What we heard report: Consultation on the impacts of alternative fuel and fuel blends on measuring devices

Introduction

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, an interim policy on the examination of volumetric measuring devices that are used to measure or dispense alternative fuels or alternative fuels blended with compatible hydrocarbons. The interim policy enables MC to gather data on the performance of volumetric measuring devices that are used in trade, but are not currently approved for use with alternative fuels. This will support current and future initiatives aimed at the decarbonization of fuels while continuing to ensure the accuracy of trade measurement in the Canadian marketplace.

MC consulted on the bulletin between October 10, 2023, and February 2, 2024, to gather feedback and insights on the content and effectiveness of the interim policy, and to provide an avenue for stakeholders to contribute additional information such as test data or any other pertinent details that may benefit the ongoing review of the impact of alternative fuels on measuring devices.

Who we heard from

Comments were received from five respondents. These included industry representatives, manufacturers, transporters or traders of alternative fuels, a major industry association as well as an animal welfare group. Due to confidentiality issues arising from the limited number of respondents, specific responses to questions asked during the consultations are not discussed below. An overall summary is provided.

What we heard

Stakeholders indicated that they consider hydrogenation-derived renewable diesel (HDRD) to be identical in composition and nature to conventional diesel for the purposes of trade measurement. The percentage (ratio) of HDRD to conventional diesel is variable depending on seasonality (winter or summer blends) and feedstock pricing. Blend ratios are routinely adjusted by traders based on market conditions, customer requirements or renewable fuel availability. Traders have indicated that the present 15% reporting threshold (as stated in bulletin V-30) is difficult to comply with, given the variability in the blends offered. Stakeholders also recommended that MC ensure alignment with other regulatory authorities on trade measurement policies related to alternative fuels that are blended with conventional fuels.

Conclusion and next steps

We would like to thank all respondents for their contributions to the consultation.

Because blend percentages for HDRD are higher in the warmer months, Measurement Canada will continue to gather and analyze data submitted throughout the summer and fall of 2024 to enable a fulsome review of the data which will inform policy.

It is anticipated that bulletin V-30 may evolve to become a directive on trade measurement for all types of pure or blended alternative fuels.

MC is committed to working closely with stakeholders to ensure the integrity and accuracy of trade measurement and related technologies in Canada, in a manner that supports and fosters innovation while protecting consumers.