Purpose
We are looking for input into our strategy for allowing the continued use and oversight of electric vehicle (EV) charging devices already deployed in the Canadian marketplace and used in non‑public settings. This document proposes requirements for owners of EV charging devices used in non-commercial applications who intend to charge for the electricity supplied, using the kilowatt-hour (kWh) as a unit of measurement, in order to recoup energy costs from a limited group of users.
Background
In the fall of 2022, Measurement Canada consulted Canadians regarding a temporary dispensation for level 1, level 2 and level 3+ electric vehicle supply equipment (EVSE) already used in commercial applications to obtain the basis of a charge (i.e. bill) for electricity supplied. The temporary dispensation program will allow owners of eligible commercial EVSE already in service to charge based on the unit of energy (kWh) instead of using a time-based or flat-rate fee structure.
As we continue supporting clean fuel initiatives and taking into account the potential financial impact of any interim solutions on early adopters, we recognize that a different regulatory solution may be required for owners of EV charging devices that are used to supply energy in a non-public setting, such as a residential building, workplace or private vehicle fleet.
Scope
The proposed approach described below applies to EV charging devices that are used in non‑commercial applications to deliver and receive electricity during a recharging event and not intended for use by the general public or for making a financial profit other than to recoup the cost of operating the device and delivering energy to a limited group of users, such as residents of a multi-unit residential building.
Non-commercial applications
The requirements described below apply to device owners who provide EV charging services in a non-public setting such as:
- a parking stall assigned by a condominium strata that is intended for the private use of condo owners or renters (i.e. not used as a public visitor parking);
- a shared parking lot on a residential property that is intended for use by the residents of the property;
- a workplace parking stall that is only accessible and used by employees or that is used to charge EVs owned and used by an organization, such as a company, government agency or public utility (e.g. private vehicle fleet).
Proposed approach
Owners of EV charging devices used in non-commercial applications may bill users for electricity supplied (kWh) either by:
- using conventional means of metering, such as an electricity meter or a multiple customer metering system (MCMS); or
- using an EVSE approved in accordance with a temporary dispensation, subject to terms and conditions set by Measurement Canada.
Program details
Conventional metering option:
- Starting on March 1, 2023, device owners providing a non-commercial EV charging service may sell electricity on the basis of kWh.
- Before they can sell electricity on the basis of kWh, device owners must hold a valid certificate of registration issued in accordance with requirements of the Electricity and Gas Inspection Regulations.
- To obtain the basis of a charge (i.e. bill) for electricity supplied using conventional means of metering, device owners providing non-commercial EV charging services must use a device that has been approved by Measurement Canada and for which a notice of approval has been issued.
Temporary dispensation option:
- Prior to January 1, 2025, owners of non-commercial EV charging stations wishing to continue using EV charging devices of a type not approved to sell electricity on the basis of kWh may apply for a temporary dispensation.
- Device owners must hold a valid certificate of registration issued in accordance with requirements of the Electricity and Gas Inspection Regulations.
- Until January 1, 2030, owners of eligible non-commercial EV charging devices who have been granted a temporary dispensation may use those devices without having them verified or sealed, in accordance with the terms and conditions set by Measurement Canada. See Appendix A for the proposed terms and conditions.
- The temporary dispensation will expire on January 1, 2030.
- The temporary dispensation may be cancelled at any time during the dispensation period if:
- the owner ceases to meet the terms and conditions of the dispensation;
- the EV charging device is relocated or removed from service; or
- a new certificate of registration is issued, at which time the owner must reapply for temporary dispensation within the prescribed timeline or have the EV charging device verified in accordance with the EV charging device specifications.
Temporary dispensation notes
- A temporary dispensation is a regulatory instrument authorized by section 9.2 of the Electricity and Gas Inspection Act. It is used to grant permission to put into service, without verification or sealing, any meter or any class, type, or design of meter on a temporary basis. Temporary dispensations are subject to the terms and conditions specified by the President of Measurement Canada and are in force for a specified period.
- At any point, owners of EV charging devices that are subject to a temporary dispensation may have them verified for compliance with applicable Measurement Canada specifications. If their devices are found to be in full compliance, their participation in the temporary dispensation program will end.
How to participate
Measurement Canada is seeking your input into its proposed approach for allowing the continued use and oversight of non-commercial EV charging devices already deployed in the Canadian marketplace.
Please send your comments and details of any suggested changes to our proposed approach by email at mcfeedback-retroactionmc@ised-isde.gc.ca.
This consultation will close on February 17, 2023.
Contact us
If you have any questions regarding this consultation, please contact us by email at
mcfeedback-retroactionmc@ised-isde.gc.ca.
Appendix A – Proposed terms and conditions
The proposed terms and conditions of the temporary dispensation include, but are not limited to the following:
- EV charging station owners or operators must ensure that, at a minimum and for the duration of the temporary dispensation, each eligible EV charging device:
- is not operated commercially or available to the general public;
- supplies electricity within a limit of error agreed upon by the owner and the consumer ("purchaser" under the Act), or where an agreement is not in place, supplies electricity within a limit of error of ±3%;
- is installed with a metering system capable of measuring the delivered energy;
- uses the watt-hour, or any multiple or submultiple of the watt-hour, as the unit of measurement for the sale of electricity;
- is operated in accordance with manufacturer specifications; and
- is equipped with a means to display and invoice legally relevant information that is either connected to an integral, remote or non-connected system (e.g. a remote register) or any information storage system such as the Cloud network.
- EV charging station owners or operators must put in place a process for dealing with customer complaints that, at a minimum:
- records complaints from purchasers;
- makes inquiries with the purchaser who made the complaint and of any person who could reasonably be expected to have knowledge relevant to the matter;
- examines any records related to the EV charging devices that are the subject of complaints;
- when applicable, documents the results of any tests and provides a copy of the results to the purchaser who made the complaint;
- makes records available to Measurement Canada upon request; and
- institutes corrective measures to address any failure to meet the terms and conditions of the temporary dispensation, discovered as a result of the complaint investigation process.