ELECTRIC VEHICLE INCENTIVE…

ELECTRIC VEHICLE INCENTIVE PROGRAM (EVIP)

What should the government tie the EV purchase incentives to (e.g., vehicle tailpipe GHG emissions, battery size, technology type, etc.) in order to support a significant growth in EV sales and GHG emissions reductions?

Toronto Hydro strongly supports the Government’s continuation of the EV Incentive Program as a means of encouraging EV take-up in the Province. We encourage the Ministry of Transportation (“MTO”) to retain the tie to battery size in the design of the incentive program. We expect that batteries with larger capacities would tend to decrease the share of charging that occurs during “peak” times on the electricity grid – the hours when the demand for, and prices of, electricity are highest – because a full charge is more likely to meet a day’s needs. Whether for residential or fleet purposes, Toronto Hydro favours incentives and other mechanisms that encourage EV users to charge their vehicles when electricity demand and prices are lowest. Avoiding charging during “peak” times will help to defer necessary investment in the electricity grid to support this new source of electrical load.

The battery size criterion aside, Toronto Hydro encourages the Government to ensure the final design of the incentive is simple and easily understood by potential customers to make the EV acquisition process as easy as possible.

How should the government adjust the current 30 per cent Manufacturer’s Suggested Retail Price (MSRP) incentive cap and the $3,000 cap on vehicles with an MSRP greater than $75,000 in order to promote EV sales and GHG emission reductions in a fiscally responsible manner (e.g. remove the cap? Relax the cap)?

Toronto Hydro understands why such a cap may be a necessary element of the EVIP in the short-term. If it is retained, we encourage the Province to review this aspect of the program on a regular basis.

Do you think these caps influence an EV buyer’s decision to purchase an EV or a specific type of EV?

Toronto Hydro has no position on this question at this time.

How can the government adjust the Electric Vehicle Charging Incentive Program (EVCIP) to benefit even more EV owners?

Toronto Hydro is supportive of removing the eligibility requirement for the EVCIP that is tied to the receipt of an EVIP rebate. As a resale market emerges for EVs (either as existing owners opt for new models or as initial lease agreements come to a close), the purchase incentive for an EV charger would be more effective if available to any EV owners. Broadening the eligibility criteria in this fashion could also create an incentive for developers or renovators to build EV-ready homes and businesses, further encouraging the deployment of EVs.

Further, Toronto Hydro submits the EVCIP could offer a greater value proposition to customers and Local Distribution Company (LDC) if the incentive was tied exclusively or in part to having built-in demand controls on the charging station. With the customer’s permission, built-in demand controls would allow utilities to schedule EV charging at times when electricity demand and prices are lowest. Combined with other incentives, such as the Ministry of Energy’s planned Overnight Charging Incentive Program, Toronto Hydro could help to simultaneously reduce the EV owner’s cost of charging and defer grid investments triggered by EV uptake.

ELECTRIC VEHICLE CHARGERS ONTARIO PROGRAM (EVCO)

What program features (e.g., eligibility requirements, evaluation criteria, technical requirements) should be considered in a program to deploy charging stations at workplaces, multi-unit residential buildings, downtowns and town centres?

Toronto Hydro is encouraged that the MTO will be pursuing additional rounds of the EV Chargers Ontario program. Situating an expansive, pan-provincial network of charging infrastructure is in our view an effective deterrent to range anxiety.

If not already under consideration, Toronto Hydro encourages the MTO to include public street parking locations as eligible for this program. Street parking locations in downtown areas, and particularly those in Toronto, represent a unique opportunity to expand a Level 3 charging network and would provide an alternative to charging stations located in private parking garages or other private locations. We encourage the MTO to work with LDCs and City partners to this end.

To ensure charging equipment is safe, Toronto Hydro recommends that LDCs develop and maintain a pre-approved Vendor of Record for charging station units from which program participants can select for their projects.

Specifically for multi-residential and workplaces:

Who are best positioned to implement the installation of charging stations?

LDCs should be eligible to partner with multi-residential and business customers to implement publicly-accessible EV charging, as they have been in other jurisdictions.

In California, for example, a moratorium on utility-owned charging infrastructure was lifted in order to support the Governor’s commitments on zero-emission vehicle deployment targets. The state’s utility regulator has since approved comprehensive pilot projects that allow utilities to own and operate charging stations at workplaces and multi-unit dwellings in a fashion that aims to uphold a competitive market for that service. (For example, see: http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M158/K071/15807133…)

Toronto Hydro is ready to partner on these types of initiatives in support of the province’s EV goals for 2020.

How should funding for charging stations be structured and/or capped? What value(s) of cap(s) should be applied?

In cases of LDC involvement, payments made to the LDC could be in the form of a capital contribution.

How can government best engage workplaces, condos and apartment boards to participate in the EVCO program?

Toronto Hydro encourages the MTO to leverage existing relationships LDCs have with workplaces, condos and apartments managers, all of which are already utility customers. LDCs deliver electricity conservation and demand management programs and have numerous communications channels through which customer engagement occurs.

How should government ensure that Local Distribution Companies are involved in EVCO applications?
In instances where LDCs are not partner to the project, LDC notification could be added as an application requirement. Understanding where potential EV charging locations could be located is valuable information for Toronto Hydro’s grid planning purposes, so this would be a constructive amendment to the current process. Of course, Toronto Hydro is inevitably engaged in projects where proposals require infrastructure upgrades on Toronto Hydro’s grid, but accelerating that notification to earlier in the process would represent an incremental improvement.

What aspects of the first round of EVCO do you feel should be repeated or done differently?

Toronto Hydro would welcome exploring options to broaden the scope of the EVCO to include projects that are deployed in conjunction with energy storage or conservation and demand management technologies.

EDUCATION AND AWARENESS

EV Educational Campaigns

What are your current perceptions related to EVs? How can government help in improving perceptions related to EVs, and help consumers better understand the benefits of EVs?

Toronto Hydro would welcome further support in communicating the value proposition of fueling passenger vehicles on electricity rather than imported petroleum. We acknowledge the work done by Plug N’ Drive and encourage the government to build on their success and messaging.

What innovative education and/or awareness programs or policies, currently operating in other jurisdictions that provide support for the adoption of EVs, could be applied in Ontario?

Toronto Hydro is open to exploring new ideas about how to better engage customers about EVs, to make the acquisition process more customer friendly. As the EV market is still at a nascent state, awareness campaigns are still acutely necessary, and events such as test drive demonstrations can garner positive media attention.

Who should the government be partnering and collaborating with to deliver an EV educational campaign?

As the primary fuel delivery agent for EV users, LDCs are natural partners for government in designing and delivering EV educational campaigns. Moreover, information that can be gained about customers’ preferences and intents with respect to EVs can be more easily integrated into capacity and grid planning processes if Toronto Hydro is involved in delivering an integrated campaign with government and other stakeholders. Understanding where EVs are located is important at the local (i.e., transformer) and system-wide level.

To increase education and awareness of the benefits of EVs, what forms of communication and key messages should the government consider to reach an audience beyond the EV community?

Toronto Hydro encourages the MTO to consider funding market research and demographic studies to better understand what forms of communications would be most effective at marketing to prospective and existing EV drivers. There may be regional variations in what communications media and messages prove most effective, and better understanding the urban/metropolitan context would be beneficial information for Toronto Hydro.

Partner and Dealership Programs

What are potential tools that can be used to increase the availability of EV models on the showroom floor, for test drives and for purchase at dealerships?

Beyond the purchase and dealer incentives already contemplated in this consultation, Toronto Hydro does not have a position on this question at this time.

What supportive mechanisms and/or incentives should the government provide to EV salespeople and dealerships in order to increase EV sales?

Dealers should be encouraged to partner with LDCs to better communicate and facilitate the customer’s transition from purchasing to fueling an EV. Dealer-LDC relationships could also facilitate better and faster information about where EVs will be located on the grid, allowing utilities to make more informed decisions about where infrastructure upgrades are required.

Private Fleet Awareness Campaign

How can we effectively raise awareness of EVs and EV incentives to private fleets?

Through its Key Accounts program that promotes CDM to large electricity customers, Toronto Hydro has established relationship with many customers across the City of Toronto that own and operate private fleets. EV promotion is an activity that should be integrated into that approach.

What elements should be included in a decision-making tool or cost calculator to help fleets consider purchasing an EV?

Toronto Hydro believes the costs of fueling fleets on electricity, as opposed to conventional petroleum-based fuels, are very competitive. We encourage the development of a cost calculator that uses conventional fueling as a baseline for comparison to demonstrate the value proposition of electricity.

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