Pollution Probe applauds the…

Pollution Probe applauds the Ontario Ministry of Transportation (MTO) in its commitment to funding expanded public transit in the Greater Toronto and Hamilton Area (GTHA), as well as the expansion and electrification of the GO Regional Express Rail. Both of these initiatives will serve to significantly reduce transportation emissions and congestion in a region that is home to almost 20% of Canadians.

Ontario’s goal of 5% of new vehicle sales being electric vehicles (EVs) and hydrogen fuel cell vehicles (HFCVs) by 2020 is very ambitious, but Pollution Probe sees this goal as a critical first step in the widespread deployment of these emerging technologies, which offer significant potential for deep reductions in greenhouse gas (GHG) emissions in the province. We support the extension of the Electric Vehicle Incentive Program (EVIP) to 2020, and see this program as a crucial way by which to successfully promote the adoption of EVs and their associated home charging equipment. Continuing to deploy public EV charging stations will also play a central role in increasing EV adoption in the province, as these stations will facilitate long-distance travel via EVs, addressing the range anxiety that continues to pose a barrier to widespread EV adoption.

Overall, Pollution Probe feels that the Government of Ontario’s approach to increasing EV usage is comprehensive and well-informed, with its focus on purchase incentives, charging station deployment in public spaces, workplaces and multi-unit residential buildings, the establishment of standards for EV-ready buildings, and education and outreach efforts aimed at the general public and auto dealerships. This focus will serve to address three major barriers to increased EV adoption identified in the discussion paper: cost of ownership, range anxiety (and refuelling time), and public awareness.

The following represents some initial commentary from Pollution Probe on government incentives and promotional programming around EVs. For additional suggestions related to supporting the acceleration of EVs in Ontario, we invite the MTO to review Accelerating the Deployment of Plug-In Electric Vehicles in Canada and Ontario, a collaborative report completed by Pollution Probe, Bruce Power, Plug’n Drive and the University of Waterloo, which can be accessed at: http://www.pollutionprobe.org/publications/accelerating-ev-deployment-r….

Key recommendations from the report include the following:

•Create a framework through which EV owners can voluntarily share their intention to purchase an EV and the technology they choose to purchase (i.e., vehicle model and charging equipment)with their local distribution company (LDC).
•Further investigate options for LDCs to have more control over EV charging times, allowing for greater EV uptake without infrastructure upgrades.
•A joint task force comprised of all level of government, LDCs and industry should be formed to determine the correct fee structures for public charging infrastructure.
•As they move beyond their initial investments, governments should encourage and enable the active participation of LDCs in the installation and management of public charging infrastructure.
•Government should work together with automotive manufacturers, non-governmental organizations and other stakeholders to provide dealerships with support to increase engagement through sales training and awareness. This will contribute to salespersons being better able to discuss the benefits of EVs with customers.
•Government, automotive manufacturers and dealerships should consider further adoption of enhanced financial incentives and recognition for salespersons in an effort to increase EV sales.
•Assign a lead ministry or agency within the provincial government with a mandate to implement Ontario’s vision related to EV deployment. Provide a platform for communication and collaboration across different levels of government and among relevant stakeholders.

Pollution Probe also participated and submitted recommendations in response to the Government of Ontario’s Electric and Hydrogen Vehicle Advancement Program consultation. A number of these ideas may also be of value considering as MTO continues to gather feedback. In particular, the successful deployment of EV technology depends on actions and decisions taken by a range of individuals and organizations. As such, a new level of integration and co-ordination across a wide range of stakeholders, decision-makers and sectors including transportation, electricity, environment, infrastructure, natural resources and economic development, will be required. If not approached efficiently and proactively, coordination in the development of EV supportive policies and programs could cause delays at a critical point for the technology and may signal to the market that strong support does not exist.

As such, continued opportunities should be provided for collaboration and consultation on the part of a broad range organizations, including all levels of government. This will contribute to ensuring efforts are aligned across sectors and that the needs of the market are effectively addressed while continuing to evolve the program in a manner that will allow it to adjust to the changing needs of consumers and automakers. The establishment of a partnership of stakeholders to pursue a collaborative approach to the implementation of EV-related programming would be an effective means of ensuring a wide range of perspectives infuse the discussion, thus enhancing the value and relevance of potential outputs and increasing consumer acceptance.

In response to Section 4.2:

On eligibility requirements, evaluation criteria and technical requirements for workplace, MURB and downtown public charging infrastructure, key factors to consider would include: number of employees/residents/visitors at a given site, number of parking spaces, willingness of property managers/employers to manage, promote and maintain charging stations (and perhaps share in purchase and installation costs), proximity to existing public charging stations, proximity to popular destinations where drivers would tend to remain parked for an hour or more, estimated cost of installation, nearby traffic flow levels, site accessibility, and level of visibility.
The following should also be taken into consideration:

•A 2014 US DOE study (http://energy.gov/eere/articles/survey-says-workplace-charging-growing-…) showed that employees at workplaces that provide EV charging are 20 times more likely than the average worker to buy an EV
•Despite the fact that many employees would rarely need to charge their EVs while at work, the presence of charging stations nonetheless offers a substantial amount of reassurance to potential EV users
•Pollution Probe is currently developing a public EV charging station siting methodology that can be easily applied and adapted to municipalities or regions of any size. The provincial adoption of such a methodology (which would prioritize zones and sites within them based on a points system and a series of siting criteria that can be applied at macro and micro scales) would make the task of selecting sites and funding EVSE installation efficient and effective.

Another issue that should be addressed, either in collaboration with individual electric vehicle supply equipment (EVSE) hosts or at the provincial level, is the setting of standards around charging duration. Such standards will be relatively easy to enforce at fee-for-service charging stations (charging users for each hour/minute they are plugged in should offer enough incentive for them to unplug and move their vehicles after charging), but at stations where charging is complimentary or covered in the cost of parking, developing and implementing such standards will be more difficult. In jurisdictions where EV adoption levels are relatively high, such as the San Francisco area, incidences of “charge rage” are rapidly on the rise. These incidents typically involve EV users arriving at a destination where they require charging only to find that other users with fully-charged or unplugged cars are parked in the spaces adjacent to EVSE. All public parking spaces and associated EVSE in the province should have clearly indicated time limits for parking in EV-only spaces. Different limits will make sense at different locations and for different levels of charging stations. For example, Level 1 (or even Level 2) charging at an intermodal transit hub, where drivers will often have to remain parked for the entire day, could have no limit in terms of duration. Level 2 charging at workplaces or popular destinations, however, could have charging limits of three or four hours. Level 3 chargers could have limits of no more than one hour.

Government funding for public EVSE in Ontario should prioritize the installation of Level 3 charging stations along inter-city corridors. The high costs of Level 3 charging stations is currently a key barrier in terms of the private sector business case for their installation. However, Level 3 chargers are critical to facilitating long-distance trips via EVs and eliminating range anxiety. As more public charging stations are deployed, range anxiety will likely become less of a factor influencing EV utilization compared to recharging time. Not only do Level 3 chargers relieve EV drivers of the burden of having to wait hours to gain a significant amount of range, but they also relieve the likelihood of congestion and long line-ups at charging station sites. Due to the relatively low costs of Level 2 charging infrastructure, it is recommended that all sites equipped with Level 3 charging also have Level 2 charging capabilities (with additional parking for Level 2 charging), as this level of charging would be sufficient to recharge many plug-in hybrid vehicles relatively quickly (or to provide EVs with a top-up if that’s all that’s required), freeing up space at Level 3 charging sites.
Further, the relatively low costs associated with Level 2 chargers means that private sector involvement in their deployment is far more achievable and likely. Workplaces, landlords and retail establishments should be encouraged by government to offer Level 2 charging to employees, occupants and visitors. To support these efforts, financial incentives should be offered to charging station hosts, possibly taking the form of tax breaks or offset credits under the new cap and trade program. Increasing EV adoption rates also means that the provision of EV charging is simply good for business. The case of Peavey Mart, a hardware store chain based in Alberta that installed Level 2 charging stations at all of its locations, indicates that offering EV charging to customers is a cost-effective way to enhance sales and grow a loyal customer base. Companies such as Ikea are also capitalizing on this trend, recognizing the value in providing customers with charging. Similarly, landlords and employers can advertise the fact that they provide EV charging to prospective occupants and employees, as a value-added offering.

In response to Section 4.3:

In communicating the benefits of EVs, the government should recognize that cost and convenience are still the primary concerns of most drivers, as opposed to environmental benefits. Emphasizing that the total cost of ownership of an EV (which includes lifetime fuel and maintenance costs) is far less than a conventional vehicle despite the higher purchase costs should be a key component of promotional efforts.

Purchase incentives should also feature prominently in public awareness campaigns, as should the significant perk of free overnight charging (which means that EV users could theoretically fuel their vehicles for free, given the fact that roughly 90% of EV charging takes place at home, overnight). The number of public charging stations now operational in the province should also be highlighted, as should the rapidly increasing range of EVs.

In order to incent automakers to market and sell EVs – a product line that currently represents a small percentage of total market share – the government should consider offering tax breaks, subsidies or carbon offset credits for expenditures related to advertisements featuring EVs in the province. The drive to increase EV sales will inevitably oblige automakers to enhance marketing efforts, and these efforts should be incentivized and rewarded.

Most car-buyers now do the majority of their research into new vehicles online, and tend to show up at dealerships already knowing the vehicle(s) they want to enquire about and test-drive. More online educational resources dedicated to EVs should thus be encouraged from automakers and their dealerships, to ensure that car-buyers are made aware of what EVs can offer relative to their gasoline-powered counterparts. Simple total cost of ownership calculators, in which customers enter a few pieces of information like daily driving distance and vehicle size requirements, can help to introduce customers to an EV or plug-in hybrid model that may be right for them. A dedicated information platform on EVs should be established to provide comprehensive, authoritative and user friendly information and tools on EVs. This platform should be maintained by a consortium of organizations, including automakers, as no single organization currently has the public presence and resources necessary drive significant traffic to such a website.

EV salespeople and dealerships could be incentivized to implement EV training programs and increase EV sales by developing a “Find A Dealer” list that could be made available on government and partner websites and include dealerships specializing in EVs, with sufficient inventory and expert sales and service staff. On the topic of incentivizing private fleets to purchase EVs, a focus on economics should again take the forefront. Pollution Probe’s Project EVAN (Electric Vehicle ANalysis) culminated with the publication of the Business Case for Electric Vehicle Use in Service Vehicle Fleets. This document (available for download at: http://www.pollutionprobe.org/publications/project-evan-electric-vehicl…) clearly shows that even without purchase incentives, EVs offer a payback period of one to three years compared to their conventional vehicle counterparts. After that milestone has been reached, EVs begin saving fleet owners both time and money; and due to the predictability and stability of electricity prices relative to gasoline, managers can budget for fleet maintenance costs with increased accuracy. The Project EVAN report lays out a simple yet effective accounting mechanism for projecting savings related to EV adoption in fleets, and could be used to guide future developments in this area. Hosting high-profile events for fleet owners and managers, which would demonstrate EV technology and communicate how EVs could save them money while maintaining fleet performance is another strategy to incentivize private fleets to purchase EVs.

Pollution Probe would welcome the opportunity to meet with representatives at MTO to discuss the ideas presented in this submission or any additional strategies to enhance EV uptake in Ontario, including its submission to the Electric and Hydrogen Vehicle Advancement Program. Pollution Probe has an extensive body of work addressing barriers to EV adoption from consumer, industry, utility and government perspectives, and would be happy to share its insights.

[Original Comment ID: 196579]