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Consultation on the oversight of electric vehicle charging devices used in non-commercial applications

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:

Proposed approach

Owners of EV charging devices used in non-commercial applications may bill users for electricity supplied (kWh) either by:

Program details

Conventional metering option:

Temporary dispensation option:

Temporary dispensation notes

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 January 31, 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:

  1. 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:
    1. is not operated commercially or available to the general public;
    2. 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%;
    3. is installed with a metering system capable of measuring the delivered energy;
    4. uses the watt-hour, or any multiple or submultiple of the watt-hour, as the unit of measurement for the sale of electricity;
    5. is operated in accordance with manufacturer specifications; and
    6. 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.
  2. EV charging station owners or operators must put in place a process for dealing with customer complaints that, at a minimum:
    1. records complaints from purchasers;
    2. 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;
    3. examines any records related to the EV charging devices that are the subject of complaints;
    4. when applicable, documents the results of any tests and provides a copy of the results to the purchaser who made the complaint;
    5. makes records available to Measurement Canada upon request; and
    6. 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.
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