Introduction
In anticipation of the development and publication of technical standards and requirements that will allow electric vehicle (EV) charging device operators to bill customers based on the amount of electricity consumed during the charging process, Measurement Canada (MC) conducted a public consultation to seek feedback from Canadians, including EV charging device operators, equipment manufacturers and consumers, to gauge their opinions concerning various options on the oversight of level 1 and level 2 EV charging devices already in service. This report provides a summary of the feedback received during the consultation period.
Who we heard from
The consultation was launched on May 9, 2022, and closed on June 22, 2022, at which time a total of 18 respondents had provided comments. More than half of the respondents indicated they represented a business (33%) or an industry association (22%). The remaining respondents indicated they represented a utility or municipality or identified as residents of a multi-unit residential building (MURB) or members of the public. Table 1 provides a breakdown of respondents to this consultation by stakeholder category.
| Stakeholder category | Percentage of respondents |
|---|---|
| Business | 33% |
| Industry association | 22% |
| Utility | 17% |
| Member of the public | 11% |
| MURB resident | 11% |
| Municipality | 6% |
What we heard
The consultation was focused on obtaining feedback from stakeholders concerning proposed policy options for allowing the continued use and oversight of level 1 and level 2 EV charging devices already deployed in the Canadian marketplace. The scope of the consultation included:
- policy considerations;
- proposed options for a temporary dispensation program; and
- proposed terms and conditions of the temporary dispensation.
Respondents welcomed the opportunity to express their opinions and proposed solutions to various areas of concern. MC received a large volume of observations and suggestions regarding the proposed terms and conditions, as well as general comments regarding the direction of EV charging device regulations in Canada. The two-phase approaches presented as options 1 and 2 were more well received than the three-phase approach presented in option 3. Based on the implementation time frame for options 1 and 2, industry stakeholders widely agreed that option 2 was the better choice, mainly due to logistical considerations. Some respondents had additional comments pertaining to the duration of the temporary dispensation, suggesting more flexible time frame options instead of a fixed date.
Members of the public expressed concerns regarding current billing practices and are eager to see energy-based billing introduced at public EV charging stations. Although options 1 and 2 received the most support from this group, there were concerns about the complexity of the complaint process as well as the terms and conditions presented. Canadians do not wish to hinder the adoption of electric vehicles or burden industry stakeholders in a way that would discourage the deployment of charging infrastructure.
Respondents from municipalities, utilities, businesses and industry associations share the same enthusiasm for the rapid adoption of an energy-based billing policy as well as many of the same concerns. Notably, some expressed concerns about the exclusion of a time-based or flat-rate billing option, suggesting that this billing option continue to be available during the implementation of the temporary dispensation. The elimination of time-based or flat rate billing is viewed as a possible hindrance to the overall cost and deployment of electric vehicle technologies. Other primary concerns from this group included the mandating of physical displays as well as the annual device testing requirements.
Overall, respondents from all stakeholders categories are supportive of MC's consumer protection initiatives; however, many requested a revision to the proposed placard requirements as well as further clarification regarding the proposed policy options. Some respondents were dissatisfied that the policy for level 3 fast charging and residential charging would not be implemented concurrently during this phase of consultation. Respondents from businesses also had concerns about the not-yet-published type approval specifications and would have preferred more details regarding type approval, certification and verification requirements before committing to an option.
Next steps
MC will continue to work closely with industry 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. Specifically, MC will use the feedback received during this consultation to finalize its temporary dispensation program which will allow EV charging device operators to sell electricity using the kilowatt-hour as a unit of measurement.
Before the end of 2022, MC will continue to engage Canadians by launching new consultations: one regarding the oversight of level 3 EV charging devices already in service and another regarding energy-based billing for EV charging in residential settings such as multi-unit residential complexes like apartment and condominium buildings and private homes (townhouses, single family homes, etc.).