Each original recommendation is listed in its entirety along with
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.
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
|