A Response from the Ontario Ministry of Transportation to our EV Program Review

I received the letter below from Jamie Austin, the Director of the Transportation Policy Branch MTO. The original letter is here, I have made the text available below and I have added links to the programs Mr Austin discusses.  I am very grateful to Mr Austin for taking the time to respond and I think he is offering some insights into how the Province will address the issues we see with the EV programs.  As a community we still have a lot of work to do to address some of the policy gaps.

Our review is here, I suggest you read it first if you have not seen it before.

 

 

Dear Mr. Eglin,

Thank you for your email to the Honourable Steven Del Duca, Minister of Transportation dated October 5, 2017 and your emails regarding your review of Ontario electric vehicle programs. I appreciate your interest and enthusiasm for electric vehicles, and assure you that we share your ambitions for the electrification of transportation in Ontario. As a follow up to our brief discussion on these matters at the ITS World Congress in Montreal, I am happy to respond to you in greater detail on behalf of the Ministry of Transportation.

Electric Vehicle Incentive Program (EVIP) and Electric Vehicle Charging Incentive  Program (EVCIP)

I appreciate your positive feedback of EVIP and EVCIP, and acknowledge that there have been unfortunate delays in processing applications for these programs. While I am happy to report that demand for these programs has significantly increased over the last year, this led to a backlog in processing applications and making payments to program recipients. The Ministry of Transportation has recently committed new resources to the management of these programs in order to address both the current backlog and ongoing increased demand, and I’m pleased to say that this issue should be mitigated in the near future.

Electric Vehicle Chargers Ontario (EVCO)

EVCO was an application-based program that received an overwhelming response of over 200 applications. Applicants identified what they felt were good locations for the deployment of EV chargers. Because program recipients are responsible for the ongoing maintenance and operation of the chargers it is important that they themselves choose the locations, giving due consideration to the business plans under which they operate. Through the evaluation process, cost efficiency, appropriateness of the site and the number of stations per site were carefully considered, with a focus on the greatest possible connectivity of the network from among the eligible applications received.

As you have noted, there are a number of chargers that are planned under the EVCO program that are not presently listed on our website/program map. For a number of reasons, such as site conditions or host business decisions, some sites originally planned under the EVCO program have been determined to be unsuitable. In these cases wherever possible, EVCO program recipients have been proposing replacement sites to the government for consideration. These sites are added in to the EVCO map as they are approved for inclusion in the program. Where alternative locations cannot be found, projects will be modified to a smaller number of chargers/locations and the government will recover a portion of the funding that was allocated. The program is currently tracking towards the installation of nearly 300 level 2 chargers and over 200 level 3 chargers at approximately 250 locations across the province, and is currently two-thirds complete.

I note you have also observed some customer service issues with EVCO recipients. We do expect that EVCO recipients, and particularly operators of level 3 chargers, operate a 24/7 toll-free customer assistance number so that drivers can report outages and malfunctions, obtain assistance with point-of-sale and customer authentication, or to request assistance operating the charger. We are working with EVCO recipients to ensure they are meeting these expectations and we believe the issues that you have observed will improve over time.

Moving forward, we will be working to implement actions in the Climate Change Action Plan (CCAP), such as the rapid deployment of charging in government facilities, workplaces, multi-unit residential buildings, downtowns and town centres. CCAP includes up to $80 million over four years, for the continued deployment of EV charging infrastructure. We will be launching the first programming with these additional funds in the near future. As part of our program planning, we are monitoring the use of EVCO charging stations to better understand remaining service gaps. As we move towards our future plans, we will be sure to keep your suggestions in mind and welcome any additional suggestions that you may have.

I should also acknowledge the investments that the federal government is making in charging in Ontario, including projects under the Electric Vehicle and Alternative Fuel Infrastructure Deployment Initiative (EVAFIDI) and the Energy Innovation Program (EIP). We are also working closely with Natural Resources Canada to identify other opportunities for investment in Ontario.

Reduced Output Fast Chargers

Your observation about some level 3 chargers having reduced output in your review and your email addressed to Minister Del Duca is correct, as is your assessment about the root cause – that 50 kW is the threshold after which higher demand fees are incurred. This is in part associated with local distribution company (LDC) policies across the province, many of which will not permit secondary electrical services to a property for safety considerations. Accordingly, some EVCO recipients have reduced the total output of fast chargers to between 30 and 40 kW. Under a program like EVCO, the only alternative would be significantly fewer chargers or to have level 2 chargers installed. We understand your concerns about this matter and are currently determining the best approach to ensure that this information is communicated to the public transparently.

Cost of Charging

Recognizing that EVCO program recipients are responsible for all operating and maintenance costs of the chargers installed as part of their projects, the province did not specify the rate that would be charged by public charging stations. Fees are set by the owner/operator of the charger, and you will find a variety of fees across the province ranging from free to $17/hour, depending on the charging speed and other factors (i.e. parking included, etc.). We are monitoring the pricing for EV charging in Ontario at both EVCO and non EVCO chargers and reserve the right to intervene where the province determines fees at EVCO chargers are unreasonable.

With regard to kWh pricing for EV charging, there are additional regulatory considerations which fall under the authority of Measurement Canada, specifically under the Weights and Measures Act. The province of Ontario has had an open dialogue with the federal government on this through work related to the upcoming national Zero-Emission Vehicle (ZEV) Strategy, and we are monitoring the federal government for any regulatory changes or developments. Chargers installed as part of the EVCO program were required to have the capability to charge by kWh, so if and when these federal rules are changed EVCO recipients will have the flexibility to use kWh pricing if they choose.

EV Supply Management

Ontario has not opted to proceed with establishing a ZEV mandate, such as the approach taken in Quebec, as Ontario believes that a collaborative approach with a province-wide sales target that represents a collective goal will be the most effective approach. Through the Electric and Hydrogen Vehicle Advancement Partnership (EHVAP), the province is working closely with automakers, unions and other interested stakeholders to ensure that there is an adequate supply of EVs available in Ontario to meet demand over the next few years. We are also monitoring EV policies from other jurisdictions, including Quebec, with a particular interest on any potential impacts in Ontario.

In closing, I would like to thank you again for your feedback on Ontario’s electric vehicle programs. We are continually looking for opportunities to improve and adapt our programming to meet a fast evolving sector. I believe that we share the same enthusiasm for electric vehicles and optimism for the potential they offer to reduce greenhouse gas emissions, improve air quality, and lower transportation costs for all Ontarians. Thank you for your commitment to the electrification of transportation in Ontario.

Sincerely,

Jamie Austin Director

  1. Darryl Soshycki, Manager, Sustainable and Innovative Transportation Office, Ministry of Transportation

The Cost of EV Public Charging – The Untold Story

What if I told you that from now on, in order to fill up your gas tank you had to pay $5 to put the nozzle in, and then pay per minute to get some random flow of gas. You have no control over how fast or slowly the gas comes out of the nozzle, but when your time is up, if your tank is not full yet, you will have to put in another $5 to get more minutes of flow, and repeat until full. Sounds crazy, right?! Well, this is exactly what we have at the worst of the EV chargers. Over the summer we carefully logged our travels in our new e-Golf, and discovered that road-tripping costs at least as much in an EV as it does in a fossil. In fact, gas costs could actually be cheaper, depending on the chargers you use, and the time savings per fill-up are substantial.

How can that be true, you ask? Everyone knows it only costs a few dollars to plug into a public charger, where it costs $40 or $50 whenever you go to the gas pumps. Well, if you are like me, and amps and kilowatts are a foreign language, it’s easy to be fooled into a false sense of economy.

There is no standardization in the current charging infrastructure, so sometimes you can charge your car for free, sometimes you are quoted an hourly rate, sometimes a fixed fee, and sometimes a combination, such as a connection fee and a per minute rate. Is that confusing enough? It gets worse, because even if you could do the math to compare those rates, the big unknown is how much power the individual charger will put out (this is the technical part about amps – refer to Matthew’s recent post Ontario’s EV Program, a User’s Review” if you want a full explanation of that).

For our e-Golf’s efficiency rating of 17.4KWh/100kms, it takes over an hour, and costs more than double the price of gas to get enough KWh’s to drive 100kms! But I needed an app to do that calculation. If only charging was sold by the kWh – then all I would need to do is replace litres with kWh’s in the typical fuel efficiency equation of  “L/100kms” to make my comparison.

Time and Cost to add 100km range at a typical KSI DC Fast Charger

We did a calculation comparing the different charging networks encountered on our trips, and this is what we found when we compared apples to apples. Putting everything into the same units, the cost to travel 100 kilometres, and comparing that to the cost of the gas required to cover the same distance in an ICE vehicle, the costs are all over the place from free right up to “Ouch”.  Because of the wild west nature of EV charging, without careful planning and some inside knowledge  EV charging can cost way more per kilometre than gas!  And to add insult to injury, it takes a lot more time to fill up at a charger than at a gas pump.

To be clear, if you mainly charge at home, the amount added to your electricity bill is definitely way less than the cost of gas. And if you only take a few road trips a year, this is probably not really going to worry you that much. But for anyone who does not have access to a home charger, such as out-of-town travellers, and local condo and apartment dwellers, who must rely on public chargers, the economics of charging an EV are way out of line.

The Electric Vehicle Chargers Ontario (EVCO) program that is providing funds for Level 3 chargers across the province, failed to provide clear specifications for the output, so many of these are way more expensive than gas. The City of Ottawa’s proposed EV Charger Policy risks falling into the same category if it follows the same path. This is counter-productive to all their other programs aimed at promoting EV’s as a more environmentally sustainable mode of transportation. Never mind range anxiety, who would buy an EV if they knew that charging it while on the road might cost two or three times as much as gas, and add two or three hours to the trip?

It’s easy to see how consumers could misunderstand the cost of public charging, and I am afraid that the policy makers are no more clear on the concept than the rest of us. They need to identify their target markets, and provide reasonably priced charging options for each market segment in order to make EV ownership viable for all. The way things stand, city dwellers who do not have access to their own home charger, and tourists or long-distance travellers, both face a serious disincentive to EV ownership. And that is the untold story of EV public charging in Ontario. Who knew?

Something missing from all EV chargers

 

 

EVs are Traffic Too

In the before time, when we still had a fossil car we had a rule, we did not take the car out for one errand. One errand was a walk or a cycle to the closest store, not perhaps the cheapest but we saved on gas to make up the difference. We tried hard to make sure we had at least three errands to do in the same end of town before we pushed another dinosaur out into the atmosphere. When we reached enlightenment with Electric Alice that rule went out the window. With no pollution, low costs and even lower guilt, we were freed to drive whenever we felt like it.

In the last couple of weeks and after driving 12,000 km since July, it has become clear to me that this freedom comes at a cost – traffic. Arriving late somewhere we, like most people say we were stuck in traffic, but this a lie, the honest way to phrase this is “we were traffic and traffic was slow”. EVs are great in traffic, quiet, easy to drive and with one foot driving being in traffic is far less taxing than a fossil car.

But we are traffic too, we might not pollute but we can contribute to congestion and by the same measure contribute to pollution indirectly.

With an EV, the personal cost of being in congestion is reduced.  An EV is easier in traffic, and more relaxed generally, so it is more tolerable to sit in a traffic jam. The personal cost gets less as the cars get smarter. Tesla, Nissan and VW all sell EVs that will just follow the car in front in a jam, taking over much of the driving task. If we take this to the extreme with autonomous cars (should this turn out to be possible, more on this point in a later post)  the personal cost of traffic congestion is almost completely removed. You could work, sleep, play just as you might on a train.  You have to wonder if autonomous cars are going to need a washroom and a club car to be really successful.  There is a real chance that the move to more automated EVs will mean more traffic. A lot of the rest of traffic will still be burning dinos, reducing the benefit of electrification through congestion.

Fleets of shared self-driving cars, such as Waymo and Uber are proposing would be catastrophic for traffic if they succeed as a large scale replacement for personal cars.  Each trip with passengers will require an extra trip for pick up.  50% of traffic from these services will be empty.  As a replacement or supplement to transit, the issue of traffic is even worse.

Widespread electrification could impact cities with congestion charges like London. With the current system, EVs are not charged to enter central London, but if significant percentage of all vehicles are electric there is quite the potential for gridlock. Policies will have to be adjusted to ensure traffic can flow and that the streets are not totally given up to cars and trucks, no matter how green they are.  Oslo, perhaps the most electrified city in the world will start to charge EVs to enter the city centre as of January.  The charge is small (€ 1.1 vs € 4.7 for a petrol car) but will rise again in 2020.

So, my plan is to try to go back to the three errand rule, at least when there is a lot of traffic. Walking and cycling are still better for the world, even if you drive an EV.

Ontario’s Electric Vehicle Programs – A User Review

The Government of Ontario has a broad set of policies and programs aimed at promoting electrification in the province.  As a user of many of these programs I think a personal review might be of benefit to other users and the managers of the programs.

 

http://www.mto.gov.on.ca/english/vehicles/electric/index.shtml

Program Reviews

Electric Vehicle Incentive Program (EVIP)             B

The EVIP is designed to subsidise the purchase of EVs, based on factors such as battery capacity and number of seats, the EVIP delivers an incentive  of between $3000 and $14,000 depending on model.  We qualified for the full $14,000 and this was processed by the dealer when we bought the car.  The incentive brought the price of our car into a similar price range as a fossil car of the same make.  By removing the premium for EVs, it allowed us to consider an EV when we would likely not have been able to afford one without the EVIP.

As a way of seeding the market and ensuring demand this program has been very successful.  It has created long waiting lists for EVs in Ontario and has to be regarded as successful.  This has highlighted a lack of effective supply side policy, but I will come back to this later.

My personal take on the incentive is I have been paid $14,000 to be an ambassador, I am happy to help promote EVs and share my experiences.  But even if other beneficiaries of the program don’t share this view, just by being present on the road shows that EVs are now a normal choice of regular people.   

The only thing standing between EVIP and an A are the delayed payments.  The province did not have enough staff to process the payments quickly and there is a large backlog.  Most dealers will not process the incentive on behalf of their customers due to long delays in getting paid. This means that the customer has to pay the $14,000 out of pocket and wait months for the cheque from the province, this reduces the affordability of EVs.  I understand that more staff have been hired to process payments.  Hopefully this will improve quickly.

 

Electric Vehicle Charging Incentive Program        B+

This is a small program that provides a 50% incentive for both a home charger and the installation of the charger, up to $500 for each.  This program is small in value compared to the EVIP but it has some great features that will help grow the EV market.  Firstly the incentive is only available for chargers bought in Canada from a Canadian source.  Without the incentive I would have saved some money and imported a charger from the US.  With the incentive, I used a dealer in Ontario.  The Canadian distributors and manufacturers are helped to grow and this will ensure that EV chargers are sold and supported in Canada.  This is great choice by the province and means that you can go to Home Depot and pick up a charger just like any other appliance.  The program also requires an electrical inspection ensuring that the charger is safely installed.  

Once again, the only thing reducing my mark is the slow processing of payments, I have yet to receive my payment after 3 months.

Electric Vehicle Chargers Ontario (EVCO)                         D-

The EVCO grant program was intended to fund a large role out of Level 2 and Level 3 chargers with a completion date of March 2017.  Funding of $19,845,122 is intended to deliver 274 Level 2 chargers and 211 Level 3 chargers.  Level 2 chargers are slower chargers and are suitable for sites where users will spend 2-5 hours such as hotels, parking etc, Level 3 chargers are faster and suited to places where the stay is 40 minutes or less and along a travel corridor.

Without the EVCO program, long distance travel by EV (other than Tesla) would not be possible at all.  The program has problems but these have to examined remembering that there were next to no level 3 chargers on the highways of Ontario before this program.

Missing Chargers

At seven months after the target date of the promised over a third of the chargers have not been delivered.  Of the 274 promised Level 2 chargers, 50 are “coming soon”, with no plans for the final 42 and of the 211 Level 3 stations, 24 are “coming soon”, with the final 53 not planned .

I think this delay is understandable and forgivable, it is hard to plan a large project like at well over 200 sites, some delay is inevitable.  Perhaps less understandable is that 42 Level 2 and 53 Level 3 chargers are not accounted for.  It is unclear from the data available if these chargers are in process somewhere or if these are not going to happen.

Lack of Network Design

The design of the public network of level 3 chargers has favoured urban and suburban locations rather than the highway locations needed to enable long distance travel. There are significant gaps east and west of the GTA that are not yet filled.  There are currently no plans for fast chargers at any of the 400 series highway service centres.  

Low Power “Fast” Chargers

However, there are some more critical issues with the program.  A large number of the Level 3 chargers that are intended to charge at 50 kW are restricted to much lower power.  Koben Systems Inc (KSI) won over half of the available funding under the EVCO program with a promise of 152 level 2 chargers and 126 level 3.  Many of KSI’s level 3 chargers are limited to 50 amps, outputting about 20 kW.

The time taken to make a trip longer than the range of an EV is highly dependant on the time it takes to charge.  Using a charger rated at 50 kW, an EV will extend its range at about 250-280 kph.   A charger limited to 20 kW will give about 110-130 kph. Driving 500 km beyond the range of an EV will take about 2 hours longer using restricted chargers compared with chargers operating at full power.

The chargers that are limited share their power feed with the host site and this causes a problem with Ontario’s demand pricing for electricity.  Exceeding 50kW even once changes the class of an electrical service, increasing the overall cost of power significantly.

It appears that the vast majority of KSI stations are limited to 20 kW (50 amps) and as they are due to deliver 126 of the 211 the negative impact on the public charging network is extensive.

With so many of the chargers in the public network unable to deliver a truly fast charge, the prospects for long distance EV travel in Ontario are not good.    

KSI also has severe support issues.  Unlike any of the other charger network, the support line is not answered by someone able to do anything with the chargers.  They promise that “support will call back” but it is unclear if they ever do.

The Province failed to provide clear specifications for the level 3 chargers and support processes and as a result we are left with a mess, fast chargers that are slow and non-existent support for the majority of the charging stations.

Cost of Charging

Currently, EV charging stations charge either based on time or a connection fee plus time.  This model incentivises lowering the power of a fast charger to increase the time connected and the fees paid for a charge.  

In my view, the fairest way to charge for level 3 charging is a small, fixed connection charge and then a per kWh rate that is published. EV charging stations need to be regulated in exactly the same way gas pumps are, from a consumer’s point of view there is no difference.

For KSI Level 3 chargers the combination of reduced power, their fee structure can push the cost of a charge to double the cost of gas for the same journey.

KSI fees at a power restricted Level 3 Charger

Charge Time Charge Cost 1 Range Added Equivalent

Gas Cost 2

20 minutes $          8.95 44 km $      3.47
30 minutes $        10.95 67 km $      5.20
40 minutes $        12.95 89 km $      6.93
50 minutes $        14.95 111 km $      8.67
60 minutes $        16.95 133 km $   10.40

1 Charging cost based on KSI rates ($4.95 connection fee and $0.20 per minute) on a charger limited to 50 amps.

2 Gas cost based on $1.20 per litre and consumption of 6.5 l/100km.

Families with a conventional car in addition to an EV are far less likely to undertake long journeys in their EV if it costs them more and takes them a lot longer due to KSI’s chargers.

The EVCO charging network requires regulation and policy changes to move EV long distance travel from possible to the best alternative.

Quebec’s network of Level 3 chargers consistently delivers fast charging at a much lower price.  A 30 minute charge will deliver 133 km and cost $6 on an Electric Circuit station, 64% cheaper and 100% faster than KSI delivers in Ontario.

EV Supply Management                                         F

At this time, the Province is not attempting to manage the supply of EVs in Ontario.  There a provision in the Electric Vehicle Incentive Program that each manufacturer must demonstrate a path to raise EV sales to 5% by 2020. However the only sanction is the loss of access to the EVIP, which, if you don’t plan to sell cars, is no sanction at all.

Today, EVs from Nissan, GM, Hyundai and Volkswagen are sold out until the middle of 2018, Tesla’s Model 3 first Canadian deliveries are not expected until late 2018. Finding a lower cost EV in Ontario is just about impossible.  In 2018 I expect this to get much worse as Quebec has introduced a quota system for EVs that starts in 2018 at 3.5% of all car sales, rising to 15.5% by 2025.  This quota has already removed the 2018 Ford Focus Electric from sale in the rest of Canada and it seems likely that Ontario will lose access to other models as the impact of Quebec’s quota system is felt.

As Quebec pushes forward there is a high likelihood that the shortage of EVs in Ontario will continue for many years, handicapping the Province’s EV programs.  There is little point in stimulating demand, as Ontario has done so successfully if there are no cars to buy.

Federal Minister of Transport, Marc Garneau has not indicated any desire to move forward with a national EV quota system, it is left to the Provinces to address this as Quebec already has.

 Overall Assessment                       D+

A Promising Start, Follow Through Lacking

The current programs have changed the landscape for the EV in Ontario.  By making EV ownership easier and long distance EV travel possible, the Province is to be congratulated.  

The lack of supply side policy has undermined these successes and in 2018 I expect to see the slow growth of EV sales to continue or perhaps fall back depending on how Nissan and Tesla address the Quebec market.

Urgent action is required to address the issues with EVCO and quotas if growth in EVs is to continue.