It is encouraged that MTO:…

It is encouraged that MTO:
- provide many low-carbon fuel types such as hydrogen and biofuel to boost program participation and overcome significant limitations to refueling stations
- provide low-carbon refueling infrastructure incentives to off-set the incremental costs required by low-carbon vehicles
- consult with dealers, leasing companies and carriers to give these groups the opportunity to provide input on payback, results and case studies on types of equipment, in advance of a pre-approved dealer list and finalized incentive amounts
- consider increased incentive amounts to accommodate both the incremental cost of equipment acquisition as well as re-fueling (including time and distance considerations to low-carbon re-fueling stations), and repairs and maintenance uncertainties
- expand the classes of vehicles eligible to participate in the program to include Class 2 fleet vehicles for utility use
- consider eligibility by vehicle use in addition to classification
- include applicants who have significant transport requirements, but whose fleets do not fulfil the current criteria (such as off-road fleet vehicles, vehicles which are not currently registered with MTO) but whose participation represents an opportunity for a reduction in GHG emissions and the electrification of fleets
- ensure that dealers located outside of Ontario are eligible
- additional lead time be provided for consultation with dealers on the application process to ensure the process is simplified for optimal uptake

In addition to the above, MTO is encouraged to undertake the following for the Innovative Pilot:
- provide a draft Program Book be provided to the industry for consultation
- electrification of fleets be eligible
- consider applicants who have significant transport requirements but whose fleets do not fulfil the current GCVP criteria (such as off-road fleet vehicles, vehicles which are not currently registered with MTO) but whose participation represents an opportunity for a reduction in GHG emissions
- offer geographic and technology-specific pilots such as for industrial commercial areas with large-scale commercial traffic, and one that is focused on specialized and innovative equipment new to Ontario

Submitted, with thanks.

[Original Comment ID: 211153]