RESPONSE TO: Ministry of Transport’s Charging Our Future: Discussion Document

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PART A: INTRODUCTION

About us

Drive Electric is a not-for-profit advocacy organisation supporting the uptake and mainstreaming of e-mobility in New Zealand as part of the effort to decarbonise transport.

Drive Electric represents a member base comprising new car OEMs and retailers, used car importers and distributors, infrastructure organisations (electricity generators, distributors and retailers, electric vehicle service equipment suppliers), e-bike/scooters, heavy vehicle importers, finance, fleet leasing and insurance companies, along with electric vehicle users. We have more than 70 members from the sector.

The case for an EV Charging Strategy

New Zealand is on the cusp of the biggest transformation in transport in over a century. Over the coming decade, driven by technological advancements and requirements to decarbonise, the transport system will shift away from being powered by fossil fuels.

It is rapidly becoming clear that electric vehicles will replace petrol and diesel ICE vehicles in most use cases (1). International jurisdictions are setting dates for the end of new fossil fuel vehicles. Automakers are committing to dates by which they will only produce electric vehicles. The Climate Change Commission’s analysis shows that by 2030 67% of cars entering the New Zealand market are EV.

The scale of this transition cannot be underestimated. New Zealand currently has 4 million passenger cars in its fleet, the vast majority of which are fuelled by petrol and diesel. Within two decades, Drive Electric anticipates that the majority of these cars will be electric. The government itself has set a target to have 30% of the light fleet electric by 2035.

By definition this issue is not just a transport issue, it’s also an energy issue. The transition to electric vehicles depends on the availability of renewable electricity and the infrastructure to enable users to charge their vehicles.

This transition will not occur without careful planning and cooperation between government, local government, and the private sector.

The government must play a role in enabling the private sector to deliver private and public charging, by ensuring regulatory settings are fit-for-purpose and market failures are addressed. Local governments must ensure that national rules around public and private charging are implemented. The private sector must invest in and deliver public and private charging.

First and foremost this strategy provides the foundation for which government, local government, and private sectors collaborate to deliver a charging ecosystem in New Zealand. This collaboration should first and foremost occur ‘upstream’, by identifying where there are barriers to roll-out and resolving these. However, there are immediate steps that need to be taken now, particularly in public charging.

A commitment to investment

The strategy is silent on the government’s intention to invest in the delivery of this strategy. The strategy also does not express a view on the role of the government to co-fund public charging to accelerate the roll-out where there is a case to do so. There is a case for continued government intervention in the short to medium term. (We explore this in 9.2.1 below).

If we pursue the mandate of smart charging in private homes, there needs to be consideration given to government support for this, particularly for lower income households and retrofitting apartment buildings. There are also innovative ideas that could be explored if businesses wish to install chargers in their employee’s home – e.g. forms of tax incentives.

Skills and training

The strategy is also silent on the need for skills and training to support the roll-out of private and public charging in New Zealand. Analysis should be undertaken on whether we have the right people available in New Zealand to support the electrification of transport. (E.g. installing chargers in residential homes at scale.)

Shifting to implementation

We note that the strategy identifies the various issues that need addressing (subject to finalisation through this confirmation). However, most of these actions require significant policy work, investment, and collaboration with the local government and private sector. There needs to be a rapid shift to implementation. We cover the institutional models necessary to do this in 1.1.1 below.

Acknowledging a rapidly changing context for the electricity sector

As we have already stated, a National EV Charging Strategy depends on the ability of the electricity system to produce, transmit, and distribute enough renewable energy.

Demand for electricity has been relatively stable over the past several decades. From here to 2050, it is expected that demand for electricity could double. This demand will come from a range of drivers associated with decarbonisation and other technologies, including industrial process heat conversions, population growth, data centres, and electric vehicle uptake.

A critical component of achieving the vision of the charging strategy is ensuring the regulatory context for new renewable generation capacity, transmission, distribution, and managing demand, enables decarbonisation.

A case for urgent intervention: public charging

In New Zealand, currently 82% of charging is done at home.2 There are issues that need to be addressed around at-home charging including the adoption of smart charging, retrofitting apartment buildings, safety rules etc. To support user confidence, reduce range anxiety, and drive the uptake of EVs there is an immediate and pressing need to ensure our public charging system is built out.

Public charging gives users the confidence to adopt EV technology, and alongside the sticker price of EVs, is probably the greatest enabler of uptake. This is in part psychological and in part a necessity. Necessity stems from the need for users to charge their vehicles on long-distance travel and when away from home. Additionally, there are many users who cannot charge at home and will need to depend on public facilities. The Climate Change Commission’s 2023 Draft Advice to inform the strategic direction of the Government’s second emissions reduction plan (draft advice) says around 15% of households lack a dedicated car park, and these people will need public facilities.3

Compared to other countries, New Zealand is desperately behind in the rollout of this infrastructure. The graph below from the IEA sets out the Charging points per EV and kW per electric Light Duty Vehicle (LDV) in selected countries, 2021.4

Table: Charging points per EV and kW per electric Light Duty Vehicle (LDV) in selected countries, 2021

This shortage in public charging infrastructure has been confirmed in the Climate Change Commission’s draft advice. It has specifically recommended (recommendation 17) that the government must rapidly resolve the barriers to scaling up vehicle charging infrastructure. We note this must be done well before the second emissions budget period, or we risk hampering the uptake of electric vehicles.

Public charging businesses, including Jolt, ChargeNet, Z, BP, Tesla, and Meridian, have private capital to invest in public charging in New Zealand. All of these businesses have significant pipelines that are constrained.

Charging providers say that the consequences of the current situation may be significant, and could include:

1. Inability to meet consumer demand for charging;
2. Regional disparities / postcode lottery;
3. Dampening consumer demand in EVs; and
4. Difficulty in securing a steady stream and sufficient depth of private investment.

To overcome these risks there needs to be a number of short-term and long-term actions undertaken.

Headline Recommendations

Summarising our submission, our headline recommendations are:

1. Over the next ten years, the entire shape of New Zealand’s transport system will change and accordingly the demand for renewable energy. The scale of this transformation needs to be understood. Further analysis is required to understand this future demand and the scale of response required (in terms of infrastructure, energy, skills, planning etc).
2. Accordingly, the Government should move quickly to ensure that this strategy is made a core priority in transport/energy and is resourced to deliver. Any changes to institutional arrangements should not come at the expense of delivery.
3. A partnership mechanism should be established promptly to implement this strategy in conjunction with the private sector.
4. Greater public investment needs to be allocated to the delivery of this strategy particularly to deliver on access and equity considerations.
5. There are a range of barriers to investment in public charging that need to be systematically addressed to enable private sector investment to meet future demand.
6. Clear guidance and support needs to be given to ensure households and workplaces can install and use smart charging.
7. Local Councils need to be engaged and mandated to deliver on this strategy.

 

Part B: Formal response

1.Implementation arrangements

1.1 Do you have any comments about the institutional arrangements for implementation set out in Annex 2, or on the way central government should work with the private sector when implementing the final version?

1.1.1 Government institutional arrangements

The government has a fundamental role to play in e-mobility and EV infrastructure delivery:

• Setting direction through policy and strategy
• Enabling consistency across regions (including in partnership with local councils and and EDBs)
• Clearing regulatory barriers / setting the conditions for the market to deliver
• Co-investing in infrastructure as it becomes economic (or where it is uneconomic)
• Resolving market failures
• Managing equity considerations
• Supporting skills and training

Currently, responsibility for EV Charging (and e-mobility generally) sits across a number of government agencies (MBIE, MOT, EECA, Waka Kotahi, Work Safe, Commerce Commission, and the Electricity Authority). Policy, regulatory regimes, investment, and consumer information fall across these different agencies.

The status quo creates a number of challenges, including:

• No single point of responsibility in government / many parts of government involved in policy and delivery. (This may make it difficult for agencies to focus on the EV transition amidst competing demands and coordination between agencies is time consuming.)
• No single mechanism through which government and industry can easily partner on delivery.
• No ‘one stop shop’ to communicate with consumers on this transition. (Also no ‘one stop shop’ to deal with any emerging standards and compliance issues.)

In principle, we support the concept of the government streamlining its approach, and bringing together e-mobility policy, regulation, funding, and implementation functions into one part of government. This will have the effect of giving e-mobility prominence within government and ensuring rapid progress can be made.

We note however that establishing a new institutional model, as set out in Annex 2, within government is time-consuming and resource intensive. We do not want to wait to grapple with pressing issues relating to charging infrastructure, while this work is done. As such, we would recommend that an interim function is established, and if it is deemed necessary a more formal institution could be set up over time.

In the longer term, if a more formal entity is established, it could take a number of forms including a dedicated Office of Zero Emissions Vehicles5 or a function within a specialised ministry, such as a new Ministry of Energy. We are relatively agnostic on the form this takes, it is more that it enables the following:

• Priority: Provide a dedicated area of government the mandate and resources to deliver the EV targets under ERP, reflecting the size and scale of this transition.
• Process: Streamline the government’s leadership and approach to the transition.
• Engagement: Make it easy for businesses and citizens to engage with the government regarding the transition.
• Coordination: Central point of coordination with all players: e.g. local government, other parts of central government, and energy/EDB sector. ● Standards and compliance: Ensure the infrastructure meets user expectations, setting and administering safety standards.
• Communication: Take New Zealanders on the journey with the information they need.

1.1.2 Delivering with the private sector

It is essential that the government partners with the private sector on the implementation of this National EV Charging Strategy. As we cover in our introduction, government, local authorities, and the private sector have specific roles to play. We strongly support the adoption of a mechanism that is established to implement the strategy.

Again, we do not want to wait while this mechanism is established, before we make progress under this strategy. As such a more flexible mechanism should be established, to collaborate on strategy delivery, in the short term that enables quick progress on core issues.

In the longer term, the mechanism should support the roll-out of private and public EV charging infrastructure and services (including the interaction between electricity and charging infrastructure) by:

• Systematically identifying issues and barriers where there would be benefit from public and private sector participants working together to overcome these, such as potential misalignment between the regulation applying to electricity networks and charging infrastructure;
• Effectively communicating those issues and barriers, both across government agencies and externally;
• Determining a work program that works through the issues and barriers in a logical way and which is complimentary or feeds into the interagency working group work on a National EV Charging Strategy;
• Undertaking the work program, including:
  • identification and analysis of options to address identified issues and barriers
  • agreement on specific solutions, either through consultation on solutions proposed by the interagency working group or through consensus or agreement
• As the EV Charging Strategy begins to be implemented, monitoring progress by continuing to identify and potentially resolve ongoing issues and barriers; and
• Where appropriate, actively supporting infrastructure roll-out (e.g., through funding or partnership).

There are many forms this mechanism could take. It could be an informal arrangement or a legal entity. It could share information, provide advice, or be tasked with decision-making.

We have developed some criteria for assessing a private sector implementation mechanism, which is included in Appendix A.

1.1.3 One model

The table below summarises our thinking.

2. Drivers of the strategy

2.1 If there are drivers missing, what are they and what impact do you think they would have on the content of the final strategy?

We support the drivers listed, but there are also others:

• New Zealand is a technology taker, so we must position ourselves to transition the fleet to electric as that is currently the global direction. (If we do not prepare for this change effectively, we could become a dumping ground for the old RHD ICE vehicles.)
• EVs are increasingly cheaper to run and maintain than petrol and diesel vehicles. Eventually they will reach price parity for purchase (with ICE equivalents). Household economics will drive their widespread adoption. The Ministry for the Environment forecasts that in 2030 electrification of vehicles will have a negative marginal abatement cost, saving costs for consumers and the economy while reducing emissions.
• There are significant barriers (particularly in terms of unhelpful or lacking regulation) that exist in the roll-out of public and private charging infrastructure and there must be a government-led mechanism to identify and address these systematically and effectively.
• That New Zealand’s future energy strategy and future approaches to e-mobility charging can’t be distinguished and must be considered holistically.
• There will be large scale private sector investment in charging, but there are reasons for government co-investment to accelerate progress and overcome market failures and support equity of access. There must be a framework for identifying and scoping this investment.

3. Status quo

3.1 Do you agree with this description of the status quo? Is anything missing from this description of the status quo?

We agree with the description of the status quo in terms of the range of charging types. There are a couple of things missing from the status quo, which include:

• An analysis of future demand for charging in its various forms (private and public) and the resultant need for investment and installation. (I.e. what is the scale and size of the opportunity.) For example, a rough estimate by one chargepoint provider suggests $400m will need to be invested in New Zealand’s public EV charging network over the next 3-5 years.
• An analysis of future demand for additional renewable electricity generation and investment in transmission and distribution by e-mobility charging. With accelerating rates of electrification, modelling from Transpower in 2020 anticipated electricity demand will increase by 20% by 2030 and 68% by 2050.6
• Relatedly, there needs to be analysis of the barriers to investment in public and private charging. For example, public charging companies report that their investment pipelines are significantly constrained by various barriers identified in the strategy and our response (e.g. Council alignment, network connections). However, there are some legitimate reasons for these barriers that need systematic resolution.

4. Vision

4.1 Do you think this draft vision serves as a useful guide for the EV Charging Strategy? If not, what is missing from the vision?

We generally support the vision. There are a couple of additional considerations:

• The vision is built around ‘charging infrastructure’, however successfully transitioning to e-mobility will require more than charging infrastructure. In particular it will require we have the electricity generated, transmitted, and distributed to that charging infrastructure (private and public). In other words, the vision should be built around the EV charging ecosystem, rather than the charging infrastructure itself.
• Is ‘low emissions transport’ the correct framing for the vision, given the charging infrastructure will really support ‘zero tailpipe emissions’ transport?

5. Outcomes

5.1 Do you agree with the proposed outcomes? If not, please explain why.

We support these outcomes.

5.2 Should the final strategy focus on more or different outcomes? If so, please identify what these outcomes should be.

We believe these outcomes (at the headline level) are sufficient.

5.3 Do you consider any of these outcomes more important than the others? If so, which one(s) and why?

All of these outcomes are required to achieve the transition to e-mobility in New Zealand.

Currently, our immediate priority would be around Outcome 4. The public charging network is essential to supporting EV uptake as it provides confidence in the system for users. There are barriers to private investment which are delaying the roll-out of public charging, with respect to connections to networks.

6. Outcome 1

6.1 Do you agree with the focus area under outcome 1? If not, please explain why.

We agree with Focus area 1a. Minimising stress on the electricity network.

Smart charging will help make the most of New Zealand’s existing electricity infrastructure and avoid unnecessary capital investment, by helping manage peak demand. It is critical that measures are taken to support widespread adoption of ‘smart chargers’ in parallel with the adoption of Electric Vehicles (EVs). EV smart charging could save the New Zealand economy close to $3 billion by 2035.7

We have provided a full submission on this matter to EECA’s Green Paper: Improving the performance of electric vehicle chargers. To summarise our views:

• Drive Electric supports the definition and regulation of ‘smart chargers’, but this needs to be done carefully.8
• The intent of this regulation should be to enable the creation of a demand response market in the interests of end users, in support of decarbonisation, and making cost effective investments in infrastructure.
• Drive Electric supports the exploration of a well designed government subsidy to overcome barriers to uptake of ‘smart chargers’, justified by the collective benefit of smart charging to the electricity system (including economy-wide savings) and decarbonisation.

6.2 Which further actions under Focus area 1a would you prioritise? Please explain your answer.

We believe however that Focus area 1 needs to explicitly connect to New Zealand’s future energy strategy, in particular how demand will be managed and integrated with a growing portfolio of renewable (and potentially intermittent) energy sources with efficient levels of investment.

Careful consideration needs to be given to the concept of ‘load control tariffs’ as they apply to public charging services. There are a range of views, including:

• Designing effective and sustainable protocols which serve the public and network stability should be co-designed between operators and network companies. Simple pricing structures or top-down load controls may not create the desired outcomes.
• Tariffs should be left to CPOs. Competition amongst providers will reveal what is in the best interests of consumers. It may be a price signal that a consumer responds to actively or it may be a lower price with some control ceded to the retailer i.e. a passive role for the consumer.

6.3 Please provide any comments on the timing of completing these actions.

It is essential that the following actions are focused on 2023 as they will help unlock investment in public EV charging:

• Publish detailed electricity network capacity data so public and private infrastructure planners can see where constraints are to encourage efficient investment. (But this needs to be achieved at a level of granularity that is of use for connection seekers.)
• Work with EDBs to identify opportunities, mitigate risks, and clarify responsibilities in developing EV charging infrastructure.

7. Outcome 2

7.1 Do you agree with the focus areas under outcome 2? If not, please explain why.

We support focus areas 2a and 2b.

7.2 Which further actions under Focus areas 2a and 2b would you prioritise? Please explain your answer.

Focus area 2a. Improving the equity of, and access to, safe residential/ home charging

In addition to those actions listed, there needs to be an exploration of mandating the provision of EV charging in new residential and commercial buildings. There
also needs to be consideration given on how to easily enable the retrofitting of EV charging infrastructure in existing multi unit dwellings.

Focus areas 2b. Accommodating for geographic variation in charging needs and energy supply

We agree with the actions listed. We strongly support the need to engage local councils to provide consistent, practical planning and approval processes. In our experience to date, the majority of Councils are not engaged in enabling the rapid rollout of public charging at the pace and scale required.

In addition to those actions listed, other important actions include:

• Central government making Crown-owned land available to be long-term leased for charging stations with fast-tracked consenting processes.
• Local councils making locally owned car parks and other amenities available for public charging provision.
• Local councils provide on-street EV charging in suburbs where there is limited off street parking.

7.3 Please provide any comments on the timing of completing these actions.

Engaging Councils in the delivery of this strategy needs to be a priority.

7.4 Are there any actions needed to reflect the particular EV charging needs of disabled communities, Māori, or other groups? Please explain your answer.

We recommend consulting specific groups on their requirements.
We do however note that public EV charging stations need to be safe, accessible, and secure for all users.

7.5 Please provide any comments relating to targets for EV charging infrastructure.

More important than targets is that public charging providers are enabled to provide charging points (in a range of types) to users to meet current and forecast demand.

In most cases it will be public charging companies, rather than the government that will deliver on these targets (i.e. install and run the chargers). Therefore the government’s focus needs to be on enabling these businesses to do so first and foremost.

Targets can be useful as one measure of progress and to identify where there may be market failures or gaps in the network. But they should not, in themselves, determine where private investment should go. (This should be demand-led.)

In addition to targets, we recommend that a full New Zealand market assessment could be undertaken to understand the energy and infrastructure requirements for charging over the next 10-15 years, and where demand is likely to occur. This would be useful for government policy development and industry planning. Targets need to be built out of this sort of analysis, rather than constructed arbitrarily. Also these targets need to get ahead of demand, rather than try to meet it in the short-term (as we know EV adoption is only going to grow).

In response to the proposed targets:

7.5.1 Having a journey charging hub every 150 – 200 kms on main highways by 2028.

We understand the intent of this target, but we wonder whether the locations and types of charging hubs are best left to the private sector to advance based on real and forecast demand. However, there may be a role for the public sector to co-invest, as these hubs may not be commercially viable for some time, depending on location etc.

7.5.2 In urban areas with limited off-street parking (generally in central Auckland and central Wellington) we could aim to have one public charger for every 20 – 40 EVs.

As of December 2022, New Zealand is at 1:62. A target like this may have some uses, but it needs further consideration:

• What type of chargers are being proposed in this target, AC or DC? There needs to be consistency as to what is being measured.9 Potentially energy available per EV might be a better metric, as also used by the IEA.
• In the EU, guidance has been 1 public charger for every 10 EVs.10 There are many countries with more aggressive ratios than this, including China, Korea, and the Netherlands. However, all these countries are quite different. On what basis should this be calculated for New Zealand?
• The target needs to be built out of forecast demand (and ahead of demand), which will be geographically dependent.

7.5.3 That all settlements with a population of 2000 or more should have public charging at municipal or community facilities by 2025.

This target needs further consideration:

• Smaller locations, particularly tourist locations where populations swell at peak times, should be included in this target.
• The target is silent on the number of charge points at these facilities. There needs to be some thought around the depth of requirement.
• Some smaller population locations may have constrained capacity, which won’t be cost effective to upgrade. These sorts of areas are likely to require public support to ensure they are viable in the short-medium term.

8. Outcome 3

8.1 Do you agree with the focus areas under outcome 3? If not, please explain why.
Yes.

8.2 Which further actions under Focus areas 3a, 3b, and 3c would you prioritise? Please explain your answer.
8.2.1 Focus area 3a. Improving standardisation and interoperability

Standardisation and interoperability in payment systems is essential for user experience over the longer term. We recommend working with public charging companies to identify solutions that can be deployed.

In addition to the actions listed, we note there should be consideration given to ensuring charge points are available and online (i.e. specific performance standards). For example, in some jurisdictions there are fines issued for charge points that are not operational for specified periods of time. In others, public funding is tied to ensuring that charge points are operational.

8.2.2 Focus area 3b. Optimising data capture and use

We support exploring this with public charging companies.

8.2.3 Focus area 3c. Consideration of housing and urban development planning, where appropriate

We support the action areas.

Drive Electric recommends that the Building Code be updated to require every new home with a dedicated parking space to install a Smart EV charger with a universal socket for all makes of electric vehicles. 

It is significantly more cost effective to install charge points in new builds. Drive Electric analysis suggests that an EV charger installed in a new home will add an approximate cost of $2,000. However, if an EV charger is retrofitted this cost more than doubles. By mandating the installation of chargers in new builds, this will potentially save hundreds of millions of dollars by 2050. 

Existing residential buildings undergoing “major renovation” should also be required to make the parking spaces EV-ready, with cabling routes installed to support charge points at each parking space. 

New non-residential buildings and older such buildings undergoing major renovations should be required to install at least one EV charger and the cabling routes to support charge points at one in five parking spaces. Large existing non-residential buildings with more than 10 parking spaces should be required to install at least one EV charger.

To ensure the Code is sufficiently future-proofed, all EV chargers should have a minimum output power of 7 kW and must be “Smart” devices, using an open communications standard enabling demand response capability.

Installation and safety
The Worksafe Charging Safety Guidelines (2019) need rapid revision to balance safety and need for pragmatic installation. For example, the guidelines state AC chargers need to be installed in a garage at home, but that charger can be installed at an office premise outside. Regulation and oversight of this must be fit-for-purpose.

8.3 Please provide any comments on the timing of completing these actions.

Interoperability and standards availability should be a priority as this affects user experience and confidence in the system. Our starting point is that this should be left to the market to resolve in the first instance.

9. Outcome 4

9.1 Do you agree with the focus areas under outcome 4? If not, please explain why.

We strongly agree with focus areas under 4.

9.2 Which further actions under Focus areas 4a and 4b would you prioritise? Please explain your answer.

9.2.1 Focus Area 4a. Accelerating commercial investment

As per our introductory remarks, demand for electricity is increasing as a result of the focus on decarbonisation, including in transport. These changes include:

1. EV charging has changed – the number of providers has grown rapidly and demand for charging is increasing with EV adoption.
2. Speed is of the essence – new chargers require capacity and load from the network.
3. Can EV chargers be uniquely managed as a class of customers: What are some of the opportunities in creating unique pricing and connection solutions for EV chargers to enable a smooth transition to a decarbonised e-transport fleet?

There are a range of initiatives that need to be pursued under Focus Area 4a, including public funding; regulatory review and change; and voluntary action.

Funding
The case remains for government investment in the roll-out of public charging. This is to address barriers to investment or market failures, particularly to ensure equity of access (e.g. in small or rural locations, tourist towns with fluctuating demand). (The government should not intervene where the private providers are willing and able to make commercially viable investments.)

This investment will need to go beyond what the existing Low Emissions Transport Fund (LETF) is designed to do, both in terms of mandate and scale. Public funding support should be tied to demonstrated market gaps and long-term pathways to sustainable business models. The market can solve for the location and charging offer. In other words, public funding agencies should not be prescriptive about location and type of chargers. It is likely that relatively small government contributions can be used to unlock much larger private sector investments. In other words, it is unlikely 50/50 co-funding will be necessary.

Additionally, there may need to be public investment in the short term to build additional network capacity to ensure EV adoption and enable decarbonisation across other residential and commercial energy users. This is particularly the case if other mechanisms will not address barriers relating to network connections within the next 12 months.

In addition, the government could explore low cost capital loan funds for carbon transformation which have a low administrative burden to access, with a slightly broader mandate. In particular, the role of the Green Investment Fund could be further considered, given so far it has invested in only one EV charging related project.

 

Regulatory options

New Zealand’s network businesses (EDBs) are regulated by the Commerce Commission and Electricity Authority. Their mandate has been to pursue efficient markets. Until recently, this model has served New Zealand well. Given the increased demand for renewable electricity to replace fossil fuels to decarbonise New Zealand, a new question has emerged. This question is, ‘who pays for decarbonisation’ and what is the most efficient way to make those investments.

Currently, the costs of connecting to networks can be prohibitive to private sector investment in public charging or may curtail the scale of investment undertaken, resulting in fewer chargers/charge sites. There are valid reasons for this, given the regulatory context for network businesses and the ways they must attribute costs. However, unless there is some change it’s difficult to see public charging being deployed at the pace and scale that is required.

We have identified options, under the existing regulatory system, that could be considered to facilitate connections for public charging infrastructure. These include:

1. Asking the Electricity Authority to consider whether public charging infrastructure should have:
   1. a dedicated access regime, similar to distributed generation
   2. Capital contribution policies that improve predictability (and consistency), e.g. through standard connection charges or other options
   3. Dedicated tariff category that rewards load management and addresses subsidy at a consumer group level (not individual sites).
2. Asking the Electricity Authority and the Commerce Commission to consider:
   1. Working with distributors on broadening the eligibility of who can do connection work (including design and construction) or what
      equipment can be used, subject to important safety criteria.
   2. Asking distributors to make network location information readily available to access seekers, for example through open GIS.
   3. asking distributors to make network capacity information available proactively, to further assist access seekers to select suitable locations.

 

We appreciate that analysis of these options with officials, regulators and industry needs to be undertaken – which we are keen to support.

However, there’s also a possibility that the current regulatory system for network businesses may not be fit for purpose to enable decarbonisation through electrification through the economy. It’s possible that the electricity sector regulators may need to be given a fundamental mandate to support decarbonisation.

We strongly recommend that officials move with haste to identify options. In the short term, it’s likely that public sector investment will be required to facilitate private sector investment into areas where it is not economic to invest.

Voluntary action

As part of voluntary industry agreement, there is an opportunity to make the process around applying for and installing new connections for public charging more streamlined and consistent.

9.2.2 Focus Area 4b. Enabling innovation in new technology and business models
We understand the value in this, but the priority at the moment needs to be the rapid deployment of public charging throughout New Zealand.

9.3 Please provide any comments on the timing of completing these actions.

Progressing outcome 4a is urgent to maintain progress with EV adoption in New Zealand.

10.Outcome 5

10.1 Do you agree with the focus areas under outcome 5? If not, please explain why.
We agree.

10.2 Which further actions under Focus area 5a or 5b would you prioritise? Please explain your answer.
Nothing further at this stage.

10.3 Please provide any comments on the timing of completing these actions.

We acknowledge that demand for charging is growing most rapidly for light vehicles, but that commercial vehicles and buses are not far behind. In addition, electrifying heavy freight, aviation and marine provide considerable opportunities for decarbonisation at scale. As such, this work needs to be continued at pace.

[ENDS]

 

Appendix A: Criteria for assessing an implementation mechanism with the private sector

As well as outcomes, it is also important to set out criteria or characteristics that could be used to compare and assess potential options.

Some initial criteria are:

• Appropriate resourcing | Does the mechanism include independent and commercially minded decision makers or advisors who are focused on outcomes and have the capability to help deliver them?
• Effective private sector input | Does the mechanism ensure the private sector input is given appropriate weight when developing the EV Charging Infrastructure Plan?
• Simplicity and timeliness | How simple or otherwise is the mechanism to establish and operate? How much time would be needed to develop and establish the option?
• Effective stakeholder engagement | How would the mechanism ensure all relevant viewpoints are considered – noting different stakeholders may have different abilities or need to engage at different times?
• Effective operations| Can the mechanism produce effective and timely outputs (e.g., advice or recommendations)?
• Robust analysis | How important is it that the mechanism produces decisions that are based on robust evidence and analysis?
• Flexibility | Should the mechanism be able to operate flexibly, for example by responding quickly to new issues and priorities?
• Accountability | How are accountability requirements addressed? (Representatives involved in day to day-work may have accountability obligations to their employer or a stakeholder organisation.)
• Cost effective | What would the costs of the mechanism be, would these be proportionate to the benefits?
• Management of conflicts of interest | Are conflicts of interest a concern and, if so, how would they be managed?
• Completion Law | Are there risks of breaching relevant competition law and, if so, how would they be managed?

References: 

1. We acknowledge that other technologies may emerge, such as hydrogen. However, at this moment in time, battery electric vehicles are the dominant low carbon technology for private vehicles. We also acknowledge that active and public transport will also play a significant part in the future of mobility.

2. https://www.climatecommission.govt.nz/our-work/advice-to-government-topic/advice-for-preparation-of-emissions-reduction-plans/2023-draft-advice-to-inform-the-strategic-direction-of-the-govern ments-second-emissions-reduction-plan-april-2023/full-report/

3. https://www.climatecommission.govt.nz/our-work/advice-to-government-topic/advice-for-preparation-of-emissions-reduction-plans/2023-draft-advice-to-inform-the-strategic-direction-of-the-govern ments-second-emissions-reduction-plan-april-2023/full-report/

4. https://www.iea.org/data-and-statistics/charts/charging-points-per-ev-and-kw-per-electric-ldv-in-sel ected-countries-2021

5. The office’s functions could include:

   ● Policy and regulation

   ● National strategy and implementation

   ● Monitoring the performance of key programmes

   ● Coordinating with local government and industry

   ● Investment (i.e. consumer incentives, EECA funds)

   ● Standards and compliance

   ● Comms, education, and engagement

6. https://web-assets.bcg.com/b3/79/19665b7f40c8ba52d5b372cf7e6c/the-future-is-electric-full-repo rt-october-2022.pdf

7. https://web-assets.bcg.com/b3/79/19665b7f40c8ba52d5b372cf7e6c/the-future-is-electric-full-report-october 2022.pdf

8. We believe functionalities for inclusion in a standard are:

   1. Capability to connect with an aggregator or service provider, for dynamic and remote management;

   2. Default off peak charging mode – particularly for the earlier stages of EV uptake;

   3. Open communications protocols; and

   4. Safety and other settings.

9. https://www.iea.org/reports/global-ev-outlook-2022/trends-in-charging-infrastructure

10. ttps://www.iea.org/reports/global-ev-outlook-2022/trends-in-charging-infrastructure

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