Electrical Utility Strategies for Transportation Electrification

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Electrical Utility Strategies for Transportation Electrification: Canadian Market Scan & North American Case Studies

OCTOBER 2021 AUTHORS Janet Eby, BSc, MBA Leah Geller, BSc Ted Wojcinski, BASc, CIM Josipa Petrunic, PhD


2 COPYRIGHT © 2021 Information in this document is to be considered the intellectual property of the Canadian Urban Transit Research and Innovation Consortium (CUTRIC) in accordance with Canadian copyright law. The material in it reflects CUTRIC’s best judgment, considering the information available to it at the time of preparation. Any use that a third party makes of this report, or any reliance on or decisions to be made based on it, are the responsibility of such third parties. CUTRIC accepts no responsibility of such third parties. CUTRIC accepts no responsibility for damages, if any, suffered by any third party as a result of decisions made or actions based on this report.

Canadian Urban Transit Research and Innovation Consortium (CUTRIC) Consortium de recherche et d’innovation en transport urbain au Canada (CRITUC) Knowledge Series Volume 2, Number 3 1 Yonge Street, Suite 1801 Toronto, ON M5E 1W7 info@cutric-crituc.org

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TABLE OF CONTENTS List of Tables___________________________________________5 List of Figures___________________________________________6 List of Acronyms_________________________________________7 Executive Summary______________________________________9 Canadian Market Scan by Province_________________________11 Introduction______________________________________________________________11 Newfoundland and Labrador__________________________________________________________11 Prince Edward Island_______________________________________________________________12 Nova Scotia_______________________________________________________________________13 New Brunswick____________________________________________________________________14 Quebec__________________________________________________________________________16 Ontario__________________________________________________________________________ 20 Manitoba_________________________________________________________________________27 Saskatchewan_____________________________________________________________________28 Alberta___________________________________________________________________________29 British Columbia___________________________________________________________________31 Yukon___________________________________________________________________________32 Northwest Territories________________________________________________________________33 Nunavut__________________________________________________________________________33

North American Case Studies_____________________________34 Introduction______________________________________________________________34 Case 1: Newmarket-Tay Power (NTPDL) and York Region Transit (YRT)______________34 NTPDL and the YRT electric bus trial___________________________________________________34 NTPDL as charger owner____________________________________________________________35 Regulatory and other challenges______________________________________________________35 Result___________________________________________________________________________36 Longer-term options________________________________________________________________37 Summary_________________________________________________________________________37

Case 2: OPG-TTC-Toronto Hydro Electrification Framework________________________38 Required charging infrastructure_______________________________________________________38 Funding gap______________________________________________________________________38 Toronto Hydro and OPG roles________________________________________________________39 Electrification framework_____________________________________________________________40 Summary_________________________________________________________________________40

Case 3: BC government, BCUC and transportation electrification____________________41 Early policy decisions_______________________________________________________________41 British Columbia Utilities Commission (BCUC) inquiries____________________________________41 BC Hydro: Fleet rates_______________________________________________________________41 BC Hydro: Fast-charger rates_________________________________________________________42 Fortis BC: Fast-charger rates_________________________________________________________42

Case 4: California legislation_________________________________________________42 Introduction_______________________________________________________________________42 Early policy decisions_______________________________________________________________43

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4 Senate Bill 350____________________________________________________________________43 Senate Bill 1000: Electric vehicle charging infrastructure____________________________________45 CPUC electrification framework_______________________________________________________45 Summary_________________________________________________________________________46

Case 5: Pacific Gas and Electric______________________________________________46 Capital infrastructure________________________________________________________________46 Rates____________________________________________________________________________47 Summary_________________________________________________________________________49

Case 6: Southern California Edison____________________________________________49 Capital infrastructure________________________________________________________________49 Rates____________________________________________________________________________50 Summary_________________________________________________________________________50

Case 7: San Diego Gas and Electric___________________________________________51 Decision on charging station ownership_________________________________________________51 Upfront costs of charging infrastructure_________________________________________________51 Rates____________________________________________________________________________51 Summary_________________________________________________________________________52

Case 8: Liberty CalPeco____________________________________________________52 Capital infrastructure________________________________________________________________53 Summary_________________________________________________________________________53

Conclusion____________________________________________54 Various roles of utilities in transportation electrification_____________________________54 North American best practices________________________________________________55 Looking ahead____________________________________________________________56

Appendix A____________________________________________57 References____________________________________________58

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LIST OF TABLES Table 1: Responsibilities for EV overhead charger installation...................................................37 Table 2: Three large investor-owned utilities (IOUs) approved Senate Bill 350 projects.............45 Table 3: Three small IOUs proposed Senate Bill 350 projects under CPUC review...................46 Table 4: Large clean energy vehicle (CEV) rate proposal..........................................................50 Table 5: Summary of SCE’s proposed commercial EV rates......................................................51 Table 6: Time-of-use (TOU) energy charges for EV-HP customers............................................53

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LIST OF FIGURES Figure 1: Utility owner-operator arrangement.............................................................................36 Figure 2: Options for ownership of charging systems................................................................38 Figure 3: Contract bundling strategies.......................................................................................40 Figure 4: Scope of electrification infrastructure..........................................................................41 Figure 5: Make-Ready versus Business as Usual......................................................................48 Figure 6: Sample transit estimated bill cost comparison............................................................49

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LIST OF ACRONYMS AIF – Annual information form ARTM – Autorité régionale de transport métropolitain ATUQ – Association du transport urbain du Québec (ATUQ) ARTM – Autorité régionale de transport métropolitain AZETEC – Alberta Zero Emissions Truck Electrification Collaboration BC – British Columbia BCUC – British Columbia Utilities Commission BEB – Battery electric bus BEV – Battery electric vehicle CBC – Canadian Broadcasting Corporation CDPQ – Caisse de dépôt et placement du Québec CEA – Canadian Electricity Association CEV – Commercial electric vehicle CPUC – California Public Utilities Commission CSR – Corporate social responsibility CUTRIC – Canadian Urban Transit Research & Innovation Consortium DC – Direct current ERA – Emissions Reduction Alberta ESS – Energy storage system EV – Electric vehicle EVID – Electric vehicle infrastructure demonstration EVSE – Electric vehicle servicing equipment FCBEB – Fuel cell battery electric bus FCET – Fuel cell electric truck GGRR – Greenhouse Gas Reduction Regulation GHG – Greenhouse gas GS>50 – General service rate greater than 50 kW demand ICIP – Investing in Canada Infrastructure Program IRP – Integrated resource planning ISED – Innovation, Science and Economic Development LDC – Local distribution company LU – Liberty Utilities LRT – Light rail transit NSPI – Nova Scotia Power Inc. NSUARB – Nova Scotia Utility and Review Board NTPDL – Newmarket-Tay Power Distribution Limited NRC – National Research Council Canada NRCan – Natural Resources Canada NWT – Northwest Territories OEB – Ontario Energy Board OEM – Original equipment manufacturer OPG – Ontario Power Generation OPUC – Oshawa Power & Utilities Corporation PEI – Prince Edward Island PG&E – Pacific Gas and Electric PHEV – Plug-in hybrid electric vehicle PSO – Programme de soutien aux organismes de recherche et d’innovation PTIF – Public Transit Infrastructure Fund PTIS - Public Transit Infrastructure Stream RASD – Reduce and shift demand REM - Réseau express métropolitain RFP – Request for proposal RFSO – Request for standing offer SCE – Southern California Edison

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8 SDG&E – San Diego Gas & Electric SOP – Super off-peak STL – Société de transport de Laval STM – Société de transport de Montréal THESL – Toronto Hydro Electric System Limited TOU – Time of use TTD – Tahoe Transportation District TTC – Toronto Transit Commission YRT – York Region Transit ZEV – Zero-emission vehicle

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EXECUTIVE SUMMARY Canadian utilities play an important role with regards to the electrification of transportation, including electric vehicle supply equipment (EVSE), for both high-powered and low-powered electric transit systems, as well as hydrogen fuel cell electric transit systems. Canadian transit agencies recognize the need to develop robust utility relationships to ensure sustainable electrification initiatives. However, most major utilities in Canada are poorly prepared for transit electrification as most of the few utility-led transportation electrification strategies existent in Canada today are focused on light-duty electric vehicles (EVs) as personal passenger cars. This report provides a comprehensive market scan of electrification of transportation strategies launched by Canadian electrical utilities. It also provides a review of case studies and best practices across North America related to electrification strategies, including legislation and regulation that promote utility involvement in the electrification of transit fleets. This market scan is based on documents available online on the websites of Canadian utilities. These documents are examined to identify strategies related to electrified transportation, with an emphasis on information related to electric buses. Overall, few utilities mention electrified transport strategies in any manner on their websites or in other publicly available documents. In cases where electrified transportation is mentioned, it most often relates to light-duty EV charging stations and networks or the purchase of EV fleets for utilities themselves. Hydro Québec presents the most evident and transparent strategy among Canadian utilities with regards to electrified transportation. That utility strategy aligns the goals of the Province of Quebec with the utility’s own growth projections. In other parts of Canada, however, the situation is less promising. Some significant initiatives have emerged that involve utilities, such as Toronto Hydro’s support for the Toronto Transit Commission’s (TTC) Green Bus Program, transit-focused strategies at BC Hydro in support of TransLink’s electric bus program, and Newmarket-Tay Power Distribution Ltd. (NMTPD) support of York Region Transit’s electric bus program. However, few other examples of explicit transit electrification strategizing or planning exist within the Canadian utility sector. In Canadian jurisdictions where regulations do allow utilities to engage in businesses related to electrified transportation, some utilities are creating unregulated affiliates or using their unregulated affiliates to enter the electric vehicle marketplace. This can include providing for-profit or consulting services to electric bus fleet operators. For example, Envari Energy Solutions, an affiliate of Hydro Ottawa, designs and installs EV charging equipment and has been involved in Ottawa’s transition to electric buses in recent months [ 1]. This report also provides case studies of specific electric utility investments and rate developments that promote the electrification of transit fleets in Ontario, British Columbia and California. These case studies provide examples of best practices in legislation and regulation that can overcome transit electrification barriers. For example, California Senate Bill 350 redefines the state’s Public Utilities Code to allow utility investment in transportation electrification as an activity in the interest of the ratepayer. Electricity ratepayers, in general, are deemed to benefit from investments in transportation electrification assets owned and programs run by California’s utilities. This means those utilities can share the cost of EV and electric transit investments with all electricity customers, regardless of whether the ratepayer/customers own or operates an EV themselves. The case studies reviewed in this report also demonstrate ways in which utilities address the financial and infrastructure barriers of fleet owners moving to electricity as a fuel source. Several California utilities, for example, are replacing high-cost demand charges (i.e., the charges utilities levy to build the infrastructure required to deliver high-power electricity to customers) with subscription rates. They are also investing in make-ready infrastructure and electric vehicle supply equipment (EVSEs) as allowed for by the California Public Utilities Commission (CPUC) to build networks of distributed users overtime.

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10 In brief, Canadian utilities and provincial ministries of energy can look to California for examples of leadership on experimental utility-led programming and regulation that has allowed for the growth in that state’s heavy-duty (transit) and light-duty (EV) marketplace, in the interest of action on climate change and domestication of energy supplies. Canadian case studies from British Columbia, Ontario and Quebec show that utilities can be involved in supporting transit electrification through unregulated business operations or regulated business operations. This is especially true if provincial regulators and political decision-makers make a concerted effort to recognize the value to all ratepayers of transit and transportation electric charging equipment investments in the fight against climate change.

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CANADIAN MARKET SCAN BY PROVINCE Introduction

This section summarizes the results of an online review of electrical utility strategies specific to transportation electrification across Canada, with an emphasis on information related to electric buses and electrified transit fleets. To conduct this review, CUTRIC identified electrical utilities by province and examined their websites for information specific to electrified transportation. The search was then expanded to include company documents such as annual reports, strategies, mission and vision/values statements, sustainability reports and corporate social responsibility (CSR) reports available within the public domain. Other sources of information such as federal and provincial government strategic reports and websites, and utility general distribution system plans, were also included in this review where relevant. In some cases, where a utility is owned by a municipality or town shareholder, the review includes the city, town or municipality’s plans with relation to sustainable energy management, environmental stewardship and/or transportation planning. Additional information gleaned from sources other than utility websites or allied public domain documentation is, at times, also included (and referenced) when deemed relevant to the specific case study in question. This review is intended to be a thorough assessment of publicly accessible information and utility documentation. However, the scope of the study is restricted wherever possible to documentation that is a maximum age of approximately two years, and thus draws on materials that were published primarily on or after January 1, 2019. It should be noted that utilities may have business plans and internal corporate strategies at play that are not accessible outside the organization and are not, therefore, included in this report.

Newfoundland and Labrador The utility marketplace in Newfoundland and Labrador is composed of two utilities: Newfoundland and Labrador Hydro (a provincial Crown corporation and subsidiary of Nalcor Energy) and Newfoundland Power (a division of Fortis). A review of publicly accessible information demonstrates no interest from either utility in electrified buses or electrified heavy-duty transportation or public fleets. Newfoundland Power does not present any electric transportation corporate strategies on its website. Newfoundland and Labrador Hydro does not present anything termed “strategy” or “strategic” anywhere on its site. Meanwhile, Nalcor’s strategic plan (as featured on its website) focuses on three priorities: energy security and reliability, maximized value, and oil and gas industry development [ 2]. This plan appears to be outdated, as it only addresses the years 2017 to 2019, despite being the only plan available online. Both utilities do, however, demonstrate some support for EV charging systems, specifically. Newfoundland and Labrador Hydro, which features an “Electric Vehicles” page on its website, states it is "working with the provincial and federal governments to build the province’s first fast-charging network" for deployment in 2021. Fourteen charging stations have been planned as part of that scheme. The company’s website also states that 11 of these stations are functioning as of May 2021. All stations are located on the island of Newfoundland and feature both “Level 2” and “Level 3” charging system capabilities. 1 This program is funded by the provincial government as well as Newfoundland and Labrador Hydro and the Government of 1 For a full definition and description of “Level 1”, “Level 2”, and “Level 3” charging systems for EVs, and standards for higher powered charging for electric buses, please see Petrunic, Josipa et al. “Best practices and key considerations for transit electrification and charging infrastructure deployment to deliver predictable, reliable, and cost-effective fleet systems,” Knowledge Series, CUTRIC. Vol 1, No. 1. Toronto, ON. 2020 (pages 31-39).

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12 Canada via the Natural Resources Canada (NRCan) Electric Vehicle and Alternative Fuel Infrastructure Deployment Initiative [3]. In its funding, NRCan states the federal government contributed $770,000, with the Government of Newfoundland and Labrador providing $1,289,400 [ 4]. However, according to the Canadian Broadcasting Corporation (CBC), the total project cost is closer to $2.2 million in total, with Newfoundland and Labrador Hydro contributing at least $500,000 in additional funding [ 5]. Newfoundland Power does not feature information on its website about EVs or electrified transport. On the corporate website for Fortis, however, there is a “Sustainability” page [ 6] that documents Newfoundland Power’s filing of its Electrification, Conservation and Demand Management (CMD) Plan: 2021-2025 with the regulator in December of 2020. Included in this five-year plan is the proposed implementation of an EV charging infrastructure network for Newfoundland and Labrador. Further information regarding this claim cannot be located on either the Newfoundland Power website or the provincial website of the Government of Newfoundland and Labrador. Online documents also describe another initiative named takeCHARGE, which involves Newfoundland and Labrador Hydro, and Newfoundland Power, conjointly. This program aims to achieve the installation of 19 new EV charging stations in Newfoundland. The utilities accepted applications up to the end of 2020 from interested parties wanting to host EV charging stations, with an installation target date of late 2021 [ 7]. However, the utilities state that meeting that deadline is contingent on regulatory approval [ 8]. No further information or update on the status of the implementation plan is available online. No information or strategic documentation is available across Newfoundland and Labrador’s utility marketplace related to the implementation of a charging network for public transit. This is despite the fact such a system could help the province and energy sector achieve global environmental and emissions objectives by supporting the electrification of diesel transit buses in Newfoundland, while also increasing domestic energy usage.

Prince Edward Island The utility marketplace in Prince Edward Island is composed of the province’s main electrical utility, Maritime Electric, a subsidiary of Fortis, while the City of Summerside also has a small utility. A review of publicly accessible information demonstrates no identifiable “strategy” regarding electrified transit in the province’s electricity marketplace. Maritime Electric’s website features an “Electric Vehicles” page which contains general EV-related information and connects the user to ChargeHub [ 9], an EV charging station app. Maritime Electric advertises the fact it is a CEA Sustainable Energy Company. The information posted about this certification states the utility is "(e)xpanding the Electric Vehicle (EV) charging station network on PEI” and “(a)dding electric vehicles to the company fleet [10].” However, the company’s online Sustainable Energy Policy [11] does not specifically mention EV, electric transit or other electrified transportation, even though Maritime Electric is an active participant in the installation of an EV-charging network on Prince Edward Island (see NRCan’s Electric Vehicle and Alternative Fuel Infrastructure Deployment Initiative below). The City of Summerside issued a tender in mid-2020 for 26 new EV charging stations to be located in and around its downtown area and along its boardwalk [12]. The installation of these chargers is expected to be completed by June 2021 and will be added to the City’s existing 30 chargers [ 13]. The 10-year Prince Edward Island Provincial Energy Strategy 2016/17 discusses the benefits of EVs, including adopting electric school buses and the potential for acting as a “testing ground for substantial penetration of electric vehicles [14].” This strategy provides some evidence of a preliminary commitment to the electrification of transit on Prince Edward Island (PEI). On February 25, 2020, the premier of PEI announced that the provincial government will transition its entire fleet of 300 school buses to electric school buses over the next few years – a commitment that is also supported by the Official Opposition, the Green Party of Prince Edward Island.

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13 As part of this effort, in June 2020, PEI issued a Request for Standing Offer (RFSO) to provide 12 electric school buses, with the provision to provide additional buses in the future. Lion Electric of Québec [ 15] secured the winning bid and in November 2020 the province announced that 12 Lion electric school buses would be in service for the “next school year.” According to Lion, those 12 electric school buses have been delivered to PEI and are currently in service [16]. The initial announcement indicated the buses might be leveraged when off-duty for public transportation purposes in rural PEI as well, although there is no current update available on whether this opportunity has been realized [ 17]. Federal and provincial governments committed $2.1 million and $2.7 million, respectively, to PEI’s initiative [ 18], [19]. The province has a broad five-year Sustainable Transportation Action Plan [ 20]. The Plan discusses the need for a province-wide electric vehicle charging network, putting in place incentives for EV and home charging station purchases, exploring opportunities for electrified public transportation and replacing government light-duty vehicles with electric models. Charging stations for electric vehicles are being constructed across PEI. The province has installed EV chargers at six locations on the island with funding assistance from NRCan’s Electric Vehicle and Alternative Fuel Infrastructure Deployment Initiative [21]. In February 2021, the federal government announced that it was providing $250,000 of funding for the installation of 50 “Level 2” EV charging stations, with the balance of the $590,000 required provided by Maritime Electric and the PEI provincial government [22]. This initiative began with a small community aiming to install EV chargers, but unable to satisfy the minimum requirement of 20 charging stations required for federal funding. The town engaged its local utility, Maritime Electric, which coordinated nine communities to apply jointly for financial assistance for the charger deployments with the Federation of PEI Municipalities [ 23]. On December 10, 2020, the federal government granted $495,000 to St. John Energy as the principal applicant in a pan-Maritime consortium to construct 99 “Level 2” EV charging stations in six Maritime villages, towns and cities, including the City of Summerside [ 24]. Beginning in April 2021, the government of PEI started offering an EV purchase incentive applicable to both new and used vehicles. The incentive of $5,000 for a new or used EV, or $2,500 for a plug-in hybrid, is applied at the point of sale (i.e., dealerships). This incentive is in addition to the federal rebate offer of $5,000. The province is also offering a free “Level 2” charger for battery electric vehicle (BEV) and plug-in hybrid electric vehicle (PHEV) purchasers, although the owner must pay for installation [ 25].

Nova Scotia The province’s main electrical utility is Nova Scotia Power (NSP), a subsidiary of Emera. The NSP website does not show an explicit strategy regarding electrified transportation. NSP recently completed an integrated resource planning (IRP) exercise, which offers as a “strategic guide” for serving current and future customers. The summary of the final IRP (dated November 27, 2020) states that “electrification of vehicles and buildings is key to achieving economy-wide decarbonization.” It also says that the utility proposes to “initiate an electrification strategy to develop options for encouraging beneficial electrification with the goals of maintaining rate stability while decarbonizing the Nova Scotia economy consistent with the Sustainable Development Goals Act.” NSP filed its planning document with its provincial electricity regulator. NSP’s recommendations also include developing “pilots and/or programs that focus initially on the transportation and building electrification sectors identified in the Deep Decarbonization Pathways report as key sectors for early electrification adoption [26].” The utility intends that the pilots and early-stage programs will subject to Nova Scotia Utility and Review Board (NSUARB) oversight. NSP’s website documents the utility’s Electric Vehicle Smart Charging Program [ 27] [28]. The program (which is now closed to new applications) aimed to attract up to 120 participants, although there is no information available currently as to how many applicants were ultimately received into the program. As part of the program, customers are to install a ChargePoint Home Flex EV smart charging system allowing the utility to control the charging cycles of customers’ EVs, thereby shifting consumption to off-peak periods and providing the utility with insight into the effects on the overall electrical system of charging EVs. The utility claims this type of grid-control will enable the optimal use of “greener” energy over time.

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14 This program is part of a larger initiative called Smart Grid Nova Scotia, supported by the federal government, through Innovation Science and Economic Development Canada (ISED) and NRCan, and the provincial government. As part of this initiative, the utility has been active in supporting the creation of an EV charging network. In 2018, Nova Scotia Power/Emera and the Government of Nova Scotia installed a network of 12 DC fast chargers and 12 “Level 2” chargers in the province with federal funding assistance from NRCan [29]. There are signs of progress in Nova Scotia regarding bus electrification, as well. The City of Halifax’s Regional Council voted on May 26, 2020 to proceed with a bus electrification project, subject to obtaining government funding support [30] [31], with the goal of electrifying 200 or more of Halifax’s fleet of 350 buses by 2028. The expected cost is between $400 million and $460 million. The plan is estimated to take eight years to execute [32]. The estimate of the incremental cost is estimated to be between $247 million and $307 million [33]. Implementing the plan involves changes to the two transit centres so that the infrastructure will be in place for charging. The introduction of electric buses is planned to occur in the next two to three years. Halifax indicated it would seek provincial and federal funding to support the conversion, including through the Investing in Canada Infrastructure Program (ICIP), the Green Infrastructure Fund and the Public Transit Infrastructure Fund (PTIF). Transit electrification is aligned with the objectives of the municipality’s Integrated Mobility Plan (2017) [34] and HalifACT 2050, a long-term climate action initiative [35]. Recent controversy, however, has emerged as Halifax has proceeded with an agreement to purchase up to 150 diesel buses over a three-year period to serve its interim needs for replacement buses [ 36]. According to Halifax Transit, the plan for electrification is contingent on federal and provincial funding applications that are still pending [37]. Cape Breton has initiated a $900,000 two-year study funded by federal and provincial governments ($660,000) and the municipality ($240,000) regarding a transition to electric transit buses. The study includes an evaluation of costs associated with a new transit facility and transit hub, and an evaluation of most suitable routes [38]. In 2020, the Government of Nova Scotia contracted CUTRIC as a principal nonprofit research entity to carry out Cape Breton’s zero-emissions bus (ZEB) performance prediction analysis and full-fleet ZEB feasibility analysis. Those results – which demonstrate the challenges of long routes and rugged driving conditions – have been provided to Cape Breton in recent months and are being integrated into the region’s electrification strategy going forward. The region is currently assessing the estimated costs of transitioning its facilities as well. The province’s EV charging network is expanding. On December 10, 2020, the federal government granted $495,000 to St. John Energy as the lead in a pan-Maritime consortium to construct 99 “Level 2” electric vehicle charging stations in six Maritime villages, towns and cities, including the towns of Berwick, Mahone Bay and Antigonish [39]. The province of Nova Scotia has begun offering rebates to EV purchasers. The incentives offered by the Electrify Nova Scotia Rebate Program pertain to electric vehicles purchased or leased from businesses in Nova Scotia beginning February 24, 2021. A typical BEV would qualify for a $3,000 rebate under this program [40].

New Brunswick The province’s main electrical utility is New Brunswick Power. Little is available online regarding electric buses in New Brunswick and no information exists in the public domain regarding electric buses within the constellation of services provided by New Brunswick Power. New Brunswick Power does have an “Electric Vehicles” page on its website, which speaks to its involvement in installing an EV charging network in the province for light-duty electrified cars (see eCharge Network below) [41]. The utility has a Strategic Plan (2011–2040), which mentions EVs briefly as one of the strategies that can be used to “reduce and shift demand” (RASD) [ 42]. The Strategic Plan does not identify

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15 whether the “strategy” involves purchasing such vehicles for the utilities fleet or supporting the charging of such vehicles across the region with incentivizing ratepayer and customer programs in the future. Nova Scotia Power and New Brunswick Power are collaborating in the Smart Grid Atlantic initiative, a fouryear research and demonstration program that began in 2019 with funding provided by NRCan and ISED and involving the National Research Council Canada (NRC). The focus of the Smart Grid Atlantic initiative is “to determine how energy technologies of the future can provide customer, community and provincial benefits [43].” The project uses an energy system platform produced and deployed by Siemens. One of the areas of investigation of this project is electric vehicle fleet and residential EV charging [ 44], including vehicle-to-grid connectivity. New Brunswick Power has facilitated the creation of the eCharge Network in New Brunswick, which includes both “Level 2” and DC fast chargers, located at participating municipalities and businesses across the province [45]. In 2018, the utility’s regulator criticized New Brunswick Power for spending on charging stations, stating that it was not part of the utility’s core business and that the expense should have been financed by the private sector. As a result, the utility’s application to approve $1.3 million in spending in its 2018 rate application to expand the network was rejected. Despite the ruling, New Brunswick Power completed the build-out of the EV network as construction work was already underway [ 46]. New Brunswick Power has also replaced 50 per cent of the utility’s own light-duty passenger fleet vehicles with electric vehicles [47]. The Province of New Brunswick embraced the reduction of greenhouse gases with its Climate Change Action Plan (2016). The document stated, “the provincial government will…prepare a green transportation policy that will include measures to…develop a government electric vehicle program relating to fleet vehicles and recharging infrastructure [and] implement new fleet procurement, consistent with the Green Procurement Policy, and management systems including alternative fuel vehicles that improve fuel efficiency and lower GHG emissions [48].” The same document also spoke to the need for a green procurement policy. The document also stated, “the provincial government will work to have 2,500 electric vehicles on the road in New Brunswick by 2020 and 20,000 by 2030; implement an electric vehicle strategy that specifies the required incentives, regulations, policies, programs and charging infrastructure to achieve the abovementioned targets for electric vehicles…collaborate with municipal and local governments to expand cleaner alternative transportation options such as electric vehicles, public transit, carpooling, ride-sharing, bicycling and walking [and] advance public transportation planning at the regional level to allow for route integration and improvements in access.” Unfortunately, the province did not meet this 2020 target, nor is there an indication or strategy published that explicitly states how it will achieve this target in the future [ 49]. In 2017, an electric school bus pilot program took place in New Brunswick using two Lion buses – one in an Anglophone school district and one in a Francophone school district [ 50]. The province then moved to a pilot of 16 propane-powered buses [51]. As of May 2021, the province is beginning an evaluation of gasolinepowered school buses as an alternative to diesel. A report on the various pilots is expected by the end of summer 2021. Although the two electric school buses in operation have continued to function well, the upfront capital cost of electric school buses is a deterrent in purchasing more units and funding has not been obtained as yet to defray the expense [ 52]. Operators have identifies concerns over the installation of new charging infrastructure and the ability for school buses to travel on longer routes of approximately 100 km. On January 21, 2021, the provincial government released a progress report on the 118 actions from the Climate Change Action Plan covering 2017 to 2020 [ 53] [54]. It states, under Action 22: Provincial Transportation GHG Emissions, that from 2017 to 2018 the provincial government acquired two electric school buses. In 2018 to 2019, it procured another 11 plug-in hybrid electric vehicles for its general fleet. From 2019 to 2020, it procured 16 propane school buses and 74 gasoline buses, rather than diesel school buses, because “they are more environmentally friendly than diesel.” Action 47 in the plan addresses electrified transportation by noting the need to expand the charging network in New Brunswick, although the action contains little information as to how this expansion will occur.

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16 In parallel, on December 10, 2020, the federal government granted $495,000 to St. John Energy as the principal applicant in a pan-Maritime consortium to construct 99 “Level 2” EV charging stations in six Maritime villages, towns and cities, including St. John, Edmundston and Perth-Andover [ 55].

Quebec Hydro Québec, along with the provincial Government of Quebec, is explicit in its corporate view that the electrification of transportation is a priority for both the utility and the province as the main shareholder in an economic future of energy production. In its Strategic Plan 2020–2024, Hydro Québec states one of its four objectives is to “contribute to reduction of GHG emissions in all our markets,” and one of its four strategies is to “electrify Québec and be a leader of the energy transition [ 56].” Hydro Québec identifies the utility as a key agent in fostering the development of electric transportation province-wide, including public transit. The Strategic Plan also talks about other initiatives the utility will undertake to encourage transportation electrification such as increasing public awareness, “densifying” the Electric Circuit charger network across Quebec, continuing innovation in EV-related energy storage and charging systems, and increasing the percentage of electric vehicles within Hydro Québec’s own fleet. The utility’s Sustainable Development Plan 2020–2024 [57] aligns with the company’s strategy of increasing the electrification of transportation overall across the region. In May 2021, the utility published a progress report focused on implementing the Plan, titled Hydro Québec Sustainability Report 2020 [58]. Addressing the period from January to December 2020, the report identifies 10 strategic objectives. The utility’s objective of “Contribution to Transportation Electrification” ranked second only to “Social Acceptability of Projects,” which is a substantial jump in priority from its previous rank of ninth place in the utility’s previous report on sustainability. Hydro Québec devoted part of its main website to the entire eco-system of “transportation electrification.” In “developing innovative battery and motor technology for electric vehicles as well as a charging network, and producing clean and renewable energy, Hydro Québec is actively involved in transportation electrification [59],” the website states. Within this digital network of information, the company provides readers with general information regarding EVs and electric school buses. It also reviews the utility’s subsidiary, InnovHQ, which has established a phone line to provide support to school bus operators interested in procuring and deploying electric school buses, including available grants, and potential electric bus and charging station suppliers [60]. The utility’s Centre of Excellence in Transportation Electrification and Energy Storage is featured on this page, as well.

Electric bus-related projects involving Hydro Québec More than any other utility in Canada, Hydro Québec has been involved in several EV and electric busrelated innovation projects: Dana TM4: TM4 was a subsidiary of Hydro Québec set up in 1998 to develop and market electric propulsion technology. The company continues today as Dana TM4, a joint partnership between Dana and Hydro Québec [61]. Dana TM4 “develops, manufactures and markets electric motors for different kinds of vehicles as well as inverters and controllers [ 62].” The Lion Electric school bus (see below) uses an engine produced by Dana TM4. Société de transport de Laval (STL): On August 15, 2019, STL (the transit agency for the City of Laval) announced that its first electric bus with a range of 250 km would be tested and validated prior to being deployed in 2020, as part of an all-electric bus line [63]. Although Hydro Québec did not fund the project, it did co-fund STL electric bus performance analysis and research over the following years, allocating $100,000 to the effort, as well as in-kind contributions of expertise. This first electric bus procured by STL is part of a larger deployment. STL plans to purchase only electric buses from 2025 onwards and will aim to operate only electric buses in its fleet by 2035 to 2040 [ 64]. Ten 40-foot slow-charge New Flyer buses were ordered via the Association du transport urbain du Québec (ATUQ). A total of $9.6 million in funding for the project came from a combination of federal Gas Tax Fund ($6.8 million) and the Québec Programme d’aide aux immobilisations en transport en commun (public

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17 transit capital acquisitions assistance program) of the Société de financement des infrastructures locales du Québec ($2.8M). In December 2020, STL announced its 10 buses would be delivered in the next six months, and that the transit agency would also be purchasing the required charging equipment at a cost of $4.9 million, including $1.3 million over the 2021–2022 fiscal year [ 65]. Société de transport de Montréal (STM): Three all-electric quick-charge Nova Bus buses began operation in Montreal in 2017 as part of the Cité Mobilité project [66]. The Cité Mobilité initiative operated on a budget of $16.7 million [67], of which $11.9 million came from the Quebec Ministry of Transport, $100,000 from Hydro Québec and $4.7 million from STM. In addition, Volvo and Nova Bus invested $8 million in research and development for the electric bus system. The three electric buses purchased in 2017 continue to operate on Montreal’s 36 Monk route. Four more fast-charge 40-foot electric buses from Nova Bus have been added to that route, making it one of the first fully electric routes in Canada. In addition, STM is in the process of purchasing 30 slow-charging New Flyer electric buses that contain large battery packs to employ on various routes in its fleet network. According to STM’s website, “We have received six New Flyer buses so far. In the coming months, the rest of the 30 buses will arrive at the Stinson bus garage. They should be delivered by the end of winter 2021. We are continuing tests on the buses and plan to gradually introduce them into service for our customers starting in winter 2021 [ 68].” There are two fast-charging stations and four slow-charging stations (for overnight use). The purchase of 30 new electric buses for STM has been coordinated with the purchase of 10 all-electric slow-charge buses for STL (via ATUQ). The combined procurement of these buses is part of the 2017 STM Strategic Organizational Plan, which calls for purchasing only electric buses starting in 2025 [ 69] to help achieve the goal of zero GHG emissions by 2040 [70].

Other transportation electrification activities involving Hydro Québec In addition to these electric bus projects, Hydro Québec is involved in many aspects of the electrification of transportation. The following list is a sampling of other transportation electrification activities it has supported in recent years to help grow the electrified transportation industry in Canada. Réseau express métropolitain (REM): Since 2016, Hydro Québec has been collaborating with the Caisse de dépôt et placement du Québec (CDPQ) Infra on the Réseau express métropolitain (REM) light rail electric train project for Montreal. The REM is a 100 per cent electric, automated light rail transit system for the Greater Montreal area providing high-frequency service 20 hours per day, seven days per week, on 67 km of dedicated tracks. A massive project originally estimated to cost $6.3 billion resulting in 26 stations and three connections to the Montreal Metro, it is one of the largest automated rail projects in the world. Construction of the REM began in 2018. Commissioning was to take place between 2021 and 2023 [ 71], [72], [73], but delays and cost overruns have pushed the commissioning dates out by at least one year and have added more than $200 million to the overall cost [74] [75]. Initial project financing is provided by:  Government of Quebec: $1.28 billion  CDPQ will both develop and operate the project: $2.95 billion (for 70 per cent equity)  Canada Infrastructure Bank: $1.28 billion  Hydro Québec: $295 million  Autorité régionale de transport métropolitain (ARTM) in Montreal: $512 million Additionally, funding bodies are leveraging green bonds to support the project. The project is expected to reduce GHG emissions by 680,000 tonnes over 25 years. However, delays to the project have resulted from unforeseen difficulties associated with the Mount Royal tunnel and the COVID-19 pandemic. Research and development: Hydro Québec operates a Centre of Excellence in Transportation Electrification and Energy Storage [76], which serves the purpose of acting as a “world class innovation hub in the field of battery materials for electric vehicles and other energy storage applications, both stationary and mobile.” The focus of research and development is on battery technology – from cellphone batteries to electric vehicle batteries to energy storage – including both advanced lithium-ion and solid-state. In

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18 February 2020, Hydro Québec announced a partnership with Mercedes-Benz [ 77] to advance battery technology for electric vehicles, specifically solid-state batteries [ 78]. Electric vehicle charging network: Hydro Québec has been instrumental in building an extensive EV charger network across Québec called the “Electric Circuit.” Per the Electric Circuit’s website, it now offers more than 3,000 charging stations, including 450 fast chargers [ 79]. Hilo: In October 2019, Hydro Québec launched a new brand, Hilo, to market energy products and services, which will eventually include electric mobility offerings, smart storage and self-generation. Hilo’s main purpose is to help customers manage their energy consumption efficiently and offers financial incentives to do so [80]. As of May 2021, Hilo’s services and products were related to smart devices for the home. However, according to Hilo’s website, an electric mobility offering is “coming soon” [ 81], though no details exist currently in the public domain as to what that offering will be composed of. Purchase of electric bucket truck: In recent years, Lion Electric developed an electric bucket truck, with its first sale of the vehicle to Hydro Québec in 2019 [82]. In March 2021, Consolidated Edison in New York announced it is working with Lion Electric and Posi-Plus on the development of an all-electric bucket truck estimated to be on the road in 2022 [83]. Energy storage subsidiary: In December 2020, Hydro Québec announced the launch of EVLO Energy Storage Inc. (EVLO). This subsidiary “designs, sells, and operates safe, efficient and sustainable energy storage systems…intended mainly for power producers, transmission providers and distributors, as well as the commercial and industrial markets for medium- and large-scale storage [ 84].” The storage units include power control and energy management software for systems-level deployments in support of, potentially, electrified transportation fleets. Plan for a Green Economy 2030 In addition to leveraging its core utility to fundamentally influence and shape the electrified transportation landscape in Quebec, the Province of Quebec issued its Plan for a Green Economy 2030 on November 16, 2020 [85]. The $6.3 billion Plan places electrification of transportation at the top of a list of priorities for the province. The Plan includes the following targets for 2021 to 2026:  1.5 million EVs on roads in Quebec by 2030  No sales of new gasoline vehicles after 2035  Electrification of 55 per cent of city buses and 65 per cent of school buses electrified by 2030  Electrification of 100 per cent of government cars, SUVs, vans and minivans and 25 per cent of government pickup trucks by 2030 On April 23, 2021, Quebec Premier Francois Legault announced that the province would provide a major boost to the electrification of school transportation. The government has allocated $250 million to be spent over the next three years to put approximately 2,600 electric school buses on the road in Quebec. Funding will cover both buses and infrastructure. And the government is aiming for 65 per cent of the province’s school bus fleet to be electrified by 2030 [ 86]. The Government of Quebec also offers a substantial rebate for purchasers of EVs of up to $8,000 for vehicles priced up to $60,000 [87].

Lion Electric In reviewing transportation electrification in Quebec, and electric buses in particular, it is worthwhile commenting on recent events surrounding Lion Electric, which uses an electric propulsion system onboard its bus models that was originally developed by a subsidiary of Hydro Québec. 

On May 22, 2021, the company announced that First Student had purchased 260 buses from Lion [88], the largest purchase yet for the manufacturer. The buses, which will be deployed in Quebec, will be delivered between 2021 and 2023. Another order earlier in the year for 60 electric school buses to Autobus Séguin, also for deployment in Quebec, further supported corporate growth goals [89]. Ten electric school buses will be delivered in 2021, with the remainder delivered over the

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19 following five years. Autobus Séguin, for its part, has declared it will aim to electrify its entire fleet of 310 buses by 2030. 

In March 2021, Lion Electric announced a new battery production facility [ 90]. The factory is intended to begin operating in 2023 and will produce lithium-ion battery packs and modules. The project is funded by Lion ($185 million), the federal government ($50 million) and the Government of Quebec ($50 million).

Lion Electric has also expanded its production into the United States. In May 2021, the company announced an initial investment of US$70 million into a facility that will produce zero-emission medium- and heavy-duty vehicles in Joliet, Illinois [ 91]. The first vehicles will be produced by the second half of 2022.

The company’s electric buses are equipped with bidirectional inverters, meaning they can charge the bus or store energy and feed electricity back into the electrical grid at optimal periods in the day, as directed by smart software technology and chargers developed by San Diego-based Nuvve Corp. This bus-to-grid capability is the subject of a pilot project currently underway in White Plains, New York [92] [93] [94]. In this pilot, Consolidated Edison has employed five Lion electric school buses fitted with Nuvve software and onboard bidirectional inverters as energy storage batteries. The pilot is considered a success by Consolidated Edison [ 95]. The buses are now charging from and discharging into the grid at a bus depot in North White Plains [ 96]. The pilot’s scheduled end date is September 2021.

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20 Ontario Ontario’s electricity marketplace is more complex in nature and design compared to the marketplaces reviewed above in this report, largely due to the separation of generation, transmission and distribution of electricity in the province. As a first source of analysis, researchers assessed information provided by local distribution companies (LDCs) across Ontario. In summary:  Approximately 60 per cent of the LDCs reviewed do not present any information on their web portals or in their public domain documentation regarding electrified transportation in general, any current initiatives related to electric transportation or any strategy for electrification of transportation.

Approximately 25 per cent of LDCs show only a very low level of support for electrified transportation. This “support” might include providing basic and general information and links to other sites regarding EV ownership and/or charging, links to announcements regarding the installation of a small number of charging stations, or links to a strategy related to EVs but no relevant activities, milestones, funding announcements or target dates. In some cases, the aggregate total of “EV” effort at LDCs amounts to only the purchase of one or two EVs or plugin hybrid vehicles (PHEVs) for local LDC use.

The remaining 15 per cent of LDCs assessed in Ontario demonstrate a higher level of commitment, such as establishing a charging network, offering to sell or lease chargers to residential customers, conducting research into the effects of charging on the distribution system, and direct involvement or leadership in an EV or electric bus pilot or deployment.

Electric bus demonstration projects Three utilities in Ontario – Newmarket-Tay Power Distribution Inc. (“Newmarket Hydro”), Toronto Hydro and Ontario Power Generation (OPG) – present significant involvement in electric bus demonstration projects in the province. Newmarket Hydro and York Region Transit: Newmarket Hydro is engaged in a national Electric Bus Demonstration and Integration Project, which is part of the CUTRIC-led Pan-Canadian Electric Bus Demonstration and Integration Trial. As part of this project, York Region Transit approved the purchase of six 40-foot electric buses for the trial from New Flyer and Nova Bus in 2019. On June 29, 2020 [ 97], two of these buses were put into operation. The project will provide data and operating experience essential to future decisions regarding electric bus deployment. Newmarket Hydro owns and operates the on-route charging system; however, the utility’s website does not feature or discuss the bus trial. While York Region Transit is moving towards a goal of zero GHG emissions by 2051 [ 98], Newmarket Hydro does not appear to have an electrified transportation strategy on its website identifying a long-term corporate strategy. Toronto Hydro, OPG and the Toronto Transit Commission (TTC): The TTC is involved in a multi-year electric bus conversion project (the “Green Bus Program”). Two utilities are involved in this project – Toronto Hydro and OPG. As of September 2020, the TTC was operating the largest fleet of electric buses in North America [ 99]. Its first 60 buses in the Green Bus Program are part of a “head-to-head” evaluation of performance comparing different bus manufacturers to one another directly and providing useful information for future procurements. The purchase of the first 30 electric buses was approved in November 2017 and the purchase of 30 more was approved in June 2018. Three vendors supplied the buses – Proterra, New Flyer, and BYD. The City of Toronto and the Government of Canada (through the Public Transit Infrastructure Fund) provided a total of $140 million for the project. The first electric bus went into service in June 2019 and the final vehicle was deployed in December 2020. Since then, TTC has publicly reported on the performance of those vehicles in comparison to one another at CUTRIC’s national and monthly ZeroEmissions Bus Committee.

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21 The TTC has outfitted three of its garages with charging equipment: Arrow Road Garage (for New Flyer buses), Mount Dennis Garage (for Proterra buses) and Eglinton Bus Division (for BYD buses). Toronto Hydro is responsible for upgrading the distribution feeders for the TTC’s Arrow Street garage and for constructing a behind-the-meter energy storage system (ESS). According to Toronto Hydro’s Rate Filing for 2020–2024 [100], “the TTC Arrow Road Garage ESS] project will provide reliability improvements, resiliency, financial relief through peak-shaving, and emergency capacity. The cost of this CustomerSpecific ESS project is $12.3 million [and] is fully funded by the customer through capital contributions.” The battery energy storage system has not yet been commissioned, but the TTC states its aim is to procure that system and have it in operation by year-end 2021. In Toronto Hydro’s 2020 Environmental Performance Report the utility states, “Toronto Hydro assisted the TTC with the technical requirements for adopting electric buses and with selection of the first locations for the electric bus program…Toronto Hydro is also assisting the TTC in implementing energy management and energy storage projects at TTC facilities. Once in service, the energy storage will allow the TTC to balance its electrical load throughout the day and increase overall reliability at the garages. Toronto Hydro will accommodate the future growth of electric buses by enhancing the electrical infrastructure required for new bus-charging equipment [ 101].” Given the need to further expand the bus charging infrastructure to accommodate more buses, the TTC Board approved a Framework for Agreement between the TTC, Ontario Power Generation and Toronto Hydro [102] at their April 2021 meeting. Under this agreement: 

TTC is responsible for the acquisition and operation of electric vehicles.

OPG is responsible for engineering, procurement, construction, operation, and maintenance of behind-the-meter charging infrastructure and distributed energy resources at TTC Sites. OPG will deliver, own, maintain and operate the electrification infrastructure and co-invest in the infrastructure at the TTC sites, such as battery energy storage systems, backup generators and solar generation. OPG will also be responsible for optimization of the assets, including TTC’s electricity usage and cost.

Toronto Hydro is responsible for providing electrical service to the TTC sites.

TTC staff are asked to report back to the Board no later than Q3 2021 with a proposed negotiating position and proposed commercial terms for the TTC-OPG Master Agreement [103]. Other utility activities of note by utilities in Ontario with respect to transportation electrification include the following initiatives and projects.

Other Ontario-based transportation electrification projects Ontario Power Generation (OPG): In addition to the TTC/Toronto Hydro/OPG electric bus initiative mentioned above, OPG has been active in other transportation electrification projects. OPG is one of the few utilities in Canada with an explicit electric vehicle strategy. Although brief, the strategy does identify “leveraging our clean electricity to support the electrification of transportation; maximizing the use of existing clean generation investments with increased electricity demand; and creating new commercial growth opportunities [104]” as its goals. OPG’s website also states that the utility will “design, build, operate and maintain high-power charging infrastructure” as part of its Fleet Electrification Services [105]. OPG’s intentions regarding electrified transportation are more evident in Building a Brighter Tomorrow: Our Climate Change Plan, released in November 2020 [106]. In this plan the utility says, “We’re helping decarbonize the Ontario economy by electrifying our province’s transportation sector.” The document indicates that the utility sees itself as taking a major role in Ontario’s EV landscape, including its electric bus and marine transportation charging networks in the future. In its 2020 Annual Information Form (AIF), OPG states, “In 2019, OPG constructed a vehicle-to-grid pilot with electric vehicles and bidirectional chargers hosted at two commercial buildings in Toronto, Ontario.

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22 This pilot implementation with Peak Power Inc., a global energy technology services provider, will explore feasibility of demand management using an aggregate resource [ 107].” OPG and Hydro One formed a joint venture called “Ivy” in 2019 with the purpose of constructing a network of EV chargers in Ontario2. According to the Ivy website, by the end of 2020, the corporation had equipped 43 locations, with another 30 to be installed by the end of 2021. As of May 11, 2021, the site demonstrated that 33 out of 58 locations had been completed [108], although the site also states, “Ivy's 70+ sites are scheduled for completion in 2021.” NRCan provided part of the funding for this initiative through its Electric Vehicle and Alternate Fuel Infrastructure Deployment Initiative. Greenlots, a company headquartered in the U.S., and a member of the Shell Group, will operate and manage the network. Furthermore, OPG is working with the Ontario Ministry of Transportation to electrify the Amherst Island and Wolfe Island ferries. In its 2020 Annual Information Form, OPG states, “The Company will be responsible for building, owning and operating onshore battery storage assets used in the charging infrastructure to power these marine vessels [93].” The utility also states it will convert its fleet of 100 corporate vehicles to EVs by 2030 and provide more than 40 charging stations at sites and offices for staff and fleet vehicles. In its Climate Action Plan, OPG states the utility will be net-zero carbon by 2040. Elexicon Group is the non-regulated utility affiliate associated with Elexicon Energy, formerly Veridian and Whitby Hydro. Elexicon Group has emerged with a full suite of electrified transportation services [ 109], including services related to electric buses. These include consulting services to help convert bus fleets from diesel to electric by:  Replacing engines and drivetrains with battery packs and electric motors  Financing the conversion or acquisition of a new fleet of electric buses  Designing and installing electric bus charging infrastructure  Route planning for electric bus fleets  Fleet acquisition planning, including interfacing with local utility companies  Designing, sourcing, installing, and maintaining charging systems for trucks, buses, and commercial vehicles  Sourcing and installing “Level 2” and “Level 3” electric vehicle chargers. It is not clear from Elexicon’s website, however, how often the non-regulated entity has engaged in these activities or supported transit agencies in the province in doing so. Alectra has also established a presence in EV adoption programming. The utility has created a Green Energy and Technology (GRE&T) Centre, which focuses on evaluating and accelerating the adoption of clean energy solutions [110]. One solution includes establishing the AlectraDrive @Work initiative to help the utility manage peak demand while providing adequate charging for vehicles. This initiative is listed as an ongoing project, although the site indicates it was to be completed in 2020 [ 111]. The utility also offers the AlectraDrive @Home initiative, which examines the impact of incentives on customers charging their cars at home [112]. Alectra engaged in an E-Bus Simulation Study with York University and CUTRIC. The purpose of the study is to examine the impact of bus charging on the distribution network and assess best practices for transit fleet electrification [113]. Cooperation in technology development between Alectra and Newmarket-Tay Power Distribution Ltd. is described in a 2019 Alectra rate filing – specifically, in the 2020–2024 Distribution System Plan Assurance Review Report attached to the filing [114]. The document states Alectra and Newmarket-Tay Power Distribution will pioneer “new technologies and solutions showcasing the strategic vision and direction of the two utilities.” Their Plan includes identifying promising technologies and solutions, recruiting technology partners and stakeholders, commissioning a test bed facility, developing an “innovation cluster” and incorporating proven solutions into utility asset plans. The technology solutions include battery electric vehicle storage capabilities.

2 Hydro One and OPG are co-owners of Ontario Charging Network LP, a numbered company that is the parent company of Ivy Charging Network.

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23 Alectra, along with Fleet Carma and Burlington Hydro, also received financial support from the Ontario Smart Grid Fund in past years to support a project called “Piloting electric vehicle load shaping with dynamic price signals.” However, the project is still described on the utility’s website as “in progress” [ 115]. Toronto Hydro has been active in supporting transportation electrification beyond the electric bus initiative mentioned above. It does not appear, however, to have a defined strategy for electrified transportation, at least not one that is publicly available or distributed online. Currently, the utility is collaborating with Metrolinx to build a battery energy storage system to provide backup and emergency power for the Eglinton Crosstown Light Rail Transit (LRT) line [ 116] [117]. The battery will provide up to four hours of emergency power to the LRT in case of a power outage. It will also be capable of reducing operating costs by charging during the night and discharging during the day. Toronto Hydro has contracted Renewable Energy Systems (RES) Canada for the project. RES Canada will own the battery, even though it is behind the meter. Metrolinx will pay for the battery through a customer contribution arrangement. The battery will be 10 MW in capacity. This battery was chosen as an alternative for backup power (as opposed to a gas plant, which was rejected by the surrounding community) [ 118]. The project also includes the installation of a rooftop solar photovoltaic system of about 250 solar panels capable of generating 90kW DC of electricity [119]. Toronto Hydro hosts an EV information webpage on its main website, which contains general information for the EV owner [120]. In its 2020 Environmental Performance Report, Toronto Hydro states it will be purchasing fully electric or hybrid light-duty passenger vehicles going forward, but these commitments do not include purchases already committed for 2021 [121]. The utility has also installed 14 chargers at three of its work locations for employee use. In total, Toronto Hydro and the City of Toronto have installed 17 EV chargers in nine locations in the city as part of a one-year joint pilot [ 122]. According to its 2019 Annual Report, Oshawa Power & Utilities Corporation (OPUC) demonstrates support for transportation electrification [123]. The utility states, “We are doing more to support the City and Durham Region’s sustainability and smart city visions. Following our successful deployment of two electric vehicle (EV) charging stations in Oshawa’s downtown core in December, we received $1.4 million in funding from National Resources Canada to install an additional 20 stations throughout the City.” In its 2020 Annual Report, the utility confirms that it “partnered with [a] local transit company to provide the necessary charging infrastructure for eight buses under a pilot program testing the viability of electric buses in Durham [124]” (see Durham Transit below). On OPUC’s website currently, the utility features a general information page on EVs (titled “E-mission”) [125], which states that its EV strategy is to educate, empower and evolve. EnerFORGE is OPUC’s non-regulated arm (formerly known as Oshawa Energy Services). According to this firm’s website, it offers services focused on the design, build, finance, operation, and maintenance of electric infrastructure. It also states the portfolio of services will soon “include residential and transitfocused electric vehicle charging assets [126].” Burlington Hydro’s non-regulated affiliate, Burlington Electricity Services, offers an initiative called Future Grid Network [127]. Interested residential participants can obtain a Flo X-5 “Level 2” EV charger installed in their home for an “installation fee that will be quoted after the initial consultation” plus $800 for the charging station and $11 per month for five years of service support [ 128]. As part of this program offering, Fleetcarma (now part of Geotab Fleet Management) provides a logger and a communications device that allows Burlington Hydro to track and control charging behaviour. The resulting data are used by Burlington Hydro to help the utility determine the impacts of EV charging on the local grid. According to its website, Burlington Electricity Services plans to extend this initiative in the future. And Burlington Electricity Services also offers a Future Grid Condo Bundle aimed at developers and a “Level 2” charger targeting condo suite owners [129]. Currently, however, there is no electrified transit strategy apparent on Burlington Hydro’s website, although Burlington Hydro has been engaged in Burlington Transit’s full fleet electrification feasibility study being carried out by CUTRIC from 2020 to 2021.

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24 In addition to utility engagements in electrified transportation in Ontario, as discussed above, several municipalities, cities and towns are supporting electrified transit initiatives at the local level in the province. Several city and municipal governments already provide information on EVs for the general public on their respective websites. Other municipalities have proceeded to install charging units or have municipal strategies in place to move forward with explicit electrified transit programs to battle climate change. The following is a sampling of some of the activities undertaken by city and municipal governments in Ontario. Toronto: The City of Toronto itself has an Electric Vehicle Strategy [ 130] which calls for 100 per cent zeroemitting vehicles in Toronto by 2050. Electric buses and the TTC’s Green Bus Technology Plan are mentioned in the strategy. In addition, TransformTO, Toronto’s climate action strategy approved in 2017, includes a goal to achieve 100 per cent low- or zero-emissions transportation technologies (including public transit and personal vehicles) by 2050 [131]. The electrification of TTC buses and the transitioning of Toronto’s light-duty fleet to low-carbon vehicles by 2030 are action plans already underway, which are associated with this strategy. The TTC has joined with other transit agencies in Ontario through the Ontario Public Transit Association to form an “inter-agency co-operative procurement of eBuses. The aim of this collaboration is to develop a single zero-emissions bus procurement specification with the immediate benefit of reducing cost through economies of scale. The long-term benefit is through the optimization and standardization of customer experience, operations and maintenance throughout the GTHA and beyond [ 132].” In parallel, CUTRIC launched its own member-driven Joint Procurement Initiative (JPI) in 2020, which includes cities within the Greater Toronto and Hamilton Areas (GTHA). The CUTRIC JPI supports midsized and smaller agencies seeking a joint procurement of electric buses, electric charging systems (depot and on-route opportunity charging), and software systems support for city-wide transit electrification. Brampton: The City of Brampton is conducting a Transit Electric Bus Demonstration and Integration Trial as part of the CUTRIC-led Pan-Canadian Electric Bus Demonstration & Integration Trial. As part of this project, eight battery electric buses (BEBs) – two from Nova Bus and six from New Flyer – went into service as of May 4, 2021 [133]. The project demonstrates the interoperability and standardization of overhead bus charging systems with electric buses on a number of bus routes in the City of Brampton. Partners include CUTRIC (which spearheaded this initiative), Brampton Transit, the City of Brampton, York Region Transit, and the Regional Municipality of York. The Low Carbon Economy Fund provided $7.6 million and NRCan’s Green Infrastructure Program provided $3.5 million, totalling $11.1 million in funding [ 134]. The overall cost of the project is approximately $16 million, and it supports Brampton’s efforts to reduce its GHG emissions by 80 per cent by 2050 [135]. In addition, Brampton City Council recently approved plans for new bus maintenance and storage facilities for the electric bus fleet. The first phase of construction will begin in 2022 to be completed in late 2024 and will provide storage for about 250 buses. The estimated cost is between $120 million and $150 million. The second construction phase will allow for the storage of an additional 188 buses. Construction is contingent on obtaining government funding [136] [137]. Energy storage may be included in the facility plans. Guelph: The City of Guelph has confirmed it will also convert its transit bus fleet from diesel-powered to fully electric in the near- and mid-term future [138]. On January 16, 2020, the City announced that it would proceed immediately with the purchase of 35 battery electric battery buses (BEBs) that carry large battery packs, but which do not offer rapid fast charging on route (i.e., the vehicles will slow-charge at the transit agency’s depot only). The City also confirmed the purchase an additional 30 buses in the near future. Charging infrastructure and a bus storage facility are part of this conversion project. The City of Guelph is contributing $104 million to the initiative. The provincial and federal governments are contributing $33 million and $40 million, respectively.

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25 In late 2020, Guelph’s City Council approved the purchase of four electric bus chargers to be installed at the Watson Road transit headquarters at a cost of $1.5 million [ 139]. The Region of Waterloo: Regional Council approved Grand River Transit’s electric bus strategy on June 3, 2020. Grand River Transit has a service area that includes Kitchener and Waterloo. The transit agency will stop purchasing diesel-powered buses for its fleet beginning in 2021 and it will pilot electric buses beginning with the purchase of six electric buses in 2022 and five in 2023. Hybrid buses will be used in the interim. A review of the pilot will be conducted in 2024. The timing of the conversion could be expedited if federal funding becomes available [140]. Grand River Transit currently has a fleet of 276 buses. It is planning to have a fully-electric fleet by 2038 [141]. Kingston: One of Kingston City Council’s priorities is to electrify the city’s fleet, including vehicles used for public transit. The City of Kingston developed a Strategic Plan 2019–2022. The Plan included the acquisition of 12 electric buses and the replacement of up to 11 light-duty vehicles and arena equipment by 2022. In May 2019, Kingston’s City Council approved the purchase of two 40-foot long-range battery electric buses and related charging equipment. In a recent update to its Strategic Plan, the City confirmed, “With funding support from the Federal and Provincial governments the City has purchased 2 electric buses and charging equipment [142].” These two first buses, manufactured by New Flyer, were delivered to Kingston Transit in May 2021 [143]. Charging equipment has been commissioned and training of mechanics and drivers has begun. The buses were expected to be in service by the end of July 2021. Durham Region Transit (Oshawa): In November 2019, Durham Regional Council approved the purchase of up to eight battery electric buses and required charging infrastructure. Funding of $10.1 million is provided through the Federal Gas Tax Program. The feasibility analysis and scope development for the electric buses and charging infrastructure has been completed. Durham Region Transit is currently in the pre-design stage focused on enabling the deployment of charging infrastructure and electric buses in the third quarter of 2022. Durham Region Transit is also planning for the design and build of a new facility in north Oshawa to support a full fleet of zero emissions vehicles, while aiming for higher energy standards that will allow it to be a net-zero emissions building overall. At present, the agency has secured the required land, and the design stage of the project will commence in summer 2021. Durham Region Transit is also planning to complete a full fleet feasibility study on its conversion to zero emissions propulsion technologies, and to develop a transition plan for the fleet and supporting infrastructure by the end of 2021. The agency’s electrification plan will be aligned with the greenhouse gas emissions reductions targets set out by the Corporate Climate Change Action Plan (CCAP) adopted by Regional Council on March 24, 2021 [144]. The CCAP sets the following targets for greenhouse gas reduction (all relative to 2019 levels): 20 per cent reduction by 2025, 40 per cent by 2030 and 100 per cent by 2045 [145]. Oakville Transit: The Town of Oakville announced that it plans to replace 57 diesel buses with electric buses over the next six years and purchase an additional 16 buses for fleet expansion. The total cost of the conversion is $66 million, with $26.5 million coming from the federal government, $22.1 million from the provincial government and $17.6 from Oakville [146]. In addition, 32 charging stations will be installed [147]. On September 24, 2020, Oakville issued a request for proposals (RFP) for work to begin in November 2020 to be completed on May 2, 2021 for “consulting services to conduct an Electric Bus Needs Assessment and Rollout Plan to help us better understand what is required from an Operations and Infrastructure perspective to support a transition to Battery Electric Buses (BEB) [ 148].” There is no information available on its website currently on the outcome of that assessment. London: In January 2020, the City of London funded a feasibility study regarding a transition to electric buses. City councillors also agreed that the City of London would approach the province and the federal government for funding [149]. On April 28, 2021, the London Transit Commission voted to contract CUTRIC to “to map out a move to zero-emission buses,” with “a report that will weigh up the costs, benefits and

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26 risks to convert to an electric fleet.” CUTRIC had already completed a first full fleet feasibility study in 2020 for the transit agency based on BEB performance predictions. It is preparing its full ZEB Implementation Plan for London Transit in preparation for the City’s 2022 budget [ 150]. Sarnia: City Council voted on March 2, 2020 to investigate the option of purchasing electric buses for Sarnia [151]. In September 2020, the City of Sarnia asked for bids to complete a greenhouse gas and energy analysis of the current-versus-proposed electrified bus fleet, perform an operating cost analysis based on Sarnia’s bus routes, perform a facility analysis for capital planning purposes and do a route schedule review for electric bus optimization [152]. The bid was awarded in December 2020. Ottawa: Ottawa has made significant progress in transitioning to electric buses. In December 2020, the City of Ottawa announced it would be purchasing four 40-foot electric buses and charging infrastructure from New Flyer at cost of $9.3 million [153] with funding coming from the City of Ottawa ($6.0 million) and the federal government ($3.3 million) [154]. In March 2021, a report to the Ottawa Transit Commission reviewed progress made on the 2020 Business Plan [155]. The report states the Transit Commission is partnering with Hydro Ottawa and its subsidiary, Envari, to determine the modifications required to the power system to accommodate new BEBs. The Battery-Electric Bus Project is listed as a key priority for 2021. The report states OC Transpo staff are preparing a Recommended Technology Implementation Plan this year, and the Transit Commission is “working with Hydro Ottawa and their subsidiary Envari to plan and install electric charging infrastructure,” while “working closely with other City departments and stakeholders, including Hydro Ottawa to develop a comprehensive strategy to test and examine the functionality of battery-electric buses in Ottawa’s climate conditions.” In March 2021, with the announcement of federal government financial support for transit electrification, the Mayor of Ottawa announced the City would be considering an expansion of its electric bus pilot to take advantage of the funding opportunity, and that a report potentially increasing the number of electric buses would be prepared “before the summer [156].” In June 2021, the Ottawa Transit Commission proposed the purchase of up to 450 BEBs between 2022 and 2027 [157]. According to a report delivered to the Transit Commission on June 7, 2021 and to City Council on June 16, 2021, “With a gradual phase out of diesel buses, OC Transpo can achieve a zeroemission bus fleet by 2036. The next buses to be purchased, according to the fleet plan, are 74 40-foot buses to be ordered in 2022 and delivered in 2023 3.” The size of the current fleet is 932 buses [ 158]. The cost of the conversion program is approximately $1 billion, with funding support from Canada Infrastructure Bank loans and grants from the federal government. According to a report by the CBC, the proposed funding will also include a deal with Hydro Ottawa to create charging infrastructure for the new buses [159]. In July 2021, the Auditor General for the City of Ottawa announced there will be an audit of the risks associated with the conversion program before Council signs funding agreements. This audit of risks will include a review of assurances regarding winter performance and warranty provisions. The CBC reports the Auditor General “noted politicians have also delegated powers to city staff to negotiate with the federal government and Hydro Ottawa, which will install and run charging equipment at the St. Laurent garage [160].” GO Transit: Another major transportation electrification initiative in Ontario is the GO Transit Electrification project led by Metrolinx [161]. The project requires coordination with and assistance from Hydro One. The Hydro One Transmission Rate Filing for 2020–2022 [162] contains the Transmission System Plan for 2020– 2024. The plan includes load customer connection work to be completed during the plan period to connect six traction power stations for the Metrolinx rail electrification project. The fully recoverable gross costs for the project are estimated to be $24 million, with the in-service date slated as the first quarter of 2023. There may be additional costs at play for the utility due to conflicts caused by the construction of overhead catenary systems for the electric trains on property where Hydro One allows secondary land uses. 3 Note that these are in addition to the four electric buses already ordered for 2021.

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27 Manitoba Manitoba Hydro is the primary utility in the Province of Manitoba. Its website hosts no explicit strategy for the electrification of transportation. Furthermore, the utility’s Climate Change Strategy 2019 is only a highlevel document that does not mention electric vehicles in any manner [ 163]. The utility’s Climate Change Report 2020 states that Manitoba Hydro is “investigating new ways to electrify our fleet vehicles [164].” The company website does provide information on EVs [165], including the effects of cold weather on performance, and the site mentions that financing of up to $3,000 is available to customers for a “Level 2” electric vehicle charger through a Home Energy Efficiency Loan. The City of Winnipeg is making significant progress in adopting electric transit buses. In 2014, it announced that up to four New Flyer Xcelsior BEBs were put into service. This initiative was part of an electric bus demonstration project involving the City of Winnipeg, the Province of Manitoba, Manitoba Hydro, New Flyer Industries, Mitsubishi Heavy Industries, Red River College and Sustainable Development Technology Canada4 [166].” According to interviews carried out with staff at Winnipeg Transit as part of this report [ 167], the four buses went into service from 2014 to 2016. New Flyer installed a high-power (DC) charging station at Winnipeg’s international airport in October 2014 and four AC chargers were installed at the transit facilities. The buses continued to run into 2018, but were no longer operating as of January 2019, even though data for the pilot demonstrated several performance successes. On February 11, 2021, Winnipeg Transit presented its Transition to Zero-Emission Technical Evaluation Report to the city’s Standing Policy Committee on Infrastructure Renewal and Public Works [ 168]. The report features a technical, environmental, and cost evaluation of various zero-emission technologies, as well as an implementation strategy for transitioning the fleet to zero emissions by 2050. The transition will begin with a 16-bus trial, during which Winnipeg Transit will examine the costs and performance of an initial fleet of BEBs and hydrogen fuel cell battery-electric buses (FCEBs), among other factors such as the optimal fleet mix (i.e., battery size, propulsion type, etc.). The proposed composition of Winnipeg’s test fleet of buses is as follows:  Four 40-foot long-range BEBs with approximately 440 kWh of capacity  Four 60-foot long-range BEBs with approximately 466 kWh of capacity  Four 40-foot FCEBs  Four 60-foot FCEBs The test period will run over a period of 12 to 24 months. Following the trial, Winnipeg Transit aims to replace its diesel buses over time starting with an order of 18 zero-emission buses (ZEBs) in 2023, 18 additional ZEBs in 2024, and an additional 53 ZEBs through 2025 to 2026 [ 169]. Eventually, replacements will proceed at the rate of 30 to 35 buses per year. As a result, Winnipeg Transit aims to achieve a 40 per cent zero-emission fleet by 2031, one year behind the city’s target of 2030 and a 100 per cent transition of its 650 buses by 2045, five years ahead of the city’s 2050 target. Winnipeg Transit is initially considering a fleet mix of 70 per cent BEBs with large batteries that will charge primarily at depots, and 30 per cent FCEBs. However, the bus trial will provide the information necessary for this decision. The 16-bus test fleet will operate out of Winnipeg Transit’s Brandon Garage until 2027. Meanwhile, a new facility will be constructed to replace the North Garage at an estimated cost of $210.9 million, excluding costs associated with charging or fueling equipment. The New North Garage will become the main garage for future expansion of Winnipeg’s electric bus fleet after 2027. The cost of the test fleet project is approximately $38.3 million. The proposed Transition to Zero-Emission Bus Program is projected to cost $280.4 million by the end of 2026 with the estimated cost of the 100 to 110 zero-emission buses being $186.2 million of the total (inclusive of the initial 16 zero-emission buses).

4 Note that Manitoba Hydro’s collaboration was not described on the Manitoba Hydro webpages examined.

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28 Funding for the Transition to Zero Emission Bus Program is being sought from the governments of Canada and Manitoba through the Investing in Canada Infrastructure Program (ICIP): Public Transit Infrastructure Stream (PTIS). The City of Winnipeg will be responsible for the balance of the cost, although it is worth noting that the City’s budget already includes $61 million for its six-year Transit Bus Replacement Program, resulting in a gap of approximately $15.9 million in additional incremental funding required for the proposed program. As a municipal level, the City of Winnipeg is supportive of transportation electrification overall. The City’s Climate Action Plan includes recommendations to “increase the use and efficiency of public transit… increase the use of electric vehicles [and] utilize zero-emission buses [ 170].” The Province of Manitoba produced a document in 2017 titled A Made-in-Manitoba Climate and Green Plan [171], which indicated that the government could be exploring the purchase of zero-emission vehicles for the government fleet or installing electric vehicle charging infrastructure at government-owned buildings. In the 2019 Report of the Expert Advisory Council to the Minister of Sustainable Development for Manitoba, a council of experts further advised the province to support electrified transportation initiatives, including the requirement that developers incorporate EV charging stations into new residential and commercial developments above a minimum size, require a certain percentage of new vehicles sold in Manitoba to have zero emissions platforms, add an initial 20 electric buses to Winnipeg Transit’s fleet with associated charging infrastructure, and establish an incentive program for the purchases of EVs and charging stations [172]. It is unclear, however, what actions have been taken to implement these recommendations at the provincial level, as none of these recommendations appear in the province’s utility or energy strategy at Manitoba Hydro. Recently, several municipalities in Manitoba conjointly announced that 31 “Level 2” EV chargers will be installed in Winnipeg and other locations in southern Manitoba, funding for which will be provided by the federal government ($155,000), Eco-West Canada and the municipalities involved ($201,000) [ 173].

Saskatchewan SaskPower is the major utility in the province. Electric buses are not mentioned in SaskPower’s publicly available information, although the utility has general information on their website regarding electric vehicles and charging stations [174]. There are high-level strategic directions for the company to “reduce emissions by at least 50 per cent from 2005 levels by 2030” and ensure that “up to 50 per cent of our supply [is] coming from renewable sources”) [175]. An electric bus pilot is active in Saskatoon. In 2018, the City of Saskatoon produced a document called Low Emissions: Saskatoon's Mitigation Strategy [176]. The authors make recommendations regarding implementing an electric vehicle fleet and converting city-owned buses, vehicles, and equipment to electric, where feasible. In August 2019, the city produced a Low Emissions Community Plan in which the authors recommend 100 per cent of the City’s transit fleet should be electric by 2030. Early stages of this proposal would involve piloting a leased electric bus (if funding were available), developing an electric bus phase-in strategy and obtaining funding from various levels of government. Saskatoon released an RFP in August 2019 for a one-year lease of a slow-charged BEB using an in-depot charging system only [ 177]. The city intends to phase in a fully electric fleet and charging stations between 2022 and 2030 [ 178]. In July 2020, Saskatoon Transit announced a 40-foot BYD bus had begun its one-year term. The bus is leased at a cost of $9,500 per month with half of this provided by the Green Municipal Fund. The project is intended to help the City of Saskatoon determine how an electric bus fares in a Saskatchewan’s winter season [179] [180]. Saskatoon Transit’s preliminary reporting demonstrates the bus is proving reliable [ 181]. According to the City of Saskatoon’s Climate Action Plan: Progress Report 2020, this pilot bus should save approximately $30,000 annually in operating costs and 50 tonnes per year of greenhouse gas emissions. But “there is currently no funding identified to expand the number of electric buses in the City’s fleet [ 182].”

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29 The City of Saskatoon wants to convert its municipal fleet to electric by 2030 [ 183] and had planned to develop a strategy for EV and charging stations in 2021. The strategy is not going to be completed on schedule, but the city has proceeded with a pilot of four light-duty EVs this year [ 184]. Conversely, the Premier of Saskatchewan recently announced a $150 annual tax would be placed on EVs in the province so that EV drivers pay their share of road maintenance, normally funded by gas taxes [ 185]. The tax will be payable beginning in October 2021. Saskatchewan is the only Canadian province to impose such a tax.

Alberta There are several major companies involved in electricity transmission and distribution in Alberta, such as ATCO, AltaLink, ENMAX and EPCOR. A review of website and public information provided by AltaLink, TransAlta, Direct Energy and the City of Lethbridge Electrical Utility revealed no utility-led interest or strategy focused on electrified transportation in the province’s electricity or utility marketplaces5. ATCO's website states the company’s “innovation team is focusing on the electrification of transportation” through its investments in constructing the Peaks to Prairies network of 20 DC fast chargers and a series of “Level 2” charging stations funded by a consortium of municipalities and federal and provincial governments [186]. ATCO is also invested in two electric transportation initiatives, namely, the Alberta EV Corridor and Curbside Charging. The Alberta EV Corridor consists of three “Level 2” and “Level 3” stations installed and operational in Calgary, Red Deer and Edmonton. Curbside Charging is a five-year project in conjunction with the City of Edmonton to pilot up to five public curbside electric vehicle chargers. ATCO reports all stations are now energized and operational [187]. ATCO also reports it will “help you successfully find and apply for government grants related to electrification of transportation! [ 188].” The utility states it can deliver a full-service business consulting service for EV design, installation, and maintenance. This includes commercial charging systems for light-duty cars and “electric bus fleet, heavy duty and freight charging, fleet charging optimization strategies, and solar/battery integration and optimization,” although it is not documented publicly which (if any) transit electrification projects in Alberta ATCO has been actively involved in. ENMAX (Generation Portfolio Inc.) was recognized as Emissions Reduction Alberta (ERA) BEST Challenge Project recipient, receiving funding for an EV technology pilot related to its fleet of medium-duty trucks. The pilot consists of two medium-duty Class-6 trucks outfitted as box vans for tools and crew. The vehicle platforms, built by Navistar, will be tested for one year at minimum (the same platform used for bucket trucks) [189]. According to ERA’s website, the E-Fleet Pilot will demonstrate and test truck electrification technology in the operational environment of a utility and in all weather conditions, including harsh winters. ENMAX is monitoring truck capacity and performance, as well as battery and charging infrastructure performance and usage, to assess viability and “identify any infrastructure barriers to adoption [190].” The cost of the project is $2.1 million with approximately $1 million contributed by ERA. In parallel, ENMAX is running a program called “Charge Up” across Calgary to gauge the effect of EV adoption on its grid. The utility has helped to offset the cost of EV chargers in selected business and home locations to obtain a better understanding of demand-related issues resulting from EV use [ 191]. A section of ENMAX’s website is also dedicated to designing, constructing, and maintaining electric light rail transit (LRT) systems [192]. In contrast to ATCO and ENMAX, EPCOR Alberta’s web site contains general information only for customers about EVs and charging systems for cars [193].

Other transportation electrification projects (not utility-led) Several significant transportation electrification projects are taking place in Alberta for which electrical utilities do not appear to be sponsors. The City of Edmonton conducted several electric bus test projects in 2014 to determine performance across seasonal weather conditions. More field trials were conducted in 2015 and 2016, specifically 5 Note that the City of Lethbridge is a participant in the Peaks to Prairies initiative and has installed EV chargers in two locations.

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30 examining winter operation. In August 2020, Edmonton Transit deployed the first of 40 electric buses ordered from Proterra. All 40 buses are now in service [194]. The buses use in-depot overhead charging. The conversion to electric buses is part of a larger City of Edmonton electric vehicle strategy that focuses on electric buses, fleet management and electric vehicle charging city-wide [ 195]. Edmonton Transit Services, eCAMION, the University of Alberta and the University of Calgary received approximately $9 million in funding from the ERA BEST Challenge Project to support a clean technology innovation project. The research involves the use of an energy storage battery for bus charging at the City of Edmonton’s Kathleen Andrews Transit Garage [196]. In St. Albert, Alberta, four new slow-charged electric buses were added to the local transit fleet in 2018 to serve local and commuter routes. Funding was provided by the Government of Canada’s Public Transit Infrastructure Fund and the Government of Alberta’s GreenTRIP funding program. These four new buses were in addition to three electric buses originally purchased in 2017 [197]. In late 2020, provincial funding for the purchase of more electric buses fell through, which also affected St. Albert’s ability to obtain federal funding. As a result, the City of St. Albert opted to purchase five diesel buses instead [ 198]. The City of Calgary Electric Bus On-Route Charging Deployment is another project receiving ERA funding ($7 million). According to the ERA website, “the proposed project scope will include the deployment of electric public transit buses and associated on-route rapid-charging infrastructure at three to four transit hubs for the City of Calgary. The objective of this project is to build capacity for Calgary Transit to integrate BEBs into the transit fleet with the objective of meeting Council approved goals related to climate resiliency in a fiscally responsible way.” The city states that “lessons learned from the project will be shared with Alberta municipalities, transit organizations, and other Canadian municipalities, and will complement electric bus demonstrations underway across Alberta [ 199].” The project entails procuring 14 battery electric shuttle buses and installing charging stations in one of the Calgary maintenance facilities. In June 2021, Calgary Transit selected Vicinity Lightning EV shuttle buses. The vehicles are intended to be fully delivered and in operation by 2022 [200]. The cost of the buses is $6 million. The shuttles, about half the size of regular transit buses, were chosen because Calgary Transit articulated a desire to learn more about the performance of small buses, including how well they function during winter [201]. Calgary Transit will evaluate the trial results in a year’s time and determine next steps. Another relevant initiative is the Alberta Zero Emissions Truck Electrification Collaboration (AZETEC). This project is based in Edmonton and is led by the Alberta Motor Transport Association (AMTA) in collaboration with project partners Hydrogen Technology and Energy Corporation, Zen Clean Energy Solutions, Canadian Energy Systems Analysis Research, Bison Transport, Trimac Transportation, Suncor Energy, Emissions Reduction Alberta, Dana, Ballard, and Freightliner [ 202]. The cost of this threeyear project is $16.5-million, $7.3 million of which comes from ERA. The project incorporates hydrogen fuel cell technology and will demonstrate two “long-range” fuel cell electric trucks (FCET) between Edmonton and Calgary. The fuel cell hybrid trucks will be powered by a Ballard Power Systems “next generation” proton exchange membrane fuel cell engine, integrated along with a lithium-ion battery pack into a hybrid electric drive by Nordresa, on a Freightliner Class 8 truck platform [203]. On June 3, 2021, the federal Minister of Natural Resources announced a $2.3 million investment in the project, contributing to the construction of a hydrogen fueling station to serve highway heavy-duty commercial fleet vehicles in real-world conditions such as temperatures ranging from -40°C to +40°C and able to refuel in 20 to 45 minutes. The trucks are in development and are scheduled to begin transporting goods in the second quarter of 2022.

British Columbia The largest electrical utility in British Columbia is BC Hydro. Other utilities are New Westminster Utilities, FortisBC and Columbia Power.

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31 BC Hydro clearly outlines its role with respect to electric vehicles on its website and has an EV page featuring general information for customers [204] [205]. The utility owns and operates one of the charging networks in the province, BC Hydro EV, which consists of 70 fast-charging stations, as well as some “mini” fast-chargers and “Level 2” chargers. There is a mobile app associated with the network [ 206]. The utility also identifies opportunities for electric vehicle innovation and solutions, works with Powertech Labs on demonstration projects, and is developing a “technology road map” of the evolution of electric vehicles. Nothing in the material reviewed online, however, addresses the electric bus pilots being conducted in the province, despite BC Hydro’s extensive support of the CUTRIC-led Pan-Canadian Electric Bus Demonstration & Integration Project with TransLink [207]. In August 2019, BC Hydro approached its regulator, the BC Utilities Commission, for approval of two rate schedules – the Overnight Rate (150 kW and over) and the Demand Transition Rate (150 kW and over) – applicable to charging electric fleet vehicles and vessels. The request was predicated on the fact the current rate structure is an impediment to public transit providers that wish to convert their fleets to electric buses. Consultation took place with both TransLink and BC Transit [ 208]. On March 26, 2020, the British Columbia Utilities Commission approved the utility’s request, and the Overnight Rate was approved effective April 1, 2021. The Demand Transition Rate was approved effective April 1, 2020 and will terminate effective March 31, 2032 [209]. FortisBC hosts an electric vehicle webpage on its website with general information for EV owners [ 210]. Fortis states that it operates more than two dozen DC fast chargers at locations across the southern interior of BC. Plans to have at least 40 chargers in 23 communities by the end of 2021 are underway [ 211]. Fortis Inc.’s Sustainability Report for 2020 [212] notes the utility is a founding member of the Alliance for Transportation Electrification in the United States. The utility is also involved in the Accelerate Kootenays initiative, which is installing an EV charging network in BC. Fortis has provided $10,000 seed funding for that project and $180,000 of funding for “Level 2” and direct current fast chargers for service area sites [ 213]. The material reviewed did not reflect any interest by Fortis in electric buses. The City of New Westminster is incorporating electric vehicles into the city's fleet, installing electric vehicle chargers, and requiring new buildings to have the electrical infrastructure to allow for “Level 2” charging. During this review, little was found that discussed electric buses, although one of the current British Columbia electric bus pilot projects (TransLink) is taking place in Vancouver and New Westminster [214]. Columbia Power’s website contains no information about electric transportation.

Electric bus initiatives There are significant electric bus initiatives ongoing in British Columbia. BC Transit operates transit outside of Metro Vancouver. It has produced a Low Carbon Fleet Program that seeks to achieve the following goals:  Transition all vehicles to electric propulsion based on the fleet replacement plan  Bridge transitioning to electric with renewable fuels  Guide investment decisions through business cases  Develop partnerships (including working with BC Hydro to define infrastructure requirements for the bus charging systems) [215]. BC Transit plans to replace more than 1,200 existing buses and add another 350 buses over the next 10 years, while also aiming to have the entire fleet composed of electric buses by 2040 [ 216]. The transit agency has committed to deploying 10 BEBs and required charging infrastructure to the Victoria Regional Transit System by 2022. TransLink serves and delivers transit to the Metro Vancouver region. It has entered into a long-term demonstration program as part of CUTRIC’s Pan-Canadian Electric Bus Demonstration and Integration Trial: Phase I. TransLink’s deployment includes four electric buses and two overhead chargers

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32 standardized to the OppCharge™ Protocol internationally. It is taking place in Vancouver, Burnaby, and New Westminster. The four electric buses (two from Nova Bus, and two from New Flyer) went into service in 2019 [217] [218]. TransLink is committed to operating a 100 per cent renewable energy fleet by 2050. In January 2021, TransLink announced it will purchase 15 additional electric buses from Nova Bus. Funding for this $16 million initiative is provided by the Federal Gas Tax Fund. The buses will begin arriving in 2022. In addition, TransLink has applied for funding to support a future purchase of another 57 electric buses and requisite charging infrastructure [219]. TransLink plans to convert all buses to zero emissions by 2050 and has committed to replacing all retiring diesel buses with electric buses. TransLink’s electric bus plan and targets are outlined in its Low Carbon Fleet Strategy [220] [221]. Electric school buses are also being introduced across British Columbia. The Sooke School District procured two electric school buses in May 2021. Five additional BC school districts are expected to receive their buses within the 2021 fiscal year. The province has invested in the purchase of 18 electric school buses in total as part of its electric school bus programming [ 222].

Province-led transport electrification initiatives The Province of British Columbia is also active in promoting electrified transportation in the light-duty vehicle sector. It is offering up to $3,000 in rebates for individual purchases or leases of new battery electric or hydrogen fuel cell electric vehicles, as well as longer-range plug-in hybrid electric vehicles. The province also offers $1,500 for the purchase or lease of a shorter-range plug-in hybrid electric vehicle. In British Columbia, homeowners can also obtain a rebate for home chargers of up to 50 per cent of the costs of purchase and installation of “Level 2” charging equipment. Up to a maximum of $350 is offered and administered by BC Hydro and FortisBC for this purpose. The province also offers rebates for apartments, condominiums, and workplaces to encourage the installation of charging equipment en masse. BC’s SCRAP-IT program offers incentives to vehicle owners who are purchasing an EV and scrapping their gas-powered vehicle [223]. Under the province’s Zero-Emission Vehicles Act passed on May 30, 2019, at least 10 per cent of all lightduty vehicle sales must be electric by 2025, 30 per cent by 2030 and 100 per cent by 2040 [ 224].

Yukon Yukon customers are served by Yukon Energy and ATCO Electric Yukon. No information is available on their websites concerning electrified transportation. One electrified transportation project appears to involve ATCO Electric Yukon, however. In October 2020, the Yukon government installed three new “Level 3” EV chargers, bringing the total number of publicly accessible EV chargers in Yukon to 16. The chargers are being installed as part of a three-year study into cold-weather functioning of electric vehicles, including travel range, and charging efficiency. Funding of $676,500 has been provided by the Canadian and Yukon governments. Several other partners are named as participants in this project, one of which is ATCO Electric Yukon [ 225]. On September 14, 2020, the Yukon government released its climate change strategy titled Our Clean Future [226]. Yukon states that it plans to reduce its “total greenhouse emissions from transportation, heating, electricity generation, other commercial and industrial activities, waste and other areas so that our emissions in these areas are 30 per cent lower than they were in 2010” by the year 2030. As road transportation accounts for 54 per cent of Yukon’s greenhouse gas emissions, the strategy contains many details related to electrified transportation. In summary, the Yukon plans to achieve a target of at least 4,800 zero emission vehicles (ZEVs) registered on the road by 2030, representing about one in eight passenger vehicles. It has also established a requirement that ZEVs comprise 10 per cent of light-duty vehicle sales by 2025 and 30 per cent by 2030, although it is not clear how the region will achieve this ambitious goal. It will offer rebates for purchasing ZEVs and it will aim to ensure that half of all new cars purchased by the government itself are ZEVs.

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33 As part of its climate action efforts, the region also aims to increase the use of public and active transportation and launch a pilot project in 2021 to test the use of short-haul medium- and heavy-duty electric vehicles for commercial and institutional applications. To help achieve all of these goals, the Yukon has budgeted $18.4 million over the next 10 years to provide rebates to purchasers of EVs and to support incentives for installation of charging stations. The rebate of $5,000 is in addition to that offered by the federal government [227].

Northwest Territories Two utilities operate in the Northwest Territories (NWT), the larger of which is Northwest Territories Power Corporation and the smaller of which is Northland Utilities. Neither has information on their websites related to electrified transportation. Northland Utilities’s website provides a link to the Arctic Energy Alliance, a not-for-profit organization founded by the government of the NWT [ 228]. The NWT government is interested in promoting electrified transportation. In its 2030 Energy Strategy: A Path to More Affordable, Secure and Sustainable Energy in the Northwest Territories, one strategic objective is to reduce greenhouse gas emissions from transportation by 10 per cent per capita by the year 2030 [229]. The NWT has also produced a 2030 NWT Climate Change Strategic Framework [ 230] which links to the Energy Strategy. In June 2020, purchasers of new electric or hybrid cars in the NWT became eligible for a $5,000 vehicle rebate and a $500 charger rebate if they are in a community served with hydroelectric power. The rebates are offered by the Arctic Energy Alliance [231].

Nunavut The electrical utility in Nunavut is the Qilliq Energy Corporation. No electrified transportation initiatives could be found on its website.

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34

NORTH AMERICAN CASE STUDIES Introduction

This section provides utility case studies of key legislation, policies and methods that have overcome barriers to the electrification of transit bus fleets. Case studies cover examples in Ontario, British Columbia, and California. Transit fleet electrification is a complex and costly process. It is driven in part by government policy designed to reduce vehicle GHG emissions to low or zero levels. Recognition that “business as usual” will not achieve emissions reductions goals has resulted in a number of jurisdictions taking measures to stimulate the electrification of vehicles, including transit fleets. This section of the report reviews case study information obtained from a combination of sources, including regulatory documents, utility documents and, for Ontario cases, direct discussions and interviews with utility personnel involved in the activity described.

Case 1: Newmarket-Tay Power (NTPDL) and York Region Transit (YRT) Newmarket-Tay Power Distribution Limited (NTPDL) is an electricity distributor licensed by the Ontario Energy Board (OEB). NTPDL provides electricity distribution services in the Town of Newmarket, the Town of Midland and certain parts of the Township of Tay. NTPDL currently serves approximately 44,000 customers across its service areas [232]. NTPDL is 93 per cent owned by Newmarket Hydro Holdings Inc., a wholly owned subsidiary of The Town of Newmarket, and seven per cent owned by Tay Hydro Inc., wholly owned by the Township of Tay. NTPDL earns revenue by delivering electric power to the homes and businesses in its service territory. Performance standards and rates are regulated by the OEB. York Region Transit (YRT) was created in 2001 from the amalgamation of five municipal transit systems. It serves a population of over 1.2 million residents and more than 54,000 businesses [ 233] [234]. YRT facilities in the Town of Newmarket receive their electricity supply from NTPDL.

NTPDL and the YRT electric bus trial In 2016, NTPDL attended its first CUTRIC-led Electric Vehicle (EV) Working Group meeting for the (thentitled) Pan-Ontario Electric Bus Demonstration & Integration Trial. The purpose of the two-year trial was to show how electric buses can reduce GHG emissions by displacing diesel buses and help meet Ontario’s GHG reduction goals. As one of the lead participants in the trial, YRT proposed a six km electric bus route in the Town of Newmarket. This route would use an on-route bus charger to allow buses to remain on routes longer than with just depot charging. One of the lessons that CUTRIC learned from other jurisdictions is that agencies require local utility engagement early on in the planning process to maximize lessons learned from a demonstration trial and to support long-term BEB integration. As this trial would be in NTPDL’s service area, CUTRIC engaged the utility that immediately expressed support for the project in terms of ensuring adequate supply infrastructure on the distribution side. Federal funding for part of the trial was achieved through a CUTRIC-led joint application to the NRCan Electric Vehicle Infrastructure Demonstration (EVID) Program. This program funded up to 75 per cent of the charging facilities, with the remaining 25 per cent of costs funded through other stakeholders in the

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35 project. In this case, the utility, NTPDL, was asked to invest the remaining 25 per cent of the charger cost. The on-route charging facility was estimated to cost approximately $1 million. EV bus funding was to be covered equally by the transit agency and the province.

NTPDL as charger owner Following internal senior leadership discussions on the proposal, NTPDL agreed to become the stakeholder for the acquisition of the overhead on-route EV charger. Its share of the charger cost would be approximately $250,000. NTPDL ownership would mitigate some of the financial barriers the transit agency was experiencing in moving towards fleet electrification at the time. NTPDL also determined that utility ownership of the charger is beneficial to its business as well as to society at large as it would help ensure that transit agencies could rely on a secure source of electrical (i.e., “fuel”) supply. Utilities typically ensure power is always available to clients through system planning, design, installation, and operational management of electrical infrastructure. NTPDL’s executive leadership also identified that the trial would demonstrate the value of long-term utility ownership of charging stations and it would help to develop a successful partnership between public transit and local utilities operating in the same service area. This owner-operator model is shown in Figure 1 below:

Figure 1: Utility owner-operator arrangement

Regulatory and other challenges There are challenges, however, to this intended ownership model for NTPDL. As a regulated utility under the OEB, NTPDL is subject to OEB rules on allowable activities and investments. The OEB’s objectives in the regulation of electrical utilities are stated in the Ontario Energy Board Act. As a general rule, regulated utilities do not invest in customer-side infrastructure [235]. This is because utility customers (residential, commercial, industrial, etc.) are expected to fund their own infrastructure needs and not have them funded through the utility ratepayer base. In most cases, only the customer benefits from the investment and thus only the customer should carry the cost of the infrastructure. Ownership of an electric car charger or electric bus would not be allowed in the rate base using a strict interpretation upon which only the transit agency (as opposed to society at large) benefits from the charging equipment. This basic regulatory requirement precludes utilities from continuing with electric bus co-investment pilots, therefore. However, in July of 2016, the OEB specified that “the Act” provides exemptions for services that assist in the province’s goals in electricity conservation. It stated that “licensed electricity distributors are not precluded from owning and operating EV charging stations so long as the equipment provides for the management of load in keeping with the Government’s goals for electricity conservation [ 236].” In this sense, charger ownership as part of the rate base could be achieved through mechanisms such as pairing the chargers with energy storage and smart grid controls to limit on-peak charging activities. To perform activities that would not be subject to regulation, some utilities have created affiliate entities. These entities operate separately from the regulated utility business. Examples of utility affiliate operations include activities such as fibre ownership, and operation and maintenance services. Affiliates operate on commercial market terms and are not funded by regulated utility operations. NTPDL does not have an

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36 unregulated affiliate. Charger investments had to reside within the regulated local distribution company (LDC). Under OEB regulation, NTPDL was not able to earn a rate of return on the charger on the LDC side. While this restriction is manageable for a one-charger pilot program is it not sustainable for mass charger deployment on behalf of a fleet-wide transit agency program. Other challenges arose for NTPDL in the timing of funding sources, as well. With the support of CUTRIC, which led a joint federal bid for funding on behalf of three transit agencies (York Region Transit, Brampton Transit and TransLink) in 2016, NTPDL secured its portion of the winning funds from NRCan in early 2018. However, a portion of funding for the project was also confirmed by the Government of Ontario under Premier Kathleen Wynne. Upon election of Premier Doug Ford’s government, however, the province cancelled its portion of committed funds. As a result, the purchase of electric buses by the transit agency was delayed until 2019, when York Region itself voted to fill the provincial funding gap from regional revenues. This delay resulted in coordination difficulties with infrastructure installation, commissioning, and program spending deadlines.

Result Following procurement and commissioning, the NTPDL on-route charger was placed into service in June 2020. NTPDL and YRT collaborated on the site development, installation, and commissioning of the overhead on-route charger. YRT has agreed to an operations arrangement that enabled NTPDL to manage its charger on YRT property. The Government of Canada (through NRCan) has provided a sizeable capital contribution that covers a significant portion of the overall project cost associated with NTPDL’s charger, thereby allowing NTPDL to invest in EV supply equipment (EVSE) infrastructure on the YRT site. As part of the charger procurement process and bus deployment program, the charger original equipment manufacturer (OEM) provides ongoing planned and unplanned maintenance support for the unit for the duration of the program (of approximately two and a half years). The resulting installation and pilot period responsibilities for the EV overhead charger installation in Newmarket serving YRT buses are summarized in the table below: Table 1: Responsibilities for EV overhead charger installation

Responsibility

YRT

NTPDL

Grid capacity and connection Charger procurement Charger ownership Charger operation Bus procurement Bus ownership Bus operation Site civil and electrical design Site civil and electrical procurement Site civil and electrical ownership 1 Site civil and electrical inspection and testing Overall site maintenance Planned and reactive charger maintenance

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Charger OEM


37 The on-route charger was commissioned in 2020 and is now in full-service operation. YRT’s six electric buses have been using the charger while gathering valuable operating experience and performance data from the vehicles and chargers. CUTRIC collects, analyzes, and reports on the performance of the NTPDL charger and YRT electric buses on a regular basis to both NTPDL and YRT as well as the wider consortium of partners involved in the Pan-Canadian Electric Bus Demonstration & Integration Trial (i.e., Brampton Transit, TransLink, BC Hydro).

Longer-term options Over the long term, and once the demonstration project is completed, NTPDL must consider three options: 1. Maintain ownership and operation of the charging unit with the charger remaining outside of the rate base. 2. Work with YRT to integrate site storage and renewable generation with the charger and demonstrate management of load, in keeping with Ontario’s goals for electricity conservation with the charger in the rate base. 3. Develop an agreement with YRT to transfer ownership of the charger and customer site supply infrastructure to YRT so that NTPDL returns to strictly utility supply-side ownership of distribution system infrastructure.

Figure 2: Options for ownership of charging systems

Summary This arrangement demonstrates the best practices that can be achieved under current utility regulatory restrictions in Ontario. Utility ownership of charging systems in Ontario is possible under specific regulatory criteria and guidance. Ongoing utility–transit agency cooperation on roles and responsibility for charger installation is required to identify gaps and resolve areas of uncertainty. External third-party government funding is crucial to the success of programs like the demonstration project described above. Without external funding to support charging units, the NTPDL-YRT (CUTRIC-led) program would not have proceeded. This case also demonstrates the pitfalls of inconsistent government policy (i.e., provincial funding of YRT buses failing despite confirmation by the province) that raises venture risk and sends mixed signals to those involved in long-term sustainable transit or energy programs, which require large capital investment.

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38 Case 2: OPG-TTC-Toronto Hydro Electrification Framework Ontario Power Generation (OPG) is the province’s largest electricity producer. As part of its business, OPG owns and operates both regulated and unregulated generation facilities. OPG’s Climate Change Plan commits to being a net-zero carbon company by 2040 [237]. Toronto Hydro is owned by the City of Toronto. Toronto Hydro owns and operates the electricity distribution system that delivers electricity to approximately 779,000 customers in the City of Toronto [ 238]. The Toronto Transit Commission (TTC) serves over 500 million riders annually in the City of Toronto and consists of over 3,400 vehicles of various types. In 2019, the TTC launched its Green Bus Program with the procurement of 60 fully electric battery buses. The TTC’s Green Bus Program outlines a plan to transition the bus fleet to zero-emissions by 2040 by procuring approximately 190 battery electric buses (BEBs) per year starting in 2023 [ 239]. OPG’s partnership with the TTC and Toronto Hydro in the Electrification Framework is through an unregulated subsidiary [240].

Required charging infrastructure Through its Green Bus Program, the TTC has obtained extensive knowledge about electric bus operations through metrics that have been monitored, tracked, and analyzed over the two-year deployment of its first 60 electric buses [241]. As part of its Green Bus Program rollout, the TTC determined that a significant amount of charging infrastructure will be required to support full fleet electrification. This infrastructure is not just limited to chargers at TTC facilities, but also includes upstream infrastructure at the electricity distribution system level (Toronto Hydro). Lessons learned from this deployment have been applied to an Electrification Infrastructure sub-program of the Green Bus Program. The Electrification Infrastructure program deals with the necessary upgrading of Toronto Hydro’s local distribution system and the implementation of required charging-related infrastructure at TTC sites.

Funding gap The TTC plans to procure 190 battery BEBs per year that are expected to require $500 million in funding over the 2021 to 2035 period (this includes related charging infrastructure and facility improvements). However, its 10-year 2021–2030 capital budget identifies only $79 million (16 per cent) in available funding, which allows for 300 of the 1,440 required charging stations. Additional funding sources will be required to meet the plan requirements [242] [243]. In 2020, the TTC began exploring potential partnership opportunities that could address its funding gap and minimize risk for the TTC’s electric vehicle charging infrastructure. Specifically, the TTC reviewed contract bundling strategies and explored potential partnerships with Toronto Hydro and OPG. Contract bundling strategies, while feasible, carry performance and cost risks [ 244]. These risks may be mitigated in a TTC-OPG-Toronto Hydro partnership. The TTC reviewed the contract bundling options and strategies outlined below.

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Figure 3: Contract bundling strategies

Toronto Hydro and OPG roles Toronto Hydro is precluded by regulation from investing in electric bus charging activities through the rate base, so it would not be able to address any funding gaps the TTC faces in terms of charging infrastructure procurement. Any funding from Toronto Hydro must come from outside of the rate base and be commercially viable. Nonetheless, Toronto Hydro will still have an important role to play in the deployment of the charging stations by connecting the charging infrastructure to its distribution system and ensuring capacity is available. By contrast, OPG will be able to invest in charging activities for the TTC and help to address the funding gap through an unregulated subsidiary. OPG could own, design, install and operate charging systems and related infrastructure at TTC facilities. OPG’s owner/operator role would be based on commercial terms through a TTC-OPG Master Agreement. The OPG’s ownership and operation of the charging fleet would ensure independence from any single manufacturer of charger or bus products, and it would allow for greater procurement flexibility at the TTC.

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40 Electrification framework After considerable review and discussion between the TTC, OPG and Toronto Hydro, the three entities produced a recommended Framework for Agreement. This agreement envisions the TTC, OPG and Toronto Hydro entering into a non-binding memorandum of understanding for the co-investment, ownership, design, build, operations, and maintenance of all electrification infrastructure required to implement the TTC’s Green Bus Program [245]. Toronto Hydro will provide upstream capacity and connection, OPG will design, own, operate and maintain the charging stations, and the TTC will focus on BEB procurement and operation. Although the TTC explored other program delivery models, this arrangement presented above entailed the least amount of perceived or actual risk to the transit agency given that the operational risk of the charging stations is being transferred to the OPG, while Toronto Hydro continues to perform its normal utility role in ensuring reliable connections and making capacity available. The arrangement described above is shown in Figure 4 below:

Figure 4: Scope of electrification infrastructure

As previously shown in Figure 2, OPG will have the potential to install additional infrastructure on sites besides the substation and charger. OPG envisions the potential installation of storage batteries, generators, and renewable generation to complement the reliability of electricity supplies. When aggregated, this type of storage capacity could be leveraged by OPG to access value in the electricity market through vehicle-to-grid (V2G) mechanisms, such as the provision of frequency regulation, spinning reserve and demand response. This infrastructure could also minimize the TTC’s demand and energy charges from Toronto Hydro by minimizing the TTC’s energy draw from the main electrical grid at times of highest cost.

Summary This case provides a good example of how the commercial private sector can invest in transit charging facilities. There are no regulatory restrictions in this arrangement. Toronto Hydro’s role is to ensure capacity is available in the distribution system and to connect the customer (TTC) to the grid. This is business as usual for the local distribution company. The arrangement with OPG also minimizes risks to the TTC associated with operations and costs, while providing the required funding for the agency’s bus fleet electrification efforts. Third party funding/financing is provided on a commercial basis, which will be defined in specific agreements between OPG and the TTC. This arrangement also leaves the door open to government funding to supplement the cost of fleet electrification, and it provides an opportunity to demonstrate V2G benefits and capabilities where the market value of electrification infrastructure (i.e., capacity payments for grid support) can be accessed without impacting ongoing transit operations.

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41 Case 3: BC government, BCUC and transportation electrification The Government of British Columbia has been a leader on the Canadian transportation electrification scene for several years. It’s passage of the Clean Energy Act and Greenhouse Gas Reduction Regulation (GGRR) provided a road map for the province to reduce its greenhouse gas emissions by 2050 to at least 80 per cent less than 2007 emissions levels. The British Columbia Utility Commission (BCUC) is the provincial regulator for energy services. The two key electric utilities in the province are BC Hydro and Fortis BC.

Early policy decisions In 2010, the British Columbia government passed its Clean Energy Act (CEA), which committed the province to move towards significant reductions in greenhouse gas emissions by the year 2050 [ 246]. A key component of the Act is the provision of terms defining “prescribed undertakings” (CEA Section 18) [ 247], which allows the government to designate projects or activities that reduce GHG emissions and allow utilities to recover their costs from the ratepayer base. In 2012, the British Columbia government passed the Greenhouse Gas Reduction Regulation (B.C. Reg. 102/2012) [248]. The Regulation defined “prescribed undertakings” related to electrification that would encourage customers to use electricity instead of other energy sources that produce more emissions. Utility ownership of EV charging infrastructure is not addressed in that Regulation, however, as a “prescribed undertaking.”

British Columbia Utilities Commission (BCUC) inquiries In 2018, the BCUC held an inquiry into the regulation of electric vehicle charging services. The inquiry explored the level of regulation necessary in the EV charging services market and rates for EV charging services. The inquiry considered several regulatory issues including:  Should the selling of EV charging services be a regulated activity?  Is the EV charging market a monopoly requiring regulation?  If utilities have a role in providing charging services, what is the risk to the ratepayer and how much cross-subsidization of this activity is appropriate? Phase 1 of the inquiry concluded the EV charging market is not a monopoly and the provision of EV charging services does not require regulation. In Phase 2 of the inquiry, BCUC reviewed the role of the public utility’s participation in the EV charging market. By Order G-50-19, dated March 6, 2019, the BCUC agreed there is a role for utilities in providing public EV charging services. The BCUC considered the specific level of utility investment required for EV charging infrastructure to kick-start the emerging EV marketplace, while at the same time avoiding monopoly control over the emerging market (thus minimizing risk to ratepayers of the investments over the long-term) [249]. The BCUC concluded that amendments to the Greenhouse Gas Reduction Regulation (GGRR) to allow public utilities to own and operate EV charging stations as a “prescribed undertaking” would be required to provide direction to utilities and to allow for cost recovery efforts of EV investments by utilities in the ratepayer base [250]. In 2020, the British Columbia government amended the GGRR by adding provisions that make certain EV fast-charging stations “prescribed undertakings.” This amendment shows that utility ownership of publicly accessible charging stations is in the public interest. It enables utility ownership of publicly accessible EV fast-charging stations and associated infrastructure and the recovery of these costs in the rate base [ 251]. The “prescribed undertaking” designation does not apply to non-public charging facilities for fleet use.

BC Hydro: Fleet rates In 2019, BC Hydro applied to the BCUC for approval of rates for two new services that would benefit electric vehicle fleet operators [252]. The two proposed rates were:

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42 

An Overnight rate that has no demand charge overnight and a flat energy charge that applies to energy usage any time of the day

A Demand Transition rate that results in no demand charges for the first six years of a 12-year program, but which transitions back to the normal rate over the remaining six years of the program

The Overnight rate applies to demands of 150kW size or larger and is primarily targeted to support and benefit depot charging. The Demand Transition rate applies to demands of 150kW size or larger and is primarily targeted to support on-route charging. BC Hydro demonstrated to the BCUC that both rates would provide benefit/cost ratios greater than one (>1) in both the medium and long term as the utilization of the charging facilities increases over time. The Overnight and Demand Transition rates were approved and came into effect on April 1, 2020 [ 253].

BC Hydro: Fast-charger rates With the amendments to the GGRR, BC Hydro applied to the BCUC for EV fast-charger rates to cover 25 kw, 50 kW and 100 kW fast-charger installations owned by BC Hydro [ 254]. BC Hydro had 96 fast-charger installations as of March 31, 2021. The rates are time based, as rates based on energy use cannot be implemented due to the lack of Measurement Canada-approved metering [ 255]. The proposed fast-charger rates recover the cost of electricity but are not expected to recover all the capital costs associated with the stations themselves or the maintenance costs. Costs not recovered by the proposed rates will be recovered from ratepayers. BC Hydro’s long-term plan is to adjust rates for full-cost recovery once the EV charging market matures, mitigating the impact on ratepayers.

Fortis BC: Fast-charger rates Fortis began the installation of EV charging stations prior to the BCUC decision on utility ownership and operation of EV charging stations. Fortis BC applied for EV charging rates in December 2017 [ 256]. The BCUC approved interim EV rates and instructed Fortis BC to exclude its EV charging stations from the rate base, and then adjourned the regulatory process. With the amendments to the GGRR in place, Fortis BC re-applied to the BCUC for EV fast-charger rates to cover 50 kW and 100 kW fast-charger installations owned by Fortis BC. Fortis BC had 40 fast-charger installations in service prior to the passage of the GGRR amendment. In its rate filing, Fortis proposed EV charging rates that would recover the cost of its eligible charging stations over the next 10 years [ 257]. Fortis BC is also seeking BCUC approval to apply GGRR amendment terms to the 40 EV charging facilities installed prior to the passage of the GGRR amendment [258].

Case 4: California legislation Introduction California is considered a leader in transportation electrification and emissions reductions measures. Transportation electrification in California has been an evolving process. Key players in the transportation electrification effort are the California Public Utilities Commission (CPUC) and the investor-owned electrical utilities that supply power to consumers, including transit agencies, throughout the state. The key utilities are Pacific Gas and Electric (PG&E), Southern California Edison (SCE), San Diego Gas & Electric (SDG&E) and Liberty Utilities (LU). The CPUC is the regulator of the state’s electric investor-owned utilities. It plays a critical role in the state’s transportation electrification efforts. With respect to transportation electrification, the CPUC is involved in electric rate design, electric system infrastructure deployment and grid management.

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43 Early policy decisions As in other jurisdictions, many barriers to EV adoption, including regulatory ones, occurred. In 2009, the CPUC held a review of policies to overcome barriers to EV adoption and address utility ownership of electric vehicle service equipment. In their 2011 decision, the CPUC concluded that due to the potential for competitive limitations resulting from utility ownership, they should not own EV service equipment. However, utilities could own EV service equipment to charge their own EV fleets and for employees to charge their own vehicles [ 259]. The CPUC held further consultations on establishing policies to expand utility roles in the development of electric vehicle infrastructure. In their 2014 decision, the CPUC determined that state utilities had a critical role in the electric transportation sector as the fuel suppliers [260]. The decision expanded the utility role in the supply of EV infrastructure. Any request for the utility to own public EV charging infrastructure would be considered on a case-by-case basis based on factors such as the nature of the utility program and the impact on competition. In a sense, the CPUC confirmed the intent of the previous 2011 decision, namely that: “Benefits of utility ownership of EV charging infrastructure must be balanced against the competitive limitation that may result from that ownership [261].” The blanket prohibition on utility ownership of EV service equipment was overturned. It was even noted that utility activity that promoted and accelerated EV infrastructure would aid third party business cases.

Senate Bill 350 In 2015, Senate Bill 350, the Clean Energy and Pollution Reduction Act, was filed [262]. This legislation provided direction to the CPUC in five major policy areas:  Integrated resource planning  Energy efficiency  Renewable energy  Transportation electrification  Disadvantaged communities Key actions enacted by this legislation were amendments to Sections 701.1 and 740.8 of the Public Utilities Code. These changes amended the definition of “interests” of the ratepayer to include reductions in pollution and greenhouse gas emissions and added transportation electrification as a principal goal of electric utility resources planning [263]. This redefinition is a fundamental change from historical regulatory definitions of what constitutes ratepayer interest in utility regulation. Most regulatory objectives concentrate on regulating utility activity with respect to prices, adequacy, reliability, and quality of electricity service. For the state to meet its clean energy and pollution reduction targets, utilities need to increase access to electricity as a transportation fuel, and the status quo regulatory investment rules would not achieve these goals. To this end, Section 740.12 was added to the Public Utilities Code. Section 740.12 directs utilities to file applications for programs and investments to accelerate widespread transportation electrification, to reduce dependence on petroleum, meet air quality standards and achieve the goals set forth in the Charge Ahead California Initiative, which would reduce emissions of greenhouse gases to 40 per cent below 1990 levels by 2030, and to 80 per cent below 1990 levels by 2050 [ 264]. The key impact of Senate Bill 350 is that it requires utilities to invest in transportation electrification measures, which is a stark contrast to typical regulatory restrictions on non-electricity distribution activities, such as those found in the Ontario Energy Board Act (Section 71) [265]. The California utilities are required to file plans with the regulator, which provides review and approval of the utility’s transportation electrification investment plans subject to it being in the ratepayer’s interest, as newly defined above. Under these new rules, all six state utilities have filed plans with the CPUC that address a number of activities that accelerate transportation electrification [ 266].

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44 Graphic summaries are provided below:

SDG&E

Table 2: Three large investor-owned utilities (IOUs) approved Senate Bill 350 projects Medium/Heav y Duty Infrastructure

Residential Infrastructur e

$592 Million

$141 Million

Fleet Delivery Service $3.7 M

Residential Charging Infrastructure $137 M

SCE

Transit Bus Make-Ready & Rebate $4 M MD/HD Charging Infrastructure

Public DC Fast Charging

Taxi/Shuttle

Education/ Outreach

$30 Million

$3.2 Million

$2.3 Million

Electrify Local Highways $4 M

Green Shuttle $3.2 M

Car Dealer Incentives $1.8 M

Residential Grid Integration Rate

$13 Million Airport Ground Support Equipment $2.8 M MD/HD and Forklift Port Electrification $2.4 M

Residential Make-Ready Rebate $4 M

Port of Long Beach Gantry Crane $4 M

Urban DC Fast Charger Clusters $4 M

Offroad Infrastructure

Total SDG&E Budget: $155 M

Total SCE Budget: $360 M

Port of Long Beach ITS Terminal Yard Tractor $0.5 M

Commercial EV Rate Design

PG&E

MD/HD Fleet Demonstration $3.4 M

Idle-Reduction Technology Demonstratio n $1.7 M

Fast Charge Infrastructure $22 M

Electric School Bus Renewable Integration $2.2 M FleetReady Make-Ready Infrastructure $236 M

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Home Charger Information Total PG&E Budget: $266 M


45 Table 3: Three small IOUs proposed Senate Bill 350 projects under CPUC review Public DC Fast Charging $4 Million

Commercial Infrastructure

Heavy-Duty Infrastructur e

Education & Outreach

$1.18 Million

$223,000

$235,000

EV Bus Infrastructure Program $223,000

Customer Online Resource Project $65,000

EV TOU Pilot Rate $139,000

Bear Valley ($746,500) PacifiCorp Liberty Utilities ($440,000) ($6.2 M)

Residential Infrastructur e $1.74 Million

Destination Make-Ready Rebate $607,500 DC Fast Charger Project $4M

Residential Make-Ready Rebate $1.6 M

Small Business Make-Ready Rebate $300,000

Demonstratio n& Development Grant Program $270,000

Outreach & Education Program $170,000

Presented at CPUC ZEV Rate Design Forum June 7, 2018

Senate Bill 1000: Electric vehicle charging infrastructure In 2018, Senate Bill 1000 was filed [267]. The Bill required the CPUC to explore:  Policies that support the development of technologies and rate strategies that can reduce the effects of demand charges on electric vehicles and fleets, and help accelerate the adoption of electric vehicles; and, 

Adopt a tariff specific to heavy-duty electric vehicle fleets or electric trucks and buses that encourages the use of charging stations when there is excess grid capacity.

Under Senate Bill 1000, the California utilities (PG&E, SCE, etc.) submitted several new rate proposals to mitigate the impact of electricity costs, as a fuel, on fleet operations.

CPUC electrification framework In 2018, the CPUC held a proceeding (R.18-12-006) to develop a comprehensive framework to guide the CPUC’s role in the electrification of California’s transportation sector [ 268]. Specifically, it directed the state utilities to develop new rates to support transportation electrification. Up to this point, the CPUC had reviewed and evaluated utility proposals for transportation electrification investment on a case-by-case basis, balancing the benefits of utility charging infrastructure ownership against the competitive limitation that may result from that ownership, which is time consuming and detracts the CPUC from addressing other critical issues such as rate structures. No long-term strategies or market signals emerged from this process. It was, however, the CPUC’s intent with this proceeding to establish a common and comprehensive framework for utility transportation electrification investments that align with Senate Bill 350, as described

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46 above, and to encourage the development of holistic strategies for transportation electrification rather than ad hoc utility plans. In 2020, the CPUC published a draft Transportation Electrification Framework. The framework’s near-term objectives are:  Ensuring strategic integration of transportation electrification load  Enhancing market coordination of utility transportation electrification investments  Enabling third-party private sector investment  Supporting state transportation electrification policy and program cohesiveness  Ensuring accountability Utilities have and will continue to play a critical role in transportation electrification infrastructure deployment. Recognizing this, the Transportation Electrification Framework is intended to provide clearer guidance to utilities about the role they should play in deploying transportation electrification infrastructure or related strategies to support the development of third-party transportation electrification business opportunities in line with the objectives noted above. The Transportation Electrification Framework requires utilities to develop 10-year strategic investment plans to support transportation electrification infrastructure. The 10-year plans should outline strategies to optimally integrate transportation electrification load onto the grid, including ratepayer-funded transportation electrification programs and the delivery of electricity as per normal utility business practices. Initial utility plans should be filed no later than one year after the CPUC adopts a final Transportation Electrification Framework. Appendix C of the Transportation Electrification Framework also provides a checklist of requirements that utilities need to incorporate into their plans [ 269]. As of the publication of this report, the Transportation Electrification Framework is still under review.

Summary This case has demonstrated the value of enabling the kind of legislation required to accelerate the electrification of transportation through utility capital and operating investments and new rate structures. Regulatory oversight plays a balancing act between the interests of the ratepayers, competitive enablement, and the need to accelerate transportation electrification through utility investment mechanisms. Long-term utility strategies are required to ensure that utility investments contribute to transportation electrification.

Case 5: Pacific Gas and Electric Pacific Gas and Electric (PG&E) is a regulated public utility in California that provides energy service to 16 million people through 5.1 million electric accounts and 4.4 million natural gas accounts in northern and central California. Its service area spans 70,000 square miles [ 270].

Capital infrastructure In 2017, in response to the requirements of Senate Bill 350, PG&E filed an application to the CPUC for the approval of proposed programs and investments to accelerate widespread transportation electrification [271]. Programs ranged from a five-year fleet make-ready infrastructure program to education programs for home charging. The programs are designed to address the following barriers:  Upfront costs of charging infrastructure  Vehicle operating costs  Access to charging  Lack of awareness and understanding One of the programs applicable to transit operations is the proposed Medium-Duty and Heavy-Duty Electric Vehicle Charging Infrastructure Program. Two key concepts described in the PG&E proposal are that of make-ready infrastructure and EVSE. The CPUC decided to define these terms for consistency and common understanding: 

“Make-ready” is defined as service connection and supply infrastructure that supports EV charging comprised of the electrical infrastructure from the distribution circuit to the stub of

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47 the EVSE. It can include equipment on the utility-side (e.g., transformer) and customer-side (e.g., electrical panel, conduit, wiring) of the meter. 

“EVSE” is defined as the equipment that interconnects the alternating current (AC) electricity grid at a site to the EV. Sometimes the term is used more broadly to mean charging station whether AC or DC, but not including the make-ready infrastructure or other charging infrastructure.

The fleet make-ready infrastructure program would support the goals of Senate Bill 350 by accelerating transportation electrification through investments by PG&E in the upfront infrastructure costs of makeready infrastructure. PG&E considered this proposal to be in the public interest as per Senate Bill 350 and, as such, could be an activity undertaken by the regulated utility. This ownership of the EVSE would remain with the customer.

Figure 5: Make-Ready versus Business as Usual

Based on its strategic proposal, PG&E would procure, own, install, operate, and maintain the make-ready infrastructure beyond the meter. The additional investment would be subject to utility ratemaking in that the investment is i) used, ii) useful, and iii) meets utility customers’ needs. PG&E would also provide financial incentives and rebates towards the purchase of charging equipment for businesses, including transit agencies, to help them electrify their fleets. Transit authorities would receive up to $15,000 towards the cost of a charger. For those customers that wish to provide and own their own make-ready infrastructure, PG&E would provide a rebate of up to 80 per cent of the installation cost. The California Transit Association welcomed the PG&E and other utility (SCE) proposals and considered them far-reaching in scope and able to address barriers to transportation electrification across transportation modes and sectors. The upfront cost of electric buses and chargers are considered a key barrier to transit electrification. The utility proposals address this and, as such, would lead to greater adoption of battery electric transit buses by California’s public transit agencies. The CPUC reviewed the PG&E proposals and approved them with modifications [ 272]. Rebates will cover the cost of the EVSE and make-ready infrastructure. For EVSE, rebates for transit agencies are up to $15,000 and limited to 50 percent of the EVSE cost, less any other funding sources that the transit agency has obtained towards its procurement. The EVSE should be competitively purchased and installed by the transit agency. Customers can also own the make-ready infrastructure if so desired. Make-ready rebates will be limited to 80 per cent of the installation cost as per the PG&E proposal. The CPUC also decided that any related rebates to customers would be treated as a utility expense and not eligible for a rate of return.

Rates In late 2018, PG&E filed an application to create a new Commercial EV Charging rate class which would include two new rate schedules (EV-Small and EV-Large) [ 273]. Distinct from current commercial and industrial (C&I) rates, these EV schedules would feature two components:

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48 1. A monthly “subscription charge” based on the customer’s maximum charging capacity 2. A time-of-use (TOU) volumetric rate, designed to encourage customers to charge at times of greater grid capacity, renewable generation, and lower marginal cost The subscription charge would replace traditional demand charges. The aim of this proposal was to improve the fuel-cost business case for commercial EV charging. For electrification to work in a business or fleet context, electric fuel must cost less than the fossil fuel that it replaces. At the time, PG&E’s existing EV general service rates favoured high-load factor customers where electricity usage is consistent and close to maximum demand. Low-load factor customers pay high demand charges relative to their total electricity consumption. This cost can be high relative to fossil fuel cost per km, especially for customers that cannot manage their electrical loads. Transit agencies tend to operate their buses on heavy-duty cycles during the day, leaving evening and overnight hours for servicing and cleaning. With electric buses, rapid charging could be added to the overnight activities. A low electricity rate during the overnight hours would reduce the fuel-cost barrier for transit agencies and make electricity more price competitive with fossil fuel equivalents. The PG&E Subscription charge would be based on a customer’s connected charging load. The subscription charge would be significantly lower on an equivalent per-kW basis compared to existing demand charges. Customers could choose a subscription level lower than their historical monthly demand, and if they maintain monthly demand levels below the subscription amount, they could enjoy considerable savings in monthly charging costs. The PG&E Volumetric charge would consist of time-of-use periods that are consistent year-round, seven days a week. The peak period hours for the Commercial Electric Vehicle (CEV) rate would be from 4 p.m. to 10 p.m., every day year-round. The Super Off-Peak (SOP) period would be from 9 a.m. to 2 p.m., every day year-round. PG&E believes this may encourage installation of on-site battery storage to shift peak consumption to the SOP. All other hours each day would be off-peak from midnight to 9 a.m., 2 p.m. to 4 p.m., and 10 p.m. to midnight. Shifting charging to off-peak and super off-peak hours would also reduce overall monthly energy costs. PG&E created a transit site model for rate impact calculations. The site model consists of the following parameters:  12 x 100 kW chargers  24 vehicles x 150 miles/day travelled  Electricity consumption of 2 kW/mile per vehicle Modelling of these rates for this transit site indicated a 30 per cent annual savings over existing rates. Electricity fuel costs are significantly lower than fossil fuel costs.

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Figure 6: Sample transit estimated bill cost comparison Source: Pacific Gas and Electric Company vehicle rate proposal prepared testimony, 2018 [274]

The parameters of the EV-Large rate that would be applicable to transit agencies is shown below: Table 4: Large clean energy vehicle (CEV) rate proposal Line No.

Rate

Primary E-CEV-L P $172.87

Secondary E-CEV-L S $183.86

1 Subscription (per 50kW) 2 Energy Charges 3 Peak (4pm – 10pm) $0.29526 $0.30267 4 Off-Peak (all other hours) $0.10807 $0.11079 5 SOP (9am – 2pm) $0.08663 $0.08882 Source: Pacific Gas and Electric Company vehicle rate proposal prepared testimony, 2018 [275].

The CPUC approved this rate schedule with a modifier that the peak period is changed from 4:00 p.m. to 9:00 p.m. [276]. The CPUC noted there would be cost shifting to other rate classes due to this new rate and that, in the near term, some rate classes may see reductions due to this rate. Any customer overages to the contracted subscription amount would be subject to a grace period of three consecutive billing cycles to allow the customer to get back into subscription compliance. The CPUC also instructed PG&E to file a dynamic rate for additional customer choice and flexibility at a future date. While this rate would consist of a fixed customer charge, variable demand charge and hourly energy charges where the price of energy varied in each hour of the day, transit operators generally preferred a simpler rate structure as presented in the EV-Large rate approved by the CPUC.

Summary The PG&E case offers an example of utility-led strategies that support transportation and transit electrification. The Medium-Duty and Heavy-Duty Electric Vehicle Charging Infrastructure Program addresses the funding barrier of transit make-ready infrastructure through utility ownership and rebates that can partially address (50 per cent) the funding barrier of the EVSE. The new commercial rate that replaces demand charges with subscription charges can also benefit transit agencies because the scheduled nature of transit operations and improved value of off-peak charging would likely result in lower overall “fuel” costs compared to current rate schedules.

Case 6: Southern California Edison

Southern California Edison (SCE) is a regulated public utility in California that provides electricity to 15 million people in southern California. Its service area spans 50,000 square miles [ 277].

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50 Capital infrastructure In 2017, in response to the requirements of Senate Bill 350, SCE filed an application to the CPUC for the approval of proposed programs and investments to accelerate widespread transportation electrification [278]. Similar to PG&E, SCE’s Medium-Duty and Heavy-Duty Vehicle Charging Infrastructure Program proposed to have SCE procure, own, install, operate, and maintain the make-ready electric infrastructure required to serve EVSE for medium-duty and heavy-duty vehicles. SCE also proposed to provide a rebate for the costs of the charging equipment, which would apply to transit cases. The SCE rebate proposal differed from that of PG&E in that it offered a 100 per cent rebate towards the cost and installation of the EVSE. Rebates would be capitalized over a 10-year period and, as such, they would be in the utility rate base and eligible for a rate of return (i.e., profit). In decision D.18-05-040, the CPUC deemed the SCE rebate to be excessive [ 279]. As with the PG&E rebate proposal, the CPUC limited rebates at 50 per cent. As with PG&E, the customer could own the make-ready infrastructure if so desired and receive a rebate of up to 80 per cent from SCE. Rebates to customers would be treated as a utility expense and not eligible for a rate of return. The EVSE and make-ready proposals would apply to transit authorities and their transportation electrification efforts.

Rates SCE also filed for new commercial EV rates, the TOU-EV-7, TOU-EV-8 and TOU-EV-9 rates [ 280]. The TOU-EV-7 rate would apply to customers with facility monthly maximum demand ≤ 20 kW. The TOU-EV-8 rate would apply to customers with facility monthly maximum demand ≥ 21 kW and ≤ 500 kW. The TOU-EV-9 rate would apply to customers with facility monthly maximum demand > 500 kW. These time-of-use periods would include a winter super-off-peak period from 8 a.m. to 4 p.m. every day and a summer off-peak period from 9 p.m. to 4 p.m. every day. The rates would not have a demand charge for a five-year implementation period. Instead, a portion of the demand costs over the implementation period would be recovered through energy charges. Demand charges would be reintroduced in year six, increasing annually to full cost by year eleven. Table 5: Summary of SCE’s proposed commercial EV rates Tariff

Monthly Maximum Demand

TOU-EV-7

20kW

TOU-EV-8 TOU-EV-9

21-500kW 500kW

Application of Demand Charges Option A: No Demand Charges Option B: Phased in, beginning year 6 Phased in, beginning year 6 Phased in, beginning year 6

Benefits of the new rates would be:  Reduced demand charges relative to current rates  Attractive volumetric rates during daytime super-off-peak periods and overnight  Lower summer season charges to mitigate seasonal bill volatility The CPUC approved the proposed rates, which became effective as of March 1, 2019 [ 281]. Under the new rate structures, transit agencies that can “smart” schedule their charging needs outside of on-peak hours should observe considerable savings.

Summary The SCE case offers an example of transportation electrification enabling that directly supports transit agencies. Similar to the PG&E program, the SCE Medium-Duty and Heavy-Duty Vehicle Charging Infrastructure Program aims to address the funding barriers facing transit make-ready infrastructure

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51 through utility ownership mechanisms for that infrastructure. It also includes rebates that partially address (up to 50 per cent) the capital cost of the EVSE. The program’s new commercial EV rates would minimize and eliminate demand charges for the first five years. And the new off-peak rates benefit transit agencies, as the scheduled nature of transit operations combined with targeted off-peak charging will likely result in lower overall “fuel” costs compared to current rate schedules.

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52 Case 7: San Diego Gas and Electric San Diego Gas and Electric (SDG&E) is a regulated public utility in California that provides energy service to 3.6 million people through 1.4 million electric meters and 873,000 natural gas meters in San Diego and southern Orange counties [282]. In 2017, in response to the requirements of Senate Bill 350, SDG&E filed an application to the CPUC for the approval of proposed programs and investments to accelerate widespread transportation electrification [283]. Programs ranged from residential charging to fleet delivery services. There were no programs that directly impacted transit fleet electrification, but there was one that had a positive decision on utility ownership of charging stations.

Decision on charging station ownership Decision D.18-01-024 addressed the issue of utility ownership of charging stations serving the public and specific commercial entities [284]. SDG&E presented several proposals where it would own the make-ready infrastructure and EV charging equipment (e.g., “Level 2” chargers) for airport, port, highway parking, fleet delivery facilities (e.g., UPS) and some shuttle services. A key barrier to customer ownership of the chargers is lack of funding. In their proposed pilot programs, SDG&E would work closely with the customers collecting operational data. This data, in turn, would be shared and would be very valuable to future customer and state electrification efforts. The CPUC agreed in this instance that it was in the public interest for SDG&E to own the chargers [ 285].

Upfront costs of charging infrastructure In 2018, SDG&E filed another application in response to the requirements of SB 350 [ 286]. Specifically, SDG&E proposed a Medium-Duty and Heavy-Duty Electric Vehicle Charging Infrastructure Program designed to address a key barrier of electrification of the public sector – the upfront capital costs of the charging infrastructure, which would apply to businesses, including transit agencies, that use medium-duty and heavy-duty vehicles. This approach is very similar to the programs offered by PG&E and SCE. In the proposal, SDG&E offered to install, maintain, and own the electricity supply infrastructure, up to the EVSE, which would be owned and maintained by SDG&E or by the businesses themselves. SDG&E would apply an allowance to the cost of the EVSE, the allowance varying on whether SDG&E or the business would own and maintain it. The business would pay the cost of the EVSE in excess of the allowance. The proposal covered a number of different charger installations, including 10 on-route charging facilities (350 kW) for transit vehicles. The proposed allowance for these chargers would be in the range of $200,000 and any costs above this (likely several hundreds of thousands of dollars still, depending on the power level of the charger) would be covered by the transit authority. The proposal was challenged by numerous intervenor groups and in late 2018 a settlement was proposed by the various parties. The settlement eliminated SDG&E ownership of the EVSE. Rebates of up to 50 per cent of the cost of the equipment would be provided to transit owners. The customer or utility could install the customer-side infrastructure that connects the equipment to the SDG&E grid. Customer-installed infrastructure would get a rebate of up to 80 per cent of the installation costs. The utility would treat these rebates as an expense, not capital. The settlement proposal did not receive unanimous consent and was further challenged by several intervenors. Upon review, it was determined by the CPUC that the settlement met the standards of reasonableness, legal consistency and being in the public interest, leading the CPUC to approve the amended proposal [287].

Rates In 2019, SDG&E filed an application for a new commercial EV rate [ 288]. The proposed new rate is designed to serve electric vehicle direct current fast-charging (DCFC) and medium-duty and heavy-duty (MD/HD) charging. The Electric Vehicle-High Power (EV-HP) rate is designed to provide a competitive price for electricity to customers who charge their electric vehicles during off-peak and super off-peak periods.

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53 Like the PG&E rate proposal, the SDG&E proposal addresses the rate barrier that many businesses experience in moving to transportation electrification through time-of-use periods to encourage off-peak and super off-peak charging along with a subscription charge replacing traditional demand charges. The SDG&E rate would apply to all separately metered electric vehicle charging loads with an aggregated maximum demand of 20 kilowatts (kW) or greater, excluding single-family home residential customers. The rate addresses the issue of demand charges, which would be replaced with a subscription charge. The rate would have a 10-year phase-in period (50 per cent over the first three years declining to zero per cent over the next seven years). After 10 years, the customer would pay the full EV-HP rate that begins when it is opened to customer enrollment. In this way, costs are scaled in over time. The time-of-use rate is structured to maximize the differential between on-peak and super-off-peak prices to encourage fleet charging during periods of lowest system demand. Table 6: Time-of-use (TOU) energy charges for EV-HP customers

TOU Energy Charges for EV-HP Customers Peak All days: 4pm – 9pm Off-Peak M-F: 6am – 4pm; 9pm – 12am Weekends & Holidays: 2pm – 4pm; 9pm – 12am Super Off-Peak M-F: 12am – 6am; 10am – 2pm March & April Only Weekends & Holidays: 12am – 2pm

Summe r $0.19

Winter

$0.12

$0.11

$0.10

$0.10

$0.18

Source: SDGE.PYDFF – EVHP Fact Sheet 2021 [289]

The subscription charge will be metered in 10 kW increments for customers with a maximum demand of 150 kW, and in 25 kW increments for all other customers. Under 150kW, fleets can subscribe in increments of 10kW at $37.79 each. Over 150kW, fleets can subscribe in increments of 25kW at $103.61 each. Source: SDGE.PYDFF – EVHP Fact Sheet 2021 [290]

This rate will be available commencing in January 2022.

Summary The SDG&E case offers two examples of transportation electrification enabling, which support transit electrification efforts. The capital infrastructure program is similar to that offered by PG&E and SCE and would benefit transit agencies that are investing in depot and on-route charging facilities. Similar to the PG&E example, the new EV-HP rate replaces demand charges and existing volumetric rates with subscription charges and new volumetric rates, which will benefit transit agencies by enabling lower overall operating costs.

Case 8: Liberty CalPeco

Liberty Utilities (LU) is a regulated public utility in California that provides energy service to several small and mid-sized communities across the state. This case study covers an application by Liberty CalPeco, located in South Lake Tahoe [291].

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54 Capital infrastructure In mid-2017, in response to the requirements of Senate Bill 350, Liberty Utilities (“Liberty”) filed an application to the CPUC for the approval of proposed programs and investments to accelerate widespread transportation electrification [292]. Programs ranged from a DC Fast Charger Project to an EV Bus Infrastructure Program. The EV Bus Infrastructure Program specifically benefited transit fleet electrification efforts at the Tahoe Transportation District (TTD). The program aimed to assist the TTD with the procurement and operation of electric buses over a three-to-four-year period. Liberty Utilities would cover the procurement, installation, operation, and maintenance of two bus chargers to provide for overnight depot charging, and it would also include all the make-ready infrastructure for the chargers. The proposal was challenged by intervenor groups that objected to utility ownership of the EVSE. Liberty cited the previous SDG&E decision (D.18-01-024) on utility ownership of chargers as rationale for EVSE ownership. The CPUC reviewed the matter and decided that the ownership of the equipment would not be exclusive to Liberty but that the site host, TTD, could also own the equipment. The utility is still allowed to own the make-ready infrastructure and integrate the cost of that capital infrastructure into its rate base [ 293]. If TTD prefers Liberty to own the charger, then Liberty can rate-base the EVSE costs. In this case, TTD would pay Liberty 50 percent of the equipment cost used towards ongoing operation and maintenance. If TTD prefers to own the charger, then Liberty will provide a rebate (50 percent) to TTD towards the cost of the charger. Liberty would expense the rebate.

Summary The Liberty case offers an example of transportation electrification enabling that support transit electrification efforts. The capital infrastructure program is similar to that offered by PG&E, SCE and SDG&E, but it also allows for utility or transit ownership of the EVSE. The transit authority can own and operate the EVSE or compensate the utility if the latter owns and operates the EVSE. This approach provides more flexible options for transit agencies, especially smaller ones that would find complete EVSE ownership and operation onerous and complicated.

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CONCLUSION The strongest utility strategy for transportation electrification in Canada is in Quebec, where clear alignment in goals exists between the province and the utility. The province benefits from vertical integration, as it fosters technology development and manufacturing related to the use of the plentiful and cheap electricity produced by the province’s own utility [294]. Hydro Québec has many initiatives geared toward promoting transportation electrification. It has created a Centre of Excellence in Transportation Electrification, which provides a service to help school bus operators electrify their fleet and serves as a research partnership dedicated to developing solid state batteries for electric vehicles. Quebec has been instrumental in constructing a province-wide charging network and is involved in large-scale transportation electrification projects. The provincial government provides further support for transportation electrification by providing generous amounts of funding. In Ontario, the situation is mixed given the large number of utilities, the variation in their size utilities and the lack of a consistent external driving force for change. However, some significant projects have emerged that involve utilities, such as Toronto Hydro’s support for TTC’s Green Bus Program. More recently, through the Framework for Agreement between the TTC, OPG and Toronto Hydro, OPG will own and operate behind-the-meter charging infrastructure and distributed energy resources at TTC sites. In Canada’s eastern provinces, utilities do not have explicit strategies on their websites regarding electrified transportation. However, there are initiatives that indicate support for electric vehicle charging. Two recent developments include Halifax Transit adopting electric buses and PEI moving ahead with electric school buses. Electric vehicle charging networks are being installed in Newfoundland, PEI, Nova Scotia, and New Brunswick. A review of Manitoba Hydro documents did not reveal a strategy for electrified transportation, but Winnipeg Transit is starting a significant electric bus trial, and the utility is offering its support. In Saskatchewan, a review of SaskPower documentation did not reveal a strategy for the electrification of transportation. There is an electric bus trial taking place, however, in Saskatoon. Similar to Ontario, Alberta utilities did not have clear electrification-of-transit strategies available for review. However, initiatives taken by these utilities include electric vehicle charging, electrification of fleet mediumduty trucks, the construction and maintenance of light rail transit, and transit fleet conversions in Edmonton and St. Albert. In British Columbia, BC Hydro’s electrified transportation strategy points largely to supporting electric vehicle charging. Fortis BC also has an interest in electric vehicle charging. There are significant bus electrification initiatives in the province such as the BC Transit fleet conversion, and the TransLink pilot and plans to purchase additional electric buses. Electric school buses are also starting to appear in British Columbia. Utilities in the Northwest Territories, Yukon and Nunavut do not appear to have electrified transportation strategies. The governments of the Northwest Territories and the Yukon have expressed an interest, however, in electrified transportation.

Various roles of utilities in transportation electrification

This report also reviewed strategies for electrifying transit across several cities, municipalities, and provincial governments in cases in which these entities are the owners of their utilities and can, therefore, influence priorities. It is easier to make a change, such as converting a transit fleet from diesel to electric, when the interests of the transit owner are aligned with the interests of the utility owner. In some instances, the unregulated arms of some utilities are entering into the electric vehicle charging marketplace and other allied electrified transportation initiatives as pure business opportunities. One example is Elexicon Group, which offers a large suite of electrified transportation services, ranging from bus conversions to fleet acquisition planning and financing.

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56 In some locations in Canada, electrified transportation projects are proceeding without the explicit involvement or support of their electrical utilities, although there are examples of utilities offering these projects consulting on load and infrastructure issues. In fact, in at least one case, engaging in transport electrification can be punishing as it may negatively affected the utility’s rate decision. In British Columbia, BC Hydro, has already approached the regulator to obtain more advantageous rate structures for public transit providers. Some small towns and their respective local utilities lack the resources or expertise for transportation electrification. During this review, examples of smaller utilities that formed or joined a larger group with an interest in transportation electrification illustrated that they did not have the resources to pursue transportation electrification on their own.

North American best practices As a leader in enabling legislation and policy to allow utility investment in transit electrification measures, California demonstrates progressive actions and measures ranging from capital equipment investment to development of rate schedules specifically designed to provide favourable conditions for fleet operations, including transit, in an electrified environment. The four California case studies presented in this report review how legislation and regulations have encouraged utility investment in the electrification of transportation, including public transit (see Appendix A). California’s Senate Bill 350 redefines the Public Utilities Code to allow for utility investment in transportation electrification as an activity in the interest of the ratepayer. California Senate Bill 1000 requires utilities to develop new rate proposals to mitigate the impact of electricity costs as a fuel on fleet operations. Currently, several California utilities are replacing demand charges with subscription rates and investing in make-ready infrastructure (utility side of the customer meter) and EVSE, as allowed by the CPUC. These California case studies demonstrate the following outcomes: 1. Legislation is key to enabling utility investments in transportation electrification. 2. Promotion of fleet electrification in flexible and financially responsible manners can be achieved through utility capital investments in charging infrastructure. 3. New utility rate categories for fleets can reduce the overall “fuel” costs, while nudging vehicle charging activities to periods that benefit the efficiency of grid operations. This report also provides two case studies of utility investments in transit infrastructure in Ontario – one regulated, one unregulated. The two Ontario case studies demonstrate utility investments on the regulated side must adhere to provincial regulatory guidelines. Investments must also support other key provincial government objectives, as in the area of energy efficiency. At the same time, the knowledge, value, and flexibility of unregulated affiliates of utilities can be leveraged to support transit fleet electrification on commercial terms in a win-win scenario for both the utility and the transit authority. The engagement of unregulated affiliates can also create additional value-added infrastructure outcomes for transit agencies, such as market value for leveraging battery storage in support of grid operations (i.e., demand response, peak shaving, etc.). Overall, clear, and consistent government policy is required to provide for long-term investment in transit fleet electrification. The British Columbia case study demonstrates the evolution of utility investment in transportation electrification through detailed and consistent regulatory review and legislative direction. The case demonstrates that utilities can have a role in providing EV charging services that are in the public interest. Legislative direction to the regulator is required to provide clarity on utility ownership of charging infrastructure and the associated cost recovery of such investments. All these case studies – from California, Ontario, and British Columbia – show that utility-led investments and rate solutions aimed at transit electrification can be constructed in a way to provide positive benefits to the ratepayer.

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57 Looking ahead COVID-19 has reduced revenue and increased costs for transit agencies, reduced tax revenues for governments, and increased anxiety among people taking public transit. At the same time, the pandemic has served to highlight the consequences of human activities on the environment. The economic fallout from COVID-19 has been felt across the globe and in some countries government stimulus has been seen as an instrument to kick-start a recovery. In Canada, there have been multiple federal funding programs aimed at promoting transit electrification. The provision of funding has, without doubt, accelerated change. Still, some transit agencies have faced scenarios in recent years in which they have been forced to procure fossil-fueled options when funding has not been readily available to support the additional up-front capital costs associated with electric or hydrogen fuel cell electric buses and their associated charging or fuelling infrastructure. Additional and supplementary government support will be critical to a successful transition to zero-emissions transit fleets across Canada. Equally important, Canada’s provincial ministries of energy and their respective legislatures will need to clear legislative pathways forward that take climate change into account to enable electricity regulators and local utilities to invest in zero-emissions transit electrification infrastructure as part of a wider social “good” through programming that benefits both ratepayers and taxpayers over the long-term.

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APPENDIX A Summary of key legislation and utility activities that are beneficial to the electrification of transit fleets.  California Senate Bill 350 redefined the Public Utilities Code to allow for utility investment in transportation electrification as an activity in the interest of the ratepayer. 

California Senate Bill 350 required utilities to file plans to accelerate widespread transportation electrification.

California Senate Bill 1000 required the utilities to develop new rate proposals to mitigate the impact of electricity costs as a fuel on fleet operations.

California Public Utilities Commission established a common and comprehensive framework for utility transportation electrification investments over a 10-year period (Transportation Electrification Framework).

Pacific Gas & Electric (PG&E) Medium-Duty and Heavy-Duty Electric Vehicle Charging Infrastructure Program extended utility ownership to make-ready infrastructure for electric vehicle supply equipment (EVSE).

Pacific Gas & Electric (PG&E) Commercial EV Charging rate replaced the demand charge with subscription rates and new volumetric charges.

Southern California Edison (SCE) Medium- and Heavy-Duty Vehicle Charging Infrastructure Program extended utility ownership to make-ready infrastructure for EVSE.

Southern California Edison (SCE) Commercial EV Charging rate deferred demand charges for an initial five-year period.

San Diego Gas & Electric (SDG&E) Medium-Duty and Heavy-Duty Electric Vehicle Charging Infrastructure Program extended utility ownership to make-ready infrastructure.

San Diego Gas & Electric (SDG&E) Electric Vehicle High Power Charging Rate replaced the demand charge with subscription rates and new TOU rates.

Liberty Utilities (LU) EV Bus Infrastructure Program extended utility ownership to make-ready infrastructure and the EVSE.

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[] Conversation with Greg Gaudet, Director of Municipal Services at City of Summerside, May 17, 2021.

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141

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143

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144

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145

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150

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151

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154

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159

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161

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162

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166

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167

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168

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169

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170

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177

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178

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179

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180

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181

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182

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183

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184

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186

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187

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188

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189

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190

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192

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193

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194

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195

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196

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197

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198

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199

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200

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201

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202

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203

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204

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205

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206

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207

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208

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209

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213

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214

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215

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216

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217

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218

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219

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220

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224

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226

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227

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228

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232

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233

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234

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236

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