QUEST – Quality Urban Energy…

QUEST – Quality Urban Energy Systems of Tomorrow and the QUEST Ontario Caucus are writing to you today to applaud the Ministry of Transportation for taking bold steps to reduce greenhouse gas (GHG) emissions from the transportation sector in the Ontario, and to help the province transition to become a prosperous low-carbon economy through the Climate Change Action Plan (CCAP).

For the past 10 years, the QUEST Ontario Caucus has been bringing together organizations and individuals across the government, utility and energy service providers, building and land owners and operators, clean technology companies, among others, working at the community level to advance Smart Energy Communities. QUEST helps governments, energy service providers, and businesses bring Smart Energy Communities to life by providing market intelligence, critical connections, and policy support. While great progress has been and continues to be made in communities across the province to improve their energy efficiency and enhance energy reliability, reducing the environmental impact of the transportation sector is a goal of increasing priority.

In Ontario, the single largest source of GHG emissions is transportation. More than one-third of the province’s GHG emissions come from the transportation sector, 70% of which is caused by cars and trucks. The QUEST Ontario Caucus is forming a Transportation Working Group (TWG), to bring stakeholders across the province together to apply a systems-approach to the challenge of reducing GHG emissions from the transportation sector. By providing a forum to share cost-effective best practices, while providing clarity around technology options and regulatory policy, the TWG will help communities deliver the infrastructure, solutions, and ground swell of support needed to reduce emissions and meet the goals of the CCAP.

It is therefore our pleasure to assist the Ministry of Transportation with your inquiries to improve the infrastructure and awareness of low-carbon and EV transportation.

1. 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?

The government should tie the EV purchase incentives on a performance basis, particularly on GHG emission reductions. Tying incentives to performance, rather than vehicle cost, will allow for the most significant reductions in energy use and GHG emissions. For example, newer “conventional” hybrid technology may have similar GHG benefits as EV models when highway driving is taken into consideration, yet conventional hybrids do not receive incentives.

How should the government adjust the current 30 per cent Manufacturer’s Suggested Retail Price (MSRP) incentive cap and the $3000 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)?

As mentioned above, the government should adjust the 30 per cent MSRP cap, to an incentive based on vehicle efficiency and GHG emissions reductions. A performance-based incentive will increase the uptake of electric and low carbon fuel vehicles, beyond just personal vehicles.

2. 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?

There are many technical issues and requirements associated with electric vehicle chargers that should be considered in a program to deploy charging stations at workplaces, multi-unit residential buildings, downtowns, and town centres. These include the ability of the grid to meet the demand, the proximity of other charging stations and what impact that could have on the grid, and the type of use and occupancy of the building or area and therefore when the charger will most often be used (residential vs. office tower).

Level 1 (120V) charging should be included within the scope of the multi-residential and workplace program, as this will allow EVCO to stretch its program dollars to provide a much greater reach of EV charging across Ontario. For multi-residential buildings, every PHEV on the market now can be completely recharged overnight using 120V, even with a lower 8A draw (the default setting when most EVs plug into a generic wall outlet with a shared load). For workplaces, assuming an eight-hour workday, a dedicated Level 1 charger (120 V, 12A) is capable of adding about 50 to 65 kilometres of range, which would completely recharge most PHEVs currently available. This range is also likely suitable for most BEV drivers, since the majority of commuters travel less than 50km to work, especially in municipalities outside of the Greater Toronto Horseshoe Area.

In addition to deploying charging stations at workplaces, multi-unit residential buildings, downtowns, and town centres, consider the installation of utility-scale batteries along the 400-series highways, with multiple vehicle-chargers integrated into it. This would reduce the stress on the grid while allowing multiple EV's to be charged at the same time.

The EVCO Program must be developed in a collaborative consultation process with local governments, utility and energy service providers, the real estate sector (builders and developers as well as owners and operators) in addition to provincial government agencies and the automotive sector.

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

The Transportation Working Group cautions against identifying one group or industry as ‘best positioned’ to implement the installation of charging stations, as there are multiple groups and/or industries well positioned to implement them. The critical factor is making sure the roles and responsibilities of different stakeholders, such as governments (provincial and local), regulators and utilities (both electric and natural gas), vehicle OEMs, and consumers, are clear and developed cooperatively and collaboratively.

We also recommend that the installation of charging stations becomes part of the real estate development application process for development, so that it becomes business as usual to include EV charging stations in new residential and commercial developments.

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

The government should consider consulting with utilities, existing education and engagement groups like Plug N Drive, existing industry associations such as BOMA and, existing programs like Save on Energy to develop marketing and outreach campaigns.

We also invite you to use the QUEST Ontario Transportation Working Group, which includes key stakeholders in the EV and low-carbon fuel transportation sectors, including Plug’ N Drive and representatives from both electric and natural gas utilities, as a resource for connection to these groups.

How should government ensure that Local Distribution Companies are involved in EVCO applications?

It is imperative that LDCs are consulted early on in the process of developing EV infrastructure plans. LDC’s need to play a role in the approval of the applications as the capacity of the grid in any given area is critical to the success of the EVCO.

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

The application window should be lengthened to allow municipalities to assess participation in the program and report recommendations to council for their approval. Furthermore, the selection of public charging sites should take into consideration whether those sites have received support from the LDC and the municipality, or as a minimum, that the municipality and LDC have been informed of the proposed location.

In addition to EV infrastructure and awareness, we would also like to take this opportunity to encourage a similar consultation process be conducted for the implementation of alternative and low carbon vehicle and fuel sectors. In order to meet the GHG emission reduction targets outlined in the CCAP, it is important that the Ontario government create the market conditions for the uptake of all alternative fuel and technology vehicles for personal vehicles, public and private fleets, return to base, and long haul transportation in the province.

On behalf of the QUEST ON Caucus and the QUEST ON Transportation Working Group, we thank you for the opportunity to provide input to this important process.

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