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Implementation Decisions Electricity Trade Sector Review Recommendations 2002-02-28


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Program Development Directorate
Standards Building, Holland Avenue
Ottawa, Ontario
K1A 0C9

PURPOSE
The purpose of this document is to set out Measurement Canada's decisions regarding implementation of the recommendations of the Electricity Trade Sector Review (ETSR) Team. These recommendations were based on the consensus reached with electricity sector stakeholders in November 2001.

Each original recommendation is listed in its entirety along with

  • Measurement Canada's decision regarding whether to accept the recommendation;
  • any conditions associated with Measurement Canada acceptance;
  • rationale for any recommendation that has not been accepted;
  • implementation considerations and issues; and
  • completion priority indicating Measurement Canada's suggested time frame as to when the associated process, program or activity will be in place. (Note: The final priority for recommendation implementation will be determined in consultation with key stakeholders.)

As next steps in the implementation process, Measurement Canada will prepare a detailed implementation plan by April 2002 and commence consultation with electricity sector stakeholders to reach agreement on implementation responsibilities, priorities, time frames and coordination mechanisms.

Any questions associated with the content of this document should be addressed to Gilles Vinet, Vice-President, Program Development Directorate, Measurement Canada, by telephone (613) 941-8918, facsimile (613) 952-1736 or e-mail to vinet.gilles@ic.gc.ca .

This document as well as all other ETSR documents are available for electronic viewing or downloading on our web site, under Trade Sector Review.

LIST OF ACRONYMS

APEM Advisory Panel on Electricity Measurement
ASD Alternate Service Delivery
CEA Canadian Electricity Association
CSA Canadian Standards Association
EGIA Electricity and Gas Inspection Act
EGIR Electricity and Gas Inspection Regulations
E-MAP Electricity Measurement Accuracy Program
EMTC Electricity Meter Technical Committee
ETSR Electricity Trade Sector Review
ISO International Standards Organization
MC Measurement Canada
MPC Major power consumer
MW Megawatts
NIST National Institute of Standards and Technology
NRC National Research Council Canada, Institute of National Measurement Standards
NSS National Standards System
QMS Quality Management System
SCC Standards Council of Canada
SDO Standards Development Organization
SMC Senior Management Committee (MC)
TBT Technical Barriers to Trade
WG Working Group
WTO World Trade Organization

February 2004 - Update: Recommendation 7.b)

Implementation of recommendation 7.b) has been postponed. Measurement Canada is committed to adopting international standards. Once Measurement Canada has adopted international recommendations, Measurement Canada plans to pursue Mutual Recognition Agreements (MRA), an internationally accepted practice for recognizing approval testing performed by other countries. The scope of these agreements will include acceptance of testing performed by participating countries, removing the requirement to repeat the same tests in Canada, and greatly expediting the issuance of approvals. It is therefore premature to begin working on an ASD program for meter approvals, knowing that Measurement Canada will be adopting international recommendations and utilizing the MRA approach. In addition, if a "Made-in-Canada" ASD mechanism is introduced in advance of the completion of the international harmonization work, it could create a situation where the program would have to be revoked or significantly reworked in order to meet the MRA approach. Implementation of recommendation 7.b) will be revisited once international recommendations have been or are about to be adopted.



Electricity Trade Sector Review Recommendation that:

Measurement Canada Decision and Conditions (as applicable)

Implementation Considerations

Measurement Canada Completion Priority

1. DISPUTE RESOLUTION(1)

a)

MC continue as the investigator and facilitator of last resort in resolving any electricity meter dispute at the request of either an electricity purchaser or seller.

Accepted

 

On-going

b)

All electricity suppliers put in place procedures that lead towards resolution of meter complaints and disputes with their customers to the best of their ability prior to MC involvement.

Accepted

1. It is understood that "supplier" means any person or body that has undertaken to supply electricity to any purchaser; i.e., a contractor (as defined in the EGIA).

2. The implementation of this recommendation requires commitment and action by electricity suppliers.

3. The emphasis of this recommendation is on suppliers having a documented process in place to resolve customer complaints involving a meter.

Medium Term
- by April 2004

c)

All electricity suppliers refer a customer to MC whenever a dispute involving measurement performance of a meter cannot be resolved satisfactorily between themselves and the customer involved.

Accepted

1. MC wants to ensure that electricity suppliers implement documented processes (Recommendation 1 (b)) to handle their customer complaints and refer all non-resolved complaints to MC.



2. MC will investigate discrepancies in the number of disputes referred to MC by individual suppliers, i.e., some suppliers tend to have many more disputes than others.

On-going



2. INFORMATION FOR MARKETPLACE PARTICIPANTS

a)

MC explain to electricity marketplace participants its role and activities in ensuring accurate and equitable electricity measurement in order to promote confidence in the electricity marketplace.

Accepted

 

Medium Term
- by April 2004

b)

Electricity suppliers accept responsibility for satisfying their customers' information needs about how meter accuracy is maintained and the recourse mechanisms available.

Accepted

1. It is understood that "supplier" means any person or body that has undertaken to supply electricity to any purchaser, i.e., a contractor (as defined in the EGIA).



2. The implementation of this recommendation requires commitment and action by electricity suppliers.

Medium Term
- by April 2004

c)

Suggested methods that MC might pursue include:

i) Taking full advantage of consumer web sites to explain its mandate, programs and services.

ii) Partnering with utilities in order to have adequate links from utility web sites to the MC web site.

iii) Making its web site more user-friendly for Canadian consumers at large, by using plain language and easy to find information about MC programs. e.g., adding a "consumer issues" button

iv) Developing a plain language information package and compliance guide tailored to retailers' and contractors' needs in the marketplace.

v) Encouraging and training MC staff to explain and promote what MC does, to stakeholders, particularly consumers, at every opportunity.

Accepted

1. The suggested methods will be considered during implementation.



N/A

3. REQUIREMENTS FOR MAJOR POWER CONSUMERS

a)

A trade meter used in a metering installation at a single geographic location where the purchaser has a demand equal to or greater than three megawatts (3 MW), be exempted from current MC approval requirements related to the functionality of the meter.

Accepted in principle but further clarification and validation by MC is required before authorizing implementation.

1. MC accepts the principle that MPC can protect themselves.

2. How demand (3MW) will be calculated when there are several meters, needs to be clarified.

3. Which types of customers can be included under this recommendation needs to be clarified.

4. MC is concerned that small market players could fall under the proposed requirements for MPC without being fully aware of the related implications.

5. In the case of power resellers, MC is concerned that inaccuracies could be passed through to customers.

Short term
- by April 2003

b)

A trade meter used in a metering installation at a single geographic location where the purchaser has a demand equal to or greater than three megawatts (3 MW), be exempted from current MC sealing requirements (i.e., seals could be replaced without triggering reverification, provided that a utility enforced reverification program exists that meets or exceeds the requirements of the EGIA and Regulations. Event logger requirements would also not be applied to these meters).

 

c)

Any such exempted meter continue to require type evaluation and approval by MC of its accuracy performance.

1. MC needs to confirm that meter manufacturers and purchasers see value in obtaining MC approval of a meter exempted from sealing and event logger requirements.



2. A MC approval without sealing and event logger requirements may create a false sense of security for MPCs.

d)

Any current and potential transformer used with any such exempted meter also continue to require type evaluation and approval by MC.

 

e)

Mandatory periodic reverification rules do not apply for these meters provided the meter is reverified at least as often as is required by the EGIA and Regulations. Suppliers and customers may set their own rules for verification and reverification by contractual or other agreement.

1. If mandatory reverification rules do not apply, then there should be no conditions as to how often the meters are reverified.

f)

If either party so wishes, a major power consumer and its electricity supplier have continued access to MC's meter dispute resolution process if they have been unsuccessful in resolving a dispute themselves. However, MC's ability to resolve a dispute without an event logger audit trail is greatly impaired.

 

g)

A contract must exist between the electricity supplier and purchaser wherein they agree on the use of such exempted meter(s).

 

h)

MC work with the CEA Task Group that has offered to prepare a first draft of suggested standard wording for use in the supplier-purchaser contract explaining the implications of using such exempted meter(s) in the event of a measurement problem or dispute.

1. In addition to working with the CEA, MC will involve vulnerable parties in this implementation work.

4. CERTIFICATION OF ELECTRICITY MEASUREMENT STANDARDS(2)

a)

Traceability of Canadian electricity measurement standards to international electricity measurement standards is necessary.

Accepted

 

On-going

b)

MC and NRC continue to provide necessary standards calibration and certification services to maintain traceability of Canadian electricity measurement standards to international standards.

Accepted

 

On-going

c)

The frequency for electricity measurement standards recertification continue to follow the relevant rules set out in the Weights and Measures Act and Regulations.

Accepted

 

On-going

d)

Recognition of the equivalency of traceability to NRC and NIST be pursued using a suitable ASD mechanism as soon as possible.

Accepted

1. The recognition of international traceability and equivalency of calibration chains is primarily within NRC's sphere of responsibility to resolve.

Long term
- by 2005-06

e)

The foregoing does not prevent MC from pursuing additional ASD mechanisms for conducting standards calibration and certification if future conditions warrant this.

Accepted

 

On-going

5. CERTIFICATION OF ELECTRICITY METER CALIBRATION CONSOLES

a)

MC continue to initially test and certify electricity meter calibration consoles to independently establish their initial traceability.

Accepted conditionally, provided this applies to new calibration consoles only.

1. A policy statement will be issued to ensure consistent understanding and application of "initially test" and what MC considers a new console, e.g., newly manufactured, significantly refurbished, etc.

On-going

b)

Accredited organizations be permitted to re-certify their own calibration consoles under additional provisions of the Accreditation Program to be developed based on international QMS principles and practices regarding the control of measuring and test equipment.

Accepted conditionally, provided that calibration consoles must still comply with S-E-01, Specifications for the Calibration, Certification, and Use of Electricity Calibration Consoles and that the traceability and performance of a multifunction electricity standard used in a console (e.g., Radian) continue to be certified by MC or NRC (per Recommendation 4 b)).

1. MC is concerned that including this work within the scope of its Accreditation Program may not be the most cost efficient approach.



2. Other ASD mechanism options will be explored.

3. A policy will be issued regarding notification of MC following changes or repairs to a console.

Short term
- by April 2003

6. METER TYPE APPROVAL PERFORMANCE REQUIREMENTS

a)

MC make increased use of the NSS consensus based standards development process for its specification development purposes.

Accepted

1. Increased understanding is needed of how the NSS standards development process works, its potential for effective use by MC in rule making, what the costs are and what MC's role on the technical committee will be.

Long term
- by 2005-2006

(unless a need for a specific meter standard is identified earlier)

b)

MC adopt a principle that new Canadian electricity meter requirements be performance based and aligned with American and other international standards.

Accepted conditionally, provided stakeholders acknowledge that valid reasons exist where Canadian standards may differ from American or international ones - e.g., due to ambient temperature considerations.

1. MC wants "performance based" to be better defined since requirements for meters are not limited to accuracy performance, e.g., sealing and marking requirements.



2. MC wishes to avoid creating requirements that result in meters manufactured solely for the Canadian marketplace.

c)

Adoption of the NSS consensus based standards development process be piloted (see Recommendation 9) and, if proven successful, serve as the basis for the development of all future meter requirements.

Accepted

1. MC considers this recommendation to be the same as Recommendation 9 (b) and that the considerations for Recommendations 9 (b), (c) and (d) apply equally here.



d)

MC remain in control of rule making through its participation and influence in the NSS electricity meter standards development process and through its EGIA regulatory amendment process, which can be used to mandate specific requirements by referencing a consensus based standard in whole or in part.

Accepted

 

7. METER TYPE APPROVAL PERFORMANCE TESTING

a)

MC continue to offer electricity meter type approval testing services for the foreseeable future in order to provide this service to manufacturers who require it.

Accepted

 

On-going

b)

The competency of other testing organizations including manufacturers to test meters and submit results for type approval decision making purposes be recognized by MC in the medium term through an ASD program, e.g., this could include joint in-factory witness testing.

Accepted conditionally, provided it is understood that the ASD program will address conditions under which test data will be accepted by MC and it not be limited to simple automatic acceptance of testing data by MC.

1. MC recognizes that manufacturers and meter users need faster approval service in an era of rapidly changing technology.

2. Increased onus will be placed on manufacturers to accept more responsibility for demonstrating conformance of their metering devices during the approval process.

3. MC feels that improving the quality, preparation and pre-testing of prototype samples submitted will speed up approvals in and of itself.

4. The new ASD program must be robust to ensure data is valid and to overcome any perceived "conflict of interest" concerns.

5. Before implementing a new ASD program, MC will ensure it is cost effective.

6. A major consideration is that MC must continue to provide meter approval testing services for all those who need it.

Implementation of recommendation 7.b) has been postponed.

c)

The criteria for the ASD program be developed based on relevant international standards and practices adapted to the Canadian context.

 

d)

MC continue to issue Notices of Approval on the basis of the current EGIA accuracy requirements (i.e., ± 1%).

Accepted

 

On-going

e)

Where a manufacturer or purchaser desires meter type approval testing to higher accuracy standards (e.g., ± 0.2%), this testing be carried out by a 3rd party laboratory recognized by meter manufacturers and meter purchasers as being technically capable of performing the higher accuracy tests required.

Accepted

 

On-going

8. VERIFICATION AND REVERIFICATION OF METERING DEVICES

a)

MC adopt a principle that verification and reverification rules and procedures be based on objective performance data of the meter technology involved, so barriers to marketplace introduction of new technology are minimized.

Accepted conditionally, provided MC retains the ability to establish additional requirements with good justification in the absence of objective performance data and/or to adequately protect vulnerable parties.

1. "As found" meter performance data may need to be captured to properly judge meter performance objectively.



2. A considerable length of time may be needed to determine accuracy performance of new technology (e.g., sampling and seal period of digital electronic meters).

3. It is acknowledged that the linkages between approval testing and field testing of meters must be improved.

4. MC needs "new technology" to be better defined for its policy development purposes.

Short term
- by April 2003

b)

Mandatory initial verification and periodic reverification of meters be maintained using the Accreditation Program to protect purchasers and sellers.

Accepted

 

On-going

c)

Appropriate meter sampling plans, seal periods and testing specifications for electronic meters be developed on an urgent basis either by a MC/CEA Joint Working Group or by using the new consensus based standards development process (see Recommendation 9) to avoid continued delay in marketplace introduction of new technology.



Accepted

 

Short term
- by April 2003

9. CONSENSUS BASED STANDARDS DEVELOPMENT PILOT

a)

MC, when developing or changing technical regulations, follow the Government of Canada Regulatory Policy (November 1999) which requires federal regulatory authorities to be aware of and take into account their general obligations laid out in the WTO Technical Barriers to Trade Agreement and other multilateral, regional and bilateral agreements referring to regulations and standards.

Accepted and acknowledged that this applies to Specifications as well as Regulations.

1. MC intends to adhere to the principles and intent and not simply the process.

Short term Information gathering - by April 2003



Medium Term Implementation

- by April 2004 (assuming the specific subject of a needed meter standard is identified in time)

b)

One or more pilot standards be developed using the NSS consensus based standards development process to assess its effectiveness and efficiency in meeting MC's Long term needs and obligations for developing technical requirements in the electricity sector.

Accepted

1. Criteria will be established by MC at the outset to evaluate the efficiency and effectiveness of using the NSS standards development process pilot.

c)

MC consider using this NSS consensus based standards development process for future electricity meter standards development needs and in other sectors assuming that the pilot is satisfactory from timeliness, cost and effectiveness perspectives.

Accepted conditionally, provided "and in other sectors" is deleted.

1. Stakeholders in other sectors will determine if they wish to use the NSS for measuring device standards development purposes.

2. MC will use the NSS process in the electricity sector on a Long term basis only if Recommendation 9 (a) continues to be achieved and the pilot results are satisfactory from the timeliness, cost and effectiveness criteria established.

d)

The subject matter of the pilot standard(s) be related to the introduction of new metering technology and measurement accuracy.

Accepted

1. In collaboration with stakeholders, MC needs to determine the appropriate subject of the pilot standard; who will participate; participants' roles and responsibilities; the estimated costs and how these costs will be shared.

10. ACCREDITATION PROGRAM

a)

MC continue to accredit organizations to provide specific electricity meter testing services.

Accepted

 

On-going

b)

MC recognize the QMS audit work performed by ISO Registrars. MC immediately begin coordinating the timing and scope of its audits with those conducted by ISO Registrars.

Accepted

1. MC understands that the goal is to reduce duplication of MC and ISO 9000 Registrar audits without compromising results.



2. As regulator, MC needs to stay directly involved in the auditing of metrological and legal requirements.

3. Work is required to develop criteria and a process for recognizing the equivalency of ISO 9000 Registrar and MC QMS auditing and for reconciling auditing results.

4. MC may disagree with an ISO Registrar and if so, as regulator, will consider its views on compliance with metrological and legal requirements to take precedence.

5. A new process is needed to coordinate the timing of ISO 9000 Registrar and MC audits. MC is concerned about how practical such coordination will prove to be. 6. MC must decide how accreditation and surveillance audits could be handled under this program.

Short term
- by April 2003

c)

In the medium term, MC explore with SCC the costs and benefits of the recognition of technically competent registrars by participating in the development of an industry specific ISO standard which would replace the existing accreditation standard, by specifying legal and metrological check points for ISO audits and by training ISO auditors.

Rejected

1. This recommendation was not accepted by MC due to ongoing operational and human resource management considerations.



2. We remain committed to the continuous improvement and delivery of professional and proficient accreditation services which address the needs of our clients.

3. This decision and its rationale was communicated to MC staff and ETSR participating stakeholders in January.

N/A

11. METERING INSTALLATION INSPECTION (3)

a)

MC implement a national data collection project process to determine accuracy compliance levels of metering installations and the magnitude and types of measurement problems.

Accepted

1. This work is to be done by industry stakeholders who will play an active role in developing the implementation plan.



2. Some industry firms may have insufficient equipment or expertise to provide this data and a practical solution must be found.

3. MC's objective is fact finding and MC will consult with stakeholders on an appropriate enforcement tool to use for cases where data is not provided by industry.

4. To be clear, this program is to encompass all metrological aspects of the metering installation including accuracy, wiring, meter application, etc..

5. All parties must agree on a clear definition of "metering installation" at the outset.

6. MC needs an effective way to validate that the data collected is objective.

Short term
- by April 2003

b)

Standard check points, reporting format and reporting method be developed by E-MAP members in consultation with MC, non E-MAP utilities and other suppliers.

Accepted

 

c)

Reporting be mandatory for E-MAP members (via CEA) and for utilities and other electricity suppliers (directly to MC).

Accepted

1. Incentives are needed to ensure cooperation and a mechanism is needed for MC to enforce consequences of non reporting.

d)

This not include submetering metering installations at this time pending completion of the submetering requirements review (see Recommendation 14).

Accepted conditionally, provided this exclusion applies to commercial submetering marketplace participants only.

1. Commercial submetering marketplace participants are to be consulted for inclusion in this program as part of the requirements review (See Recommendation 14).



2. Residential submetering marketplace participants are not expressly excluded from this program.

On-going

e)

Results of this monitoring program are to be discussed with the APEM (see Recommendation 15) to decide next steps.

Accepted conditionally, provided that "decide" is replaced with "who would recommend".

1. The Advisory Panel will provide advice to MC only and not make decisions on MC's behalf. (See Recommendation 15.)

Short term
- by April 2003

f)

This not preclude MC from expanding the scope of its Accreditation Program in the interim to include metering installation inspection for any accredited organization who voluntarily wishes to enter into this type of program.

Accepted

 

Short term
- by April 2003

12. MARKETPLACE MONITORING PROGRAM

a)

The following performance information be adopted and collected from each E-MAP organization, non E-MAP organization and from MC on an annual basis:

Accepted

1. Before proceeding with implementation, MC wishes to review with all stakeholders the reporting objectives and the list of indicators suggested in the recommendation and discuss a standard reporting format and a mechanism to permit review and ensure industry members provide the performance information agreed to.



2. MC will put in place a system to receive, analyse and distribute the performance information internally and externally and possibly for other sectors in future.

3. Flexibility is needed to alter/add to the list of performance indicators in consultation with stakeholders.

4. Stakeholders must remain open to the development of better performance indicators to ensure that only the right information is being collected and there is value added at all times.

5. MC may require more details for certain indicators, e.g., which meters are failing, what kinds of installations pass or fail inspections, etc.

6. MC's foresees the following potential uses of this information:

  • to know if MC's level of intervention is adequate
  • to provide a needed level of confidence for consumers
  • to compare performance to other sectors
  • to direct resources and inspection efforts within the sector or to other sectors
  • to promote compliance
  • to set performance improvement goals

Short term
- by April 2003

 

i) QMS Compliance Performance Indicator:

  • number of audits performed (by MC and ISO Registrars)
  • number of minor non-conformances (found by MC and by ISO registrars)
  • number of major non-conformances conducted (found by MC and by ISO registrars.)

 

 

ii) Meter Compliance Performance Indicator:

  • number of meters tested by test type (verification, reverification, product audit) (by accredited organizations and by MC)
  • % of tested meters found within tolerance (by accredited organizations and MC)
  • number of metering installations inspected (see Recommendation 11)
  • % of metering installations inspected found to be accurate (see Recommendation 11)
  • total $ value of metering errors found through metering installation inspections (see Recommendation 11).

 

 

iii) Meter Dispute Resolution Performance Indicator (MDRPI):

  • number of disputes handled by organizations and by MC
  • total $ value of dispute errors found by organizations and by MC
  • % consumers satisfied with MDRPI provided by organizations and by MC.

 

 

iv) Standards Development Performance Indicator:

  • number of electricity meter accuracy related standards (specifications) under development and completed
  • average development time for standards completed in reporting year
  • % of existing MC technical specifications replaced by international standards.

 

b)

This performance information be reported to MC by E-MAP members via CEA and by non E-MAP members directly in disaggregated form.

Accepted

1. MC wishes to work with E-MAP and non-E-MAP members to develop a standard format for reporting this information.

c)

This performance information be made available by MC to APEM for review in aggregate form only (see Recommendation 15).

Accepted

 

Short term
- by April 2003

d)

MC publish the annual performance information in aggregate form on its web site for public and media consumption.

Accepted

1. Release of performance information will comply with Access to Information Act and Privacy Act requirements.

Medium Term
- by April 2004

(right after completion of 12 (a) and (b))

e)

The performance information be used by MC to establish baseline performance and for setting performance improvement goals in consultation with APEM each year.

Accepted

1. MC intends to use the information to monitor the trends and impacts of program changes and to identify areas that need improvement.



2. The Advisory Panel is an advisory body only (see Recommendation 15 (a)).

3. Any performance improvement goals will have to be justified on a cost/benefit basis before MC would agree to them.

Medium Term
- by April 2004

f)

MC develop and document national procedures that instruct its personnel on how to carry out specific monitoring programs for spot checks and audits.

Accepted conditionally, provided that "procedures" is replaced with "guidelines" and "instruct" is replaced with "guide".



1. These guidelines will ensure consistency of process while leaving sufficient flexibility for MC staff to use discretion when carrying out their monitoring and enforcement activities.

Medium Term
- by April 2004

g)

MC explain to APEM in advance each year, its general and specific plans for audits and electricity meter surveillance tests to ensure consistent application across the country.

Accepted conditionally, provided that "and specific" is deleted, "explain" is replaced with "communicate" and "in advance" is deleted.

1. MC agrees to communicate its priorities and work plans only after these have been established for the fiscal year involved.

Short term
- by April 2003

h)

MC staff participate in any independent verification processes carried out by E-MAP members (3 or 4 member sites to be selected annually at random for independent audit for compliance to E-MAP member requirements).

Accepted



 

Medium Term
- by April 2004

i)

MC not be prevented in any way from gathering and reporting on additional monitoring data in any part of the sector using its own resources through such means as liaison with ISO registrars or by carrying out legal/metrological audits, spot checks, independent reviews or special monitoring programs, provided that this monitoring work is based on a national program and reported nationally.

Accepted conditionally,



(This recommendation viewed to be the same as Recommendation 12 (f))

1. MC needs flexibility to add to industry reporting indicators as detailed in Recommendation 12 (a) if necessary, in consultation with affected stakeholders.



2. Consistency and fair treatment are the goals, however, MC must still be able to use discretion in its enforcement activities.

On-going

13. COMPLIANCE AND ENFORCEMENT POLICY

a)

MC develop and implement comprehensive compliance and enforcement policy and procedures to facilitate consistent national implementation and compliance with the EGIA and Regulations and building on the proactive conformity assessment methods to be implemented by E-MAP members.

Accepted

1. MC will take into consideration the program and activities of E-MAP members and other organizations in creating this compliance and enforcement policy.

Short term
- by April 2003

b)

MC explore using new administrative penalties (i.e., ticketing, fines) as a way of securing compliance as an alternative to prosecution.



Accepted

 

Long term
- by 2006-07

14. SUBMETERING CONTRACTOR COMPLIANCE(4)

a)

Submetering stakeholders (i.e., contractors, their associations, manufacturers, submetered consumer groups, etc.) and MC undertake to review the legal, technical and performance requirements for submetering in light of technological and marketplace change.

Accepted conditionally, provided that the scope of the review be submetering requirements in the commercial marketplace only and not in the residential marketplace.



1. Only commercial marketplace submetering stakeholders have requested such a review.

2. Residential submetering stakeholders, including consumers, who were represented during the ETSR, did not request such a review.

3. MC agrees to this review to respond to stakeholders' request and not for reasons of technological change.

Short term
- by April 2003

b)

MC in collaboration with submetering stakeholders develop and implement a special strategy targeted to facilitate the compliance of submetering contractors with the revised requirements.

On hold pending the outcome of Recommendation 14 a).

1. MC reserves its decision on this recommendation until the requirements review has been completed.

To be determined after the completion of Recommendation. 14 (a)

c)

In the interim, MC consider declaring a moratorium on its field enforcement of existing commercial submetering requirements.

Rejected

1. MC will continue to enforce legislation to protect buyers and sellers as this is MC's mandated and legal responsibility.



2. During the review, MC will not initiate new programs to monitor compliance in the commercial submetered marketplace.

3. MC agrees to suspend enforcement of contractor registration and record keeping rules in the commercial submetered marketplace, during the review.

On-going

15. PILOT ADVISORY PANEL ON ELECTRICITY MEASUREMENT

a)

MC establish a multi-stakeholder APEM to help MC create, prioritize and monitor strategies for ensuring accuracy of measurement in the electricity trade measurement sector, on a pilot basis.

Accepted

1. MC is willing to participate in dialogue with and accept policy advice from APEM members.



2. APEM will not be a decision making body on MC's behalf. Its function is to provide advice only.

3. The scope of this advice is program and policy input at a high level and not input on technical issues.

4. MC needs to have a full-time non-voting member on APEM to answer policy and program questions and ensure key information is available to APEM members.

5. MC wants to ensure there is sufficient value added for consumer groups to participate.

Short term
- by April 2003

b)

The membership of this panel be composed of approximately 8 stakeholders balanced between regulatees (meter manufacturers, accredited organizations, electricity contractors and/or their advocacy groups or associations) and beneficiaries (industrial, commercial and residential consumers and/or their advocacy groups or associations) plus a MC ex-officio member to serve as liaison and resource.

Accepted conditionally, provided "approximately" is replaced with "no greater than" and "to serve as liaison and resource" is deleted.

1. APEM membership may have to be altered if the advisory panel concept is expanded to other sectors in the future.



2. The role of the MC member is to

  • ensure stakeholders are fully informed
  • promote better understanding of our policies and programs and the reasons for them
  • explain MC's position.

3. MC agrees that its member is ex-officio, i.e., non-voting.

c)

APEM meet at least once a year, possibly during the Canadian Forum on Trade Measurement.

Accepted

1. MC cautions that one meeting per year may be too infrequent.



2. MC suggests that meetings be timed to facilitate input into MC's priority and operational planning cycle.

d)

APEM have the following initial terms of reference which could be further modified prior to or after implementation:

  • providing MC with strategic advice on electricity measurement policy issues and feedback on proposed or desired regulatory amendment and program changes
  • reviewing marketplace metering accuracy and equity performance issues and
  • aggregate performance monitoring information
  • advising on work priorities and monitoring the progress of ETSR implementation items
  • issuing a report annually of stakeholder views on the accuracy and equity performance of the industry including recommendations to MC on issues requiring attention .

Accepted

1. MC cautions that "advising on work priorities" means high level policy and program advice only.



2. Consideration may be given by MC eventually to expanding the scope of this initiative to beyond the electricity sector if the pilot proves successful.

e)

The agenda, minutes of the APEM meetings and its annual report and recommendations would be public documents posted on MC's web site.

Accepted

 

f)

The role of the panel will be advisory in nature only.

Accepted

 

g)

An assessment of the effectiveness of this pilot advisory panel be carried out by MC in consultation with APEM members and other stakeholders after an agreed upon period of operational time (e.g., 2 years suggested) to ensure it is meeting stakeholders' and MC's needs.

Accepted

 

16. MODERNIZATION OF THE ELECTRICITY AND GAS INSPECTION ACT (EGIA) AND REGULATIONS

a)

MC and stakeholders make maximum use of the flexibility/innovation provided by the current EGIA provisions and regulatory amendment processes to modernize the existing regulatory rules.

Accepted

1. MC wishes to work together with all electricity sector stakeholders and marketplace beneficiaries on this but reminds stakeholders that the EGIA can only be amended by Parliament.

On-going

b)

MC and stakeholders identify where desired requirement changes are impeded by wording of the existing EGIA.

Accepted

 

Short term
- by April; 2003

c)

That future consideration be given to modernizing the EGIA to overcome the identified impediments.

Accepted

 

Long term
- by 2007-08



1. Dispute: as per the Electricity and Gas inspection Act, "a contractor or purchaser dissatisfied with the condition or registration of any meter used in respect of electricity or gas supplied by or to him", may request a Measurement Canada inspector to investigate and resolve the situation."

2. Typically, a working electricity measurement standard is a highly accurate multi-function electronic device used as the basis for making comparative measurements in a meter test board. Other standards are also included as necessary for the accurate measurement of electricity.

3. For the purposes of this recommendation, a metering installation is considered to be an installation that is transformer rated, i.e., includes one or more instrument transformers to reduce voltage and/or current to values permitting metering to be carried out safely.

4. Submetering refers to the metering of electricity for billing purposes using a meter or meters owned by an organization or individual such as a commercial or residential property owner or management organization, e.g., a campground or marina owner, an apartment building, office or shopping centre owner or property manager. Typically a submetering organization's metering of electricity to customers is not its main line of business. Both are defined as 'contractors' with the same rights and responsibilities to comply with the EGIA and Regulations' provisions for accurate and equitable electricity measurement.


    Created: 2003-07-08
Updated: 2005-03-08
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