As a group of interested stakeholders, we welcome the opportunity to provide feedback on the Department of Climate Change, Energy, the Environment and Water’s (DCCEEW) consultation on the Accelerating Electric Vehicle Charging Program.
We support the Australian Government’s objective of accelerating the rollout of electric vehicle charging infrastructure. We also recognise the objectives set out in DCCEEW’s National EV Strategy, namely to:
- increase the supply of affordable and accessible EVs;
- establish the resources, systems and infrastructure needed to enable rapid EV uptake; and
- encourage increased demand for EVs.
However, we recommend that DCCEEW make targeted amendments to the current program design to ensure it delivers on these objectives and intended outcomes without imposing unnecessary costs on taxpayers and electricity consumers, or distorting the competitive charging market. In particular, the program should avoid embedding an inappropriate role for Distribution Network Service Providers in selecting, owning or controlling contestable EV charging assets.
The program can be very successful if it is redesigned around five principles:
- Customer-led demand identification – infrastructure should be located where consumers, communities, and drivers actually need it.
- CPO-led site selection with government coordination – Charge Point Operators (CPOs), working with DCCEEW and relevant governments, should lead site selection, with councils providing local planning, parking, accessibility and safety input where required.
- CPO-led delivery – CPOs should lead the ownership, operation, maintenance and customer service functions for EV charging infrastructure wherever possible.
- User-pays and targeted public funding – EV charging is a transport service delivered in a competitive market. Costs should be recovered from users and private investment wherever possible, with public funding used only to bridge clearly demonstrated viability gaps.
- DNSP-enabled connections – DNSPs should support the rollout through network capacity data, pole suitability information, make-ready works, connection assessments, and streamlined approvals. They should not select sites or own chargers by default.
The current proposal gives DNSPs central a role in the EV charging infrastructure rollout. This gives us material concerns:
- It is proposed that DNSPs are the eligible grant recipients and would play a role in identifying sites, undertaking connection and installation works and, in some cases, owning charging infrastructure. The Commonwealth would contribute 30 per cent of approved program costs, with remaining 70 per cent recovered through the Regulatory Asset Base (RAB) – this would be a cost to ALL electric consumers, EV users or not.
Public EV charging infrastructure is a transport technology and a contestable service. The network connection and any efficient make-ready works may involve legitimate DNSP functions, but the public charger itself is not a natural-monopoly network asset. As such, public charger costs should not be recovered through the RAB by default.
- Regional blackspot funding also requires careful design. Any regional funding should be targeted to genuine journey-enablement gaps and assessed against strict value-for-money, utilisation, safety, amenity and CPO market testing criteria.
Summary of key recommendations
Recommendation 1: Add a customer-led demand portal stream
DCCEEW should establish a national web portal through which consumers, businesses, councils and fleets can request public EV charging infrastructure, providing a clear demand and locational signal. Validated requests should be used to inform site prioritisation and competitive CPO tenders.
Recommendation 2: Make site selection CPO-led with government coordination
Kerbside sites should be chosen by CPOs, working with DCCEEW and relevant governments. Councils should also be consulted and provide input on parking, accessibility, safety and local planning matters where required.
DNSP network feasibility should be an input into site selection, not the primary determinant of where chargers are located.
Recommendation 3: Require CPO validation and market testing
No site should be deemed non-commercial unless CPO market testing has first been undertaken. CPOs should be given the opportunity to identify, bid for, own and operate sites before any DNSP ownership or last-resort delivery model is considered.
Recommendation 4: Limit DNSPs to an enabling role
DNSPs should support deployment by providing network capacity data, pole suitability information, connection cost estimates, streamlined approvals, make-ready works where efficient, and technical standards.
DNSPs should not select sites, own chargers by default, or control customer-facing services.
Recommendation 5: Replace default RAB recovery with user-pays and targeted grants
The proposed 30 per cent Commonwealth grant/70 per cent RAB recovery model should not be the default funding mechanism for contestable public charging assets.
DCCEEW should instead use user-pays charging tariffs, CPO co-investment, targeted public grants, transparent viability-gap funding, and where justified, limited funding for DNSP’s to provide genuine connection-enabling works.
Recommendation 6: Apply strict tests to regional blackspot funding
Regional funding should be limited to genuine journey-enablement gaps, not locations selected primarily because they are convenient for DNSP assets.
Eligibility should be assessed against utilisation, access, safety, amenity, relevant government and local input, CPO market testing and value for money.
Recommendation 7: Strengthen competition and ring-fencing protections
DCCEEW should ensure DNSPs and related parties do not receive preferential access to data, connections, funding, sites or market opportunities.
Program rules should include robust protections against cross-subsidy, discriminatory access, preferential connection treatment, shared branding, shared systems, and the use of monopoly-funded information to support contestable activities.
Recommendation 8: Require transparency and performance reporting
All publicly supported chargers should be subject to reporting and performance obligations, including uptime, utilisation, pricing, maintenance performance, customer complaints, accessibility, data sharing and subsidy per charging session or per kWh delivered.
Recommendation 9: Remove existing EV charging roadblocks
DCCEEW should make connection and approval reform a core part of the program. This should address three barriers to CPO-led deployment: inefficient or unpredictable network tariffs, limited network data transparency, and slow or inconsistent connection processes. Reforms should include fit-for-purpose public charging tariffs, earlier access to network capacity and constraint information, indicative connection cost data, standardised connection timeframes, controlled application and assessment fees, streamlined connection pathways, and public reporting on DNSP connection performance.
Read full statement here: Joint submission – DCCEEW – Accelerating EV Charging Program