National Electric Vehicle Strategy: consultation paper

Submission National Electric Vehicle Strategy Consultation

31 October 2022
Tesla Motors Australia, Pty. Ltd.
Level 14, 15 Blue Street. North Sydney 2060

Introduction
Tesla’s mission is to accelerate the world’s transition to sustainable energy. Tesla believes the world will not be able to solve the climate change crisis without directly reducing air pollutant emissions including carbon dioxide (CO2) and other greenhouse gases (GHGs) from the transportation and power sectors.

To accomplish its mission, Tesla designs, develops, manufactures, and sells high- performance fully electric vehicles and energy generation and storage systems, installs, and maintains such systems, and sells solar electricity. Tesla currently produces and sells four fully electric, zero emissions vehicles (ZEVs): The Model S sedan, the Model X sport utility vehicle (SUV), the Model 3 sedan, and the Model Y mid-sized SUV. Tesla is by far the highest-selling manufacturer of ZEVs in Australia, accounting for 2 in every 3 ZEVs sold.

Tesla employs over 600 people in Australia and purchases over $1 Billion annually of
Australian minerals. 75% of the lithium and 40% of the nickel in Tesla’s lithium-ion batteries around the world come from Australia.

Globally, by 2030, Tesla aims to sell 20 million electric vehicles per year. Tesla also continues to make significant investments in advancing EV, solar, and battery storage technology with over $1.1 billion dedicated to research and development (R&D) in 2021 alone.

The company is also investing in its growing network of retail stores, vehicle service centres, and electric vehicle charging stations to accelerate and support the widespread adoption of its EV products. Tesla operates the largest network of EV chargers in Australia.

In 2021, Tesla opened 912 new Supercharger locations around the world, an average of two and half new locations every day. Tesla’s global network has grown to include over 3,700
Supercharger Stations with almost 34,000 individual connectors. Tesla’s charging network also includes over 14,000 Destination Charging. Tesla is committed to continue expanding these networks to provide a convenient and seamless charging experience for our customers.

Tesla believes that the transition to a fully electrified light duty vehicle sector can and will happen much quicker than many anticipate. As demonstrated by the Model 3 being the world’s best-selling premium sedan and the Model Y becoming one of the top selling SUVs
in the Australia, consumers continue to embrace electric vehicles.

Tesla shares the Australian Government’s air quality, clean transportation, and climate goals, and applauds the government on embarking on a National Electric Vehicle Strategy consultation.

Throughout this submission Tesla have attempted to answer the consultation questions as directly as possible. Some additional information has been provided as an appendix, which outlines Tesla’s recommendations specific to charging infrastructure. Tesla stands ready to provide any further information that might assist this process.

Tesla in a member of the Electric Vehicle Council of Australia (EVC) and supports their submission to this process. Tesla is also a member of the Federal Chamber of Automotive
Industries (FCAI) and welcomes the chambers support for decarbonising vehicles in Australia as quickly and efficiently as possible.

Responses

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

Yes, Tesla agrees with the objectives and goals of the National Electric Vehicle Strategy consultation paper.

Another objective that Tesla recommends for consideration is increasing Australian supply of electric vehicle minerals. While this could be considered part of the objective to “increase the supply of affordable electric vehicles,” mineral supply is of such fundamental importance that it merits particular focus.

One of the key constraints on decarbonising transport is the availability and cost of battery- grade lithium and other critical minerals. Australia currently supplies 75% of the lithium in
Tesla vehicles worldwide and has the strongest reserves of lithium in the world. To meet global decarbonisation goals, production of refined lithium must scale by over 25-fold by
2035. This rate of growth cannot be achieved unless Australian federal and state governments work together with industry to expedite projects, mobilise capital, and prepare Australian workers to make the most of this opportunity.

2. What are the implications if other countries accelerate EV uptake faster than Australia?

Most comparable countries have already accelerated EV uptake much faster than Australia, and the implications are clear:
- Australian motorists now spend over $5000 on petrol each year on average, up to
30% more than they would have if vehicle CO2 standards had been enacted in
previous parliaments;
- Vehicle pollution kills more Australians than vehicle accidents and is a leading trigger
of respiratory illness including childhood asthma;
- Australia’s is a decade behind other countries on reducing carbon pollution from
transport, which puts increased pressure on other sectors to decarbonise; and
- Australia continues to rely on oil imported from overseas rather than Australian
renewable electricity.

Australia can take decisive action now to catch and surpass other countries in electrification.
Failing to do so will lead to compounding consequences of inaction.

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

Fleet decarbonisation.

It’s important that indicators of progress be publicly available from trusted government sources. Just as progress in electricity generation and national greenhouse accounts factors should be regularly published by government in an accountable fashion, so too should vehicle fleet statistics.

Tesla recommends that the Federal Government collaborate with industry and with motor vehicle registration authorities to publish regular vehicle statistics. A strong example is New
Zealand’s Te Manatū Waka (Ministry of Transport) Ngā tatauranga ā-kahupapa (fleet statistics) reporting. This includes weekly low emissions vehicle reports and comprehensive statistics about new vehicle sales and the existing vehicle fleet.

Key metrics for the National EV Strategy might include:
- Monthly vehicle statistics broken down by model variant with real-world CO2
emissions data; and
- Fleet statistics including:
o Vehicle retirement rate (based on deregistration or scrappage); and
o Vehicle age and retirement rate by CO2 emissions.

Charging infrastructure.

The most critical barrier to increasing fast-charging infrastructure in Australia is the amount of time it takes to obtain grid connection and transformer upgrades. Fast charging infrastructure is critical for supporting longer-distance electromobility, and the charging needs of those (e.g. apartment dwellers) who lack adequate access to home-based chargers.

For Tesla, Australia is the most difficult country in the region to install direct current (DC) fast chargers, with transformer upgrades and grid connections often taking over 1 year for utilities to complete, compared to just 6-8 weeks in other countries. Attached at Appendix 1 is a whitepaper outlining this challenge and suggested solutions in more detail.
To measure progress toward its National Electric Vehicle Strategy (NEVS) goals, Tesla suggests that government track timeframes for fast-charger installations, aiming to reduce average timeframe from application to site readiness to below 3 months.

Where public charging stations receive funding from government, Tesla recommends that minimum standards of reliability and performance are also measured and considered in grant processes. Unfortunately, some public charging networks that have benefited from significant government funding are not able to provide satisfactory experiences to EV drivers. Far too often, drivers arrive at fast-charging station to find that some or all charging ports are not operational due to hardware or even software outages. This causes significant delays and frustration. This phenomenon is eroding trust in public charging infrastructure and should urgently be considered by government. All other regulated or publicly-funded electricity assets are subject to minimum reliability and uptime requirements; it makes sense for vehicle chargers to be treated the same. Markets including the UK, Singapore, and the USA are planning to introduce minimum uptime requirements for fast-charging infrastructure. Tesla recommends that Australia consider uptime requirements of >95% but cautions that such measures should be carefully designed to ensure they do not impose unnecessary red tape on operators.

The majority of EV charging is done at drivers’ homes or workplaces with lower- to medium- powered (level 2) chargers. Access to off-street charging is one of the most important enablers of EV adoption, and one of the key equity challenges of EVs, because Australians who are less socio-economically advantaged are less likely to own their homes, have off- street parking, or be able to access workplace charging. Tesla recommends that the Federal
Government make access to charging a key metric for its National EV Strategy. One approach would be to use census data to map areas where home-ownership and/or off- street parking are low and prioritise these areas for on-street parking trials or multi-unit- dwelling charging programs.

Australian critical minerals for electric vehicles.

A critical factor for global decarbonisation is the supply of critical minerals for EV batteries from Australia, particularly lithium. Measures of success for this may include:
- Current output of lithium spodumene;
- Timeline of prospective and expected spodumene output;
- Number and size of lithium deposits found;
- Amount of domestic and foreign capital deployed toward lithium projects; and
- Portion of spodumene refined in Australia.

Health impacts.

Vehicle pollution kills more Australians each year than vehicle accidents: an estimated 1715 deaths in 2017 according to the Clean Air and Urban Landscapes Hub, which was 40% greater than the road toll in that year.

Australian governments at all levels spend a great deal on infrastructure and public education to reduce the vehicle accident road toll; government advertising campaigns affirm
that “zero is the only acceptable number” of road deaths. These road safety efforts are laudable, and Tesla is proud that its vehicles have the lowest probability of passenger injury of any by the National Highway Traffic Safety Administration (NHTSA), and among the highest Australasian New Car Assessment Program (ANCAP) scores yet recorded.

Deaths caused by vehicle pollution in respiratory wards are no less tragic and preventable than deaths on roads. It is time that governments treated them with the same gravity and urgency.

So too, the long-term impact of air pollution on health should be closely studied and mitigated. Australia’s most common cause of general practitioner presentation in children under five is asthma and allergy. In 2012, Gasana et al. observed that children attending schools near high traffic density roads were exposed to higher levels of vehicle pollutants and had an associated increase in the incidence and prevalence of childhood asthma and wheeze.

As a starting point, it is important that vehicle pollution deaths and illnesses are adequately measured. It has been 17 years since BITRE released a detailed report on health impacts of transport emissions in Australia. There is a serious dearth of quality data collected to measure the overall impact of transport pollution, let alone provide granular insights that would allow policy makers to effectively target and iterate interventions. If road accident data was not collected in sufficient detail to accurately estimate how many Australians died or were injured in accidents, policy makers and public health officials would be justly outraged; the same response is justified for pollution data.

Tesla recommends the federal government fund an expansion of particulate and noxious pollution monitors to better quantify vehicle and other pollution around Australia.

Health and Air Pollution New Zealand (HAPINZ 3.0) is a thorough and internationally peer reviewed framework for evaluating the effects of air pollution on human health across New
Zealand and the resulting social costs. The authors of the study (Kuschel et al) estimated anthropogenic (human-made) air pollution in New Zealand was responsible for approximately 3,300 premature deaths per year and social costs of $15.6 billion per year.

This framework is more thorough than those used in Australia to date and give reason to believe if that air pollution causes a great many more deaths than previously estimated; if
New Zealand’s results were translated on per capita basis to Australia, air pollution could be responsible for more than 8,600 premature deaths.

Tesla recommends that Australia investigate adapting the HAPINZ 3.0 framework for use in
Australia. Furthermore, Tesla recommends that the federal government publish an annual estimated vehicle pollution road toll alongside regular reports on health impacts of anthropogenic air pollution.
4. Are there other measures by governments and industry that could increase affordability and
accessibility of EVs to help drive demand?

The Electric Car Discount is a key early policy to encourage uptake of EVs and will inject the used car market in Australia with thousands of more affordable used electric vehicles in coming years; Tesla applauds this initiative. By reducing the Fringe Benefits Tax payable
(FBT) on an electric vehicle, the Electric Car Discount makes electric vehicles a fantastic economic choice for any motorist taking a novated lease on a vehicle.

Although EVs in Australia typically have higher upfront prices than internal combustion engines (ICEVs), the total cost of ownership of EVs can be lower overall. Australian motorists are now spending over $5,000 a year on petrol on average, and maintenance costs of ICEVs are significantly higher than EVs. Furthermore, modern electric vehicles tend to hold value well, leading to lower depreciation rates over the term of ownership. This means that for many Australian families, an EV may already be cheaper overall to run than ICEV alternatives they are considering, even where the upfront purchase price of the ICEV is lower.

Government programs can help spread these benefits to those who are less able to access
EVs because upfront costs.
- Substituting upfront costs such as purchase taxes and registration duties for lower
ongoing costs such as road user charges.
- Using the government’s borrowing power to provide concessional finance or asset
underwriting to better enable those on lower or fixed incomes to access finance and
leases on EVs.
- Working with state, territory, and local governments to rapidly solve the challenges
of on-street charging for EVs. International best practice includes: charging on street
lights and power-poles; urban charging hubs; grants for local shopping strips to
install charging; community charging hubs; and right to charge legislation that
enables renters and those in multi-unit-dwellings to install charging without
unnecessary delay.

5. Over what timeframe should we be incentivising low emission vehicles as we transition to zero
emission vehicles?

The level of incentivisation required to boost low emission vehicle uptake depends on the strength of regulatory settings in place such as vehicle CO2 standards, and the levels of incentives flowing to higher emissions vehicles and to fossil fuels. Incentives to fossil fuels are still far greater on net than those to low emissions vehicles, notwithstanding recent federal government measures to support EV uptake.

Although electric vehicles are expected to be exempted from FBT under the Electric Car
Discount, light commercial vehicles have enjoyed FBT exemptions for decades. This is a major factor in the popularity of these vehicles in the Australian market and the dominance of dual-cab utes in Australian passenger vehicles sales. While many Australian who drive utes and vans require such vehicles for their trade, for a great many others they are a preference not a necessity. The cost to the budget of this exemption over several decades
would surely be in the tens of billions. The Fuel Tax Credit is budgeted for $7.9 billion in
2021-22. Payments under the Fuel Security Bill 2021 are costed at $2 billion to 2030.

Ambitious and robust CO2 standards for new cars are the most important policy lever for driving vehicle decarbonisation.

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

Informing Australians about EVs should be an important priority for both industry and government.

The federal government has announced the laudable aim of ensuring Australians can access charging every 150km across Australia’s road network. Government investments under the
Future Fuel Strategy and ARENA are already helping to enable this. However, most
Australians remain unaware of these plans, or the charging available to them already. Tesla recommends that the federal government consider a significant public information campaign to inform Australians of the charging network that is and will be available to them, and of other key facts about the transition to electric vehicles.

7. Are vehicle fuel efficiency standards an effective mechanism to reduce passenger and light
commercial fleet emissions?

Yes. Fuel efficiency standards (or new vehicle emissions standards) are among the most effective mechanisms available to governments and have been adopted in every other market comparable to Australia.

8. Would vehicle fuel efficiency standards incentivise global manufacturers to send EVs and lower
emission vehicles to Australia?

Yes, but only to the extent that Australia’s standards are comparable to those implemented in other comparable markets.

For instance, the European Union’s vehicle emissions standard currently has a 95-gram
CO2/km target and a penalty price of 95 Euros for every gram exceeding that target. A carmaker that otherwise exceeds its target can reduce its penalties by up to 9025 Euros or
~14,000 AUD by selling a zero emissions vehicle in that jurisdiction. It should be no surprise then that carmakers tend to bring very limited stock of low emissions vehicles to Australia, even after those models are officially launched here. Carmakers have a strong financial imperative to send their most efficient vehicles to markets with the strongest targets.
Australia’s vehicle efficiency standards will incentivise global manufacturers to send low emissions vehicles to Australia only to the extent that these standards have strong rules, an ambitious target, and a competitive penalty price. Without strong rules, a target will be diluted by loopholes and bones credits. Without a strong target and an internationally
competitive penalty price, Australia will remain the least-cost option for carmakers to allocate inefficient vehicles that other countries do not allow.

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 to Australia?

Yes.

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?

Integrity

The most important design principle is integrity. Australians deserve to know that the targets set out for pollution reduction are what they appear.

There is nothing wrong with flexibility in standards: measures that allow carmakers to meet targets in the most efficient way by trading and banking credits between brands and vehicle segments. However, some design features don’t make standards more flexible, but simply make them weaker.

“Super credits” can weaken standards, hide actual pollution impact, and reduce public trust in vehicle standards. These credits mean that certain types of vehicles are double or even triple counted when carmakers count the average emissions of their vehicles.

Imagine that modern cricketers were allowed to count their half centuries twice and their centuries three times toward their average. Many would look better than Bradman. “This incentivises centuries!” some batters might say, but the public would know that their numbers are a lie. A run is a run and a car is a one car, not three.

If some vehicles are to be counted more than once toward average emissions, the
Government should provide a transparent estimate of the actual emissions target after such credits are applied, so that the public can make an honest “apples to apples” assessment.

“Off-cycle” credits are a method designed ostensibly to account for fuel efficiency technologies that are not captured by standard cycle-based emissions testing. This also has the effect of diluting stated CO2/km targets and should be carefully examined.

New Zealand lawmakers considered each of these design principles in creating their country’s Clean Car Standard and opted to omit super credits an off-cycle credits. As a result, the New Zealand standard is a world class scheme that is elegant, transparent, and accountable.
Tesla recommends that the Australian government consider aligning its standards as closely as possible with the New Zealand Clean Car Standard. The Australian and New Zealand car vehicle markets are inextricably linked; aligning vehicle standards for CO2 (and other areas including design rules) would greatly reduce regulatory complexity for international carmakers and importers.

To best incentivise low emissions vehicles in Australia, penalties should be aligned with international competitor markets, as outlined previously in this submission.

Ambition

Meeting Australia’s decarbonisation targets will require strong and urgent action in the transport sector.

Australia’s Nationally Determined Contribution (NDC) of 43% by 2030 over 2005 levels is the minimum required to put Australia on a decarbonisation pathway that is in line with the
Paris Agreement. Noting that the Paris Agreement requires targets to be further strengthened over time, and that the Australian Government has described 43% as a “floor not a ceiling” it is important that vehicle standards are able to increase ambition over time.

Unfortunately, in vehicle emissions it is now impossible to achieve 43% emissions reduction by 2030. In 2005, light vehicle emissions in Australia were 55.794 megatonnes (Mt). Light vehicle emissions peaked at 62 Mt in 2019 and are projected to be 58 Mt by 2030 on a business-as-usual trajectory. A 43% reduction on 2005 levels would mean achieving 31.8 Mt per annum, or a 48% reduction on 2019 levels.

There were 20.1 million registered vehicles in Australia as of 31 January 2021. 1,049,831 vehicles were sold in 2021. At this pace, it will take approximately 19 years to replace the vehicles on Australian roads. Approximately 5.2% of vehicles are replaced each year. So even if Australia was able to move from 2.5% of new vehicles being zero emissions to 100% overnight, only a third of the vehicles in Australia would be zero emissions vehicles by 2030, which would only reduce vehicle emissions to approximately 40 Mt annually, still falling well short of a 43% reduction to 31.8 Mt. Pursuing an ambitious CO2 standard akin to New
Zealand’s Clean Car Standard might reduce Australia’s light vehicle emissions to approximately 50 Mt by 2030. To put Australia in a position to meet its decarbonisation commitments, a new vehicle emissions standard must be ambitious and robust.

The less emissions reduction managed by the light vehicle sector, the more heavy lifting other sectors of the Australian economy must do. If carmakers were to do less, then farmers, manufacturers, and households must do more.

Given Australian vehicles have an average lifespan of some 20 years, it is likely than most
ICEV vehicles sold to Australians after 2030 will have to be regulated or incentivised off
Australian roads before their full life span to achieve net zero in 2050, given that there are no offsets available in the transport sector. This means a material reduction in the asset value of these vehicles; Australians should be aware of this, and governments should seek to minimise waste by moving quickly toward low and zero emission vehicles in all segments.
It's critical that Australia pursue ambitious targets that catch up to peer countries as quickly as possible, for example by aligning with New Zealand and the USA before 2030.

Penalties

To best incentivise low emissions vehicles in Australia, penalties should be aligned with international competitor markets, as outlined previously in this submission.

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?

Tesla have included at Appendix 1 a paper that outlines 10 recommendations for actions to improve charging station infrastructure in Australia.

Several other bodies have canvassed detailed EV strategies that deserve consideration, including:
- The Senate Select Committee on Electric Vehicles, and in particular Senator Storer’s
chair’s report, which produced a budget-neutral plan to accelerate EV uptake; and
- The Electric Vehicle Council, of which Tesla is a member, which has proposed several
policy options in its submission to this consultation and other publications.

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?

Yes. Different road transport segments have various charging requirements; analysis is needed to ensure the adequacy of charging infrastructure to support different use cases.
Additionally, the price curve for different vehicle classes will vary, so incentives and regulatory support will be required on different timelines to vehicles.

13. How could we best increase the number of affordable second hand EVs?

The Government has already committed to significant and laudable targets for electrification of commonwealth fleets. This is an important measure to drive second hand
EV availability; it does so both directly and indirectly. Directly, government fleet purchases soon become available on the second hand market. Indirectly, the government’s purchasing power pushes leasing providers and fleet owners and operators to adapt their business models for electric vehicles. Exempting EVs from FBT under the Electric Car Discount has a similar impact.

One approach government could consider is specifically incentivising ZEV uptake among taxi, rideshare, and rental fleets. It makes sense to focus efforts on decarbonising vehicles that travel the most distance each year and rideshare, taxi and rental vehicles can cover more distance in a year than some private vehicles do in ten. Furthermore, these vehicles
are often moved on to the second-hand market after a few years at considerable discounts given their mileage. Data from electric taxi trials overseas shows that even after over half a million kilometres, most Tesla vehicles still had greater than 90% battery capacity remaining; and with fewer moving and wearing parts, electric vehicles are uniquely well- suited for high mileage. Focussing on electrifying this segment can have the dual benefit of rapid decarbonisation and stimulating the affordable second hand EV market.

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?

N/A

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

Australia has a unique and enviable position in the EV value chain. Tesla’s Chairwoman is
Robyn Denholm, an Australian based in Sydney who has world-leading experience in technology and automotive sectors. Ms Denholm recently described electric vehicles as “the greatest economic opportunity of the century” for Australia and noted the opportunity for
Australia to become an “electric vehicle superpower” across mining, refining, and manufacturing.

The opportunity for Australia begins with its world-leading reserves of critical minerals for electric vehicles. Australia has the world’s largest deposits of lithium and is the only country with all 11 critical minerals required for electric vehicle batteries.

75% of the lithium in Tesla batteries worldwide comes from Australia, and 40% of the
Nickel. Tesla currently spends over $1 billion each year on Australian minerals.

However, the vast majority value in the EV supply chain is captured outside of Australia.
Lithium spodumene is the ore from which battery-grade lithium hydroxide is refined. Most
Australian spodumene is currently shipped overseas for refining. Refining onshore reduces transport costs and transport carbon intensity tenfold, reducing carbon intensity of resultant lithium hydroxide (LiOH) by approximately 1 tonne of CO2 per tonne of LiOH.

If Australia can rapidly decarbonise its grid and provide industrial-scale renewable electricity at low cost, there is an even greater case for local refining and further value-adding to
Australian battery minerals.

Tesla estimates that global lithium production must increase over 25-fold by 2030. If
Australia is to progress further downstream into manufacturing cathodes, cells, and vehicles, it is imperative that lithium refining be scaled rapidly. There are already three lithium refineries underway in Australia, with several others under consideration, but a
great number more will be required to absorb a larger portion of domestic spodumene production.

Despite the significant resource advantages Australia enjoys, there are several obstacles to
Australia realising this generational opportunity.

The first is site availability and permitting. Because the refining industry will need to scale rapidly, jurisdictions that can offer short and certain permitting for sites will be at a significant advantage. This need not reduce environmental outcomes if sites are identified and approved in advance, anticipating the unprecedented expansion required in coming years.

The next challenge is cost of power. Refining is an energy-intensive industry; large refineries will use more than 10 GWh annually. A high and unstable cost of electricity may make the industry unviable in Australia; planning for significant renewable energy zones that can service likely refining locations could increase Australia’s competitiveness significantly.

A third major challenge is labour availability. While Australia has a highly skilled workforce in adjacent industries, it’s likely that government assistance will be required to ensure workforce availability can be aligned with likely sites for refining.

If Australia can successfully ramp up lithium, nickel and other critical minerals refining in the coming years it can build a strong foundation for further progress in the EV value chain.

16. How can we expand our existing domestic heavy vehicle manufacturing and assembly capability?

Australia has a proud history of heavy vehicle manufacturing, producing vehicles that cater to Australia’s unique road conditions. As heavy vehicles turn to battery power, the presence of local mineral refining and cathode/cell manufacturing could enable continuation an expansion of this sector.

17. Is it viable to extend Australian domestic manufacturing and assembly capability to other vehicle
classes?

Tesla Chairperson Robyn Denholm recently remarked that “Australia is missing out on much of the value-add from this supply chain because, to date, the focus has been on shipping the raw materials offshore. Australia should aim to do the refining, the battery cell manufacturing, and the vehicle manufacturing. We can and should do all of that. We have the know-how, we have the skills, and an abundance of mineral resources.”

To do this, it is critical that Australia seize the immediate opportunity to accelerate lithium and nickel refining on shore, and work with industry to plan for cathode precursor production at scale.
18. Are there other proposals that could help drive demand for EVs and provide a revenue source to
help fund road infrastructure?

As electric vehicle penetration increases so too do the accompanying opportunities to benefit the electricity grid and put downward pressure on power prices for all Australians.

Electric vehicles already provide significant advantages to the electricity grid.

Telsa’s data indicates that only 15% of EV charging in Australia is DC fast-charging. The remaining 85% is lower-powered AC (level 2) charging. Within AC charging, approximately
40% is currently from standard power points; the remaining 60% is through Tesla and other wall-charging units. This means that most charging is low impact on the grid and has the potential to be controlled in demand response schemes to support the grid.

Tesla data also indicates that EV charging in Australia largely occurs at times of day that are beneficial to the grid, with a large portion of charging coincident with daytime solar peaks.

Figure 1: Tesla fleet charging profile by time of day (AC Charging)
Figure 2: Tesla fleet charging profile by time of day (DC Charging)

This reflects the fact that many EV owners seek to reduce the cost and carbon intensity of their charging by timing it to coincide with solar generation or overnight off-peak tariffs.
Time of use tariffs and incentives for demand response programs provide immediate options for improving the impact of EVs on the grid.

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

This has been covered in other responses.

20. How can we best make sure all Australians get access to the opportunities and benefits from the
transition?

This has been covered in other responses.

Appendix 1 – Charging Up: Recommendations for rapidly scaling
Australia’s public chargers
CHARGING UP
Recommendations for rapidly scaling
Australia’s public chargers
Executive Summary
Australia faces a wave of electric vehicle (EV) adoption. This has consequential impacts on electricity networks and necessitates adequate and affordable charging infrastructure across Australia.

Most EV charging will likely continue to occur overnight at residential properties, however a widespread network of public charging infrastructure (i.e. Type 3, direct current (DC) fast chargers, ultrafast or super chargers) will be fundamental to support ongoing EV uptake. This will quash range anxiety concerns and ensure charging convenience for all customer types and trip preferences.

Many stakeholders are acutely aware of the growing need for public chargers –
AEMO’s latest projections for EV uptake highlights the need to 10x our public charging infrastructure by 2025 and 25x our charging infrastructure by 2030.

There is less awareness about the opportunity this public charging load will provide to grids and utilities. DC charging is highly correlated with solar output and enables flexible load to mitigate minimum operational demand issues and compensate for lost network revenues from the rise of distributed energy resources (DER).

Various initiatives to fund and deploy public charging infrastructure are underway by state governments in NSW, Queensland, the ACT, and WA, including targeted grants from ARENA as well as continued planning for a fast-charging network across our federal highways.

However, a lack of national coordination and delayed federal policy has stymied
Australia enjoying an overarching roadmap that can accelerate the rollout of public charging infrastructure.

This paper focuses on public fast chargers and their integration with Australia’s electricity distribution network service providers (DNSPs) to explore how to streamline and speed up deployment of this critical infrastructure at scale.
It is not simply a lack of funding: there are a combination of barriers (technical, regulatory, and commercial) that need to be overcome.
As an immediate next step and as part of the upcoming national EV strategy, Tesla recommends the Australian Government, along with DNSPs and charging infrastructure operators, host a forum and develop a comprehensive plan for the rollout of a public charging network at scale, with the following focus areas:

1. Work with DNSPs to simplify and streamline grid connections (target under 4
months): recognising the rising volume and frequency of EV charger
applications over the coming years (scaling by a factor of 10x) and ensure
dedicated DNSP resources to support. There is wide variability in processes
among DNSPs and room for many to adopt the best practices of those who have
been able to craft best practice.

2. Update connection frameworks to support multiple connection points at sites –
ensuring clear separation from existing electrical boundaries and unbundling
tariffs for multi-use sites (e.g. shopping centres).

3. Improve flexibility in capital upgrades: creating competitive procurement
processes for key asset upgrades (e.g. transformers and other long-lead
network infrastructure) to expedite fast charger connections.

4. Ensure access to suitable tariffs for EV chargers: incorporating high variability
between peak/off-peak time of use rates and including demand charge waivers
to ensure equitable and affordable public charging for all EV drivers.

If done well, Australia can harness a ~AUD$3.2 billion investment opportunity to 2030, creating tens of thousands of new infrastructure jobs across planning, assessment, technical studies, technicians and construction for deployment and installation, as well as service for ongoing operation and maintenance. Conversely, failing to act will not only frustrate the ability for customers to charge their EVs conveniently and efficiently, and will slow the uptake of EVs and risk Australia’s climate commitments by prolonging the use of high emission vehicles.
Contents

Exec Summary .................................................................................................................................. 16

Context ................................................................................................................................................ 19

Opportunity........................................................................................................................................ 20

Issues & Proposed Solutions........................................................................................................ 24

The need for speed - updating service level agreements (SLAs) ................................... 26

Multiple Connection Points ....................................................................................................... 27

Network upgrades & Competitive Procurement ................................................................. 28

Affordability .................................................................................................................................. 29

Summary of Recommendations ................................................................................................... 31

Next Steps ......................................................................................................................................... 32

References ........................................................................................................................................ 33
Context
Vehicles are one of the largest contributors to greenhouse gas emissions (~16% of
Australia’s total emissions, second behind stationary energy) and remain a significant source of air pollution detrimental to public health.

Globally, EV sales have grown significantly – on average almost 50% year on year since 2016. Despite this global success Australia continues to lag, with EVs sales nearly fivefold lower than the global average.

Consumers still cite range anxiety and charging issues as key barriers to transition to an EV. A diverse, well-planned, and comprehensive network of public chargers will be critical in addressing these concerns.

Underpinning this ambition is the need for a streamlined connection process that recognises that EV charging infrastructure is unique in its application and scale – and will therefore necessitate a bespoke response from DNSP to ensure that as the EV fleet and charging infrastructure scales, the grid remains robust, secure and affordable.
Opportunity

Australia currently has over 3,000 public EV chargers, the majority (85%) AC, and
mostly concentrated across NSW, Victoria and Queensland. For context, these
chargers are distributed across Australia’s 7.7m sq km landmass and service the
40,000 EVs in Australia.

Figure 1: Australia’s existing public charging stations – by State and type
1200
1017 AC DC
1000

800 722

600 486

400 305 283
200 100 58 30
0
NSW VIC QLD WA SA TAS ACT NT

Source: Australian EV Charging Points Report 2022

Figure 2: Electric vehicle projections for Australia – National Electricity Market
25,000,000

20,000,000

15,000,000

10,000,000

5,000,000

-

Source: AEMO ISP 2022 Step Change Scenario (includes both BEV and PHEV)

EV adoption in Australia has a classic chicken and egg problem: consumers are citing
a lack of charging stations as a barrier to purchasing an EV, but the existing low uptake
of EVs combined with DNSP issues are making charging station operations difficult to
justify, streamline, and scale appropriately.
At current pace, public charger deployment will be severely insufficient to serve the millions of future EV drivers expected over the coming decade. To break the deadlock, enabling policies and updated processes from both Government and DNSPs will be vital.

Although the vast majority of EV charging is expected to occur at home, most
Australian motorists surveyed by the Australian Logistics Council (ALC) still indicate that “a lack of adequate charging infrastructure is the greatest barrier to purchasing an EV”. Indeed, an Energeia report previously estimated that up to 30% of EV drivers would still rely on public chargers for a considerable component of their EV charging needs. Accordingly, public chargers form an important part of the electric vehicle ecosystem for all EV owners, particularly for enabling wide-spread uptake of EVs for customers that live in apartment buildings or in other high-density dwellings.

If EV adoption follows AEMO’s EV forecast (see above), Australia would need at least
10x the current number of public chargers by 2026, and more than 25x our charging infrastructure by 2030.

Mckinsey estimates the cost of hardware, planning and installation for this scale of public charging infrastructure would be in the order of AUD$3.2 billion out to 2030. It would also create tens of thousands of new jobs across planning, assessment, technical studies (within DNSPs), technicians and construction for deployment and installation, as well as service for ongoing operation and maintenance (within charging operation companies).

Accordingly, Tesla suggest all of Australia’s DNSPs work with state and Federal
Governments and EV charging operators to target at least 75,000 public charging stations over the next decade, recognising their deployment will be critical in underpinning the uptake of EVs. Unlocking investment in charging infrastructure at workplaces, retail and destination locations, and along commuting and major travel corridors is imperative to increase mainstream consumer awareness for EVs and build consumer confidence in a convenient and reliable charging network.
Figure 3: Electric vehicle public charger projections for Australia

Source: Estimates based on AEMO ISP Step Change EV uptake

It follows that as the number of EVs on the road increases, annual demand for electricity consumed by EVs may surge from 100 GWh today to more than 1000GWh in
2030 (based on AEMO’s Integrated System Plan Step Change scenario). With this level of transport electrification, the proportion of EV consumption relative to total electricity demand increases from effectively 0% to around 4% by 2030, flowing through the nearly 2 million chargers. This highlights a significant opportunity for
DNSPs1 to capitalise on and will help compensate for the continued decline in energy revenues (kWh flowing) across networks given the rapid uptake of distributed solar and battery systems.

Some industry analysts still cite concerns that EV charging has the potential to be a significant new ‘peaky’ load – i.e. coincident charging from fleets of EVs increasing peak demand and placing further constraints on networks that are at or reaching thermal constraints. However, this is not what charging operators have observed in practice. For example, Tesla vehicle data (aggregated anonymously) demonstrates charging behaviour as a clear and consistent daily profile that correlates highly with solar output. This provides a complementary output for network operators.

1
Noting that DNSPs will likely be limited by ring-fencing arrangements and need to work with State Governments and private companies to facilitate the installation, maintenance and operation of public chargers
Figure 3: DCFC Daily Profile – Data from Sept 2021 to July 2022

Further, public charging is traditionally thought of as “highway fast charging” or
“Supercharging” but the focus from leading providers is to increasingly look at the opportunity to co-locate charging assets at supermarkets or shopping centres. This has the dual benefit of both increasing customer utility (customers can charge while they do their weekly shop) and incentivising charging to occur during solar generation hours, given the business opening hours of these sites align well with solar generation times. Furthermore, such public charging caters to an important market of EV drivers who cannot charge at home, often because they don’t own their own home or don’t have off-street parking; this addresses a critical equity barrier to EV adoption.

This highlights another significant opportunity that an EV fleet’s public charging load will provide to DNSPs – enabling new sources of flexible load to mitigate minimum operational demand issues (exacerbated by high solar PV penetration, particularly in
SA and WA) and compensate for lost network revenues from the rise of distributed energy resources (DER). In effect, it transforms an oft cited challenge of EV charging into an opportunity. As one DNSP in NSW recognises:
“Electric vehicles are expected to be an overall net benefit to the grid, allowing
for new and novel ways of using portable storage within the grid including grid
reliability services”
Depending on the particular region, network and local grid characteristics, congestion may still occur downstream of high-voltage transformers (i.e. at the suburb and street level), particularly if EV fleets are concentrated in particular high-consumption neighbourhoods. Upgrading grids to accommodate congestion free charging will always be costly – e.g. for a single public DCFC station with 4 x 150kW chargers site upgrades have been known to be in the order of $150,000.

However, these cost challenges are surmountable, and through a combination of
Government support, connection process improvements, and commercial innovations, charging operators can work with DNSPs to navigate these barriers and support continued deployment of chargers even in ‘deep’ network locations with high expected utilisation.

It will be essential for public charging stations to be widely accessible to all consumers providing a consistent and convenient charging experience, regardless of network location. This will require DNSPs to engage both internally and externally to resolve existing barriers currently creating costs and delays.

Building on the experience of EV charger roll-outs in Europe (where EVs account for one in five new car sales) and the United States (one in 20) this paper identifies several principles and recommendations for governments and utilities to incorporate in order to simplify and streamline Australia’s own charging infrastructure roll-out at the scale required.
The goal is to facilitate public and private investment in EV charging infrastructure, build Australian consumer confidence, and continue to build moment to enable the rapid growth in EVs.

Issues & Proposed Solutions

As noted above, DCFC charging technology is pivotal to relieve range anxiety and support uptake of EVs across all consumer types. In parallel, deploying charging infrastructure at scale can work to complement solar PV output to ensure networks are securely and efficiently utilised in the long-term interests of consumers.

However, deploying fast chargers in Australia is currently a slow, resource intensive and expensive process, far from the best practice seen globally. It can currently take over 18 months to design, construct and be ready operate typical fast charging sites, with many sites stalled indefinitely due to various process hurdles. This is clearly not scalable and will lead to a large disconnect between EV owners and pent-up demand for fast charging sites that are not yet available.
The issue is not simply a lack of funding for EVs or EV charging infrastructure.
Additional funding is necessary, but not sufficient. Fast charging installers and operators cite several additional reasons for the lack of pace and efficiency in charger deployment across Australian networks, including: a) Technical – grid studies are conservative, take time (DNSPs are resource
constrained), and often require high-voltage transformer upgrades (a long lead
asset with uncompetitive procurement practices).
b) Economic – public chargers require existing site owners/operators to agree to
network upgrade costs and estimate future usage costs, which inevitably impact
tenant tariffs and put at risk commercial terms agreed under existing ‘contracted
maximum demand’ (CMD) rates, complicating site negotiations.
c) Regulatory – Australian DNSPs are regulated monopolies with significant
infrastructure and asset maintenance pipelines under heavily scrutinised
regulated revenue allowances, and must follow strict regulator (AER and ERA)
guidelines when implementing any new processes, technical rules or project
funding disbursements.
d) Political – Australia’s sustainable electricity and transport policy has been delayed
by a decade of inaction at the federal level, creating a policy vacuum and leaving it
to states with limited legislative powers and budgets to initiate small-scale roll-
outs on an ad-hoc basis.
e) Cultural – as outlined above, some DNSPs may view EVs as a problem to solve for
(rather than an opportunity); charging data clearly shows that EV demand is
responsive to financial nudges, and is more coincident with solar generation than
many analysys expected.
Many of the ‘early wins’ for process improvement sit with the DNSPs, given they are best placed to understand any limitations at the local network level, can determine technical requirements for chargers to interface and connect with the grid, can support ancillary infrastructure assets such as battery systems or transformers, and ultimate can work with regulators and government to create bespoke regulation, service, and technical standards for the EV charger connection process.

Three priority actions that we recommend be resolved immediately are expanded upon below.
The need for speed - updating service level agreements (SLAs)
The first priority area of process improvement is to address the lengthy timelines to deploy DCFC infrastructure. As shown in the figure (based on a typical install), current processes led by DNSPs are overly complex, unwieldy, and fragmented relative to best practice. At present it can take a year or longer for fast chargers to be connected to the grid – more than 4 times as long as anywhere else in the region.

Figure 5: Illustrative Process Flow – current vs best practice

Note: day count timelines based on business days

To transition from today’s 18+ month process to a best practice target of under 4 month total install time is an ambitious, but achievable goal. Indeed, many other countries already showcase the possibility of streamlining EV charging processes.

Each step of the process can be reviewed, improved, and expedited. A simple first step will be updating the standard service level agreements (SLAs) that DNSPs use for EV charging infrastructure – currently based on the small volume of large new customer connections received (and which in some cases allow for up to 65 business day confirmation turnarounds following initial inquiry). Clearly, to achieve the scale of charger deployments and expected volume of connections projected for coming decades, a faster, more tailored model will be required for fast chargers. DNSPs will also need to be appropriately resourced and upskill connection teams to manage the increased number of requests in-house, avoiding the need for design sub-contracting
(an unnecessarily costly and lengthy step in many Australian DNSP processes) and re-allocate FTEs and budget to teams to recognise the inevitable transition to EVs and associated charging stations.

We recommend:
1. Create a standardised, transparent grid approval processes for public chargers
across all DNSPs – with a stretch goal of 3 months from initial inquiry to fully
operational.

2. Reduce all response timeframes in SLAs for charger connection requests to under
[10 business days], with penalties for delays.

3. Expand DNSP resourcing within connection assessment teams, and leverage
digital collaboration tools for approvals where possible (e.g. desktop
assessments).

Multiple Connection Points
A second barrier to the effective install and connection of DCFC at many locations is that for the most suitable public charging sites (e.g. at prominent retail and commercial locations), there is a single connection point, often managed by an embedded network operator. For these ‘single’ sites many DNSPs do not allow (or make it very difficult – e.g. requiring land sub-division and new title holds) to create second connection points. In practice, this means for many potential public charger sites:
• The embedded network operator is typically subject to standard commercial
network tariffs – subsequently passed through to all customers (e.g. shop
tenants) sitting behind the single connection point.
• Fast chargers are (by definition) high powered (100 - 350kW+) which leads to
significant increased electricity network charges being incurred, acting as a
direct deterrent for any potential host of the fast-charging infrastructure.
• Many potential landlords have already negotiated minimum components for
their ‘contracted maximum demand’ (CMD) rates and are understandably
reluctant to re-open CMD thresholds when this would increase cost pass-
throughs for tenants (typically estimated at up to $100,000AUD p.a. for 6
charging post sites). These costs would be in addition to kWh usage rates (with
peak/off-peak and REC components) flowing through a single connection and
requiring sub-metering to apportion fair costs between charging stations and
other users.
• This is now commonly leading to advocacy by major tenants against the
proposal to install fast chargers. As one potential customer noted: "Our
primary concern is how the potential risk to the capacity charges that we could
incur in 2023 could impact the average cost of power and in turn the profit we
generate through the embedded network".
• Additionally, where upgrades of existing assets are required, this will
necessitate a site-wide shut-down for day(s) to safely upgrade connection
assets, creating another barrier for potential landlords due to the expected
loss of trade for tenants.
We understand a key driver for some DNSPs to maintain single connection points is related to fire safety requirements – creating a simple, single circuit breaker switch point to ensure electricity supply can be interrupted if required. However, the application of this requirement is inconsistent across DNSPs and does not recognise the ability to create single ‘parent’ interruption points across multiple ‘child’ connection points – as used by utilities installing chargers overseas. This means fire safety services can continue to trip a main breaker in the event of an emergency and have all lines of supply to a site trip off as needed.
For many Australian proposals, this is at best adding cost, complexity, and time for fast chargers to be installed and at worst stalling their progress completely. As an alternative, we recommend:

4. All DNSPs allow the use of second connection points (i.e. 2 NMIs per site) where
isn’t compromised to clearly segregate EV charging infrastructure from existing
electricity users. This could be done either virtually or physically, and ensure
metering and connection design to maintain a single breaker for safe supply
interruption requirements.

5. Utilise dedicated connection points to create bespoke network charges for DCFC
operators and do not re-open existing CMD or agreed network charges for
embedded network operators managing multiple tenants sharing a single site.

Network upgrades & Competitive Procurement
A third key hurdle to overcome before EV fast charging infrastructure can reach scale is managing network upgrade requirements and processes. In particular, the procurement of transformers to support HV connection upgrades currently sits with individual DNSPs and follows a slow, uncompetitive process based on a sole supplier model. This is a clear ‘critical path risk’ and often leads to an unnecessary bottle neck that is highly susceptible to supply chain interruptions, equipment issues, or company delays more generally.

Whilst fast charger providers may be given the option to procure transformers on behalf of a DNSP (to fast-track their application), this fails to overcome the exclusive arrangements DNSPs have with the same single transformer supplier. Therefore,
irrespective of the appetite of connection applicants or DNSPs to expedite connection, timelines are still dictated by the single transformer supplier’s equipment stock and workload.

This arrangement is far from best practice, and can be easily improved:

6. Diversify all key asset suppliers to create multiple provider panels to ensure
competitive (and flexible) procurement outcomes

Whilst we understand the original intention may have been to support local content, procurement should still be governed by a ‘best endeavours’ approach that can ensure a total connection timeframe is achieved within 4 months and upholds the principles of lowest cost (i.e. expanding to the wider market on a competitive basis, if required).
Tightly coupled with the need for transformer upgrades is the potential impact on other key network infrastructure, whether at the connection point itself (e.g. the LV distribution boards) or upstream at the local grid level. As the concentration and load requirements of EV chargers grows (from both public and private chargers), utilities are best placed to assess these network impacts and guide operators to locations that would be most suitable for installing fast chargers (e.g. where there is spare transformer capacity). This should include exploring non-network solutions that may be preferable (i.e. lower cost, faster to deploy, greater value stack of services) to upgrading traditional network assets such as poles and wires – e.g. adding battery storage capacity or co-located solar to offset charging load where possible and encouraging and incentivising the purchase of renewable energy (or credits) where possible.

7. DNSPs to work creatively and collaboratively with charging operators to explore
the flexibility and controllability of chargers as ‘dynamic loads’ and potential
benefits from co-locating other non-network assets (e.g. battery systems and
solar) to offset/defer total network upgrade requirements

Affordability
DNSPs have a significant control over the price consumers pay for electricity at EV- charging stations through their assignment of network usage rates and maximum demand charges. Total network costs can be as much as 70-80% of the total bill cost
(including retail energy costs, metering, AEMO and environmental fees). Therefore charging operators have limited flexibility in what commercial models they can offer to EV drivers, particularly those who must rely on public charging stations (e.g. those without off-street parking) relative to those who have the ability to charge at home.
Estimates have EV drivers who use public chargers paying between five and ten times
more per kWh than those who can charge from residential chargers, making affordability for a sub-group of potential EV customers a key concern.

Whilst some DNSPs are beginning to adapt existing large user tariffs or even create bespoke ‘EV tariffs’, more work is needed to ensure fair and transparent costs for actual usage and embed appropriate incentives to control/shift load. For example, related to the multiple connection point issue outlined above, existing trials of dedicated EV tariffs still do too little to address the single connection point issue outlined above, whereby fast chargers often must fit within existing CMD arrangements customers have previously negotiated (with contracts highly sensitive to peak and total power usage across the year).

Tariff design should be a collaborative process, leveraging the knowledge and expertise of EV OEMs, charging operators, policy makers etc. as to what tariff structure drives maximum benefit for both customers and network operators.
Regulators can also support with nationally consistent tariff principles, standards and operator protocols to minimise complexity and maximise uptake of EV vehicles and associated charging infrastructure. Overall, an EV rate should be simple, straightforward, and easy to understand. It also needs to provide a better financial outcome than alternative tariffs. Affordability recommendations for public chargers includes:

8. Governments have a role to help DNSPs prioritise efforts to make public charging
cost more equitable – e.g. providing funds to help defray demand charges or
directly subsidise the installation and operation of public chargers in less
profitable locations.

9. DNSPs to work with regulators to broaden EV tariff trials to include shared
connection sites, with structures targeting time-of-use rates that have a high peak
to off-peak price ratio and comprise very low / demand charge waivers while EV
uptake is still gaining momentum (recognising EV charging customers are a low
load factor).
Summary of Recommendations
Ultimately this paper seeks to progress the simplification and streamlining of the connection process, and to explore how to create more equitable cost structures for public chargers.

This will require both bottom-up operational change from DNSPs, as well as top-down leadership and guidance from governments and regulators.

1. Create a standardised, transparent grid approval processes for public chargers
across all DNSPs – with a goal of 3 months from initial inquiry to fully operational

2. Reduce all response timeframes in SLAs for charger connection requests to under
[10 business days], with penalties for delays

3. Expand DNSP resourcing within connection assessment teams, and leverage
digital collaboration tools for approvals where possible (e.g. desktop
assessments)

4. All DNSPs allow the use of second connection points (i.e. 2 NMIs per site) where
suitable to clearly segregate EV charging infrastructure from existing electricity
users. This could be done either virtually or physically and ensure metering and
connection design to maintain a single breaker for safe supply interruption
requirements.

5. Utilise dedicated connection points to create bespoke network charges for DCFC
operators and do not re-open existing CMD or agreed network charges for
embedded network operators managing multiple tenants sharing a single site.

6. Diversify all key asset suppliers to create multiple provider panels to ensure
competitive (and flexible) procurement outcomes

7. DNSPs to work creatively and collaboratively with charging operators to explore
the flexibility and controllability of chargers as ‘dynamic loads’ and potential
benefits from co-locating other non-network assets (e.g. battery systems and
solar) to offset/defer total network upgrade requirements.

8. Governments have a role to help DNSPs prioritise efforts to make public charging
cost more equitable – e.g. providing funds to help defray demand charges or
directly subsidise the installation and operation of public chargers in less
profitable locations.
9. DNSPs to work with regulators to broaden EV tariff trials to include shared
connection sites, with structures targeting time-of-use rates that have a high peak
to off-peak price ratio and comprise very low / demand charge waivers while EV
uptake is still gaining momentum (recognising EV charging customers are a low
load factor).

Beyond the targeted recommendations for public chargers outlined above, we also recommend:

10. An overarching Federal Government EV Charging Roadmap (supported by DNSPs, AER
and ERA) – including: a. Incentives, grants, tax credits or rebates to accelerate public charging roll-out b. Principles for a streamlined connection timelines and regulatory guidelines for best-
practice to ensure consistency, compliance and alignment across all states and utilities c. Guidance and incentives for DNSPs to identify central travel corridor sites (prioritising
those with appropriate network capacity) d. Annual public charger deployment targets based on projected EV fleet growth

Next Steps

As an immediate next step and to support the above recommendations from progressing quickly, we endorse Recommendation 5 of the Senate Select Committee on EVs:

“that the Australian Government coordinate with operators in the charging
infrastructure industry to develop a comprehensive plan for the rollout of a
national public charging network.”
This will provide more detail across the range of issues identified in this paper, explore additional barriers raised by others, and test the workability of proposed solutions.

To ensure national consistency and full transparency, we recommend this progress as a stakeholder focus group that also includes DNSPs, regulators (AER and ERA), relevant vehicle manufacturers, charging network operators, and state government policy-makers, targeting a kick-off in Q1 2023.
References
1. https://www.nescaum.org/documents/2018-zev-action-plan.pdf
2. https://www.savvy.com.au/media-releases/australian-electric-vehicle-charging-points-report-
do-we-have-enough-2022/
3. Essential Energy – Electric Vehicle Fact Sheet:
https://engage.essentialenergy.com.au/69276/widgets/339410/documents/206075
4. Select Committee on Electric Vehicles -
https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Electric_Vehicles/Electric
Vehicles/~/media/Committees/electricvehicles_ctte/report.pdf
5. Public Charging Data – aggregated and supplied from anonymous charging operator, July 2022
6. https://www.pwc.com/us/en/industrial-products/publications/assets/pwc-electric-vehicles-
charging-infrastructure-mindset.pdf
7. KEPCO Electricity Rates Table -
https://home.kepco.co.kr/kepco/EN/F/htmlView/ENFBHP00102.do?menuCd=EN060201