BC Clean Growth Intentions

On August 24th, the Victoria Electric Vehicle Club in partnership with the Vancouver Electric Vehicle Association and Plug-In Richmond issued a joint submission to the British Columbia government’s Clean Growth initiative. Marking one of the first times Western Canadian EV owners have presented combined proposals on zero emission transportation, the document was signed by James Locke (President VEVC), Bruce Sharpe (President VEVA) and John Roston (Plug-in Richmond), in the interest of expanding the province’s EV support programs and infrastructure.

The VEVC is proud to have been an integral part of drafting these recommendations and offers them to the membership below…

Introduction

The Vancouver Electric Vehicle Association (VEVA), The Victoria Electric Vehicle Club (VEVC) and Plug-in Richmond are all-volunteer groups of people from across BC who advocate for the electrification of transportation in all its forms. Our BC electric vehicle groups have been in existence from 7 years for the VEVC to 30 years for the VEVA and have accumulated a collective member list of over 2,000 national and international members in that time.

Electric vehicle members know what it’s like to buy, own, charge, and drive electric vehicles (EVs). Each year we interact with thousands of members of the public to educate, assist, and learn about their concerns.
Below is our response to the Clean Growth Intentions paper for transportation. We are pleased to see that the paper has proposals in each of the areas of

• vehicle purchase price and consumer awareness (demand)

• charging and refuelling stations (infrastructure)

• market capacity to meet demand (supply)

All three areas need to proceed in concert.

We see the top priorities for EV adoption to be

1. Continued, stable, predictable rebates for vehicle purchases and charging infrastructure

2. Solving the problem of charging in new and existing multi-unit residential buildings (MURBs)

3. Supply-side measures to ensure consumer choice across a wide range of vehicle models and price points

We offer brief comments below and would welcome the opportunity to participate in more detailed discussions on the specifics of the implementation of policies.

Comments on Proposals for Clean Transportation

• Continued incentives under CEV This is critical. The biggest concern we hear from the public is the initial purchase price. We are pleased to see that continuity of incentives is proposed. However, we feel that phasing out incentives based on 5% market share is too soon, particularly because that metric includes pluggable hybrid vehicles (PHEVs). A better criterion is to achieve cost parity between BEVs and internal-combustion engine (ICE) vehicles.

• Education and awareness People are increasingly aware of EVs, but misconceptions and myths are still prevalent. Continued and increased funding for organizations like Emotive is critical. Consideration should be given to emulating Ontario’s very successful Electric Vehicle Discover Centre.

• HOV lane access This is a perk that is much appreciated and should be continued. If congestion is a concern, consideration could be given to raising the bar for eligibility, for example, based on electric range.

• Preferential parking This has the potential to cause some resentment among non-EV owners. More important is encouraging the availability of charging in public places.

• Continued infrastructure growth A significant increase in DC Fast Chargers (DCFCs) is needed to give prospective EV owners confidence that they can travel anywhere in BC. The number of DCFCs in BC today is in the dozens. The need is for hundreds.

• Encourage infrastructure at businesses and other buildingsWe support this. Studies have shown that people are much more willing to purchase an EV if workplace charging is available. Workplace charging can also be one component of a solution to the critical problem of daily charging for MURB residents and others who don’t have access to charging at home.

• PST exemption The goal of rebates and tax exemptions is to change buying behavior. We support this exemption at all price levels to encourage car buyers to choose electric. Consideration could be given to restricting eligibility based on electric range. At a minimum, all EVs should be exempt from the vehicle luxury tax.

• Expand the Specialty Use Vehicle Program We support this and the general idea of encouraging electrification of all means of transportation.

• ZEV mandate In recent years, BC has implemented measures in the areas of demand and infrastructure, but improving supply has not been addressed. We feel it is very important to work simultaneously on all three components. On the supply side, we hear countless stories of problems: availability, model selection, dealer awareness, etc. A ZEV mandate would help address this missing component of government support.

• Ban ICE LDVs by 2040 We strongly support the idea of putting a stake in the ground like this. It gives us a target for everyone to work toward and a focus for execution. We urge the government to consider a more aggressive target (e.g., 2030), as we are seeing in other jurisdictions.

• Low Carbon Fuel Standard Electricity is the lowest-carbon fuel there is. The LCFS should be capable of counting 100% of EV charging sessions wherever these sessions may take place. We further believe that revenues generated by credit holders within the electric transportation pathway should be reinvested only into initiatives that help to accelerate EV adoption.

• Cleaner transportation systems This is very important and we applaud the scope of the government’s thinking in this area.
Additional Considerations

• Solve the MURB charging problem This is one of the most problematic issues for EV adoption and needs focused attention. We advocate a multi-pronged approach. Municipalities need to be encouraged and supported to require 100% EV charging in new construction. More funding needs to be provided for rebates on retrofitting existing buildings. Consideration should be given to right-to-charge legislation such as was introduced recently in Ontario’s Condo Act.

• Shared vehicles Consideration should be given to requiring increased electrification of car-sharing co-ops, taxis, and the anticipated ride-hailing services like Lyft and Uber. In all these cases, the cars are on the road more than privately owned vehicles. It is important that their benefits do not come with an environmental cost.

• Exempt private charging from regulation The BCUC is conducting an inquiry on this issue now. The undersigned, along with many others, have argued that private charging be exempt from being regulated as a utility. The government should be aware that if this is the recommendation of the inquiry, legislative changes are likely to be required and need to be expedited.

• Specific support for low-income residents Even with rebates, the prices for entry-level EVs can put them out of the picture for low-income residents. Measures should be considered to address this, for example, by extending purchase rebates to used EVs.

Summary

The undersigned are pleased with the breadth and scope of the proposals. Successful implementation of them will require much detailed work. We suggest that the government consider formalizing an advisory council of stakeholders to assist in the process. In any case, we appreciate the opportunity to comment and provide input.

Yours truly,

Bruce Sharpe President Vancouver Electric Vehicle Association

James Locke President Victoria Electric Vehicle Club

John Roston Plug-in Richmond