The British Columbia Government recently released the Public Light-Duty Zero-Emission Vehicle Infrastructure Study (the "Study"). The Study is the latest chapter in BC's push for a decarbonized transportation sector dominated by electric and hydrogen-powered vehicles. This article summarizes the Study and comments on the legal and regulatory considerations at play.
Comprehensive Infrastructure Expansion
In recent years, BC has accelerated its efforts to increase the adoption of Zero-Emission Vehicles ("ZEVs") as one way to help the province meet its greenhouse gas emissions targets. Based on BC's recently released 2020 ZEV Update (the "Update"), it appears the Government's efforts are gaining traction. The Update reported that a record number of more than 54,000 light-duty electric vehicles are currently registered in the province, up from the 34,000 in 2019. With this increasing ZEV momentum, there may be more than 2.5 million Battery Electric Vehicles ("BEVs") and up to 350,000 Fuel Cell Electric Vehicles ("FCEVs") on the road in BC by 2040. To ensure that refueling infrastructure will meet ZEV demand, the province has been working with public and private sector entities to plan for the deployment of an extensive network of fast charging and hydrogen refuelling stations throughout the province.
The Study is a detailed guide to the deployment of refuelling stations necessary to support the increasing number of ZEVs on the road in BC. Based on detailed modelling estimates tailored to the province, the Study lays out the approximate location and number of electric and hydrogen refuelling sites that will be required to facilitate safe and convenient passenger ZEV travel throughout BC. The Government intends the Study to serve as a guide for municipalities, Indigenous communities, and private sector entities investing in the continued expansion of this network.
BC's Fast Charging Network
In BC, partnerships with governments, electrical utilities, and industry have already developed the province's ZEV network into one of the largest in Canada. There are now more than 2,500 level two and three charging stations across BC. The Study projects that by 2040, safe and convenient ZEV travel throughout all primary and secondary highways in the province will require 6,700 level three charging outlets (which charge a vehicle much faster than a level one or two charger) across 400 sites.
The Growing Need for Hydrogen Refuelling
The deployment of refuelling stations for hydrogen FCEVs will differ from fast charging network stations because there are different cost, infrastructure, and energy efficiency considerations. Compared to BEVs, FCEVs are currently more expensive, but take less time to fill and can travel further before refuelling.
Development of hydrogen refuelling stations will be prioritized in areas with high FCEV adoption potential. In practice, this means near existing gas or diesel fuelling stations, or at sites located near to a source of electricity or natural gas with access to maintenance. The Study anticipates full provincial coverage by 2040. In order to achieve this, the Study suggests the province should follow California's lead by first building "major clusters" with seven or eight refuelling stations in high FCEV areas, and then "connector" stations to provide links to allow for travel between clusters. Major cluster areas will be the Lower Mainland, Greater Victoria, and the Central Okanagan, and connector stations will be located in Hope, Merritt, and Williams Lake. Subsequently, "minor clusters" with two to four hydrogen stations will be developed, and will be located in Nanaimo, Kamloops, Prince George, Vernon, Penticton, and Campbell River. "Destination" stations will be also built in popular areas that experience large inflows of traffic from non-residents such as Whistler and Tofino.
The Study estimates a total of 82 hydrogen sites are needed to provide a core network for travel on all of BC's primary and secondary highway routes by 2040. In practice however, the number may be closer to 150 to 250 to account for the need to develop in clusters.
Regulatory and Policy Considerations
Regulatory Regime Pushing Higher Demand for Zero Emission Vehicles
Complementing the release of the Study, an increasing number of regulatory and policy mechanisms from federal and provincial governments are encouraging British Columbians to transition to ZEVs. Some highlights from the BC Government include: a ZEV mandate requiring automakers to sell increasing proportions of ZEVs each year; an increasingly stringent clean fuel standard and carbon pricing regime; a growing list of municipalities that now require all new developments to have EV charging infrastructure; and a growing host of government rebates, funding, and incentives. For a further explanation of these measures, see our previous articles on electric vehicles and hydrogen or our presentation on electrification.
Current RFPs: Zero Emission Vehicle Infrastructure Program
As part of Canada's strengthened climate plan, the federal government announced the Zero Emission Vehicle Infrastructure Program ("ZEVIP"), a 5-year $280 million program launching in June 2021. The ZEVIP will expand ZEV infrastructure across Canada by providing funding and cost-sharing agreements for projects such as BEV charging stations and hydrogen refueling stations in public places, workplaces, multi-unit residential buildings, and fleet-based infrastructure. There are currently three Request for Proposal ("RFPs") processes open under this program, with one RFP closing on June 22, 2021 and the other two closing on September 8, 2021. Eligibility requirements vary depending on the proposal, so applicants are encouraged to consult the Program website.
Current RFPs: Clean Fuels Fund
More funding is on the way for businesses that want to participate in the ZEV economy. On June 21, 2021, the federal government announced a competitive RFP process under its $1.5 billion Clean Fuels Fund, $1.38 billion of which is earmarked for projects designed to build out and expand existing clean fuel production. Suppliers of clean fuels such as hydrogen, ethanol, renewable diesel, and renewable natural gas should review the eligibility criteria to assess the significant opportunities that come with this announcement. While the RFPs will benefit all Canadian jurisdictions, BC is particularly well positioned with a favourable regulatory climate and climbing consumer demand. Applications will be open until September 29, 2021. A distinct RFP for Indigenous proponents will be announced separately.
Increasing Electricity Load
Notably absent from the Study is any consideration of how the proposed expansion of ZEV charging infrastructure will impact BC's electricity grid. Presumably, the transition by British Columbians from gas and diesel-powered vehicles to ZEVs will require a corresponding increase in power generation in order to supply electricity to the BEV charging stations and hydrogen production facilities. It is unclear how the Government intends to meet this increased energy demand, and how such a change will affect taxpayers in the province, particularly given the ongoing considerations around the Site C hydroelectric dam. We will address these concerns in a future article.
With the Government's push toward an emissions free future, market demand for ZEVs in BC is on the rise and all eyes are turning to the question of infrastructure. Through public and private partnerships, significant headway has already been made on the Government's plan for a province-wide network of fast charging and hydrogen refuelling stations across BC.
The Study demonstrates clear opportunities for public and private sector investors to get involved with further development and implementation of charging infrastructure. BC's 2021 Budget provides an additional $8.5 million in rebates to local governments, Indigenous communities, and private entities who are investing in the expansion of this public charging network. For these entities, the Study is a key informational resource to inform their funding and planning. The Study not only lays out the number and location of refuelling stations across the province, but also provides investors with important criteria to consider when planning station sites.
What remains to be seen is how the province will meet the energy demand required for the network, and how public and private entities will collaborate in order to bring the plan outlined in the Study into reality.
 FCEVs take approximately five minutes to fill and have a range of 500 to 600 kilometres per refuel (Study, p. 21).