In response to this Proposal…

ERO number

019-6000

Comment ID

62217

Commenting on behalf of

Community Energy Association

Comment status

Comment approved More about comment statuses

Comment

In response to this Proposal, we offer the following commentary:

1. Where are the geographic areas in Ontario where there are gaps in public EV charging infrastructure?
• Gaps are present throughout rural Ontario on low volume traffic corridors. Private industry investment has focused to-date on installations in high volume traffic corridors. This is a direct result of the financial opportunity high volume traffic corridors present. High volume traffic corridors will recoup their initial investment much sooner than low volume.
• Gaps outside of high density corridors should be assessed not just by distance to nearest infrastructure, but by the strategic way in which new infrastructure would support enhanced tourism and economic development opportunities for small and medium sized communities.
• Communities in SW Ontario have take a regional study approach to identify gaps in EV infrastructure within a defined geographic area that includes the Counties of Bruce, Dufferin, Grey, Huron Perth and Wellington, as well as the Cities of Guelph, Stratford and the Town of St. Mary’s. The study highlighted gaps in EV charging infrastructure and also demonstrated the positive influence EV chargers can have on neighbouring municipalities by increasing the number of travel corridors between chargers. Providing multiple travel corridors means more opportunities for drivers to support local economies.
• Results of Nuclear Innovation Institute’s Plugging In Survey showed that visitors perceive rural areas (e.g. Grey, Huron and Bruce Counties) as having limited or unreliable charging services. Hence urban EV drivers are hesitant to travel to rural areas.
• Rural EV owners in our project area do not have chargers to charge at home, increasing demand for public chargers.
• Rural residents are familiar with travelling long distances to access amenities. Range anxiety continues to be a barrier to EV adoption in rural communities. EV drivers of course go to regions where they can charge.

2. In what kinds of situations are public EV chargers most useful (e.g., type of trip, length of trip, type of charging location)?
• Public Fast Chargers are most useful in locations that support ‘quicker stop’ charging along connector routes to drivable markets and urban centres. Level 2 chargers are most useful in locations that facilitate longer dwell times – attractions, facilities or recreational areas. With both types of infrastructure, ideal locations meet multiple criteria including dedicated parking stalls for EV chargers, accessibility, desirable place to stop including lighting and safety considerations, contribution to the overall network (no islands of charging infrastructure), walkability to nearby amenities, visibility to motorists and pedestrians (can be supported with signage), available power source, and feasibility to add stations, increasing charging infrastructure at site as demand grows.
• Our regional EV charging study considered locations for EV chargers that support local economies (i.e. tourist destinations, shopping, amenities, etc.). In the study, level 3 (DCFC) chargers are placed on major travel corridors to support long distance trips (i.e. similar to On Route stations). Level 2 chargers were placed where visitors naturally stay longer (e.g. community centres, parking lots close to shopping and restaurants, major attractions and venues, green spaces/natural areas, etc.).

3. What are the challenges with increasing public EV charging in Ontario and how could the government help address those challenges?
• Focus on investing in regions of the province that are lower in density, and do not currently attract private sector investment, yet are strategic to connect to urban centres and high-density corridors. ZEVIP provides funding for both, but there is currently no dedicated funding to support emerging corridor development.
• Provide flexible funding that enable local governments to aggregate stations to create reliable and robust networks.
• Enable local governments to manage the funds on behalf of regional collaborations, and facilitate a competitive process to identify a third party technology provider, installer and operations/manager. Ensure quality by requiring appropriate Operations and Maintenance Plans, and minimum specifications/requirements for the equipment installed.
• Costs for installing, owning, operating, and maintaining these assets are not feasible (financially affordable) to small and rural municipalities, nor should the financial or risk burden be placed on small communities to install infrastructure;
• Municipalities are well positioned to enable infrastructure through the provision of land and long-term licenses of occupation. Small and rural municipalities welcome the opportunity for long-term licenses of occupation with third party suppliers to install chargers on municipal lands with minimal cost to the municipality.
• A repayability clause should not be included for station investments outside of urban centres or high volume corridors. Instilling a cap on the funding available per recipient is a barrier.
• Supportive funding is reflective of the current costs associated with purchasing and installing electric vehicle charging infrastructure (e.g., $20,000/charger for Level 2 and >$150,000 for 100kW or greater Level 3 stations), with possibility of introducing tiered charging to address realistic increase of costs and operations/maintenance burden of remote locations,
• The electricity grid must continue to be clean in order to align with municipalities’ objectives of reducing greenhouse gas emissions in the transportation sector.

Thank you for your time to explore these issues together. We are pleased to see the Province developing programs to continue to support rural communities in their transition to our net-zero emissions future.