Dear Ms. Downard, We…

ERO number

019-6000

Comment ID

62239

Commenting on behalf of

Tesla Motors Canada ULC

Comment status

Comment approved More about comment statuses

Comment

Dear Ms. Downard,

We appreciate the opportunity to provide comments regarding the recently announced funds for the deployment of electric vehicle (EV) charging infrastructure in Ontario. Tesla is supportive of the efforts being made by Ontario’s Ministry of Transportation (MTO) to expand the availability of charging infrastructure in the province.

At Tesla, we believe that our technologies and charging solutions are especially well-positioned to help maximize charging deployments and, in summary, we propose the following:

• Expanding the program scope and focusing on gaps in public EV charging needs, including:
- Where highway-side DC Fast charging infrastructure is already present but additional capacity is necessary.
- Supporting urban charging infrastructure, particularly Level 2 AC charging in multi-unit residential buildings.
- Developing DC-Fast charging hubs in densely populated areas to serve as a backstop until multi-unit residential retrofits are completed, by making public lands available for this use to charging operators and drivers.
- Where no charging operators are currently operating any service in contiguous corridors (e.g. highway 11 between North Bay and Nippigon)

• Adopting minimum power requirements to deploy DCFC equipment rated at a minimum 100 kW output per connector
• Including the Tesla connector within the design of the program, just as it has been done by Natural Resources Canada, in recognition of Tesla’s proven capacity to deliver sites on time, on or under budget, at scale, and for all vehicle drivers alike.
• Adopting reliability requirements to ensure stations deployed are dependable and fulfilling drivers’ needs.

Tesla has proven that is possible to scale EV charging deployment while also continuing to lower equipment costs while maintaining an excellent customer experience. We believe this will contribute substantially to Canada’s deployment goals and enable government to demonstrate progress quickly. Given Tesla’s global and Canadian experience – to date we have deployed 1,490 DC Fast charging connectors and over 2,100 Level-2 connectors in Canada – we believe we’re well positioned to support your department’s goals. Maximizing the number of charging stations deployed with public dollars is vital in the fight against climate change, will help avoid the economic costs of pollution, will save lives and reduce pollution related diseases.

Supporting documents