CRU (formerly CER) review of charging infrastructure

ELM327

This "decision" by the cru (I use the word "decision" loosely) is really forcing me to re-evaluate my continued use of EV. I'm at a stage where I need to fast charge twice per week, meaning that a working and fairly priced fast charge network is essential.

I think this is going to hit the values and interest in new and second hand EV pretty hard.

The upshot, and I'm struggling to take a positive from a negative here, is that it will accelerate my move towards a model S. I'm unsure what to do with the leaf I have now I'll probably end up listing it for sale early next year and use the funds as a deposit on a model S.

Any Tesla owners, ZoeZE40 owners and (perhaps the new egolf too) any other long range EV owners will not be so affected, but for the likes of us gen1 owners, this announcement is an awful decision.

Orebro

ELM327 wrote: »

Any Tesla owners, ZoeZE40 owners and (perhaps the new egolf too) any other long range EV owners will not be so affected, but for the likes of us gen1 owners, this announcement is an awful decision.

I hear ya. Although as usual it depends on usage. I got mine to do the 24km round trip commute and the other odd local errands like dropping the kids to friends houses etc so I can carry on regardless of the charging infrastructure as I don’t need it.

That being said, it has put the brakes on us going a full EV household that’s for sure. Gonna keep the other ICE car on the road for the moment until this all gets a bit clearer. Certainly won’t be making the jump until we can get a 40kwh Ioniq or the like so we can continue to steer clear of the charging infrastructure as much as possible.

ELM327

Orebro wrote: »

I hear ya. Although as usual it depends on usage. I got mine to do the 24km round trip commute and the other odd local errands like dropping the kids to friends houses etc so I can carry on regardless of the charging infrastructure as I don’t need it.

That being said, it has put the brakes on us going a full EV household that’s for sure. Gonna keep the other ICE car on the road for the moment until this all gets a bit clearer. Certainly won’t be making the jump until we can get a 40kwh Ioniq or the like so we can continue to steer clear of the charging infrastructure as much as possible.

Yes, we made that decision a few weeks ago aswell. I've an old ICE that does 600 miles per tank and we use it for backup/super long trips but I can see it being the main car, other than commuting, soon. I have work charging so I can charge at home and at work and keep my 110km odd commute all EV, but the rest of my driving at the weekends requires fast charging.

And I don't think I will pay €10-15 (as it would be on Ecotricity equivalent prices) when the ICE could do it for similar money and without the inconvenience of relying on one FCP single point of failure which may be broken/in use/iced. Not to mention the 30-35 minute wait to charge.

n97 mini

ELM327 wrote: »

You can't have competition in the Transmission/Distribution networks.
It doesnt work like that. Similarly the likes of Eirgrid cannot be commercial.

The only fully commercial org currently within the ESB family is Electric Ireland (In Ireland). The likes of ESBI etc are somewhat separate as they don't really operate in Ireland.

I agree with the rest of your post.

Ownership of the distribution network should stay in state control. Who maintains it is irrelevant as long as they're doing a good job. Let's not forget the network was supposed to be transferred to Eirgrid but the ESB unions blocked the transfer.

Orebro

n97 mini wrote: »

Ownership of the distribution network should stay in state control. Who maintains it is irrelevant as long as they're doing a good job. Let's not forget the network was supposed to be transferred to Eirgrid but the ESB unions blocked the transfer.

Yup same mistake as throwing Eircom to the wolves just as broadband was about to become the next big vital service.

n97 mini

Orebro wrote: »

Yup same mistake as throwing Eircom to the wolves just as broadband was about to become the next big vital service.

Yeah. I'll never understand that one. Anyone with half a brain could see there was a right and a wrong way to do it and the Govt picked the wrong way. And then shortly afterwards eircom sold the crown jewels to Vodafone. If you ever needed proof school teachers shouldn't be allowed run a country...

KCross

Interesting to see Nissan Irelands input to the consultation. I think their opinion had sway with CRU (rightly so, I suppose).

https://www.cru.ie/wp-content/uploads/2017/10/CRU17283-18-Nissan-Ireland-Response.pdf

- They went with option 4
- They asked for a Service Level agreement to be put in place. CRU added that.
- Asked for no barriers to be put in place to new entrants. I think the 3rd party access stipulation in the CRU decision matches this request from Nissan.


One thing they also suggested was conditions around tariffs until EV uptake goes beyond a certain level (suggesting 20k EV's). That bit remains to be seen.

Dont be at yourself

KCross wrote: »

Interesting to see Nissan Irelands input to the consultation. I think their opinion had sway with CRU (rightly so, I suppose).

https://www.cru.ie/wp-content/uploads/2017/10/CRU17283-18-Nissan-Ireland-Response.pdf

- They went with option 4
- They asked for a Service Level agreement to be put in place. CRU added that.
- Asked for no barriers to be put in place to new entrants. I think the 3rd party access stipulation in the CRU decision matches this request from Nissan.


One thing they also suggested was conditions around tariffs until EV uptake goes beyond a certain level (suggesting 20k EV's). That bit remains to be seen.

That is interesting! Do they want to bundle in Supeecharger-style free charginga via the network with new purchases, perhaps?

KCross

Some interesting points from eCars on their input:
https://www.cru.ie/wp-content/uploads/2017/10/CRU17283-12-ESB-eCars-Response.pdf

Originally, it had been the intention of ESB to commence operation of the EV assets on a commercial basis upon conclusion of the EV pilot. This strategy had been predicated on EV numbers increasing in the region of 20,000/25,000, which is the required critical mass to facilitate commercialisation in Ireland.

They didn't elaborate on how 20k EV's would make it commercially viable but it at least shows they know its not viable for the next few years anyway.


There's some hope they will provide a sane charging regime to begin with....

Therefore, in setting any fees for use of the publicly accessible infrastructure, we would consult with EV drivers, car manufacturers and other relevant stakeholders, as it is in ESB’s interests to design an attractive range of packages that would meet the needs of, and provide cost-effective driving to, all segments of EV drivers with a view to contributing to, rather than limiting, sales of EVs.

Live in hope!

KCross

This one from SSE Airtricity is also interesting

https://www.cru.ie/wp-content/uploads/2017/10/CRU17283-20-SSE-Response.pdf

1) They went with option 1, i.e do not give it free to eCars.
2) They detailed a mechanism where the charge points would have no logos on them but would be owned/operated by ESBn and then the electricity providers (i.e. Airtricity etc) would sell the electricity. So, the providers sound like they would be up for that.

3) They took exception to the idea that ESB should get the €6m overspend back! I have to say, I agree.

... A step back guarantee of funds is not available, driving developers to ensure projects are delivered in accordance with the contractual budget and timelines. An assumed recovery from customers would not set a good precedent given the scope of investments being undertaken by ESBN and their responsibility to deliver key infrastructure. It is essential that clear regulatory signals are given to incentivise managing projects successfully within the budgets provided.

4) They suggest that any sale of the assets should be on an open competitive process and believe there would be interested parties for same... maybe they are hinting they would take it over?

Whatever option CER choose, the outright transfer of the network to ESB Group to be operated on a commercial basis (option 4) is not considered appropriate use of customer funded assets. Customer funded assets should not be used to drive a commercial benefit for any company. However, if the CER were to consider option 4 in the paper, SSE believes it should be an open process whereby any potential owner could submit a proposal for cost free transfer of the network to their business. It is unclear why this process would be limited to ESB Group.
If the ESB group wish to acquire the EV network to operate on a commercial basis, SSEs view is that they should have to pay for it in an open competitive process. There is no reason this should be limited to ESB only. Should the network be offered for sale at the cost to ESB Group (€6.1m) SSE believes there would be a number of interested parties.

Bord Gais also made a submission and made the same "demand" that it should be an open competitive sale process.

BoatMad

Orebro wrote: »

Bloody hell. I for one am delighted that I can operate without using the public infrastructure 99% of the time. What a mess.

Edit: did the CER take on board anything the IEVOA had to say?

Remember we argued simply that it should be regulated whist it remains a monopoly. We also argued it should be in the rab.

But the CER has flagged since July and to anyone that asked that they were only interested in washing their hands of it.

n97 mini

Have to say, while I'n not (currently) an SSE customer, I agree with their position.

Did the IEVOA ever speak to any provider other than ESB @BoatMad?

BoatMad

n97 mini wrote: »

Have to say, while I'n not (currently) an SSE customer, I agree with their position.

Did the IEVOA ever speak to any provider other than ESB @BoatMad?

Yes but not recently.

We argued extensively with the CER that existing retail electricity suppliers should have access. But this requires the equipment is in the RAB. in fact in the early days of the ESBN abs the network that's how they envisigsed it working.

The CER completely set its face against this.

BoatMad

KCross wrote: »

Interesting to see Nissan Irelands input to the consultation. I think their opinion had sway with CRU (rightly so, I suppose).

https://www.cru.ie/wp-content/uploads/2017/10/CRU17283-18-Nissan-Ireland-Response.pdf

- They went with option 4
- They asked for a Service Level agreement to be put in place. CRU added that.
- Asked for no barriers to be put in place to new entrants. I think the 3rd party access stipulation in the CRU decision matches this request from Nissan.


One thing they also suggested was conditions around tariffs until EV uptake goes beyond a certain level (suggesting 20k EV's). That bit remains to be seen.

There was never any issue about barriers to new entrants. That would be contrary to Eu law. The effective barrier to entrants is the existence of a monopoly that ( a) has a large numbers of chargers and (b) is effectively owned by the DSO

ELM327

BoatMad wrote: »

Yes but not recently.

We argued extensively with the CER that existing retail electricity suppliers should have access. But this requires the equipment is in the RAB. in fact in the early days of the ESBN abs the network that's how they envisigsed it working.

The CER completely set its face against this.

Is the IEVOA presenting a written response to the CRU decision?

BoatMad

ELM327 wrote: »

Is the IEVOA presenting a written response to the CRU decision?

We are issuing a series of press releases.

But we're not responding directly to the CRU , dont see any point of that

We are meeting ecars soon

I mean it's not like any of us are suprised by the CER decision

Dardania

Maybe there’s too great of an expectation upon the CRU here...I wanted them to cover quality of service to end user etc.

But maybe that is better covered by DTTAS - the policy is here:
http://www.dttas.ie/sites/default/files/publications/public-transport/english/alternative-fuels-framework/6186npfalternative-fuels300517.pdf

ELM327

BoatMad wrote: »

We are issuing a series of press releases.

But we're not responding directly to the CRU , dont see any point of that

We are meeting ecars soon

I mean it's not like any of us are suprised by the CER decision

Considering there was a meeting between the evoa and the cer before the decision and the decision didnt go the way that evoa (and the ev community at large, I imagine), it would seem a good idea.

The meeting with ecars will be an important one. Wonder if they will give any idea as to their plans for the future.

BoatMad

ELM327 wrote: »

Considering there was a meeting between the evoa and the cer before the decision and the decision didnt go the way that evoa (and the ev community at large, I imagine), it would seem a good idea.

The meeting with ecars will be an important one. Wonder if they will give any idea as to their plans for the future.

We never expected much from the CER. It was made abundantly clear to us by the commissioners both publically and privately that the RAB was out. once that is eliminated it's a Hobson choice. ( and i put that to the CER )

The fact is they do not believe they have direct role in EV charging whatsoever

KCross

BoatMad wrote: »

There was never any issue about barriers to new entrants. That would be contrary to Eu law. The effective barrier to entrants is the existence of a monopoly that ( a) has a large numbers of chargers and (b) is effectively owned by the DSO

Correct, the barrier is the monopoly.
The stipulation they have put in:

The CRU expects that the operating agreement will provide for third party access to the payment system to enable the customers of parties other than ESB eCars to purchase access to the assets.

forces them to open up access to the assets to 3rd parties other than eCars!

You don't think thats a useful stipulation to limit the monopoly?

As I've said, I would have preferred they put the infrastructure in the RAB but that stipulation is better than nothing surely?

BoatMad

Dardania wrote: »

Maybe there’s too great of an expectation upon the CRU here...I wanted them to cover quality of service to end user etc.

But maybe that is better covered by DTTAS - the policy is here:
http://www.dttas.ie/sites/default/files/publications/public-transport/english/alternative-fuels-framework/6186npfalternative-fuels300517.pdf

The LEV task force ( joints DCCAE DTTAS) is focused on the next generation fast charging requirements along transport arteries.

But they dont have to statutory role in regulating charging pricing or anything like that. The Eu rules around this are very vague.

KCross

BoatMad wrote: »

We never expected much from the CER. It was made abundantly clear to us by the commissioners both publically and privately that the RAB was out. once that is eliminated it's a Hobson choice. ( and i put that to the CER )

The fact is they do not believe they have direct role in EV charging whatsoever

I suppose its hard to argue against them on that. They are not transport regulators.

Water John

The CER was given water to regulate, when it suited Govn't.

The next phase, as ye say, of superchargers is what is critical. Both for those not having access to home/work charging and long drive situations.

BoatMad

Water John wrote: »

The CER was given water to regulate, when it suited Govn't.

The next phase, as ye say, of superchargers is what is critical. Both for those not having access to home/work charging and long drive situations.

Yes. The head of the task force said to me " forget the existing network, its s research project, what do we need to do going forward. "

We did a 2 hour presentation Q&A to them in the second meeting.

( with CER , seai , ecars present too )

Dardania

Water John wrote: »

The CER was given water to regulate, when it suited Govn't.

The next phase, as ye say, of superchargers is what is critical. Both for those not having access to home/work charging and long drive situations.

To be fair, the water network is largely there, just needs some rejuvenation. Easy enough to regulate from consumers perspective and Irish water can do the strategic stuff, funded by government.

A similar situation could happen here - CRU have set some basic conditions (like clarifying the extent of electricity supply license to operate a charger) and decided how to pass the existing network on to its next caretaker. All in all, not the worst - however I get the concern that having the existing network leave the CRU people are worried that regulatory oversight and responsibility will drop.

Dardania

Water John wrote: »

The CER was given water to regulate, when it suited Govn't.

The next phase, as ye say, of superchargers is what is critical. Both for those not having access to home/work charging and long drive situations.

To be fair, the water network is largely there, just needs some rejuvenation. Easy enough to regulate from consumers perspective and Irish water can do the strategic stuff, funded by government.

A similar situation could happen here - CRU have set some basic conditions (like clarifying the extent of electricity supply license to operate a charger) and decided how to pass the existing network on to its next caretaker. All in all, not the worst - however I get the concern that having the existing network leave the CRU people are worried that regulatory oversight and responsibility will drop.

BoatMad

Dardania wrote: »

To be fair, the water network is largely there, just needs some rejuvenation. Easy enough to regulate from consumers perspective and Irish water can do the strategic stuff, funded by government.

A similar situation could happen here - CRU have set some basic conditions (like clarifying the extent of electricity supply license to operate a charger) and decided how to pass the existing network on to its next caretaker. All in all, not the worst - however I get the concern that having the existing network leave the CRU people are worried that regulatory oversight and responsibility will drop.

The removal of a supply license is actually a bad thing ( it's surprising how people don't understand this ) because the CER regulated wholesale retail suppliers that exist under those supply licenses. (Remember domestic electricity pricing is controlled and regulated )

Hence this excludes the existing retail suppliers from the charger network.

Secondly it means that end user pricing can be set without any regulation whatsoever

The " sale " of the network is equally " a fabrication ". Note that the CER did not specify it's must be sold by open competition. , merely that they must sell it ( which can be to ecars ) it within an " unspecified " time.

Ultimately the esb drive a horse and cart through the CER , but then they've been doing that for years

KCross

BoatMad wrote: »

The removal of a supply license is actually a bad thing ( it's surprising how people don't understand this ) because the CER regulated wholesale retail suppliers that exist under those supply licenses. (Remember domestic electricity pricing is controlled and regulated )

Hence this excludes the existing retail suppliers from the charger network.

Secondly it means that end user pricing can be set without any regulation whatsoever

Absolutely it means pricing with no regulation. I think we all get that.

I don't get your insistence it's a bad thing that the supply license isn't required.

It means anyone, including existing electricity providers, can access the billing system and sell charging on a per kWh basis which they could not do otherwise. Please explain why you think otherwise.

Whether they will take up that option is entirely speculative of course buts that's a different point.

Dardania

BoatMad wrote: »

Dardania wrote: »

To be fair, the water network is largely there, just needs some rejuvenation. Easy enough to regulate from consumers perspective and Irish water can do the strategic stuff, funded by government.

A similar situation could happen here - CRU have set some basic conditions (like clarifying the extent of electricity supply license to operate a charger) and decided how to pass the existing network on to its next caretaker. All in all, not the worst - however I get the concern that having the existing network leave the CRU people are worried that regulatory oversight and responsibility will drop.

The  removal of a supply license is actually a bad thing ( it's surprising how people don't understand this ) because the CER regulated wholesale retail suppliers that exist under those supply licenses. (Remember domestic electricity pricing is controlled and regulated )

Hence this excludes the existing retail suppliers from the charger network.

Secondly it means that end user pricing can be set without any regulation whatsoever

The " sale " of the network is equally " a fabrication ". Note that the CER did not specify it's must be sold by open competition. , merely that they must sell it ( which can be to ecars ) it within an " unspecified " time.

Ultimately the esb drive a horse and cart through the CER , but then they've been doing that for years

Maybe I'm very right wing / Neo-liberal, but I really think the clarity on supply license is a good thing. The major costs associated with providing an EV charger aren't the cost of electricity (as we came to the conclusion this time last year, many pages back) - it's the upkeep, and possibly the parking charges. It will be possible for the new network operator (be that ecars or another bidder that meets the limited conditions given) to be innovative about locating charging points where they can make the most money, which means the chargers will end up in useful places, and possibly be properly funded.
We don't have regulated petrol / diesel prices after all... And look at what is happening with Irish Rail for example with their regulated prices, no direct competition, and limited capital for investment - not a good situation to mirror for the EV network.
I disagree with your point that the existing retail suppliers are excluded from this market - they can tender to supply electricity to whoever runs the EV network, and indeed due to the billing backhaul access provision, they could even operate their own chargers.

BoatMad

KCross wrote: »

Absolutely it means pricing with no regulation. I think we all get that.

I don't get your insistence it's a bad thing that the supply license isn't required.

It means anyone, including existing electricity providers, can access the billing system and sell charging on a per kWh basis which they could not do otherwise. Please explain why you think otherwise.

Whether they will take up that option is entirely speculative of course buts that's a different point.

I don't see where esbn can be forced to allow virtual charger suppliers, i.e. That for example energia can buy wholesale electricity and sell it through the chargers and bill customers. Esbn could allow multiple " retailers " but I don't see where they are obliged to do that.

What it says is that new operators of chargers , i.e. People that put in chargers for the public should have access to the payment systems of esbn so as to prevent a Tower of Babel , but not access to existing charger network.

So CER have created a monopoly , provided it woth assets for 6million euros , , effectively , subjected it to zero regulation

Sure nothing could go wrong