being EVs by 2030 - where fit-for-purpose options are available

Infrastructure:
• Multi-bay charging stations every approximately 70 kilometres along arterial roads, and 5 kilometres
in urban areas, with consideration for providing access to electric cars, buses, trucks and other EVs;
noting this is a visionary target with the ambition for EV drivers to never need to drive more than
around 70 kilometres between fast-charging sites (or around 5 km in urban areas); as opposed to
strictly having a multi-bay fast-charging location at these specific intervals on every road; this aligns
with Europe targetting fast chargers every 60 km. Other charging metrics may also deserve
consideration e.g. number of public chargers: number of EVs, or kW of public charging power:
number of EVs.

Industry Development:
• At least one domestic manufacturer of EVs (car, bus and/or truck) using Australian-made batteries by
2030
• 25% of all new vehicles domestically manufactured/assembled by 2040

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
Question 4:
Are there other measures by governments and industry that could increase
affordability and accessibility of EVs to help drive demand?
• We support the Federal Government's proposed electric car discount, which includes an exemption
for EVs from the 5% import duty, and an exemption from fringe benefits tax to support adoption by
business fleets, and employees that can access salary sacrifice / novated lease packages.
• In the first instance, the Federal Government should expand its current Commonwealth
government fleet target of 75% of all new vehicle purchases being low emissions by 2025
(and the agencies covered by this mandate), and commit to a 100% EV government fleet by 2027 to
accelerate the creation of a local second-hand EV market.
• The Federal Government should also support the uptake of EVs in rental fleets to provide Australians
with the opportunity to experience an EV on a short-term basis. Enabling charging
infrastructure at airports is critical for rental fleets to significantly increase their adoptions of EVs.
• The fuel-efficient luxury car tax limit should be changed from the current threshold of 7 litres per 100
km to an emissions based threshold of 50 grams CO2 per kilometre. The additional revenue raised
through this change should be directed towards EV incentives.
• The Federal Government should work with industry, state and territory governments to investigate
the potential future introduction of a feebate scheme. Increasing fees would be levied against
higher-emitting vehicles, and the revenue used to at least partially fund upfront rebates and other
incentives for low and zero emission vehicles.
• A subsidised vehicle lease/subscription scheme for low-income households should be funded to
increase accessibility to EVs, and enable more Australian households to capture the economic, health
and environmental benefits of this technology.
• The Federal Government should also work with state and territory governments to increase the
roll-out of electric buses and micro-mobility - including associating charging and road infrastructure
- to provide affordable alternatives to private car travel. This could also include subsidising Mobility-
as-a-Service subscriptions to provide unlimited access to a range of electrified public, shared
and active transport options, particularly for low-income households.

Question 5:
Over what timeframe should we be incentivising low emission vehicles as we
transition to zero emission vehicles?
• While we recognise the desire to set a fixed time frame for incentive schemes, it is ultimately the
market share of EVs that determines whether continuing incentives will be required.
• Only vehicles with tailpipe emissions of 50 grams of CO2 per kilometre or less should receive
incentives, and vehicles with tailpipe emissions of 0 grams of CO 2 per kilometre i.e battery electric
vehicles, should receive the greatest level of incentives.
• Any incentives for plug-in hybrid electric vehicles (PHEVs) should also be designed to encourage
regular charging and/or result in more than 75% of driving (on average) using electricity only.
• If Australia achieved our recommended light vehicle fleet target of 1 million EVs by 2027, this
would equate to around 25 to 30% of new vehicle sales being EVs, after which the market is likely to
be self-sustaining, with minimal incentives required (assuming a robust fuel efficiency standard is in
place).
• Temporary incentives could be progressively reduced and ultimately phased out after achieving
this initial target of 25 to 30% of new car sales being EVs. A sudden withdrawal of incentives must be
avoided to ensure the market is not shocked through the transition.
• A similar approach should be adopted for heavy vehicles (buses and trucks), with the goal of
achieving 30% of new sales being EVs by 2030 - where fit-for-purpose options are available.

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
Question 6:
What information could help increase demand and is Government or industry best
placed to inform Australians about EVs?
• The Federal Government has a key role to play in the collection of data, and the dissemination of
trusted information on EV technology.
• At present there is no independent collection of data regarding new vehicle sales, including EVs, and
as such, there is misinformation regarding the number of EVs currently in Australia, as well as the
true emission rates of the existing vehicle fleet.
• The Federal Government should look to New Zealand as an example of the type of data that should
be collected and shared publicly to increase public confidence in EV technology 1.
• Government collection of vehicle sales data will ensure a robust fuel efficiency standard can be
enforced, and that Australian governments can track progress against this data.
• While the Electric Vehicle Council has played a key role in disseminating information on EV sales for
the past five years, and this data is a major reason why our State of EVs reports have such broad
readership, we recognise that this data should be independently collected, and published by the
Federal Government, at arms length from industry.
• Industry also has a key role to play in demonstrating leadership in the adoption and roll-out of EV
technologies, and associated infrastructure, setting an example for the community, while
accelerating the development of a second-hand EV market in Australia.
• The Government should also look to cooperate with independent, non-government organisations, to
support the dissemination of factual information on EV technology, and address some of the
associated misconceptions and mistruths.

Question 7:
Are vehicle fuel efficiency standards an effective mechanism to reduce passenger
and light commercial fleet emissions?
• The Australian Senate 2019 Select Committee on Electric Vehicles supported the introduction of a
fuel efficiency standard informed by those implemented in other comparable countries, noting that
such standards would provide environmental benefits through greenhouse gas emissions abatement.
• Under previous consideration of fuel efficiency targets, the Government determined that the
introduction of stronger standards would result in cost savings of between $10.8 and $27.5 billion by
2040, in combination with a reduction in GHG emissions between 91 to 231 million tonnes.

• Australia has now failed twice to introduce a mandatory fuel efficiency standard.
• This is our nation's last opportunity to introduce a fuel efficiency standard that can make a
concrete and tangible difference to the likelihood of achieving our emission reduction targets.
• Without an ambitious fuel efficiency standard, emissions rates of new vehicles will not fall at a
rate fast enough to achieve emission reduction targets.
• Given how far behind the transport remains in regards to decarbonisation, it is now not possible for
the sector to achieve a 43% reduction on 2005-levels by 2030.
• With the right policy settings in place, such as an ambitious fuel efficiency standard that targets an
average new vehicle tailpipe emissions rate of less than 60 grams per kilometre by 2030 or more
than 60% EV sales by 2030, it may be possible to achieve parity with 2005 emissions levels by 2030
i.e. a 0% reduction in emissions compared to 2005-levels.
• Anything less ambitious than this is likely to mean that transport emissions in 2030 will remain
higher than 2005-levels, and the burden of further emissions cuts will be placed on other sectors of
the economy to achieve our national 43% emissions reduction target by 2030.
1 https://www.transport.govt.nz/statistics-and-insights/fleet-statistics/sheet/light-motor-vehicle-registrations

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
Question 8:
Would vehicle fuel efficiency standards incentivise global manufacturers to send
EVs and lower emission vehicles to Australia?
• Several organisations have called for stronger regulation of fuel efficiency in Australia, noting that a
ambitious fuel efficiency standard would be of significant assistance in alleviating the supply issues
facing electric vehicles in Australia.
• A fuel efficiency standard sets an annual target for the average emissions rate of new vehicles
sold by each manufacturer (or groups of manufacturers).
• This target is progressively reduced each year to encourage the supply of more fuel-efficient
vehicles, including electric vehicles.
• Importantly, a fuel efficiency standard only applies to new vehicles, and does not ban the sale of any
particular type of vehicle.
• Manufacturers that do not meet these targets need to pay a penalty to government. This penalty
can be significant, and as such, manufacturers have clearly outlined that they prioritise the supply of
fuel-efficient and electric vehicles to those markets that have ambitious fuel efficiency standards to
minimise any exposure to these penalties.

• Paul Sansom, the head of Volkswagen Group in Australia, put it simply at the recent EV Summit in
Canberra, in August, 2022:
“If we had (fuel efficiency) standards today, we could start bringing in (electric cars) tomorrow."
“That’s a game changer. It really is. Not just for Volkswagen but for all car makers. It will open up
the door for more affordable EVs, there’s no doubt about that.”
“This is the single most significant measure toward securing EV supply from our factories.
Markets that are subject to punitive fines for exceeding such emissions targets are prioritised for
zero-emissions vehicles."

• Rob Giltinan, Director of Policy and Public Affairs at the NRMA said:
"We feel that a CO2 standard is the obvious missing link that can help supply, moving forward.”
• And Tesla chairwoman Robyn Denholm has said:
“We can’t keep accepting the world's dirtiest cars in Australia, which is what we have today. The
biggest change Australia could make would be to introduce (fuel efficiency) standards.”

• The evidence from overseas on the impact of these kinds of regulations is also clear:
o The International Electric Vehicle Policy Council at the University of California, Davis, notes that
supply regulations - like fuel efficiency standards and sales mandates - encourage vehicle
manufacturers to make more EVs available and to market them more heavily2.
o The International Council on Clean Transportation has observed that supply regulations are a
powerful tool for overcoming the market barrier of insufficient EV supply. For example,
California, which has a zero emission vehicle sales mandate, has more than three times the
average number of zero emission models available than in other US states3.
o The State Government of Quebec in Canada noted that when it first introduced supply
regulation in 2016, it only had 66% of the EV models available in California. By 2021, that had
increased to 85%, with vehicle manufacturers publicly stating they were prioritising the Quebec
market as a result of this supply-focussed regulation4.
• A robust and ambitious fuel efficiency standard is a necessary prerequisite for the increased supply of
electric vehicles to Australia, and in turn, to ensure Australia's transport sector does its fair share in
reducing emissions in line with achieving an economy-wide 43% reduction by 2030.

2 https://phev.ucdavis.edu/wp-content/uploads/zev-mandates-policy-guide.pdf
3 https://theicct.org/wp-content/uploads/2021/06/ICCT_zev_mandates_India_20190703.pdf
4 https://www.environnement.gouv.qc.ca/changementsclimatiques/vze/rapport-mise-oeuvre-2018-2020-en.pdf

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
Question 9:
In addition to vehicle fuel efficiency standards for passenger and light
commercial vehicles, would vehicle fuel efficiency standards be an appropriate
mechanism to increase the supply of heavy vehicle classes in Australia?
• The Electric Vehicle Council commends the Federal Government for its recent announcement that
Euro VI standards for heavy vehicles will be phased in over 12 months from the 1st of November, 2024.
This important policy measure will not only help to reduce harmful pollution being emitted, but also
help to increase the supply of low emission and electric trucks to Australia.
• In regards to the introduction of a fuel efficiency standard for heavy vehicles, the feedback we have
received from industry is that it would be a difficult, lengthy process, and it would be unlikely to
be implemented in a timeframe that would support the necessary reduction in transport emissions,
including from heavy vehicles, by 2030.
• As an alternative, we recommend the Federal Government work with industry to explore the
introduction of a zero emission heavy vehicle sales mandate - similar to the Californian scheme.
• This sales mandate would require manufacturers (groups of manufacturers) to sell a minimum number
of zero emission heavy vehicles each year.

• Consultation with industry is essential to further explore the potential design of such a scheme.

Question 10:
What design features should the Government consider in more detail for vehicle
fuel efficiency standards, including level of ambition, who they should apply to,
commencement date, penalties and enforcement?
• The Electric Vehicle Council recommends that the Federal Government commit to the development
and implementation of a mandatory fuel efficiency standard for new light vehicles that would
support Australia in achieving its targets of a 43% reduction in emissions by 2030, and net zero by 2050.
• The terms of reference for any consultations on the design of a fuel efficiency standard should be
based on the ability to support the achievement of a 43% reduction in national emissions by 2030, and
net zero (including transport) by 2050.
• The Federal Government should consult with industry in developing a mandatory fuel efficiency
standard.
• The Federal Government should also consult with international experts, and policy-makers in
jurisdictions that have already implemented fuel efficiency standards.
• The Federal Government’s priority should be to develop a fuel efficiency standard to encourage
greater supply of fuel-efficient vehicles to Australia, including electric vehicles, and ensure that the
decarbonisation of Australia's light vehicle fleet aligns with net zero.

• A secondary priority should be to adopt Euro 6 (vehicle emissions standard) initially for diesel vehicles
– given local diesel fuel quality does not differ significantly from international fuel; and for petrol
vehicles - once petroleum in Australia is produced at the quality levels required to meet Euro 6.
• Investment decisions by car manufacturers today will affect the available supply of fuel-efficient
vehicles, including electric vehicles, over the next 5 to 10 years.
• Most G20 and OECD countries already have mandatory fuel efficiency standards and are not facing
the same magnitude of challenge as Australia in securing electric vehicles.
• It is critical Australia implements an ambitious and robust fuel efficiency standard for new light
vehicles by the 1st of January, 2024 (at the latest) to ensure we can meet both our interim and long-
term emission reduction commitments.
• State and territory governments should actively support the introduction of a fuel efficiency standard
as this policy lever is critical to achieving EV targets and emission reductions targets in each of these
jurisdictions.

National Electric Vehicle Strategy:
20
Electric Vehicle Council's Submission
• The Federal Government should introduce a mandatory light vehicle fuel efficiency standard with the
following features:

o Be introduced by the 1st of January, 2024 - at the latest - with potential consideration of an initial
phase-in/grace period.
o Be consistent with Australia’s commitment to achieve 43% emissions reduction by 2030 and net
zero by 2050, and ensures the transport sector does its fair share in contributing to these targets.
o Considering Australia’s current market position, develop annual fuel efficiency targets that put
the country’s new light vehicle market on a trajectory that broadly aligns with the targets set in
the United States, New Zealand and the European Union by 2030 – at the latest.
o Annual targets should be set out to at least 2030 to provide certainty to the market. Targets 3 years
ahead should be reviewed every 2-3 years and consider alignment with climate targets. For
example, initial targets set for 2029 onwards would be reviewed in 2026, assuming a start date of 1st
of January, 2024; then in 2028, targets for 2031 onwards would be reviewed, and in 2030 targets for
2033 onwards would be reviewed.
o Consider separate targets for cars (MA, MC) and light commercial vehicles (NA), while seeking to
prevent any design that would encourage a shift towards larger, less-efficient vehicles.
o Provide an initial mechanism to allow manufacturers to gain so-called “super-credits” for selling
more battery electric (BEVs) and hydrogen fuel cell vehicles (HFCVs), to encourage greater
supply of these zero emission vehicles in the initial years of the scheme.

o Plug-in hybrid electric vehicles could also receive super-credits, but at a lower rate than BEVs.
o All super-credits should be temporary, and phased out by 2029, assuming a start year of 2024.
o Conventional hybrid vehicles (that cannot plug-in to charge) should not be eligible for super-
credits as they cannot operate at zero-emissions for any significant distance.
o Off-cycle credits could be considered where a genuine reduction in greenhouse gas emissions can
be demonstrated.
o The use of excessive ‘super credits’ and ‘off-cycle credits’ are generally sought during the
development of similar standards around the world. The Australian Government should be
conscious to accepting standard design loopholes which undermine the integrity of the fuel
efficiency targets, particularly where genuine emissions reduction is not delivered.
o To maximise the effectiveness of the standard, consideration should be made for the collection of
on-board fuel and energy consumption data to monitor real-world values as a safeguard against
significant deviations from test cycle figures - even after transitioning from NEDC to WLTP.
o A penalty should be imposed on car manufacturers (or pools of car manufacturers) that exceed
the fuel efficiency target in terms of the average emissions rate of new vehicles sold. This
penalty should be based on the exceedance of the target in grams of CO2 per kilometre
multiplied by the total number of vehicles sold, and be broadly in line with overseas scheme
e.g. $44 in New Zealand; $150 in the European Union.
o Any revenue derived by the government from the standard should be hypothecated for use in
funding EV incentives, charging infrastructure, and other supportive programs.
o Independent data should be collected and published by government to ensure the standard is
robust and administered at arms length from industry.
• While detailed modelling and consultation will be required to inform interim targets, indicative figures
are included below for initial guidance (based on NEDC emissions ratings):

o less than 55 grams of CO2 per kilometre by 2030 for cars;
o less than 75 grams of CO2 per kilometre by 2030 for light commercial vehicles.
o resulting in an overall light vehicle target of less than 60 grams of CO2 per kilometre by 2030.
• Note, if the above targets were committed to, our estimates suggest that this would still result in
transport emissions being around 5% higher in 2030, compared to 2005-levels. This is largely due to
the relatively slow turnover rate of the Australian fleet, with around 60% of the vehicles on the road
today expected to still be in the fleet in 2030.
• The above targets are expected to support a EV sales target of around 50% by 2030; noting the Electric
Vehicle Council supports a target of at least 60% EV sales by 2030 in order to ensure transport emissions
are reduced as much as possible in support of Australia's 43% emission reduction target for 2030, and that
the EV market is on a trajectory by 2030 that will support Australia in achieving net zero by 2050 - at the
latest.

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
Question 11:
What policies and/or industry actions could complement vehicle fuel efficiency
standards to help increase supply of EVs to Australia and electrify the Australian
fleet?
• Clear EV sales targets to signal to industry and consumers the government's commitment to
achieving the transition e.g. 1 million EVs by 2027; at least 60% EV sales by by 2030, etc.
• Government fleet target of 100% EVs by 2027, and support EV adoption in rental fleets to
guarantee demand for EVs, while accelerating the development of a second-hand EV market.
• Coordination of incentive policies to be nationally consistent i.e. using the same purchase
price thresholds, and criteria, so OEMs can clearly communicate policy in Australia back to their
respective global headquarters, and even more importantly, to consumers.
• While many State and Territory Governments have led on the deployment of EV incentive
programs , the Federal Government should explore further opportunities to increase incentive
programs in order to accelerate EV uptake, and demonstrate the government's commitment to
meeting ambitious fuel efficiency targets. These incentive programs could include:
o Consideration of a future feebate-style scheme - as previously described
o A GST discount, with the cooperation of State and Territory Government's
o An income tax deduction
o Zero interest loans.
• Harmonisation of Australian regulations with international standards to allow direct acceptance of
type approved EVs from global major markets (e.g. EU) in full volume supply to reduce import burden,
and increase EV supply, while still maintaining high safety standards.

Question 12:
Do we need different measures to ensure all segments of the road transport sector
are able to reduce emissions, and if so, what government and industry measures
might well support the uptake of electric bikes, micro-mobility and motorbikes?
• While light vehicles are the greatest contributor to transport emissions, it is also critical that other
transport segments are supported to decarbonise through a National EV Strategy.
• Heavy vehicles account for a disproportionately high amount of emissions relative to the number
of heavy vehicles in the fleet. As such, converting a small number of heavy vehicles to zero emission
alternatives can deliver a substantial reduction in transport emissions overall.
• With many trucks travelling less than 200 kilometres per day, even prior to long-haul electric trucks
coming to Australia, there are significant opportunities to electrify short- and medium-haul trucks.
• The Federal Government should work with State and Territory Governments to offer zero interest loans
and other incentives (rebates, night curfew exemptions, emissions zones, access to telematics data
collection and analysis) to support the purchase and use of electric buses and trucks.
• In line with the recommendations in our 2022 report with the Australian Trucking Association5, the
Federal Government should urgently update Australian Design Rules to align with international
standards and increase the range of electric heavy vehicles that can be imported to Australia, including:
o increasing the truck width from 2.5 to 2.55 metres minimum, with additional consideration for
refrigerated trucks / trailers that may require up to 2.60 metres, and
o providing at least a one tonne mass concession to zero emission / electric trucks.
• The Federal Government should also fund depot-based charging infrastructure pilots across Australia to
provide transparent insights into the costs and processes involved, as well as develop a clear guideline for
fleets to install this infrastructure. A government-affilliated fleet, with diversity in vehicle types and
coverage across the nation, such as Australia Post, would be an ideal candidate for these pilots.
• Zero / low interest loan schemes should also be investigated for electric bikes, micro-mobility; and the
Federal Government should ensure these devices can also be salary sacrificed.
• The Federal Government also has an important role to play in cooperation with other levels of
government to support the construction of active, shared and public transport infrastructure, that not
only enables electric vehicle adoption across these segments, but importantly, also supports alternatives
to private vehicle travel.
• A robust road pricing scheme that targets city congestion and emissions would not only assist in
providing long-term sustainable road tax revenue, but also help to fund public and active transport
options and related infrastructure, and encourage the use of alternative transport modes to private
vehicles during peak-hour commuting periods (see Question 18 for more detail).
5 https://electricvehiclecouncil.com.au/wp-content/uploads/2022/01/ATA-EVC-Electric-trucks_Keeping-shelves-stocked-in-a-net-zero-
world-1.pdf

National Electric Vehicle Strategy: 22
Electric Vehicle Council's Submission
Question 13:
How could we best increase the number of affordable second-hand EVs?
• The Federal Government's proposed Fringe Benefits Tax (FBT) exemption for EVs will be a significant
policy lever for developing a second-hand EV market in Australia.
• We support a 3-year limit (on a per vehicle basis - from the time of delivery/purchase) being imposed
for this exemption to encourage on-selling to the second-hand market after 3 years. Anything less
than this is unlikely to be attractive to business fleets and/or the novated lease market.
• A formal commitment to a government fleet target of 100% EVs by 2027 would also be a significant
lever for increasing the number of second-hand EVs in Australia.
• Finally, the Federal Government should explore opportunities to significantly expand the availability of
EVs in rental fleets. Such efforts would not only accelerate the development of a local second-hand
market - given the higher turnover rates of these fleets - but play an important role in providing
Australians with the opportunity to experience an EV, increase consumer awareness, and in turn,
increase the broader adoption of EVs.

Question 14:
Should the Government consider ways to increase the supply of second-hand EVs
independently imported to the Australian market? Could the safety and consumer
risks of this approach be mitigate?

• Our view is that the existing regulations on private vehicle imports are fit-for-purpose, based on the
market as it stands today.
• At this point in time, unfortunately there are too few used, right-hand drive EVs on the global market
to make a significant difference in terms of the supply of EVs to Australia, when we need to be
targeting at least 1 million EVs in the next 5 years (by 2027) to be on track to achieve >50% EV sales by
2030.
• The most efficient way to grow the second-hand EV market in Australia is through the introduction of
an ambitious and robust fuel efficiency standard, by the 1st of January, 2024 - at the latest. This will in
turn attract more EV models to Australia, and lead to the creation of a strong second-hand market in
the following 2 to 4 years.
• With the funding that would be required to setup a system of safeguards for a large, grey import EV
market, it would be more efficient to direct these funds towards accelerating the uptake and turnover
of EVs in fleets today, with incentives designed to encourage faster turnover in fleets.
• If the Federal Government wishes to further accelerate the creation of a second-hand EV market it can
also act immediately to increase the turnover of its own fleet in line with achieving our recommended
target of a 100% EV government fleet by 2027 - and expansion of the government fleets to which this
target applies.
• This issue could be revisited in the future if a substantial number of used, right-hand drive EVs become
available on the global market, and Australia continues to lack sufficient supply of EVs, however, this
will require detailed consultation with industry to ensure appropriate processes and safeguards are in
place.

National Electric Vehicle Strategy:
23
Electric Vehicle Council's Submission
Question 15:
What actions can governments and industry take to strengthen our
competiveness and innovate across the full lifecycle of the EV value chain?

• Australia is uniquely placed to capitalise on the economic benefits of the transition to EVs thanks to
our rich resource base, wealth of experience in mining, highly-educated workforce, national
security , and potential to access cheap, renewable energy.
• The mining and processing of critical minerals and rare earth elements form a key part of the EV value
chain, and Australia can meet this demand using ethical and sustainable practices.
• With strong domestic regulatory settings that seek to ensure responsible and sustainable business
practices are followed, Australia is well-placed to assist in supporting global demand for critical
minerals throughout the transition, and capitalise on this once in a lifetime economic opportunity.
• Australia should not only benefit from the increased extraction of these resources, but should aim to
increase the on-shoring of valued-added components of the EV value chain.
• In the first instance, Australia should look to onshore the processing and refining of critical minerals for
battery and EV production.
• In tandem, Australia should be looking to secure investment in the manufacturing of batteries, EV
components, charging infrastructure and electric vehicles. This downstream, local demand for value-
added products will reduce the risk for investment in the upstream segments of the EV value chain.
• Australia should look to other countries, such as Thailand and the United States, which are providing
significant fiscal incentives, tax breaks, operational certainty, and guaranteed demand to attract
and secure international investment in their domestic EV value chain.
• A necessary prerequisite to Australia capitalising on this once in a lifetime economic opportunity is
establishing a strong, domestic EV market to demonstrate significant local demand for products from
the value chain, and in turn, further increase the attractiveness of investing in our market.
• The Federal Government also has a key role to play in strengthening trade partnerships in our region to
secure investment and off-take partners for Australian resources and products.

Question 16:
How can we expand our existing domestic heavy vehicle manufacturing and
assembly capability?
• Australia should be proud of its strong heavy vehicle manufacturing industry, and look to actively
support its transition to a zero emission, electric future.

• In the first instance, changes to Australian Design Rules (as outlined in Question 12) should be
made to increase the width limit of heavy vehicles to 2.55m minimum, and provide at least a 1
tonne mass concession. This would increase the range of chassis and vehicles that could be
imported to Australia to help accelerate local manufacturing and assembly. These changes are
urgently required to increase market volumes, and as a consequence, reduce costs.

• While vehicle width and mass limits are being amended in the Australian Design Rules, all Australian
governments should enable the fast-tracking of temporary exemptions from these rules so that
companies can start to sell and deploy larger electric trucks today, providing the necessary and
urgent kick start required for decarbonising the road freight sector.

• It is critical that international investment is secured to build out Australia's domestic EV value chain
(as outlined in Question 15) to reduce the cost of input components, principally batteries.

• The Federal Government should also fund a low/zero interest loan program (and/or other
incentives) to support the adoption of electric heavy vehicles (trucks and buses). These
temporary incentive programs would accelerate local demand, and spur increased investment in
domestic heavy vehicle manufacturing and assembly.

• Tax breaks and incentives for investment in local heavy vehicle manufacturing and assembly should
also be explored to help scale local production over the coming decade.

National Electric Vehicle Strategy:
24
Electric Vehicle Council's Submission
Question 17:
Is it viable to extend Australian domestic manufacturing and assembly capability
to other vehicle classes?
• Australia already has a strong local heavy vehicle manufacturing industry, but also has the potential to
reintroduce domestic light vehicle manufacturing centered around EVs.
• Looking at other nations that have secured, or are actively seeking investment in domestic EV
manufacturing, it is clear the Federal Government, in cooperation with State and Territory
Governments, will need to offer incentives to secure international investment in local EV
manufacturing.
• Thailand, which already has a well-established vehicle manufacturing industry, is now offering 3 to 11
year tax holidays to companies that invest in EV production. This support has so far resulted in
over 20 approved electric car programs, from 17 different companies, which are expected to contribute
to the nation's target production capacity of 1 million locally-produced EVs by the end of 20236.
• The Federal Government can solidify the business case for investment in local EV manufacturing
by accelerating domestic demand and locking in the domestic off-take of vehicles, and components.
In the first instance this can be via guaranteed government fleet orders, and then more broadly by
providing temporary incentives to support Australian households and businesses to purchase
Australian-manufactured EVs.
• Note: consumer purchase incentives should be available to all vehicles, however, once domestic
manufacturing capabilities are established, a bonus incentive could be introduced for vehicles that
use local content, similar to the US's new tax credit starting in 20237.

Question 18:
Are there other proposals that could help drive demand for EVs and provide a
revenue source to help fund road infrastructure?
• The Federal Government should commit to introducing a nationally-consistent road pricing scheme
for both light and heavy vehicles, and for all fuel types, that does not unfairly disadvantage regional
and remote Australians, and replaces any road pricing schemes implemented and/or proposed by
state and territory governments.
• Before introducing a new road pricing scheme, a joint review process should be undertaken in
cooperation with state and territory governments, and industry.

• We recommend the review considers the following elements:
o Application to all vehicle types, not only one specific fuel type
o Not only target distance travelled - given this unfairly disadvantages regional and
rural Australians if this becomes the primary means of raising road tax revenue
o Explore opportunities to tax the major externalities of road transport i.e. city road
congestion and emissions. This should include consideration of the future
introduction of congestion and/or emissions zones in major urban areas
o A new road pricing scheme should be a replacement of existing road taxes e.g.
road registration, stamp duty, etc. This could include fuel excise if there was
appropriate differentiation in road pricing rates based on fuel consumption and/or tailpipe
emissions

o Revenue should be appropriately divided across states and territories.
• Electric vehicles should receive an exemption from existing road taxes as a temporary incentive to
accelerate uptake, but also be exempt from any new road pricing schemes until at least 25 to 30%
market share has been achieved - given this is the point at which the market is expected to
be well-established, and close to self-sustaining.
6 https://www.goauto.com.au/news/general-news/people/thailand-rsquo-s-ev-push-could-yield-electric-utes/2022-09-27/89219.html
7 https://electrek.co/2022/08/21/which-electric-vehicles-still-qualify-for-us-federal-tax-credit/

National Electric Vehicle Strategy:
25
Electric Vehicle Council's Submission
Question 19:
What more needs to be done nationally to ensure we deliver a nationally
comprehensive framework for EVs?

Here we outline a series of additional issues that should be considered as part of a comprehensive
national framework for supporting EV uptake.
Grid integration
• The Federal Government should investigate methods for incentivising and/or requiring EV charging
equipment installed in the Australian market to have OCPP 1.6J communications capability (or
approved equivalent), over at least one of Ethernet, Cellular modem, or WiFi.
• This measure is intended to future-proof EV charging equipment installations to support future
participation in EV charging orchestration schemes, in the event that EV charging orchestration
becomes commercially viable in a manner that requires communications capability in the EV
charging equipment.
• This requirement should be nationally consistent, and should not require jurisdictionally (i.e. state
level or DNSP level) unique compliance, testing, or qualification requirements.
• Further information on the EV Council's position on this matter can be found at:
o https://electricvehiclecouncil.com.au/reports/home-ev-charging-and-the-grid-impact-
to-2030-in-australia/
o https://electricvehiclecouncil.com.au/submissions/evc-submission-to-esb-electric-vehicle
-
smart-charging-issues-paper-2/
Vehicle to Grid
• A review and update of AS/NZS4777.1 and AS/NZS4777.2, the standards covering vehicle to grid
implementations, is currently underway. The Federal Government should engage in this process, to
ensure that the outcome of the review is such that the early stage uptake of this nascent but critical
technology is not held back by requirements to conform to unique Australian standards. A related
requirement is for the CEC approved inverter framework to be updated, once the review and update
of AS4777 is complete.
• The current state of play is that vehicle-to-grid (V2G) inverters require unique hardware and
software modifications to be deployed in the Australian market and need to be individually
qualified with each DNSP in order to be deployed. If this remains the case, it will mean that
once V2G capable vehicles start coming into Australia at scale (~2025 or so) it will be very difficult for
Australians to take advantage of this technology because there will not be a robust market offering
suitable inverters.
• Further information on the EV Council's position on this matter can be found at:
o https://electricvehiclecouncil.com.au/wp-content/uploads/2022/10/EM-001-_-4777_2-
P-000142-comment.pdf
Tariff reform
• Public fast charging sites, drawing less than 160MWh/annum, should be able to access network
tariffs that do not have kVA-based components (commonly referred to as demand or capacity
charges), and should be able to select this type of tariff at time of connection. This is intended to
solve for the commercial challenge of these sites having a high power requirement, and low
utilisation, in regional locations and in the early days of EV uptake.
• This setting is already in place in VIC, WA, TAS and most of NSW. A similar setting is in place in QLD,
and is planned for the next regulatory reset in the NT and in the Ausgrid region in NSW, where the
threshold is 100MWh. In SA, any new fast charging site capable of delivering >120kVA (which is
about half the maximum charging speed of the most common EV on the market) is exposed to
kVA-based charges.
• The Federal Government, through the AER, is well placed to work with the states to achieve some
consistency around this issue.
• With respect to home EV charging, which will comprise 80%+ of the energy delivered into EVs, the
existence of appropriate retail energy products that strongly incentivise EV charging in the home at
times of excess generation and spare network capacity (middle of day and middle of night), will
deliver excellent cost saving outcomes for consumers, while delivering excellent energy system
outcomes.
• The role of Federal Government in regards to home charging tariffs is to ensure energy networks
(DNSPs) and energy retailers are engaging with each other to develop and offer to market these
retail products.

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Electric Vehicle Council's Submission
Electrical regulations
• Currently, we have a range of different state and territory level requirements associated with the
type of EV charger that is permitted to be installed in a domestic home.
• In NSW, VIC, and TAS, it is permissible to install a single phase EV charger at 32 Amps (~7kW). In the
ACT and the NT, EV charger installations are limited to 25A (~5.5kW). In WA, SA, and QLD, EV charger
installations are limited to 20A (~4.5kW), subject to a variety of different conditions under which 32A
installations may be approved, subject to individual application by the installer to the relevant DNSP.
• This mish-mash of different regulatory settings has evolved over time, and would benefit from being
made consistent, in order to support consumers across the country getting the type of charger they
want, and equipment suppliers being able to develop consistent offerings across the country. Our
position is that 32A single phase EV charging installations should be permitted throughout the
country, subject to the requirements laid out in AS/NZS3000:2018.
• There should be no need for unique jurisdictional requirements of this nature; the EV charger is just
another appliance in the home.

Maintenance of EVs
• Various parties have raised concerns relating to electrical shock risk of persons undertaking
maintenance on EVs. The regulatory requirements around this vary by state – they’re inconsistent
across regions, and also inconsistent with respect to vehicle types.
• For example, in QLD the current rule is that a person undertaking work on an electric truck or
bus must be a licenced electrician (i.e. has completed a 4 year apprenticeship), but that a person
working on an electric car with exactly the same electrical risk present is exempt from that
requirement.
• We note that mild hybrid vehicles have been in the Australian market for a long time, with
battery voltages sufficiently high as to present potential hazard, but without any significant
incidence of electric shock. The Electric Vehicle Council has also been involved in the recent
rewriting of AS5732, which addresses this space.
• The role of Federal Government in this space should be to co-ordinate between the states, in
order to achieve an outcome whereby persons undertaking work on EVs are suitably
competent, but without requiring excessive levels of reskilling and retraining.
• An example to consider could be the limited licensing for plumbers connecting electric hot
water services in VIC – where the plumber undertakes a short course through an registered
training organisation, specifically covering only those elements he or she needs to safely
connect and disconnect an electric hot water service, in order that the installation
and maintenance of that type of asset does not require the work of both a licensed plumber
and a licensed electrician.
• Consideration should also be given to the various units of competency currently on offer in this
space, to evaluate their suitability to be mandatorily required by relevant regulations and legislative
instruments, such as: https://training.gov.au/Training/Details/AURETH101
• It may be that existing units of competency are adequate in this regard, or it may be that they need
some revision in order that they appropriately strike the balance between achievement of safety
outcomes and managing the costs and impacts of re-training/re-skilling.

Visibility of uptake
• Peak demand in local networks at a granular level drives investment decision making by DNSPs,
and has a strong linkage to reliability of supply. The uptake of EVs is not going to be uniform – there
will be cases where individual network segments see far faster than average EV uptake (known as
clustering), and if the charging behaviour in those segments is such that it occurs at peak times,
network augmentation in specific locations may be needed.
• With this in mind, the Electric Vehicle Council takes the view that the Federal Government should
engage with state and territory governments, and through the AER to support:
o Processes intended to enable networks to know which metering points have EV chargers
located at them, and the power level of said EV chargers
o Data sharing between vehicle registration bodies and relevant parties in the energy sector
(AEMO and DNSP), to enable identification of dwellings where EVs are likely to be garaged
o Network monitoring at the distribution transformer level - knowing where the chargers are
is not the same is knowing when they’re charging.

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Electric Vehicle Council's Submission
Built environment
• The Electric Vehicle Council welcomes the recent changes to the National Construction Code
requiring new apartment buildings to be built ‘EV Ready’, such that electrical infrastructure is put
in place to enable every car parking space to be wired for EV charging.
• Significant work remains in the existing built environment, where it has become very clear that
the retrofitting of EV charging in brownfield apartment complexes faces many hurdles. The NSW
Government is leading the way in addressing this issue. The Electric Vehicle Council believes that
there may also be a role for the Federal Government in supporting this transition.
• While the work undertaken to date by industry has been advocating primarily for readiness in
apartment complexes and workplaces, and has so far excluded standalone homes and standalone
multi-deck car parks, there will be merit in giving consideration to EV readiness in these structure
types in the near term.
• The Electric Vehicle Council has also noted a significant degree of discussion with respect to fire
safety aspects, including guidance notes from state-based fire services (published in the case of
Queensland Fire and Emergency Services; informally circulated without formal publication in the
case of Fire Rescue Victoria), leading fire engineers to treat EVs within buildings as special hazards.
• This is a designation that carries with it a requirement for significant additional fire proofing,
sprinkler systems, and ventilation – adding between 5% and 10% to the overall cost of construction of
structures like apartment complexes, where that construction considers the inclusion of EV charging
equipment.
• Evidence justifying these guidance positions has not been provided, and this extra cost impost has
been sufficient to prevent developers from including EV charging in building projects. It’s worth
noting that overseas experience, and expert research commissioned locally by the Australian
Building Codes Board (ABCB) has been that EVs are not significantly more dangerous than internal
combustion engine (ICE) vehicles in the event of fire in structures.
• The Federal Government (through bodies like the ABCB) has a role in working with fire services to
establish what an appropriate response to the transition to EVs looks like in the built environment
from a fire safety point of view.
• This may include substantial funding for practical testing programs, such as the SARET program
being undertaken by Fire Rescue NSW.
• It may also draw a clear distinction between road-registered EVs, where there are highly robust
regulation and enforcement practices in place around engineering design for safety and recalls
when needed, and micro-mobility EVs such as scooters and bicycles, where existing regulation and
enforcement around engineering design and recalls deserves further scrutiny.
• Further information on the EV Council's position on this matter can be found at:
o https://electricvehiclecouncil.com.au/submissions/evc-submission-to-australian-building-
codes-board-on-draft-ev-readiness-provisions-in-national-construction-code-2022%ef%bf%bc/

Airports
• It has come to the attention of the Electric Vehicle Council that major airports in Australia
(e.g. Melbourne and the new Western Sydney Airport) do not include EV charging in their master
plans, and efforts made by car rental agencies to secure EV charging infrastructure in the context of
airport car parks have been frustrated by various parties. Melbourne Airport’s master plan, published
earlier this year, in fact explicitly calls out that EV charging equipment is not required.
• This is relevant because in order to shift to EVs, car rental organisations need EV charging
equipment at airports. Global car rental organisations have capacity and desire to secure
delivery of large numbers of EVs, contingent specifically on the ability to charge them in
the airport car park environment, which will accelerate EV uptake in the country as a whole.
• Airport rental of EVs suits consumers very well. There is high demand, translating to many
consumers experiencing EVs this way, which will lead to increased consumer demand for EVs.
• Rental agencies typically turn new cars over into the second hand market after 50,000km or
2-3 years, which is significantly faster than corporate and government fleets. This will foster a
robust second hand EV market sooner.
• Given airports are an area of federal jurisdiction, the Federal Government should be well placed
to resolve this challenge.

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
Battery recycling / stewardship
• Concerns have been raised in various places about the risk of EV batteries ending up in landfill, and
the potential need for a stewardship scheme to prevent this outcome.
• The Electric Vehicle Council observes that at both local and global levels, EV battery recycling
initiatives are getting underway under existing market settings, without the need for additional
regulation.
• It is particularly impressive that this is happening in Australia, given our relatively late entry into
taking on EVs at scale.
• The Electric Vehicle Council suggests that while there is the possibility of market failure similar to the
current market failure whereby the majority of AA and AAA batteries end up in landfill, there is no
indication that significant market failure of this nature has yet occurred in Australia, or that it is likely
in the future given the significant economic value inherent in EV batteries.
• Based on this, the Electric Vehicle Council would recommend the Federal Government maintain a
watching brief on this issue, but do not support measures, such as levies, that are premature, risk
slowing the adoption of EVs, and that should only be pursued if there is proven to be a substantial
market failure for which there is no evidence of at present in Australia.
Reliable public charging
• Similarly to many other jurisdictions, Australia has seen an emergent issue whereby public fast
charging stations are not reliably available at a level that meets consumer expectations. There are
many root causes to this challenge, and many well understood techniques for addressing it in
adjacent industries.
• The desired outcome for consumers in terms of reliability/availability of EV charging should be that it
is a comparable experience to arriving at a petrol station today – which is to say, a driver has a near
100% likelihood of being able to recharge, provided they’re arriving at a time when the site is open for
business, and nothing really significant has gone wrong (flood, fire, disruption to supply to site, etc).
• The Federal Government, state & territory governments, and industry should come together to
develop a principles-based reference document that leads to this outcome, covering matters such as
redundancy at charging locations, maintenance practices, spare parts service level agreements,
payment methodologies, and uptime reporting. The Electric Vehicle Council stands ready to
participate in and support this work.
Consumer protection and consumer-focused energy reform
• New models of engagement between consumers and commercial operators have already emerged
with the advent of EVs and can be expected to continue to emerge.
• There is a need to provide room for innovation, while also providing adequate consumer protection –
the Australian Energy Regulator has been looking closely at this recently in their Retailer
Authorisation and Exemption review.
• The position of the Electric Vehicle Council is that given the supply of energy to vehicles is
significantly less essential than the supply to dwellings, and given that it is also substantially less
monopolistic (the driver being free to take their vehicle wherever they like for recharging), the
appropriate level of consumer protection is likely to be more closely aligned with Australian
Consumer Law, rather than the National Energy Customer Framework i.e. extra levels of consumer
protection above and beyond Australian Consumer Law are probably not required.
• This said, this is an emergent space. It will be important for relevant federal and state government
agencies to maintain a watching brief over the space as it evolves, and if predatory practices emerge,
take appropriate action.
• Further information on the EV Council's position on this matter can be found at:
o https://electricvehiclecouncil.com.au/submissions/evc-response-to-aer-retailerauthorisation-
and-exemption-reviewissues-paper/

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
Metrology
• The sale of energy typically requires accurate measurement to be made in kWh, in order to ensure
that the consumer gets what they pay for. In the case of EV charging, the regulation has not kept
pace. The situation at present is that there is no specific metrology requirement associated with
measurement of energy delivered to EVs when used for trade.
• The NMI is currently undertaking a review of this space.
• It will be important for the Federal Government to stay close to this process, so that we do not end
up with requirements that are jurisdictionally unique, or which unnecessarily drive up costs for
industry and consumers.
• There would be merit in the Federal Government (by way of NMI / ACCC) exploring possibilities for
verification of energy delivered at public DC charging stations, in similar manner to the existing
verification processes associated with measuring petrol bowsers.
• Further information on the EV Council's position on this matter can be found at:
o https://electricvehiclecouncil.com.au/submissions/submission-to-the-national-measurement-
institute-on-electric-vehicle-charging-stations-october-2021/
o https://electricvehiclecouncil.com.au/submissions/evc-submission-to-nmi-on-the-draft-oiml-
guide/

Cybersecurity:
• Substantial consideration is being given to the orchestration of EV charging as a supporting
element in future grid security. This is variously referred to as demand response, distributed energy
resources, consumer energy resources. There is also substantial potential for vehicle-to-grid to be
networked and orchestrated as well.
• Historically, this type of architecture in Australia has been managed through ripple signals delivered
over powerlines from zone substations – examples include off-peak hot water dating back to the
1950s, and orchestration of air-conditioning in Queensland using DREDs under the Peaksmart
program. These systems are effectively secure-by-design from the point of view of a malicious
actor; there is no connection to the internet that can be exploited. If we assume a future where
millions of consumer endpoints, each at multi-kW power level, are connected and orchestrated via
the internet, this will constitute the creation of a significant new threat surface.
• The role of the Federal Government here will be to ensure that any planned architecture for wide
scale orchestration of significant consumer loads is appropriately cybersecure, to mitigate the risk
associated with a malicious actor exercising control over multiple gigawatts of network connected
load or generation.

Equitable access to EV charging
• Consumer access to EV charging is expected to vary by housing type and by tenure type.
Homeowners in standalone houses with off-street parking have the easiest pathway to charging at
home and taking advantage of self-consumption of solar and off-peak energy pricing. Renters in
terrace houses without off-street parking will have the least access to charging at home and will
therefore be more reliant on public charging equipment.
• Consideration should be given to appropriate market settings to reduce the degree of relative
disadvantage experienced by consumers who cannot access at-home charging.

DNSP connection processes
• Proponents of DC fast charging locations experience a wide range of response timelines and
processes from DNSPs when putting forward connection requests to establish fast charging
locations. These timelines often run to many months, and significantly delay the deployment of
public fast charging equipment.
• A reasonable near term goal for the Federal Government in this matter would be to work through
the AER and ERAWA as the relevant regulatory bodies to establish what practices and metrics are in
place at the DNSPs that perform best in this respect (i.e., that have the fastest turnaround time from
connection request to response to the applicant), and work towards bringing the DNSPs with the
slowest processes into line with the DNSPs that are quickest.

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
Non-road vehicles
• While the core area of focus for the EVC is road transport, the transport sector is not limited to road
vehicles. Electrification is already a feature of light rail and rail, and options exist in maritime and
aviation. The Federal Government should explore these areas, with a view to identifying potential
areas for intervention and targeted support.

Tracking and modelling of energy sector impacts
• The current AEMO forecasting (ESOO and ISP) has significant uncertainty with respect to potential
grid impacts of EV charging over the next 10 years. While average energy consumption per EV is
relatively estimable, estimates as to numbers of EVs on the road in ten years vary through an order
of magnitude, and estimates as to probable charging profiles, which impacts ADMD (after diversity
maximum demand) at peak time similarly vary by an order of magnitude. The impact of the uptake
of EVs on the grid is the multiple of the number of EVs by the average charging profile – so with two
factors which both vary by a factor of about 10, the uncertainty spans two orders of magnitude. Low
end estimates of impact are 100 times less than high end estimates of impact.
• The cure for the uncertainty around vehicle numbers is the Fuel Efficiency Standard , argued for
comprehensively earlier. One of the cures for the uncertainty around EV charging behaviour should
be federal support for ongoing data collection, analysis and publication of consumer EV charging
behaviour, with particular attention paid to how the behaviour changes over time as EVs enter the
mass market, and how the behaviour varies by region, since it will be influenced strongly by the
energy retail offers available to consumers.

Skills and training
• The Victorian Government has supported the creation of a training program for licenced electricians
to upskill on EVs, which will result in the electrical contracting community being better placed to
support consumers and small business operators who wish to install appropriate charging
infrastructure in their homes and small businesses. This training program will be accredited by the
VRQA and delivered by RTOs, commencing in 2023.
• The role of the Federal Government here should be to support the roll-out of this accredited
curriculum by RTOs in other jurisdictions, so that electrical contractors across the country can be
better placed to support consumer’s needs with respect to EV charging equipment installations. We
have a large and established workforce of electricians; a small amount of additional training for them
will assist in delivering a lot of useful EV charging equipment.
• The Federal Government should also work with state and territory governments to offer skills and
training grants for sectors that will be affected by the transition, such as the internal combustion
engine and related component workforce.

National Electric Vehicle Strategy:
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Electric Vehicle Council's Submission
Question 20:
How can we best make sure all Australians get access to the opportunities and
benefits from the transition?
• Introduce a robust and ambitious fuel efficiency standard to maximise the supply of EV models to
the Australian market - as soon as practicable.
• Act quickly, and support acceleration now to ensure a viable second-hand EV market is established
in the next 2-4 years, which in turn will provide EV options for all Australia households and businesses.
• Explore the opportunity to introduce targetted programs that provide access to shared/leased EVs for
low-income households, as well as support broader measures to reduce the cost of transport for these
households, including subsidised Mobility-as-a-Service subscriptions.
• Support industry development to significantly expand the Australian EV value chain,
attract international and local investment, and be on a trajectory to be building EVs locally,
with locally made batteries, using Australian mined and processed materials, by 2030 (at the latest),
while supporting the creation of thousands of new, local jobs (enabled through appropriated
skills development and training - as previously outlined).
• Lead coordination of national EV policy in cooperation with state and territory governments,
seeking national consistency in program eligibility rules, and approaches - as far as possible.
• Undertake regular, annual reviews of the domestic EV market, tracking progress against targets/
metrics, and adjusting policy as required in response to these reviews. See an example annual
EV policy progress report from the State Government British Columbia, Canada here: https://
www2.gov.bc.ca/assets/gov/farming-natural-resources-and-industry/electricity-alternative-energy/
transportation/2021_zero_emission_vehicle_update_v2.pdf

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Electric Vehicle Council's Submission
National
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