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Please comment on the selection of alternative fuel vehicles, and fuel saving devices that have been identified as eligible for funding.

The County supports the selection of alternative fuel vehicles including those that are powered by electric, natural gas, and diesel-natural gas. However, the program should be open to supporting any form of alternative fuels or vehicle type that would result in GHG emission reductions. Options such as hybrids, hydrogen gas and fuel cells should also be given consideration in powering vehicles. By allowing a wider selection of alternative fuels, it can create industry capacity to implement these alternative fuels that will result in higher funding towards research & development and reduction in overall costs.

Will the incentive values proposed support and promote adoption? How appropriate are the percentages and funding caps proposed for the incremental costs for each supported vehicle fuel type or fuel saving device?

The incentive allocation is adequate and will result in making the difference between a financially infeasible project and feasible one. This result can be demonstrated with Oxford County’s existing fleet data and the County’s purchase of two dedicated CNG tandem plow trucks. Based on current estimates, a CNG tandem snow plow truck’s incremental cost is approximately $45,000 over a conventional truck. Taking mileage savings into consideration, the County is expecting a 10.5 year payback. If a 30% incentive is implemented based on the proposal highlighted in the GCVP then the payback period would reduce to 7.3 years.

Are there any potential barriers to successful uptake of the program as designed?

Potential barriers of this incentive program would be the lack of alternative fueling stations or limited knowledge of known stations. For example, the Electric Vehicle Incentive Program (EVIP) is complemented by the Electric Vehicle Charing Incentive Program (EVCIP). A similar approach should be taken with the GCVP where alternative fueling stations are given an incentive. Otherwise, this incentive program may cause an excess demand of alternative fueling stations. It would also be recommended that the MTO build on the Electric Vehicle Chargers Ontario map with adding alternative fueling stations.


Are the eligibility requirements realistic and achievable?

The County of Oxford agrees with the proposed eligibility requirements and believe them to be realistic and achievable.

Is a process where dealer/vendors apply for the rebate on behalf of purchasers preferred? Are there any issues with this approach?

The approach of utilizing dealers/vendors for applying for incentives on the behalf of the purchasers is the preferred method of choice. This approach would reduce the number of applicants and streamline the process. If purchasers were only given the rights to apply for the incentive then they would be required to comprehend the application process which may lead to higher incomplete applications. By allowing dealer/vendors to complete the incentive application, the chances of a fully complete application are higher, it will reduce additional work on the MTO, and incentives will have a lower lead time.


Where fleet vehicles already have telematics devices on board, could this electronic data be shared, both for baseline and funded vehicles, in order to facilitate documentation of GHG reductions?

The County of Oxford would be willing to share information that will benefit in the progress of reducing GHG emissions. Oxford County vehicles are equipped with Automatic Vehicle Location (AVL) and would be able to provide baseline and funded vehicle information.

Are there any considerations or concerns regarding data privacy?

The County of Oxford will provide data requests in order to maintain compliance with the Municipal Freedom of Information and Protection of Privacy Act, R.S.O. 1990.

Should other types of data be collected in the context of GHG emission reductions?

Other data types to consider will depend on the industry in which the funding vehicle operates. In the case of a municipality, it would be beneficial for the MTO to record local snow fall associated with snow plows that receive funding. Similar to heating a building, snow plow usage will vary from season to season and it is important capture parameters that significantly influence GHG emissions. This approach would allow the province to truly understand if GHG emissions are being reduced.


What type of pilot projects could be funded under this category?

This section can allow new devices and vehicles utilizing an alternative fuel to be incentivized. It will encourage ideas to move from research to commercialization and act as a hub for providing up-to-date knowledge on latest innovative ideas in the transportation sector.

What are some future trends that you believe will have an impact on the commercial transportation sector?

The County of Oxford will continually move towards reducing GHG emissions and will always consider alternative fuel sources to power fleet vehicles. This approach is solidified within the County’s Strategic Plan - A County that is Well Connected and our goal of achieving 100% Renewable Energy by 2050. The County will continue to support the government of Ontario in their endeavour to mitigate climate change.

[Original Comment ID: 211087]