We fully support the Ontario…

We fully support the Ontario Energy Board's decision to offer an ultra-low cost charging rate to users.

We fundamentally believe that this policy will help in shifting load from peak hours of consumption, to the overnight periods when there is excess supply from baseload electricity.

We also welcome the decision to incentivize adoption of electric vehicles. The electrification of transportation, particularly of public transportation and the delivery sector, are both going to play a critical role in the fight against climate change and increasing greenhouse gas emissions from the transportation sector. By creating a business case for companies to adopt electric alternatives to gasoline or diesel, we are creating a safer, cleaner and more prosperous Ontario.

We would also ask that the Ontario Energy Board strongly consider the needs of commercial and industrial tier customers on the Hourly Ontario Energy Price (HOEP) as well as customers on residential and small commercial TOU rates in this offering. It is our belief that by expanding the classification of those that can enter into the program, with a specific commercial tier offering that is unique to the billing classifications of higher use customers (who are more likely to have a fleet of electric vehicles), that addtional load could be shifted, and even greater adoption could occur.

As a result, we would like to see the ability for commercial clients with an electric fleet have a clear option to opt-in to this program at the LDC level, even if they do not currently fall onto TOU pricing which is historically reserved for consumers under 50kW in many LDC's by their Conditions of Service. Either the customer should be allowed to move their entire operation to a TOU price structure to take advantage of this rate (even if they have an industrial or commercial facility), OR there should be a clear procedure for permitting a large commercial fleet entry into the program, whichever is determined to be more prudent.