The New Canadian Light-Duty ZEV sales Regulation Will Help Accelerate EV Adoption and Offer Market Predictability to Bolster Investments in the EV Industry Across Canada

EMC welcomes the opportunity to comment on Measurement Canada’s proposed approach on the oversight of level 3+ electric vehicle charging devices already in service and thanks the agency for the information made available for this consultation. Several our members have extensive experience in EVSE development, manufacturing, deployment, as well as charging network operation and maintenance, while others have been users of EV charging services. Of the DC fast charging ports currently installed or under construction in Canada, 75% of are manufactured or are operated by EMC members.

The ability to offer pricing on a per kWh basis is a frequent customer request for many operators. Direct current (DC) charging stations of different power levels (50 kW, 100 kW, 250 kW or more) are common but actual maximum charging speed can vary based on maximum capacity of the vehicle and on battery temperature. Hot batteries in summer or cold batteries in winter can slow charging speeds below the maximum speed accepted by the vehicle or offered by the EVSE. For these reasons, per kWh billing can be a more accurate option for billing than a time-based approach, especially for DC fast charging. EMC thus shares Measurement Canada’s goal of enabling pricing base on kWh.

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