Tesla’s wish list for Ontario’s EV charging ecosystem includes rapid expansion in MURBs, developing land for charging hubs and setting a public charging speed minimum of 100kW, according to new lobbyist documents and a letter to the government

Tesla is consulting with the government of Ontario about key strategies to implement for the expansion of the province’s public EV charging network.

The updates come via a 10-page letter submitted to the government in November 2022 and Tesla’s latest lobbyist registry filing with the province.

“Ensure the efficient and consistent integration of electric vehicle (EV) charging infrastructure with the transmission and distribution systems across the province,” reads Tesla’s lobbyist filing goal from January 19.

“Tesla’s intended outcome is to help accelerate the pace at which charging station new service connections are provided while minimizing connection costs, in order to increase number of charging stations deployed in Ontario.”

Tesla’s focus on public EV charging in Canada is apparent in recent filings. But until now details have been sparse.

In a letter to Ontario’s Environmental Policy Office last year, the automaker mapped out its six-part plan for the first time. The purpose of the letter is to advise the province on allocating the $91 million in charging infrastructure funding announced in March 2022.

“To maximize the efficiency of the public dollars invested in the program, the Government must prioritize investments that will truly help deploy critical EV charging infrastructure in areas that help make charging fast, accessible, and as convenient as gasoline refueling as possible,” reads the letter, written by Tesla’s senior advisor of public policy and business development, Audrey Dépault.

In total, the province received 58 public comments as part of the public consultation for the funding. Tesla is the only automaker that appears to have contributed to the Ontario government’s EV charging consultations.

Tesla’s charging network strategy

In March 2022, the Ministry of Transportation announced a $91-million plan to build out Ontario’s public EV charging network. Specific areas of interest include filling gaps in the provincial charging network, improving charger reliability and access to fast chargers.

The pillars of Tesla’s recommended strategy for Ontario’s EV charging infrastructure cover six areas:

• Focus on remote and low utilization sites, but also on sites where additional capacity is needed.
• Expand program scope and target EV infrastructure investments where they will have the greatest impact: existing multi-unit residential buildings.
• Support public charging installations in urban settings, especially where it provides EV charging for MURB dwellers, and the establishment of DC Fast “charging hubs” in Ontario’s most dense and expensive real estate markets (where DC Fast is not otherwise economical to develop in the market’s current nascent stage).
• For DC Fast funding eligibility, require minimum rating of 100kW. Considering the types of situations in which EV drivers use DCFC stations, these stations need to be convenient and offer truly fast charging.
• Adopt minimum uptime requirements for Ontario funded connectors (calculated at a site (station) level).
• Work with the Ontario Energy Board, utilities and service providers to address inconsistent and unclear utility scope of work, high costs and long timelines that are significant barriers to fast deployment of EV charging infrastructure.

Tesla is the only OEM to operate a charging network in Canada. (Mercedes recently announced they will build their own “high power” charging network by 2027. And General Motors is funding charger installations, though they don’t operate a network.)

Telsa is also an influential business in the country. As of November 2022, the automaker says it has over 1,300 Canadian employees and 1,490 Superchargers in Canada. It also claims its economic contributions to the national economy are in excess of $830 million.

“Tesla has more experience deploying and operating charging infrastructure than any other company in Canada and is experiencing some challenges in Ontario that are slowing our ability to deploy Superchargers and increasing costs,” reads the letter.

Biggest barriers in MURBs

In its submission, Tesla is unequivocal about the state of EV charging barriers in Ontario.

“Based on our experience in engaging with prospective EV drivers in Canada, the most significant challenge facing EV charging infrastructure at this stage in the market’s development is not with highway-side or other public charging, but with access to charging at home, in multi-unit residential buildings (MURBs),” reads the letter.

“This is an Ontario-wide challenge and would benefit from provincial
leadership.”

Roughly 3.33 million Ontarians live in MURBs. To expand their access to EV charging Tesla recommends overhauling what parts of the project are eligible for funding. Instead of financing charger installations, it says funds should offset infrastructure upgrades.

Under Tesla’s proposed approach, grants would cover up to 75 per cent costs of upgrading a building’s electrical capacity. Retrofitting electrical rooms and installing electrical subpanels in parking garages would also be eligible expenses covered by funding.

“[E]nsuring that the occupants of those multi-unit dwellings have a place to charge where they already park the majority of the time would offer the Government of Ontario the greatest return on its charging infrastructure investment,” reads the letter.

Charging hubs

But there are other things to do in harmony with upgrading building electrical infrastructure. Tesla is recommending the government undertake the development of “charging hubs” in high density and expensive markets.

Tesla says current challenges to deploying fast charging in Ontario’s high-value real estate markets include the high cost of land to rent or own, power restrictions and gated, fee-based parking garages.

The solution, Tesla proposes, is for the government to use large tracts of publicly-owned land in these areas. The land would become a charging hub with “30 and 50 parking stalls” equipped with public charging ports.

“Charging hubs further encourage price and service quality competition. For this
reason, it is vital that no exclusivity ever be offered to any charging operator on the
site,” writes Tesla. “These facilities should be inclusive and welcoming to all EV drivers and vehicle brands. They would ideally be situated near good amenities.”

The on-site electrical capacity would be dedicated to EV charging only.

Charging network operators would not pay a fee to operate at the charging hub. But they would cover the costs of their installations as well as the sub-metering and electricity usage fees.

The hubs, says Tesla, would be operate for 10 years. After that time, retrofits for EV charging access in buildings should be at scale. The government could then either sell the land or continue allowing the site to be used as a charging hub.

Addressing charging speeds and reliability

A critical feature of a successful public charging network, Tesla says, is the guarantee of charging speeds and equipment reliability. The government has a role to play in ensuring both.

“[A]ccess to charging options must be as convenient as gas refueling as possible,” urges the letter.

“DCFC stations under 100 kW should not be eligible for funding. Given their cost and the
limited benefits to EV drivers, they are not an efficient use of public funds.”

In addition to prioritizing fast charging, Tesla recommends the government publish minimum uptime standard for chargers.

“Publishing data that an individual site is up at least 97 percent should be sufficient to provide drivers confidence that Ontario funded sites will be available when they need a charge,” states Tesla.

A stronger charging ecosystem

In addition to tackling access and reliability of EV charging, Tesla also suggests the government regulate costs that burden network operators.

These issues, it says, are impeding development of Ontario’s public EV charging network.

“Tesla’s experience in Ontario demonstrates that Local Distribution Companies (LDCs) are applying an inconsistent approach to line extension costs and scope of work for site preparation of Superchargers, making Ontario more complicated and costly compared to other jurisdictions in Canada,” states the letter.

The fragmented approach network operators are having navigate to date is, Tesla says, incompatible with an efficient EV charging ecosystem. A uniform, codified process will entice network operators to roll out large scale charging infrastructure in the province.

“Resolving these issues will help speed up the installation of charging infrastructure to meet consumer demand and demonstrate Ontario has a strong investment climate for EV related industry,” read the letter.

Editor’s note: after publication a second Tesla official in Canada released a social media post specifiying that charging hub land in Tesla’s proposal is “existing public lands in urban areas which are under-utilized” rather than newly purchased lands. This story has been updated to reflect the additional detail.