Share your thoughts: Impacts of alternative fuel and fuel blends on measuring devices

Measurement Canada (MC) is responsible for ensuring accuracy in the selling of measured goods, developing and enforcing the laws related to measurement accuracy, approving and inspecting measuring devices and investigating complaints of suspected inaccurate measurement.

In September 2023, MC published bulletin V-30, which establishes an interim policy on the examination of volumetric measuring devices that may be used to measure or dispense alternative fuels or alternative fuels blended with compatible hydrocarbons. This policy will enable MC to gather data on the performance of volumetric measuring devices used in trade, but not currently approved for use with alternative fuels.

Background

The introduction of the Clean Fuel Regulations is an important part of Canada's climate plan to reduce emissions, accelerate the use of clean technologies and fuels, and support sustainable diversified economic sectors. These regulations require a minimum percentage of biofuels to be blended into gasoline and diesel fuel. To meet these regulations, low-carbon alternative fuels have been introduced and are a growing part of Canada's evolving future fuel mix and includes renewable diesel, gasoline with higher ethanol ratios, hydrogen and many other fuels.

Alternative fuels are rapidly evolving and their increased use in the marketplace may impact the performance, accuracy and lifetime of meters used in trade measurement. Currently there are many different types of alternative fuels on the market. Identification of these different alternative fuels on meters is not always mandatory and is generally not common practice. As a result, wholesalers and retailers are using volumetric devices that are not approved for that purpose. This constitutes an offence under the Weights and Measures Act.

As the blend ratios of alternative fuels in conventional gasoline and diesel fuels increase, MC must examine measuring devices to ensure they perform within specifications and accurately measure higher ratio blends.

Notices of approval issued by MC's Approval and Calibration Services Laboratory describe the conditions for the approval of measuring devices used for commercial purposes.

MC's bulletin V-16 describes and classifies into groups the products applicable to the approval of specific types of meters. At present, this bulletin does not adequately address the use of alternative fuels, specifically HDRD (hydrogenation-derived renewable diesel).

MC's bulletin V-18 describes the conditions and density values for fuel types currently approved for use in automatic temperature compensated devices. MC continues to review and test requirements and standards for fuel metering devices to ensure that bulletin V 18 remains relevant for all fuel types, including increased ratios of alternative fuels, and that the current technology performs in expected ways when used for the measurement of conventional and alternative fuel types in all ratios.

MC developed its interim policy (bulletin V-30) to provide a framework to enable HDRD use in the marketplace, while gathering data on the performance of alternative fuels in volumetric measuring devices used in trade but not currently approved for these fuels. Revisions based on ongoing findings may lead to this policy being revoked or modified as data analysis takes place. Currently, the policy requires specific inspection information to be submitted to MC.

For device examination purposes by authorized service providers (ASPs), blends containing 15% or less of an alternative fuel will be considered pure products. If the product being measured contains more than 15% of any combination of alternative products, the inspector must obtain authorization from the Centre of Expertise to proceed with the examination of the device.

About the consultation

MC invites all interested parties to share their thoughts and any additional data in relation to bulletin V-30 —Interim policy on the examination of volumetric devices used for measuring low-carbon fuels.

This interim policy enables MC to support current and future initiatives aimed at the decarbonization of fuels while continuing to ensure the accuracy of trade measurement in the Canadian marketplace. Therefore, a thorough review of the classification of the various fuels is required, as well as an update to the requirements for measuring them.

Key questions

This consultation and the data gathered through this interim policy will help MC have a better understanding of how drop-in fuels are distributed, marketed and sold; in what ratios these are found in the marketplace and what impacts these blend ratios may have on the devices currently in use.

MC is seeking relevant data to support the development of a final position on the trade measurement of these alternative fuels, whether sold at 100% or blended with traditional fuels.

MC is interested in better understanding the impacts of alternative fuels on measuring devices and would welcome any data you may be willing to share regarding devices currently dispensing blends with alternative fuels such as HDRD. MC is also seeking answers to the following questions:

1. What data points do you believe might be helpful in developing a well-designed policy for the accurate trade measurement of alternative fuels and their blends?
2. Are you aware of any impact that temperature variation may have on the measurement of metered alternative fuels such as HDRD?
3. If you are an authorized service provider, how many examinations over the next 12 months do you anticipate conducting on meters dispensing alternative fuel blends over the current 15% blend rate?
4. Where does blending take place and at what point are the blending percentages determined?
5. Do you have any data that you would be willing to share regarding the performance of automatic temperature compensators (ATC) when dispensing alternative fuels?
6. Do you have any additional data on the measurement of alternative fuels that you would be willing to share?

Who is the focus of this consultation

We would like to hear from interested parties, including:

• academia
• authorized service providers, either registered or accredited by MC
• consumers
• federal, provincial and territorial government departments
• Indigenous Peoples
• industry, including manufacturers, transporters, or traders of alternative fuels
• industry associations
• international trading partners
• non-governmental organizations

How to participate

Your opinion counts!

We invite you to submit your comments by email. For ease of reference, please specify the number of each question you are addressing and include details of any proposed changes to the policy.

This consultation will close on February 2, 2024.