Subject: ERO- 019-9373 Thank…

Subject: ERO- 019-9373

Thank you for the opportunity to provide feedback on proposed BE programming. As a leading Ontario-based provider of EV charging and energy management solutions for multi-unit residential and commercial properties, SWTCH Energy Inc. appreciates the chance to contribute to this important discussion.

Specifically, SWTCH is in favour of promoting energy efficiency programming through incentives to enable managed EV charging. These incentives represent an opportunity to meaningfully control load growth associated with electrified transportation and defer the need for new infrastructure in edge-case scenarios. Vermont's recent pilot provides a compelling example, where customers are remunerated both for responding to demand events and for contributing to asset deferral. While the LDC-led stream offers the greatest potential to benefit the distribution system, all streams have the potential to support the development of managed charging programs.

Ask:

Incentivize managed EV charging programs at Multi-Unit Residential Buildings (MURBs) through Energy Efficiency programming as a tangible measure to increase beneficial electrification and hasten fuel-switching. This can occur through customer remuneration opportunities where chargers already exist, or through providing incentives to install managed EV chargers.

Rationale:

Load Management Benefits: Managed charging strategically spreads electricity demand across different times of day, preventing sudden peak loads that could increase overall system costs. This approach can defer or potentially eliminate the need for expensive grid infrastructure upgrades, ultimately keeping electricity rates more stable for all consumers.

Fuel Switching Cost Optimization: As Ontario promotes transitioning from gasoline to electricity, managed charging supports this shift by making electric vehicles (EVs) more financially attractive. By incentivizing networked EV charging installations in multi-unit residential buildings (MURBs), the system enables cost savings for consumers who otherwise must overcome higher costs and more barriers for installation. Combined with time-of-use (TOU) rates, this approach creates predictable charging schedules for grid operators while reducing the total cost of ownership for electric vehicles.

Leveraging Ontario's Electricity Advantages: With Ontario's largely non-emitting electricity mix and smart-metering technology, managed charging can maximize the economic and environmental benefits of electrification, creating a more cost-effective and sustainable transportation ecosystem.

Benefits to all Ratepayers: Affordability is crucial for any beneficial electrification initiative. According to the Regulatory Assistance Project's research, electrification can help distribute fixed grid infrastructure costs across a broader base of electricity consumption. This cost-sharing mechanism potentially reduces per-kilowatt-hour rates for all consumers, even those not directly participating in electrification, by improving overall grid economics and infrastructure utilization.