Tesla is grateful for the…

Tesla is grateful for the opportunity to contribute to the consultations regarding the province’s first integrated energy resource plan. As we work together to address anticipated energy demand growth over the next 25 years, we recognize the critical role of expanding electric vehicle (EV) charging infrastructure in shaping EV adoption and supporting the broader transition to electrification through the deployment of residential and grid-scale battery storage and rooftop solar. We have carefully selected key questions and provided our insights on how Ontario can better plan and accommodate for a sustainable energy future.

Tesla is a sustainable energy company that manufactures and sells electric vehicles, EV supply equipment, solar and energy storage products. Tesla's mission is to accelerate the world’s transition to sustainable energy.  Tesla is focused on creating a complete clean energy ecosystem, ranging from solar generation and energy storage to all-electric vehicles that produce zero tailpipe emissions. 

Tesla is the largest supplier of EVs to Canada and one of Canada’s largest EV industry employers, with employees working in manufacturing and machining, research and development, administration, infrastructure, and vehicle sales/service. Tesla is also the largest supplier of industrial scale battery energy storage systems (BESS) in Canada with over 435 MWh of capacity deployed across 46 sites and another 5.3 GWh+ contracted or under construction, with the majority of this build-out taking place in Ontario. Tesla designs and manufactures automated factory equipment, for use in the production of battery cells, in Markham and Richmond Hill, Ontario.

Input regarding the Integrated Energy Resource Plan

1. What actions should be prioritized to enhance planning across natural gas, electric and other fuels?

To enhance planning, the province should prioritize collaboration with key stakeholders in emerging business sectors. This will provide valuable insights into potential significant load increases that may materialize rapidly and are not reflected in historical data. Key trends driving greater electrification demand include building electrification, transportation electrification (light-duty vehicles and medium/heavy-duty vehicles), data center expansions, advancements in AI, and other evolving industries.

2. The Government’s priority is to ensure Ontario has the energy resources it needs to support growth. Are there opportunities to enhance the province's approach to procuring electricity generation supply to better serve this priority?

To better support Ontario’s growth, there are clear opportunities to enhance the province’s electricity generation procurement approach to energy storage. The province has quickly become a lead procurer of batteries in North America, but by viewing batteries only as a capacity resource, Ontario is only scratching the surface of the value that BESS can provide to help Ontario meet its ambitious goals for growth while maintaining affordability. Not only can storage act as reliable, fast-acting peak capacity for the grid, but it can also be deployed in innovative ways to resolve other problems facing grid operators, on deployment timelines that are much faster than traditional solutions. One relatively easy way to get more value out of the storage that has already been procured and the storage that will soon be procured is to incentivize existing BESS projects and to require future BESS projects to provide “grid forming” capability. Grid forming uses advanced inverter and control capability to automatically and almost instantly respond to changing grid conditions. Grid forming thereby directly contributes to the grid’s stability and flexibility. By using this feature, the grid planners of Ontario can increase the capacity of the existing transmission infrastructure by resolving grid constraints that currently prevent new generation and loads from connecting to many parts of the provincial grid.

To preserve and continue to build public confidence in this critical technology, Ontario should engage with industry and adjust its procurement mechanisms to incentivize projects to use only high-quality BESS that meet the highest cybersecurity, safety, environmental and cold weather performance standards.

Ontario can adopt a comprehensive “all-of-the-above" strategy to diversify its energy resource mix. As demand grows, particularly from emerging industries, it is critical to continue decarbonizing while leveraging innovative solutions like energy storage to effectively manage system peaks. By integrating both existing and new generation sources with advanced energy storage, Ontario can sustainably expand its generation capacity. This approach also presents an opportunity to strengthen market structures and optimize interconnections with neighbouring territories, ensuring a reliable and resilient power supply.

3. What actions should the government consider promoting greater access to electricity and accelerate grid-connections that will support economic growth, connecting new homes, electrifying transportation and heating?

To promote greater access to electricity and accelerate grid connections for economic growth and transportation electrification, the government should consider the following actions:

a) Expand and enforce the EV Charging Connection Process (EVCCP):
The Electric Vehicle Charging Connection Process (EVCCP) is expected to increase stability and business certainty for public EVSE owners. However, with little EVCCP enforcement, connection timelines remain inconsistent. In addition, utility processes not regulated under the Distribution System Code (DSC) continue to lack transparency. These challenges are compounded by equipment shortages and planning delays, frequently pushing installation schedules into subsequent construction seasons. To address these barriers, LDCs should be mandated to develop proactive electrification preparation plans that include maintaining strategic inventories, particularly the procurement of transformers and switchgear that are essential for EVSE installations. Equally important is establishing clear, enforceable timeline requirements for all connection processes, including those not governed by the DSC or EVCCP.

b) Enable proactive planning for large-scale projects: Encourage major customers, such as EV charging developers, to share project plans early to help utilities anticipate and prepare for large, incoming loads. This proactive approach would facilitate timely connections, especially for high-demand locations. Strategic grid upgrades in critical transportation areas, like public charging stations requiring up to 10MW of power, should also be prioritized.

c) Require utilities to offer US-standard 480V services when requested by a customer: Ontario is currently using the 600V utility standard, which is not compatible with Electric Vehicle Supply Equipment (EVSE), predominantly designed for the 480V North American standards. This technical incompatibility, in addition to the smaller market covered by EV charging networks in the province, causes frequent delays of installations, additional labour and equipment costs as the 600V service requires step-down transformation for EVSE (up to $40,000 per installation in 2024). Due to the small size of the 600V service market, OEMs find it economically unfeasible to design equipment specifically for it. Offering a secondary 480V service would reduce red tape that often causes EV charging projects to delay their deployment, leveraging the broader North American market while improving equipment availability. To address these challenges, local distribution companies (LDCs) should maintain inventories for 480V equipment to ensure the pace of electrification meets the ambition of the government (particularly EV adoption and GHG emission reduction) and the needs of private investors. Additionally, a task force should explore pathways to address this market misalignment, and programs should be developed to offset transformation costs.

d) Plan for scalable charging solutions, such as 1.2 MW Tesla V4 Supercharger cabinets, which can support both high-power public charging and lower-power private fleet needs. For example, these power cabinets can deliver up to 600 kW for medium-heavy-duty vehicles or distribute power across multiple posts for overnight charging. By adopting these measures, Ontario can streamline grid connections, support electrification, and ensure sustainable growth.

4. How can provincial planning processes be enhanced to support high growth regions, ensure greater coordination between energy resources, and better integrate municipal, distributor and regional planning processes?

To enhance provincial planning processes and support high-growth regions, greater coordination and integration between energy resources, municipalities, distributors, and regional grid planners is essential.

One key area to explore is treating grid capacity as a critical enabler of economic development. As industries such as EV manufacturing and battery mineral processing, data centers, and others expand, access to reliable electrical capacity is becoming a primary – if not the single most important, input for their operations. Strengthening collaboration with various entities, including funding sources, can ensure that grid power availability keeps pace with the demands of these emerging industries.

By aligning planning efforts across all stakeholders and prioritizing grid capacity as a driver of economic growth, the province can better position itself to meet the needs of high-growth regions while fostering sustainable development.

While outside of the electricity-sector directly and less impactful than building code changes, leveraging the Provincial Policy Statement (PPS) as a means of requiring municipalities to plan for the full electrification of transportation in their communities (including through zoning and other land use tools) may be helpful. This action would enable utilities and municipalities to work together on grid planning. (Note, utilizing the Ontario Building Code would be an even more effective tool to give clarity and certainty to utilities).

5. What cooperation opportunities exist across other jurisdictions to support energy trade, construction of transmission infrastructure (ex. pipelines and interties), and transportation electrification?

To support energy trade, transmission infrastructure construction, and transportation electrification, the province should focus on strategic collaboration and clear communication with stakeholders.

One opportunity is to provide charging developers with transparent, detailed information about existing grid capacity for transportation electrification. Highlighting areas with available capacity for both light-duty and medium/heavy-duty vehicle charging can significantly influence where developers choose to build. This approach positions grid capacity not only as a driver of economic development but also as a strategic policy tool to encourage infrastructure construction in targeted locations.

While this method does not guarantee developers or customers will priorities these areas, grid capacity along major highway corridors is likely to incentive the development of charging infrastructure. By aligning grid availability with transportation and economic priorities, the province can enhance cooperation and support key infrastructure growth in key regions.

6. What types of technical information and forecasts would best support sector participants and energy consumers as the system is built out for growth and the economy increasingly electrifies?

Capacity maps are a vital resource in supporting EV charging infrastructure and distributed energy resource (DER) deployments. Tesla fully supports the Ontario Energy Board’s (OEB) recent proposal and encourages expediting Phase 2 of the capacity maps process, aiming for completion by Q3 2025.

These maps would provide critical insights for charging station owners and operators, helping them identify financially viable locations for short-term installations and highlighting areas where utility upgrades will be required to enable network expansion in the medium to long term. By offering clear and actional technical information, capacity maps will play a crucial role in guiding investments, optimizing planning, and ensuring the efficient growth of electrification infrastructure.

Affordable and Reliable Energy:

7. What further steps should the government take to enable households and businesses to manage and make informed decisions about their energy use?

The government should consider implementing time-of-use rates for Non-RPP Class B customers to encourage EV charging installations in multi-unit residential buildings. Time-of-use rates provide a more predictable operational cost structure, incentivizing off-peak charging and supporting efficient energy use.

In the public commercial EV charging space, time-of-use rates and price signals are equally beneficial. Current non-coincident demand charges fail to incentivize charging operators to adopt customer-facing time-of-use pricing models. Introducing time-of-use pricing for public charging infrastructure would encourage more consistent and effective price signals, helping both households and businesses make informed decisions about their energy use while optimizing grid efficiency.

8. What actions could the government consider ensuring the electricity system supports customers who choose to switch to an electric vehicle?

The government can consider implementing EV-ready electrical code requirements for new multi-unit residential buildings to ensure power capacity is included in new developments as they are constructed. This would require that new residential buildings include appropriately sized electrical service during the construction phase, eliminating the need for costly upgrades and retrofits in the future. By proactively addressing infrastructure needs, this measure would make it easier and more affordable for residents to transition to electric vehicles, while also supporting the broader electrification of transportation.

Distributed energy resource investments in new subdivision communities could also be considered as a requirement. Home-based solar and energy storage can take significant pressure off the electricity grid (while even introducing new generation capacity). See Tesla’s response to Question 9 for more details on how this could be achieved.

9. What actions should the government consider, that would empower customers to install innovative technologies to generate or store energy on-site to reduce costs and improve resiliency?

To empower customers to adopt innovative on-site energy generation and storage technologies, the government can consider the following actions:

(1) Enable the installation of meter socket adapters (MSAs) to facilitate faster, more cost-effective installation of distributed energy resources (DERs) by reducing the need for extensive requirements and panel upgrades. While MSAs do not directly generate or store energy, they make rooftop solar and residential battery storage systems more accessible and affordable, empowering customers to adopt these technologies.

(2) Simplify and streamline DER interconnection process. This can be done by ensuring that interconnection procedures are fast, straightforward, and support the use of Power Control System (PCS) functions. PCS capabilities allow DERs to mitigate their grid impact, reducing interconnection costs for both DER owners and ratepayers.

(3) Leverage PCS to optimize grid hosting capacity. By enabling DERs to use PCS functions, the government can enhance grid efficiency, reduce the need for costly upstream upgrades, and allow more DERs to connect and meet customers’ on-site energy demands. This approach not only helps minimize costs but also enhances grid resiliency while supporting broader DER adoption.

These measures collectively improve the economics of DER ownership, incentive deployment, and can empower customers to reduce energy costs and improve resiliency.

10. What policy or regulatory changes should the government consider addressing financial risks and support the adoption of DER in the long-term?

To address financial risks and support the long-term adoption of distributed energy resources (DERs), the government should consider the following policy and regulatory changes:

(1) Implement Virtual Power Plant (VPP) programs. VPPs enable DERs to provide capacity, alleviate grid stress, and deliver additional avoided-cost benefits. These programs can support the adoption of both residential and commercial batteries, with many battery demand response initiatives accommodating participation from both sectors. VPPs enhance grid efficiency and resilience while delivering value to participants and ratepayers.

(2) Introduce upfront incentives for residential batteries. To promote DER deployment and VPP participation utilities could shift a portion of the ongoing VPP value into an upfront incentive. In exchange, batteries receiving the incentive would be required to participate in the VPP, ensuring they deliver consistent value to the grid and ratepayers. Examples from the U.S. show such programs can effectively reduce costs for ratepayers while encouraging DER adoption.

(3) Simplify interconnection processes. Streamlining and expediting interconnection procedures for DERs and ensuring they support the use of Power Control System (PCS) which can help simplify processes. PCS capabilities allow DERs to minimize grid impact, reduce interconnection costs, and optimize grid hosting capacity.

(4) Permitting the use of MSAs. MSAs enable faster, less expensive installation of residential DERs by reducing the need for extensive rewiring or electrical panel upgrades. This approach makes DER adoption more accessible and affordable for consumers.

(5) Streamlining permitting and building/fire codes. Ensuring that permitting processes and building/fire codes do not create unnecessary cost burdens, delays or complexities for DER deployment. Clear and efficient regulations can lower barriers and accelerate adoption.

(6) Require municipalities plan for transportation electrification, across all land use classes, through the Provincial Policy Statement (PPS).

These measures provide a comprehensive approach to addressing financial risks, reducing barriers and encouraging the widespread adoption of DERs, ensuring a more resilient and sustainable energy system.

Thank you for this opportunity to provide comments regarding the province’s first integrated energy resource plan. We look forward to additional opportunities to participate in this important initiative.