Units of Measurement Applied to the Sale of Electricity or Natural Gas in Canada and the Provision of Meter Registration Information
Recent deregulation initiatives introduced by some provincial energy distribution and rate regulators have led to significant billing invoice format changes, and some of these changes have been found to be in conflict with the requirements of the Electricity and Gas Inspection Act. Consequently, the purpose of this information bulletin is to advise electricity and natural gas suppliers of their obligations with regard to the appropriate use of legal units of measurement and the ongoing need for the communication of meter readings on consumer bills.
Where a person (including an unincorporated body that is a contractor, such as an electricity or gas utility or supplier) sells electricity or natural gas on the basis of measurement, the Electricity and Gas Inspection Act requires that the quantity of the product (e.g. electricity energy or volume of natural gas) sold to the purchaser be established using a unit of measurement that is recognized by the statute for this purpose.
Where a quantity statement is used to represent the amount of electricity sold to a purchaser, the unit of measurement expressed must conform to the standard definition for that unit as established pursuant to the Electricity and Gas Inspection Act and Electricity and Gas Inspection Act and Regulations. It is the standardization of the unit of measurement, in terms of what it represents, that provides for uniformity, fairness, and transparency in trade measurement for all Canadians.
For example, where a kilowatt hour (kWh) has been utilized as the unit of measurement for the sale of electricity, the value representing the amount of electricity sold must be capable of being independently reproduced. Reproducibility of the unit of measurement is essential in arriving at a conclusion as to whether the statement of quantity is valid (where validation is established on the basis of a comparison between the quantity of electricity supplied as represented on the billing invoice, and the true quantity of electricity that should have been supplied).
Electricity or natural gas utilities and retailers need to ensure that the following quantity-related obligations are fulfilled when electricity or natural gas is sold on the basis of measurement:
- the quantity of electricity or natural gas sold to a purchaser is established in terms of a measurement unit that is recognized under the Electricity and Gas Inspection Act;
- the unit of measurement applied is one which is capable of being realized in a manner which is valid, such that its reproducibility can be achieved in accordance with recognized and accepted legal metrology practices, and in compliance with the measurement traceability requirements of the Electricity and Gas Inspection Act & the Weights and Measures Act; and
- the measurement information used to establish the charge for the electricity or natural gas supplied, is based on the approved and verified meter registrations/readings.
Of particular note, utilities or retailers selling electricity or natural gas in Canada on the basis of measurement are further advised that quantity representations that are qualified (using terms such as “adjusted”, “adjusted consumption”, “adjusted usage” or “billed usage”) must satisfy obligations (1) and (2), where such statements are used to represent the amount of electricity or natural gas being sold to a purchaser.
Any meter used to establish a charge for the amount of electricity or natural gas being supplied to a purchaser, is required by the Electricity and Gas Inspection Act to be of an approved pattern (design) and verified for performance-accuracy before being used for this purpose. If a meter equipped with a single cumulative consumption register/display is used to measure supplied energy during a specific calendar-based billing period, the meter's registration reading taken at the beginning and end of the period must be used as the reference for establishing the specific quantity of energy that has been supplied (in accordance with obligation (3)).
Where modifications to billing invoice formats have been made by electricity utilities and retailers (following provincial electricity market deregulation) and this action has resulted in an apparent conflict with one or more of the above-noted measurement related obligations, electricity utilities and retailers will be required to implement corrective actions to ensure that their measurement related obligations are fulfilled. In recognition of the fact that some provincial electricity energy markets are still evolving and that billing format modifications will need to be implemented in an efficient and cost effective manner, electricity utilities and retailers are being provided with a corrective action implementation period to effect the necessary changes. Notwithstanding the above, Measurement Canada is requiring full compliance with the above stated obligations no later than .
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