Nexa Advisory welcomes the opportunity to respond to the AEMC’s consultation on the proposed rule change submitted by the Commonwealth Government Department of Climate Change, Energy, the Environment and Water (DCCEEW) to enable its Accelerating Electric Vehicle Charging (AEVC) Program (ERC0436).
Nexa supports rapid, efficient and consumer-focused rollout of electric vehicle charging infrastructure (EVCI). This is particularly important for households without access to off-street parking, regional communities, fleet users, visitors and drivers undertaking longer journeys.
However, it is Nexa Advisory’s strong view that the proposed rule change would not support this outcome. The rule change as proposed will enable regulated monopoly Distribution Network Service Providers (DNSPs) to play a central role in identifying sites, undertaking connection works and, in some cases, installing and maintaining electric vehicle (EV) charging infrastructure, with residual costs recovered from electricity consumers through the Regulatory Asset Base (RAB). This would risk embedding DNSPs in a contestable downstream market, socialising transport infrastructure costs through electricity bills, distorting competition and weakening ring-fencing protections.
DCCEEW has identified genuine barriers to EVCI deployment, including connection delays, limited network data transparency, facility access arrangements and uncertainty about site feasibility. These are legitimate issues. However, they do establish the case for requiring DNSP ownership, DNSP-led site selection or RAB-funded recovery of public charging assets.
Summary of key asks
- The AEMC should not make the rule change in its current form.
- AEMC must request and make public the information from DCCEEW regarding all the evidence it relied upon to justify the need for the rule change (behavioural study, modelling of net benefits and related assumptions, evidence of market failure, etc.).
- If the AEMC proceeds to make a rule to facilitate the Commonwealth program, it must demonstrate clearly and provide evidence as to how this rule change is consistent with the NEO and not facilitating political aspirations. In doing so, the AEMC should consider any indirect costs of the rule, including distortions to competitive neutrality in the related contestable markets and resulting inefficiencies.
- The scope of the rule change should also be narrowed and conditioned so that it:
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- enables DNSPs to perform clearly defined network-enabling functions;
- preserves CPO-led site selection, ownership, operation and maintenance wherever possible;
- limits any public or regulated funding to demonstrated market gaps;
- excludes contestable charger assets and charger-related opex from default RAB recovery;
- requires transparent utilisation, uptime, cost and subsidy reporting;
- includes strict market testing, ring-fencing, restrictions on affiliate dealings, data access and cross-subsidy protections; and
- prevents a time-limited program from creating an enduring DNSP role in EV charging.
Read our full submission here: Nexa Advisory – Submission – AEMC Facilitating EVCI rollout under Commonwealth grants