National Electric Vehicle Strategy: consultation paper

National Electric Vehicle Strategy

Submission by Australasian Fire and Emergency Service Authorities
Council (AFAC)

October 2022
CONTENTS
1 Introduction ......................................................................................................................... 3
2 Overview of AFAC and its role ............................................................................................... 4
AFAC strategic directions......................................................................................................... 4
AFAC is a managing partner in the Australian Institute for Disaster Resilience...................... 4
AFAC supports the National Resource Sharing Centre ............................................................ 5
AFAC Leads the Emergency Management Professionalisation Scheme ................................. 5
AFAC are the custodian of the Australasian Inter-service Incident Management System
(AIIMS) ..................................................................................................................................... 5
AFAC and the National Aerial Firefighting Centre ................................................................... 5
3 Comments on the questions posed by the National Electric Vehicle Strategy Consultation Paper
............................................................................................................................................ 7
Responses to specific questions: ............................................................................................. 7
Appendix 1: AFAC member organisations ................................................................................... 11

2
1 Introduction
The Australasian Fire and Emergency Service Authorities Council (AFAC) welcomes the opportunity to make a submission to the National Electric Vehicle Strategy Consultation. The submission is based on consultation among AFAC membership as well as our broader understanding of the context of the consultation.

We ask the Department to note that the submission should not be taken as the position of any single
AFAC member. Also, some of our members will have contributed through jurisdictional submissions, and nothing in this letter should be taken as implying that our members do not fully support their jurisdictional submissions where made.

As part of this submission, numerous documents produced by AFAC have been cited. These documents form the foundation of information used for this submission and are referenced in the text with hyperlinks where possible. AFAC takes a leading stance in the publication of industry doctrine which has been drawn on where relevant. Doctrine ranges from high-level, principles- based capstone material, through to technical guidance. Individual agencies make practical and realistic operational decisions on how they interpret this doctrine

This submission begins with an overview of AFAC and its role within Australasian fire and emergency services (Section 2). Section 3 is a response to each of the questions provided by the National
Electric Vehicle Strategy Consultation Paper.

3
2 Overview of AFAC and its role
AFAC is the national council for fire, land management and emergency service authorities in
Australia and New Zealand, representing 31 member and 21 affiliate members, comprising permanent and part-time personnel and volunteers, totalling 288,000 firefighters and emergency workers. The list of AFAC member organisations is provided in Attachment 1. AFAC engages with members through a collaboration model as well as event facilitation, professional development and by influencing regulations and standards. It exists to support the fire and emergency service industry, making communities safer and more resilient. AFAC has no direct role in the delivery of services to the community. AFAC also currently plays no role in representing its members in industrial matters.

AFAC facilitates national collaboration through the AFAC Collaboration Model, which encompasses
34 groups, technical groups and networks. AFAC members regularly come together to share knowledge and create solutions that shape practice and guide the industry’s development. The AFAC
Collaboration Model aims to add value to AFAC members, the fire and emergency services industry and ultimately enhance community safety.
AFAC’s most significant intellectual property asset is the suite of doctrine publications which articulates good practice based on the knowledge and experience of our members and informed by research where it is available. It's evidence-based, constantly reviewed and vested as the official view by the AFAC National Council and sector leaders.

AFAC strategic directions

The work of AFAC is directed by the Strategic Directions for fire and emergency services in Australia and New Zealand 2022-2026. The Strategic Directions provide clarity on intent and identifies actions at a national level for fire and emergency services in Australia and New Zealand. AFAC recognise that a collaborative approach is critical to achieving the Strategic Directions and gives fire and emergency services a national voice and broader impact, while enhancing collective capabilities.

The Strategic Directions are:

1. Supporting resilient communities through risk reduction;
2. Providing a trusted response;
3. Using credible and timely information and data;
4. Safe, capable and diverse workforce;
5. Informed by knowledge, innovation and research, and;
6. Effective and transparent governance.

AFAC is a managing partner in the Australian Institute for Disaster
Resilience

The Australian Institute for Disaster Resilience (AIDR) develops, maintains and shares knowledge and learning to support a disaster resilient Australia (www.aidr.org.au). Building on extensive knowledge and experience in Australia and internationally, AIDR works with government, communities, NGOs, not-for-profits, research organisations, education partners and the private sector to enhance disaster resilience through innovative thinking, professional development and knowledge sharing.

4
AIDR is supported by its partners: the Australian Government National Emergency Management
Agency, AFAC, the Australian Red Cross and Natural Hazards Research Australia.

AFAC supports the National Resource Sharing Centre

AFAC established the National Resource Sharing Centre (NRSC) tasked to develop and maintain the national Arrangement for Interstate Assistance (AIA); pursue collaboration opportunities with international jurisdictions; maintain the National Statement of Capability for Fire and Emergency
Services and provide support, if requested, to jurisdictions involved in deployments
(https://www.afac.com.au/initiative/nrsc/national-resource-sharing-centre-doctrine/national- resource-sharing-centre-fundamental-doctrine) Its value has been clearly demonstrated in supporting the management of large-scale incidents, facilitating interstate and international deployments.

There is a clear appetite for a national resource sharing capability and a clear understanding of the need for its further development.

AFAC Leads the Emergency Management Professionalisation Scheme

The Emergency Management Professionalisation Scheme (EMPS) exists to advance the cause of professionalisation in the practice of emergency management in Australia and New Zealand.
'Professional' and 'Professionalisation' refer to the technical and ethical standards of practice that we set for ourselves: professionalisation is open to everyone regardless of whether they are paid or volunteer, and regardless of the particular emergency management function they undertake.
There are currently 24 EMPS Certified Practitioner and EMPS Registered Practitioner roles open for application. They range from Incident Management Team functions to specialist operational roles.
Three of these roles are specific to prescribed burning; they are the Certified Burn Controller,
Registered Complex Burn Planner and Registered Complex Burn Operations Officer.

EMPS provides an excellent example of a national approach for professionalisation in the industry.

AFAC are the custodian of the Australasian Inter-service Incident
Management System (AIIMS)

AIIMS is an integral part of emergency management doctrine for the fire and emergency services industry in Australia. The system enables Australian agencies to come together to resolve incidents through an integrated and effective response.

Through the application of AIIMS in training, exercising and incident response, people from fire and emergency services, government, not-for-profit agencies and industry have been able to build trust and confidence in each other’s ability to work together and effectively manage the most challenging of incidents.

AIIMS 2017 is the latest edition of the Australasian Inter-service Incident Management System.
Endorsed by the AFAC Council, and published in June 2017, it replaced AIIMS-4 as the Incident Control
System used by all fire, emergency service and land management agencies within Australia.

AFAC and the National Aerial Firefighting Centre

AFAC provides aerial firefighting resources on behalf of the States and Territories.

5
The National Aerial Firefighting Centre (NAFC) is a business unit of AFAC formed in 2003 by the
Australian States and Territories, with the support of the Australian Government, to provide a cooperative national arrangement for the provision of aerial firefighting resources for combating bushfires.

NAFC coordinates the leasing of a national fleet of specialised firefighting aircraft on behalf of State and Territory emergency services and facilitates the sharing of these aircraft between States and
Territories during the fire season. The collaborative arrangements for the national aerial firefighting fleet have been instrumental in protecting communities and saving lives and property over past bushfire seasons.

NAFC also provides national systems to service aerial firefighting. For example, ARENA is a ground- breaking information system developed collaboratively with States and Territories to support effective management and administration of the fleet.

6
3 Comments on the questions posed by the National Electric Vehicle
Strategy Consultation Paper
AFAC has produced research and evidence-based considerations that are apolitical and are focussed on the safe implementation and uptake of Electric Vehicles. This has included a guideline for emergency service organisations to consider when responding to emergency incidents involving
Electric Vehicles, along with advocating for safer, more appropriate building standards particularly relating to carparks and charging infrastructure.

The competition in the lithium-ion battery market revolves around the intellectual property associated with battery chemistries, particularly in the electrolyte and materials used for the anode and cathode.
This presents varying levels of hazards and risks to first responders and emergency service personnel and the public when attending incidents involving EVs. Battery chemistry may not be easily identifiable at an incident, requiring responders to take the highest precautions available

There are several AFAC Collaboration Groups that have an interest in the uptake of EVs. These include the Urban Operations Group, SES Operations Group, Alternative and Renewable Energy Technologies
Working Group, Community Safety Group, Built Environment and Planning Technical Group, Climate
Change Group and the Fleet Technical Group.

There are several proposed Objectives, Goals and Actions in the National Electric Vehicle Strategy
Consultation Paper that are relevant to AFAC’s role in advocating for public safety related to the implementation of EV’s and EV charging infrastructure. Suggestions around increasing the numbers of
EVs in Federal and State government fleets (page 9), opportunities for medium rigid trucks (page 11) and relaxing of safety regulations such as Australian Design Rules (Page 11) are of concern and relevance to AFAC members.

Responses to specific questions:

Question 1: Do you agree with the objectives, and do you think they will achieve our proposed goals? Are there other objectives we should consider?

• AFAC is in broad agreement with the proposed objectives, however, believe that a focus on
safety and risk management is lacking. AFAC suggests the amendment of objective three
“Establish the systems and infrastructure to enable the rapid uptake of EVs.” to “Establish
and ensure safe systems, buildings and infrastructure to enable the rapid uptake of EVs.”
• The consultation paper suggests barriers to EV uptake that require addressing, including
“Information for consumers”. AFAC in turn suggests a national education campaign to
inform consumers of the unique risks of lithium-ion batteries and charging.
• AFAC suggests that the NEVS consider that whilst failure events may currently be occurring
at a low frequency, the potential risks that can eventuate from a thermal runaway event
may be of high consequence. A failure event within a lithium-ion EV battery (overcharge,
electrical failure, mechanical or thermal abuse) has the potential to lead to a thermal
runaway event, which may pose the following significant challenges for firefighters in the
management of the incident:
- High voltage direct current (DC) and alternating current (AC) electricity.
- Toxic and flammable vapour production.
- Vapour cloud explosion.
- Toxic smoke production.
- Rapid rate of fire spread.
- Unrecognised heat release rate and unknown temperature fluctuations.

7
- Highly directional and jet-like flames.
- Exothermic chemical reaction-fuelled fire that cannot be extinguished.
- Significant fire duration (4+ hours) and protracted incident.
- Proximity of adjacent fuel loads such as other vehicles and building elements.
- Potential for secondary-ignition.
- Stranded electrical energy.
- Contaminated cooling water runoff.
- Post fire management of hazardous waste.

Question 3: What are suitable indicators to measure if we are on track to achieve our goals and objectives?

• AFAC suggests that indicators such as incidents involving injury and/or fatality with a
particular focus on EV charging, type of lithium-ion chemistry, EV manufacturer and other
contributing factors should be considered. These indicators should be measured to ensure
that any emerging trends are informing any future requirement for upgrading and
maintaining standards, building construction and charging infrastructure.

Question 6: What information could help increase demand and is Government or industry best placed to inform Australians about EVs?

• AFAC suggests that Government is best placed to inform Australians about EVs, however
also recommends that a greater emphasis is put on the safe rollout of EV’s and associated
infrastructure, along with informing consumers about the risks and hazards involved with
lithium-ion batteries and guidance for responsible EV ownership. AFAC also advocates for
thorough consultation with relevant fire and emergency service agencies in each jurisdiction.
• AFAC supports the opportunity for introducing higher numbers of EVs in Federal and State
government fleets, including those of fire and emergency service agencies and opportunities
of their medium-rigid truck fleets.
• AFAC does not support the relaxation of any Australian Design Rules, and in fact would
recommend developing additional design rules if any modification to the ADRs are
proposed.

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?

• AFAC suggests that different measures are introduced in the separate segments of the road
transport sector. Again, AFAC suggests that the uptake of electric bikes, micro-mobility and
motorbikes requires a focus on the safe implementation of supporting systems including
manufacturing standards, regulation of the second-hand battery market along with end-to-
end supply chain safety/risk mitigation.
• AFAC is concerned by the higher risks related to charging light EV’s in residential buildings
and supports individual measures and safety messaging to address the risks.
• AFAC supports the opportunity for introducing higher numbers of EVs in Federal and State
government fleets, including those of fire and emergency service agencies and opportunities
of their medium-rigid truck fleets.

8
• AFAC does not support the relaxation of any Australian Design Rules, and in fact would
recommend developing additional design rules if any modification to the ADRs are
proposed.

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 mitigated?

• AFAC suggests that the supply of second hand EVs should be tightly regulated and that a
compliance regime as a minimum should be developed to ensure the quality and safety of
second-life batteries. Lithium-ion batteries contain varying types of chemistry and therefore
have various charging profiles to ensure the ongoing stability and state of health of a battery
cell. Battery cells with an unidentified chemistry, or those that have been unknowingly
damaged during its first life provide a risk to both the public and first responders.
• There is concern that an unregulated market could lead to the proliferation of batteries with
questionable or unknown history and therefore a higher risk to public safety.
• AFAC is also concerned that enabling the use of second-life lithium-ion battery in
‘repurposing’ or ‘remanufacturing’ processes, particularly if left unregulated could lead to
the combination of cells of differing chemistry types and state of health, which would lead to
instability within the battery particularly when charging. There is currently no effective non-
destructive process to give an accurate state of health of individual cells in a battery system

Question 15: What actions can governments and industry take to strengthen our competitiveness and innovate across the full lifecycle of the EV value chain?

• AFAC suggests that a greater emphasis is put on the safe rollout of EV’s and associated
infrastructure, along with informing consumers about the risks and hazards involved with
lithium-ion batteries and guidance for responsible EV ownership including risk mitigation.
AFAC also advocates for thorough consultation with relevant fire and emergency service
agencies in each jurisdiction.

Question 19: What more needs to be done nationally to ensure we deliver a nationally comprehensive framework for EVs?

• AFAC suggests that a greater emphasis is put on the safe rollout of EV’s and associated
infrastructure, along with informing consumers about the risks and hazards involved with
lithium-ion batteries and guidance for responsible EV ownership. AFAC also advocates for
thorough consultation with relevant fire and emergency service agencies in each jurisdiction.
• AFAC advocates for the Federal Government to continue working with states and territories
for full implementation of the National Construction Code 2022 requirement that new
apartment buildings are EV ready by 1 October 2023, as agreed at the 26 August 2022
meeting of Building Ministers.
• AFAC suggests developing further measures within the National Construction Code in
consultation with Australian fire and emergency service agencies to support easy and safe
charging of EVs (as requested at the 26 August 2022 meeting of Building Ministers).
• AFAC suggests a further consideration of the impacts of EV fires on building systems and fire
and life safety systems in new and existing buildings.

9
• AFAC suggests that guidance should be produced regarding specific risk factors that should
be considered when introducing new hazards into environments that were not necessarily
designed with them in mind.
• AFAC suggests the development of appropriate, stringent security and safety standards
relating particularly to EV charging infrastructure.

AFAC recognises and supports Australia’s transition to sustainable forms of energy. AFAC also implores policy makers to ensure appropriate safety measures are developed, maintained and regulated to reduce the risk of harm to our communities and the first responders who risk their lives daily.

10
APPENDIX 1: AFAC MEMBER ORGANISATIONS
Full Members (33)
Australian Capital Territory
ACT Emergency Services Agency
ACT Parks and Conservation Service

New South Wales
Fire and Rescue NSW
NSW Rural Fire Service
Forestry Corporation of NSW
NSW National Parks and Wildlife Service
NSW State Emergency Service
Surf Life Saving New South Wales

Northern Territory
Northern Territory Fire and Rescue Service
Northern Territory Emergency Service
Bushfires NT

New Zealand
Fire and Emergency New Zealand

Queensland
Queensland Parks and Wildlife Service
Queensland Fire and Emergency Services

South Australia
Department for Environment and Water (National Parks and Wildlife Service)
South Australian Fire and Emergency Services Commission
South Australia Country Fire Service
South Australian Metropolitan Fire Service
South Australian State Emergency Service

Tasmania
Sustainable Timber Tasmania
Parks and Wildlife Service
Tasmania Fire Service
Tasmania State Emergency Service

Victoria
Country Fire Authority
Forest Fire Management, Department of Environment, Land, Water, and Planning
Fire Rescue Victoria
Parks Victoria
Victoria State Emergency Service

Western Australia
Department of Fire and Emergency Services

11
Department of Biodiversity Conservation and Attractions, Parks and Wildlife Service

National
Air Services Australia
Department of Home Affairs, National Emergency Management Agency
Parks Australia

Affiliate members (25)
Ambulance Tasmania
Australasian Road Rescue Organisation
Australian Maritime Safety Authority
Australian Red Cross
Brisbane City Council
Bureau of Meteorology
Council of Australian Volunteer Fire Associations
Department of Conservation New Zealand
Department of Families, Fairness and Housing
Department of Health
Emergency Management Victoria
Geoscience Australia
Hong Kong Fire Services Department
HQPlantations Pty Ltd
Melbourne Water
Ministry of Civil Defence and Emergency Management
National Biosecurity Response Team
National SES Volunteers Association
NSW Environment Protection Authority
NSW Volunteer Rescue Association
Pacific Islands Fire & Emergency Services Association
RedEye Apps
Resilience NSW
State Emergency Management Committee, WA
Surf Life Saving Australia

12