Hello, Thank you for…

Hello,

Thank you for providing this opportunity to give feedback on proposed amendments to the Electricity Act, 1998, Ontario Energy Board Act, 1998 and the Energy Consumer Protection Act, 2010 to enable an affordable energy future. On behalf of Niagara Transit, we would like to submit that the following be included in changes to these acts:

Re-allocate connection costs of EV chargers away from the customer (transit agency):

o Local Distribution Company Capacity

Where transit agencies are seeking to connect EV bus chargers at their preferred location, but the Local Distribution Company (LDC) identifies that there is a lack of capacity in the distribution system or the transmitter identifies that there is a lack of capacity in the transmission system at that location, this lack of capacity impedes the connection. If the necessary upgrades were made and funded by the transmitter or distributor instead of the transit agency, it will facilitate the move to EV buses.

o Excessive Connection Costs for Transit Agencies with EV Chargers

Where transit agencies are installing EV chargers for buses but encounter excessive connection costs on either the distribution or transmission system that put the project at risk, it would facilitate the process to move to EV buses if the transit agency had an exemption from these connection costs, and/or the costs were allocated to the transmitter or distributor instead.

Changes in process, such as having a standardized application for connections by transit agencies for a group of EV chargers:

o Standard Connection Agreements

If the Ontario Energy Board Distribution System Code provided a Form of Connection Agreement for Local Distribution Company (LDC) to follow when connecting transit agency facilities, it would provide clarity for transit agencies and keep the process consistent across Ontario regardless of which LDC was involved with the connection.

Thank you for your consideration,

Niagara Transit