October 6, 2017…

October 6, 2017

Katerina Minaeva
Senior Policy Analyst, MTO
Policy and Planning Division
Transportation Planning Branch
Environmental Policy Office (Toronto)
777 Bay Street, Suite 700
Toronto Ontario,
M7A 2J8

Dear Ms. Minaeva,

Thank you for allowing us to submit feedback on your proposal to create a new Green Commercial Vehicle Incentive Program in Ontario. Founded in Shenzhen China 28 years ago, BYD is the largest electric vehicle manufacturer by units globally. We operate plants for vehicle manufacturing around the world and we are excited to bring our zero-emissions high quality trucks to Ontario.

The Green Commercial Vehicle Incentive Program Ontario is proposing, will make it possible to sell electric fleet vehicles in Ontario. Conversions of fleets to electric will have a significant impact on GHG levels in the province and we are proud to be working with you on this important initiative.

We want to begin our comments with a compliment. We have seen many incentive programs roll out for commercial vehicles throughout North America. We have learned that the program design is critical to its success in driving the uptake needed to make a significant environmental difference. It is clear from how the program has been designed that you have looked at what has worked in other jurisdictions and have brought the good together for the proposed Ontario program.

There are a few changes that we would like to see made to what you have proposed but none will alter the overall thinking or direction. A summary of our feedback is provided below:

Timing

At present the program guide says that dealers must be pre-approved by MTO IN ADVANCE of receiving orders from vehicle or device purchasers. Further, the purchase order must be signed after the program launches.
• BYD COMMENTS – We are hoping there can be some retroactivity to both conditions to allow signed orders after September 2017 to be eligible for the incentive. The dealer would have to become approved before any funds could flow.

Dealer must be located in Ontario
• BYD COMMENTS – Additional clarity is needed around what MTO means by “must be located in Ontario”.  

Refuse Vehicles/ Garbage Trucks •   BYD COMMENTS – Electric must be added to the accepted fuel types for refuse vehicles. BYD produces zero emissions class 6 and 8 refuse vehicles and it is fast becoming a top seller in the US. BYD is actively working to get this vehicle and other approved for sale in Canada/Ontario.

Incentive level
• BYD COMMENTS: BYD is very appreciative of the program but feels that 50% of the incremental cost might be low. The ideal payback period that drives major fleet conversion is 2.0-2.5 years. The payback with 50% exceeds that for most of BYD’s vehicles and they have one of the most integrated supply chains. New York’s program is highly successful and is at 80% of the incremental cost. BYD is recommending 70% of the incremental cost as ideal for Ontario.

Incentive Caps
• BYD COMMENTS – BYD feels that the cap on the incentive should increase with the class of vehicle. As the vehicles get larger the delta between the cost of a diesel or other emissions generating vehicle and electric gets larger. This should be accounted for in the program.

Commercial Transportation Innovation Pilot
• BYD is very excited to learn more about this and hopes to pilot their yard trucks as part of this program. The GHG reduction for a fully electric yard truck compared to a diesel is approximately 2.5 tonnes per week depending on usage.
• We also recommend allowing the pilot funding to be combined with other sources of funding (e.g. PTIF).

Thank you very much for considering our feedback. If you have any questions, please do not hesitate to contact me.

Sincerely,

Ted Dowling
President, BYD Canada

BYD Canada Company LTD| Build Your Dreams®
M 250 580 8754 | ted.dowling@byd.com | www.byd.com
2900 10180 - 101 Street Edmonton, AB T5J 3V5 Canada

[Original Comment ID: 211133]