Recommendations on EV charging facilities in new strata developments

Australian Electric Vehicle Association, ACT Branch
3rd revision, May 2024

Previous revisions of this document focused on suggesting low cost ways for developers to include workable EV charging facilities in new strata developments. Most recently, the 2022 National Construction Code has included mandatory provisions for EV charging. AEVA provided submissions into the NCC 2022 consultation process on electric vehicle charging. We were pleased that many of AEVA's recommendations were adopted.

These include providing sufficient electrical capacity and distribution boards to support the future installation of EVSEs to charge vehicles in, for example, 100% of car parking spaces in class 2 (multi-unit residential) buildings and 10% of parking spaces in class 5 (office) buildings. The reader is referred to Part J9 of the 2022 NCC for more details.

Notably, class 1a buildings may also feature in strata developments such as townhouse developments. NCC 2022 is silent on EV charging requirements for class 1a. This is presumably explained by the relative ease with which charging can be retrofit to these strata sites. As NCC 2022 largely caters to the most complex residential building type (class 2), this document focuses on new strata developments of building types not covered by the NCC.

Shared charging outlets are not sufficient

AEVA believes that shared charging outlets are insufficient. A limited number of shared charging outlets would cause nuisance and inconvenience. Conflict could occur when the charging space(s) is blocked by a vehicle that is no longer charging and its owner cannot be found. Queuing would be inevitable. One out-of-service fault would inconvenience all residents. The lack of assured access to charging would fail to encourage EV uptake.

A shared faster AC charging outlet or a very expensive DC fast charger might be an ‘icing on the cake’ option that a developer might offer but it should be not be accepted as a substitute for each unit having assured access to a charging outlet in at least one of its allocated parking spaces.

Assured access to slow charging is sufficient

Assured access to charging where one routinely parks is a strong incentive for the uptake of EVs, even if charging rates are slow. Even ordinary power points are sufficient so long as every resident can charge in a parking space allocated to their unit.

Slow charging is sufficient because vehicles spend long periods in their owners’ allocated parking spaces. Vehicles are rarely driven until their batteries are fully depleted as most trips are local and short and the range of new vehicles is increasing. Even when a battery is fully depleted, they rarely need to be fully charged before another trip is attempted. Even if a full charge is required, a partially charged car will soon be able to commence an intercity trip and then use a DC fast charger station en route.

Vehicles are generally supplied with a portable ‘Electric Vehicle Supply Equipment’ (EVSE) charging cable fitted with a standard 10A or 15A plug. EVSE cables communicate with the vehicle’s on-board charger to limit the charging current to less than the rating of the outlet is plugged into. Vehicles now commonly have 7kW (32A) on-board AC chargers. However, this does not mean that they must be charged at this rate. The car’s on-board charger will not charge faster than the limit specified by the portable EVSE cable or a wall-mounted EVSE. An EVSE’s limit can be 6A or 10A or 15A and so on.

Slow charging may be necessary

Faster charging of many cars simultaneously could exceed the capacity of the electrical supply to a strata site. Alternatively, making provision for rapid charging rates for many vehicles simultaneously could add unnecessarily to costs. As noted above, it is quite adequate for all electric vehicles to charge slowly, such as at 10A or 15A. The key is to convince residents that this is adequate.

The current electrical standard (AS 3000) has a voluntary suggested minimum provision of 20A for every vehicle outlet and assumes they are all running simultaneously. However, in the first instance, we suggest that standard 15A sockets (even 10A as a bare minimum), rather than 20A or greater sockets, could be permitted as a way to limit the maximum possible current draw.

As noted below, ‘smart’ charging systems exist that regulate charging rates according to the number of vehicles that are charging at any particular time to avoid exceeding a supply limit. At a later time such ‘smart’ adaptable charging systems could be retrofitted (if the unit owners want to do so) as EVs become more common and such systems become cheaper. The ‘WattBlock’ report contains excellent technical advice on systems that may be staged to manage different levels of EV uptake.

Direct connection to the meters of individual units is preferred

Whenever possible, it is highly preferable for charging outlets to be wired back to the meters of the individual units.

The advantages are simplicity, cost savings and greater flexibility:

• Individual residents will have the greatest opportunity to respond according to their preferences among different tariffs and options such as peak demand tariffs, time of use tariffs, and timed off-peak options that trade off convenience against price incentives in various ways to discourage charging at times of peak electricity demand.
• The user-pays principle is automatically applied.
• The Owners Corporation will not be burdened with obligations associated with meter reading, billing, strata legislation, maintenance and network regulations. Costs to each resident are likely to be higher if these obligations are outsourced to a third party provider, who would expect to make a profit.
• Individuals could upgrade their charging outlets according to their own preferences and requirements within constraints set by the individual unit’s and building’s electrical supplies.
• The developer does not need to supply and install a second set of meters.

Owners Corporation Rules on repair, maintenance and upgrades

AEVA recommends that the Unit Titles (Management) Act 2011 (UTMA) be amended to make it unambiguious that a unit owner has the right to upgrade their charging outlets within their allocated parking space and an obligation to repair and maintain their charging equipment at their own expense subject to appropriate conditions imposed by the Owners Corporation, such as using appropriately licensed tradespeople and obtaining approval of the particulars of any work, whether the equipment is fully or partially on common property or within the unit area. Otherwise, where a unit’s allocated parking is on the common property and/or cabling traverses common property, some or all of the charging infrastructure might be regarded (mistakenly) as the responsibility of the Owners Corporation to maintain (UTMA s.24). and default rule 4 (UTMA Schedule 4) might be interpreted as requiring an unopposed resolution, an unnecessarily high hurdle, every time a unit owner wishes to upgrade or modify a charging outlet. It may be sufficient just to add a note to s.24(e), to make it clear that a unit owner is responsible to repair and maintain, and potentially upgrade, charging equipment and cabling that is provided for the sole use of their unit, including parts which may be on or traversing common property. Such an amendment would be consistent with in the spirit of the Act which prohibits amendments to the rules that restrict the installation, operation or maintenance of sustainability or utility infrastructure (UTMA s.108(3)(d)).

Third Party Provision with Service Contract

An option for the installation and management of EV charging facilities is to have the infrastructure installed by a 3^rd party who then manages billing and maintenance. This would have the attractions of not requiring the developer to have any EV expertise and relieving the OC of some management responsibility. Jetcharge (jetcharge.com.au) is an example of a service provider that “can advise on how to set up a new building, or how to retrofit an existing one … supply the hardware, upgrade the electrical infrastructure, fit out the building and look after your residents and tenants.”

The UTMA puts strict limits on the lengths of contracts that can be entered into by an OC during and after the ‘developer control period’:

UTMA s.33 generally prohibits a developer from entering into a contract longer then 2 years unless authorized by the ACT Civil and Administrative Tribunal (ACAT), which may approve a longer contract “if satisfied that the terms of the contract are reasonable in all the circumstances.” The examples given of matters the ACAT may consider relevant are “1) short and long-term economic benefits disadvantages of the contract 2) the existence of a financing agreement related to the contract 3) environmental sustainability measures provided for by the contract”.

UTMA s.60 “An owners corporation for a units plan may, by ordinary resolution, enter into a service contract … However, the owners corporation must not enter into a service contract for a period longer than 3 years (including any period for which the contract may be renewed or extended) unless the contract is authorised by special resolution and made after the end of the developer control period for the units plan ...”

The developer might engage a service contractor to install and manage charging equipment but the equipment must be of a design that could be maintained and managed by a different service contractor after three years if the OC preferred to change contractor. If the business model of charging service installer/providers such as Jetcharge reasonably requires a longer initial contract period (say 5 years) it might be necessary to amend the UTMA to remove the need for each developer to apply separately to the ACAT for approval of the longer contract period.

Unallocated Parking

Where parking is shared on the common property and parking spaces are not allocated to specific units, there should be at a minimum as many charging outlets as there are units consistent with NCC 2022 for class 2 buildings (100% of car parking spaces). Since electricity taken from an outlet in any particular parking bay would not automatically correspond to a particular unit, the OC would be left funding residents’ transport costs inequitably. It would seem unwise for the developer to set up the future OC to fund the costs of vehicle charging without any means to charge in proportion to consumption and no disincentive to excessive consumption. Therefore, in this situation, the developer should install card activated wall/post-mounted EVSE systems to enable equitable billing by the OC or a third party provider. We suggest it would be simpler for the developer to register the Units Plan with parking spaces allocated to particular owners to avoid this situation.

Futureproofing

The wiring for ordinary ‘dumb’ power outlets with basic metering should be compatible with ‘smart’ upgrade options. Put simply, the wiring should be capable of handling 32A, even if a developer initially only installs standard 15A power points.

Systems of networked EVSEs exist in which ‘smart’ outlets negotiate with each other and their attached vehicles to decide how much current each outlet can supply. When some outlets are supplying low or no current, other outlets can permit their attached vehicles to draw more current for faster charging. Such outlets can log the total energy delivered at each outlet for electronic billing purposes and some might be able to accommodate Time of Use billing rates. ‘Smart’ systems like this are still expensive but the wiring to ‘dumb’ outlets should at least be installed at a sufficient gauge to allow retro-fitting if there is demand for it.

The type of ‘smart’ charging system described above makes the best and fairest use of a constrained electrical supply to a site. It might lock out vehicle charging for a few hours of evening peak demand and it might only permit charging at (say) 6A if many or all vehicles are attempting to charge. When fewer vehicles are charging, the system can adjust to allow higher charging rates such as 10A, 15A, 20A or 32A while remaining within the total supply capacity. Some such systems can also monitor the consumption of the rest of the site and then adjust the total current available for vehicle charging so that the total available supply to the site is not exceeded.

Assured access to slow charging where one routinely parks is sufficient to support virtually all patterns of local urban car travel, especially now that larger battery capacities are becoming the norm. For extra-urban trips one might sometimes commence without a fully charged battery but one will then be able to make use of a DC fast charger en route.

Summary

• Every unit must have assured access to a charging outlet where they routinely park.
• Slow charging rates are adequate and may be necessary to avoid exceeding the supply capacity to a building.
• Ordinary Australian standard power points are sufficient. Dedicated, more expensive, wall-mounted EVSE charging outlets can be an optional upgrade that need not be provided by the developer.
• One or a few dedicated charging bays is not sufficient, even if higher charging rates are available.
• Physical wiring of charging outlets back to the meters of individual units is strongly preferred.
• Where it is unavoidable to provide EV charging through an ‘embedded network’ behind an Owners Corporation meter, there should be sub-metering to enable billing of individual units.
• A developer could engage a third party to install charging infrastructure and then manage its maintenance and billing but they should be aware of the limits on contracts entered during the ‘developer control period’.
• Some amendments to the Unit Titles (Management) Act 2011 may be necessary or helpful.

Resources

Wattblock report for the City of Sydney

Example service contractor for EV charging installation and management (Jetcharge)