A copy of this letter was…

A copy of this letter was submitted by email to Arielle Mayer, Sr. Policy Advisor:

Dear Ms. Mayer,

PowerStream would like to recognize the Ministry of Transportation’s leadership in promoting electric mobility. PowerStream is a community-owned energy company providing power and related services to more than 380,000 customers residing or owning a business in communities located immediately north of Toronto and in Central Ontario. We believe that electric vehicles have an important role to play in helping Ontario meet its greenhouse gas emissions targets while also reducing fueling costs for drivers. With appropriate planning and investment, electric vehicles can play a helpful role in creating a more reliable and cost-effective electricity system.

PowerStream would like to provide the following comments on the discussion paper published by the Ministry on the Environmental Registry:

1.Electric Vehicle Incentive Program
The EV Charging Incentive Program should not be tied to participation in the EVIP. Under the current rules, EV owners can be ineligible for a number of reasons, such that those who purchased EVs prior to the launch of the EVIP, purchase used EVs, or who need to charge at more than one residence are not eligible. Ineligibility for the EVCIP hurts the adoption of electric vehicles by making it more expensive and thus less convenient to have faster charging at home.

The Ministry should thus provide for some method of sharing the application and/or approval of funding for charging stations through EVCIP through a consent on the application form. As a utility, PowerStream needs information about the loads it serves to manage its infrastructure maintenance and protection more effectively. Multiple level 2 chargers on the same transformer can exceed their rated capacity, even before other household loads are accounted for. This will decrease the lifespan of these transformers and increase costs for LDC customers. In addition, LDCs may have an interest in providing an additional incentive to customers to support smart charging and thus enabling charging station load to be managed by the utility within certain customer requirements. The Electrical Safety Authority should also continue to be involved to ensure that the installation passes an inspection prior to incentive funding being provided.

2.Electric Vehicles Chargers Ontario
PowerStream supports the expansion of EVCO program as a way of making charging infrastructure more widely available to the public, thus addressing the issue of range anxiety. Range anxiety is a primary concern listed by potential EV drivers as to why they may not convert to driving an electric vehicle.

It is not yet clear who is best positioned to lead charging station installation projects, as this is a new service and thus there are no incumbents. However, at this point it does seem clear that there should be multiple types of expertise present on the team providing the stations: customer service and support; installation; and electrical connection to the building/ electric system.

PowerStream recommends that the following criteria be reflected in the program design as follows:
•Evaluation criteria:
oExperience and project team capability
oFull cost, including costs of connecting to the LDC
•Technical requirements:
oA customer connection assessment cost from the LDC, including ability of the transformer to service the new load
oTime should be allocated for LDCs’ involvement in the process, in addition to other work required for putting together a bid. In general, the timelines for the first round of EVCO were very short, which may have compromised the quality of the bids. It should be recognized that installing charging stations is a relatively new type of installation, and requires an understanding of both the physical site and its usage as well as the required electrical infrastructure.
•Funding provided:
oRecognition that installation can be expensive depending on the nature of the site and the distance between the charging station and the electrical connection. These costs can be reduced on a per-unit basis by increasing the number of charging stations (i.e., what may be a large cost for one charging station can be reduced when it is done to support 10).
oA percentage of funding (e.g., 50% ) up to a maximum amount per charging station is appropriate – so long as the total installation costs can be divided by the number of charging stations. A total site maximum could also be implemented to manage costs
oNo restriction on LDCs providing an additional incentive to enable smart charging that can provide value to the electricity system
The Ministry may wish to consider a program model where, instead of a competitive RFP process, the program accepts applications on an ongoing basis and approves applications that meet program requirements/exceeds a specified score based on clearly defined requirements.

3.Education and Awareness
PowerStream believes that governments, EV car dealerships and other industry and civic organizations are important sources of information on electric vehicles.

LDCs can also play an important role in providing information about electric vehicles and charging stations to their customers. PowerStream would be happy to discuss opportunities for how it and other LDCs can support Ministry initiatives to promote electric mobility.

[Original Comment ID: 196577]