In 2020, the Government of Canada, in support of its strengthened climate plan, developed the Hydrogen Strategy for Canada, which sets out an ambitious framework for actions that will make hydrogen a tool to achieve our net-zero emissions goal by 2050 and position Canada as a global industrial leader in clean renewable fuels. Hydrogen blending is an emerging practice and multiple pilot projects are taking place across provinces and territories in Canada. From July 21, 2022, to January 16, 2023, Measurement Canada (MC) consulted interested stakeholders on using regulated meters in natural gas/hydrogen blending activities.
MC is an agency of Innovation, Science and Economic Development Canada (ISED). It 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. MC fulfills its mandate by enforcing the Electricity and Gas Inspection Act (EGIA) and its associated regulations.
Who we heard from
The consultation was scheduled to close in October 2022, but was extended until January 16, 2023, to solicit feedback from more stakeholders. Respondents included only representatives from gas meter manufacturers, gas utilities and the Canadian Gas Association (CGA), likely due to the highly technical nature of the proposed policy.
What we heard
The consultation was focused on hearing from two main stakeholder categories: gas meter manufacturers and gas utilities. MC engaged with stakeholders to cover topics such as:
- the temporary authorization to use meter types or classes that have not been formally approved by MC for use in hydrogen-enriched natural gas applications,
- temporary modifications to sample selection requirements outlined in the sampling plans for inspection of meter lots in accordance with specifications S-S-04 and S-S-06,
- modifications to reverification periods pursuant to paragraph 12(1)(c) of the EGIA.
All respondents welcomed the opportunity to provide feedback.
Temporary authorization to use meters in natural gas/hydrogen blending activities
Respondents raised concerns about the tolerances prescribed in the Act, the Regulations and associated specifications, as well as the tolerance structure. Feedback indicated that the current tolerances could be problematic for the approval and verification of certain meter types or classes. The introduction of a tolerance structure based on similar to that of the International Organization of Legal Metrology (OIML) (e.g. for class 2 meters) was recommended instead, which would allow for improvements in future meter development.
Respondents indicated that they were unable to support the choice of 5% hydrogen concentration as the basis for requiring additional regulatory involvement by MC. They believed that the proposed concentration limit could place an undue burden on the industry as it moves to meet its carbon reduction goals. They also suggested that MC consider other aspects such as the metering pressure and meter technology to design a criteria rather than a percentage (%) blend only.
Respondents also suggested that the draft policy could be misinterpreted by industry as meaning that if meters do not meet current approval standards that they will be denied approval for use with hydrogen blends over 5%. Respondents thought it would prevent the industry in meeting its greenhouse gas (GHG) emission reduction goals. As MC has no present capacity to perform approval evaluations on any other test medium except air, respondents recommended that MC use a process of acceptance of objective evidence from manufacturers or utilities. It was further suggested that the President of MC provide the appropriate level of dispensation for existing diaphragm meter technologies, as the gas industry recognizes that the meter population would possibly be under-registering at very low flow rates. The risk will become part of the utilities' assessment of how much hydrogen they are willing to inject in their networks.
As for the sale of gas by energy units, respondents indicated the development and MC approval of point heating value technologies are critical.
Temporary modifications to sampling plans
Respondents indicated they found it impractical to incorporate into existing statistical sampling plans the idea that domestic meters used only in hydrogen-blending applications represent a statistically unique sample group. They inferred from the proposal that a meter used in a hydrogen-blending application could not be used in a natural gas only application.
Modifications to reverification periods
Previous feedback to MC suggested that references to meter verification and reverification periods be removed from the Act. This point was raised again during this consultation.
Respondents also believe that MC should reconsider the application of lengthened seal periods for newly installed meters versus in-service ones. They consider this to be an unnecessary hindrance and believe that new installed meters should also be subject to lengthened seal periods.
We would like to thank all respondents for participating in the consultation. The feedback will help us to finalize the policy.
MC is committed to working closely with industry in conducting further analysis of the short-, mid‑ and long-term impacts of hydrogen-enriched natural gas on regulated meters, while taking into account international research and advances in hydrogen-metering technologies.