Objectives and options
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Objectives for assessing proposals
The objectives sought in supporting the uptake of smart EV charging are:
- EV owners and electricity networks have tools to manage peak electricity demand – technology supports shifting demand in response to price and network signals.
- Electricity consumers benefit from managed EV demand – EV owners benefit from time of use (ToU) pricing, network infrastructure is optimised, and system benefits flow through to all end consumers in reduced costs.
- Consumer experience and ease of charging is maintained or enhanced – there is no reduction in consumer experience or the ability to charge effectively.
We invite your feedback on these objectives.
Questions for consultation
9. Do you agree with the objectives? If you agree or disagree, please explain why.
10. Are there any additional objectives you think we should also adopt to inform decisions on this proposal?
Please provide evidence or data where possible to inform our analysis
Four options are proposed
Four options are proposed below that have been informed by prior consultation.
In mid-August 2022, EECA published a green paper seeking input on ways to improve the energy performance of EV chargers.[1] The majority of submitters endorsed the need to encourage the uptake of smart chargers, and submitters noted the importance of leveraging international case studies and keeping in step with evolving markets.[2]
There was general support for introducing smart EV charger requirements. The vast majority of submitters did not support the ‘do nothing’ option for New Zealand and felt that some form of intervention is needed to safeguard our electricity system and realise the full benefits of a functioning demand response/demand flexibility market.
A number of submitters supported the provision of subsidies or rebates to support the installation of smart chargers, noting that the upfront cost will continue to be the largest barrier to uptake of fixed charging units. Submitters also noted that this would only be a short-term solution. Others were not supportive due to equity grounds. For instance, some submitters felt the introduction of subsidies in the near term could solely benefit current EV owners and that this demographic tends to feature high-income households. Subsidies are not proposed as an option for this reason, and because of the current fiscally constrained environment.
These four options could apply to all chargers (public and private), or a subset of chargers – further information and questions on scope are covered after the options.
Option 1 – status quo
Option 1 is the status quo which is that there are no legal restrictions on the supply of EV chargers.
Existing non regulatory government-led activities include the promotion of PAS for Residential EV Charging and Commercial EV charging, EECA’s list of 56 approved smart and efficient chargers, and other guidance to consumers and businesses to support the voluntary uptake and use of smart chargers.
As noted above, simple time of use pricing is becoming increasingly common and is used by existing EV owners. There is some pricing innovation and work underway to improve this (such as through the Energy Competition Task Force), providing greater market incentives for consumers to use smart products, such as EV chargers.
Electricity distribution businesses may be able to require certain standards (such as complying with EECA’s PAS and associated smart requirements) for EV chargers connected to their network under the status quo. However, we understand there may be enforcement issues with this approach and therefore low compliance.
We understand that existing work to promote smart EV charging is already increasing the uptake of smart chargers, but the continued supply of non-smart chargers could mean New Zealand misses the opportunity to reduce electricity infrastructure costs.
Option 2 – Support voluntary labelling
An additional non-regulatory option we are considering is voluntary product labelling.
EV charger suppliers could be given the option of a standardised label that includes information about efficiency (similar to those seen on whiteware products) and key information about any smart functionality.
This could be a checklist indicating whether the charger does or does not perform the function (see table below for potential functions). This kind of label would enable consumers to more easily compare chargers based on efficiency and functionality.
Market research indicates that price, quality and brand are a key consideration in product purchase decisions. Energy efficiency is a second-order issue but can be a deciding factor when consumers are considering products that are otherwise similar. Labelling that indicates smart functionality could be more influential as it speaks to the ability of the product to benefit the consumer.
Option 3 – Mandatory labelling
Option 3 is to introduce mandatory labelling for all (or a subset of) EV chargers.
EECA currently administers mandatory labelling for other energy using appliances, such as Energy Rating Labels on whiteware and electronics (known as Mandatory Energy Performance Labelling). It also requires labelling on vehicles with information on emissions and energy economy, allowing consumers to make informed decisions on their purchases.
Labelling could be required to be supplied on the EV charger, as well as displayed instore, online, or in advertisements.
Option 4 – Require that all EV chargers supplied in New Zealand are smart and efficient
Option 4 is to introduce a regulatory requirement that all (or a subset of) EV chargers supplied for sale must be smart and efficient. Regulations and rules would set out the scope of EV chargers covered and requirements those chargers would have to meet.
In practice this would mean that only smart and efficient EV charging units would be available for supply in New Zealand from the date the new regulation applied. It would not, however, require consumers to install a smart charging unit – the option of 3-pin trickle charging would still be available.
The requirements would include a range of functionalities needed to ensure a charger is smart.
Option 4A – Option 4 requirements combined with mandatory labelling
Option 4A is option 4 with the addition of mandatory labelling for all (or a subset of) EV chargers. Mandatory labelling would enable consumers to easily compare chargers at the point of purchase, including both efficiency and smart functionality information as mentioned above. As with Option 3, labelling could be required to be supplied on the EV charger, as well as displayed instore, online, or in advertisements.
Option 4A is the preferred option at this stage as we believe it best supports achievement of the stated objectives.
The table below outlines the possible functionality outcomes/requirements that could be introduced under Option 4 or 4A.
Possible functionality outcomes/requirements for a ‘smart’ EV charger
| Functionality outcome | Purposes / outcome |
|---|---|
| Interoperability The communication protocol used by the charger must be interoperable with other communication systems (e.g., with the vehicle, network owners, demand aggregator, home energy management or battery system). |
Reduces duplication / increases efficiency for electricity system participants in managing EV charging by ensuring different devices and systems can speak to each other. |
| Connectivity / EV charger response Charger must be capable of responding to a third-party signal to modify (start, stop, increase, decrease) consumption or export over time. |
Enables a flexible electricity system. |
| Consumer override While smart chargers can be controlled by a third-party under delegation from the user, EV charger owners must retain ultimate controllability over their charger. They must be able to manually override any managed charging. |
Enables EV owners to charge their EV at times that suit them or when required, even if it is more expensive for them or the grid. |
| Measurement and visibility The charger must be able to measure the quantity of electricity consumed/injected in real time and make this available for the consumer or chosen assignee. |
Consumers know the amount and time of charging to make informed decisions about time shifting. Network owners or third-party providers can assess the impact of EV charging in order to offer plans/services to consumers to time shift. |
| Continued charging The charger must continue charging even if it is disconnected from the communications network. |
Vehicles will still charge in the event the charger loses communication (e.g., where it is safe, and the internet is down) and consumer is not aware. |
| Energy efficiency Minimum energy efficiency requirements for chargers being sold. |
Chargers use energy efficiently which results in overall lower energy demand. |
| Cybersecurity and privacy functionality Minimum communication cybersecurity and privacy requirements based on accepted standards. Note that there is currently no clear regulation-making power for this. |
Prevent systems going down/user experience failure due to cyber-attacks. Users are able to easily control what data they share and provide to third parties. |
| Functionality to support V2X | Smart V2X chargers may have some additional requirements to support demand flexibility from a system perspective. |
| Labelling Label EV chargers with key standardised information about the product (e.g., functionalities) so that consumers can easily compare at the point of purchase. |
Helps consumers factor functionality and potential energy savings into their buying decision. Encourages manufacturers to compete by making more efficient and more flexible products. |
Assessment of scope against objectives
An assessment of the scope against the objectives is set out below.
The “+” indicates a positive impact, the “-“ indicates a negative impact, and “0” indicates a no impact.
| Objective | EV owners and electricity networks have tools to manage peak electricity demand | Electricity consumers benefit from managed EV demand | Consumer experience and ease of charging is maintained or enhanced |
| Option 1: Status quo | - Slow uptake of smart chargers imposes greater stress on distribution and transmission networks as higher kW standard chargers add demand |
- Lower adoption of smart EV chargers means more charging on peak, contributing to higher infrastructure costs, passed through to consumers |
0 Ease of charging but programmable for set times only limits opportunity to benefit from dynamic pricing |
| Option 2: Voluntary labelling | + Possibly higher penetration of smart chargers than status quo results in some network load benefits – less effective than mandatory labelling |
+ Consumers wanting to utilise smart charging are more likely to benefit, but less overall deferred infrastructure cost for all consumers |
+ Consumers are better informed when purchasing chargers, but those purchasing non-smart chargers will not benefit from additional functionality |
| Option 3 – Mandatory labelling | ++ Likely higher penetration of smart chargers than status quo results in some network load benefits – less effective than requiring EV chargers to be smart |
++ Customers wanting to utilise smart charging have better information and can benefit. Likely supports lower infrastructure cost, but less than a smart charger requirement |
++ Customers have complete information when purchasing charger. Those who purchase non-smart chargers will not benefit from additional functionality |
| Option 4: Require EV chargers supplied for sale in New Zealand are smart | +++ Distributed flexibility technology enables more efficient distribution of load across network avoiding higher network costs |
++ Higher adoption of smart EV charging enabling off peak charging, reducing demand and lowering total infrastructure costs |
+++ Smart requirements are designed to improve customer experience and better enable consumers to obtain lower operational costs without impacting use of their EV (in a set and forget way) |
| Option 4A: Require EV chargers supplied for sale in New Zealand to be smart and have labelling | +++ As above and mandatory labelling encourages even more efficient use of electricity |
++ As above |
+++ As above, and mandatory labelling encourages purchase of more efficient and chargers with greater functionality consumers can make use of. |
Questions for consultation
11. Which option do you prefer and why? Are there other options you think should be considered?
12. Do you agree with our assessment of the options against the objectives? If you agree or disagree, please explain why.
13. What are your views on the functionality outcomes that could be adopted?
a. Are there any outcomes that you think should be required?
b. Do you think any functionality outcomes above should not be included, and if not why?
c. Are there any different types of requirements we need to consider for V2X chargers?
14. Do you think there is a case for voluntary or mandatory labelling of EV chargers, and why or why not?
a. If you support labelling, what content do you think should be incorporated in the label?
Please provide evidence or data where possible to inform our analysis
We are also seeking feedback on the proposed scope for options
The options proposed in this paper could potentially apply to all (private and public) EV chargers. For example, voluntary or mandatory labelling could apply to only private chargers or private and public chargers. Because of this, we are also seeking feedback on the proposed scope of all four options.
We expect the most opportunity and potential benefit from private charging as it is expected to remain the primary location for most EV charging. However, there may be additional benefits from regulating or requiring labelling for (larger) public chargers:
- Better peak load management – smart public chargers could enable the load to be flexible assets for the wider power system, helping to reduce overall grid costs.
- Open communication protocols – use across public chargers can lessen the risk of stranded assets by ensuring a new provider can take over management (even if proprietary software has been used) in the event that the original charging company collapses.
- Manage network constraints – using smart chargers on a group of public chargers enables the power draw to be software-limited to reduce the need for grid upgrades (limits can be removed or adjusted in the future if the physical grid capacity increases).
- Simplicity – some chargers are used for both private and public charging, so it may be simpler to regulate all EV chargers.
- Another option is to define the scope based on the physical or design characteristics of the charger e.g., type (AC, or DC) or size (7.4kW, 22kW, 50kW) as this has some correlation with use (private chargers tend to be AC and smaller).
Assessment of scope against objectives
An assessment of the scope against the objectives is set out below.
The “+” indicates a positive impact, the “-“ indicates a negative impact, and “O” indicates a no impact.
| Objective | EV owners and electricity networks have tools to manage peak electricity demand | Electricity consumers benefit from managed EV demand | Consumer experience and ease of charging is maintained or enhanced |
| Scope: EV chargers for private use only | ++ 80% of EV charging is done at home and shifting evening home charging is likely to have the greatest impact on managing peak demand |
+ EV owners will benefit from time of use pricing through shifting home usage and all consumers benefit from lower infrastructure costs |
++ Smart requirements for home chargers improve customer experience, and public charging behaviour is less likely to be impacted by managed charging |
| Scope: EV chargers for private and public use | ++ All chargers, including public, are able to be managed flexibly enabling more efficient distribution of load across networks |
+ EV owners will benefit from time of use pricing through shifting home usage and all consumers benefit from lower infrastructure costs |
+ Smart requirements for home chargers improve customer experience, and public charging behaviour could be impacted by managed charging |
Questions for consultation
15. What types of chargers should your preferred option be applied to? For instance, if you think different types of chargers (for example public vs private, or chargers smaller or larger than 2.4kW) should be subject to different parts of your preferred option, please explain.
16. Do you agree with our assessment of the scope against the objectives? If you agree or disagree, please explain why.
17. If you agree with option four – requiring EV chargers to be smart:
a. What types of chargers should the requirements apply to? For example, should there be a minimum or maximum size?
b. Is there a case to regulate public chargers as well as private, and what are the risks of including or excluding public chargers?
Please provide evidence or data where possible to inform our analysis
Footnotes
[1] Improving the performance of electric vehicle chargers [PDF 315 KB](external link) – Energy Efficiency & Conservation Authority
[2] Summary of submissions: Improving the performance of electric vehicle chargers [PDF 315 KB](external link) – Energy Efficiency & Conservation Authority