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Recommendations Based on Stakeholder Consensus 2001-12-17

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Electricity Trade Sector Review Team
Recommendations Based on Stakeholder Consensus
2001-12-17
Part 1

PURPOSE
This document sets out the Electricity Trade Sector Review (ETSR) Team's recommendations for continued Measurement Canada intervention in the Canadian electricity marketplace based on the results of the stakeholder consensus achieved at the Electricity Stakeholder National Consensus Meeting (Ottawa, October 16 - 17, 2001, see Appendix 1 for the list of participants) and at the Electricity Stakeholder Representatives' Meeting (Montreal, November 1 - 2, 2001, see Appendix 2 for the list of participants ). Our goal was that stakeholders reach consensus on the specifics of what Measurement Canada's level of intervention should be to in today's electricity marketplace, as well as on how this intervention should be carried out, to ensure accurate and equitable measurement is achieved at reasonable cost without compromising protection of vulnerable parties. We believe that our goal has been achieved.

This document also integrates and responds to the major provisions of the Canadian Electricity Association (CEA) Task Group on Metering and Regulation's proposal entitled Electricity Measurement Accuracy Program (E-MAP) and the position paper entitled Ensuring Electricity Metering Accuracy and Consumer Confidence in a Changing Market prepared by Option Consommateurs. We have also sought to integrate the views of many other stakeholders including consumers who provided us with their ideas and proposed solutions on the issues at hand. Technical issues beyond the scope and mandate of the ETSR Team to respond to are not addressed here as these will be addressed through other channels using some of the mechanisms outlined here.

These recommendations were presented to Measurement Canada senior management in December 2001 for decision making purposes early in 2002. Depending on the scope of system changes proposed, approval by Industry Canada senior management may also be required before implementation may proceed. Measurement Canada wishes to move quickly to implementation as soon as all necessary approvals are received. The ETSR Team remains fiercely dedicated to serving all stakeholder groups and Measurement Canada as the messenger and catalyst in the ETSR process, nothing more, nothing less.

The ETSR Team would like to thank all participating stakeholders for their support and ideas over the last two years during this review. It has been a real privilege getting to know you and understanding your issues and ideas. We have learned much and benefited personally and professionally from this experience. Measurement Canada and indeed all electricity marketplace participants and taxpayers are now poised to reap the benefits as well. Thanks again for your tremendous support.

Sincerely,

________________________________________________

Luc Tessier, ETSR Team Member
tessier.luc@ic.gc.ca
(819) 564-5737

________________________________________________

Luc VanOverberghe, ETSR Team Member
vanoverberghe.luc@ic.gc.ca
(519) 690-3815

________________________________________________

Dave Morgan, ETSR Team Leader
morgan.dave@ic.gc.ca
(613) 952-0661

Table of Contents
MARKETPLACE PROTECTION AND SERVICES
    List of Acronyms

1. Dispute Resolution
2. Information for Marketplace Participants
3. Requirements for Major Power Consumers
4. Certification of Electricity Measurement Standards
5. Certification of Electricity Meter Calibration Consoles
6. Meter Type Approval Performance Requirements
7. Meter Type Approval Performance Testing
8. Verification and Reverification of Metering Devices
9. Consensus Based Standards Development Pilot
10. Accreditation Program
11. Metering Installation Inspection

12. Marketplace Monitoring Program
13. Compliance and Enforcement Policy
14. Submetering Contractor Compliance

15. Pilot Advisory Panel on Electricity Measurement
16. Modernization of the Electricity and Gas Inspection Act and Regulations

Appendix 1 - List of Participants
Electricity Stakeholder National Consensus Meeting, Ottawa, October 16 - 17, 2001 31

Appendix 2 - List of Participants
Electricity Stakeholder Representatives' Meeting, Montreal, November 1 - 2, 2001 33

List of Acronyms

AO Accredited Organizations
ANSI American National Standards Institute
APEM Advisory Panel on Electricity Measurement
ASD Alternate Service Delivery
ASL Approval Services Lab (MC)
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
ENG Engineering Directorate (MC)
ESC Electricity Standing Committee (MC)s
ETSR Electricity Trade Sector Review
FTE Full Time Equivalent
IEEE Institute of Electrical and Electronic Engineers
ISD Innovation Strategies Directorate (MC)
ISO International Standards Organization
LAN Local Area Network
MC Measurement Canada
MBO Marketing and Business Operations (MC)
MPC Major power consumer
MW Megawatts
NAFTA North American Free Trade Agreement
NIST National Institute of Standards and Technology
NRC National Research Council, Institute of National Measurement Standards
NSS National Standards System
PALCAN Program for Accreditation of Laboratories - Canada
PDD Program Development Directorate (MC)
QMS Quality Management System
SCC Standards Council of Canada
SDO Standards Development Organization
SMC Senior Management Committee (MC)
TBT Technical Barriers to Trade
TB Treasury Board, Government of Canada
WG Working Group
WTO World Trade Organization

1.DISPUTE⁽¹⁾ RESOLUTION

Stakeholder Consensus and ETSR Team Recommendation

1. Measurement Canada 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.
2. 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.
3. All electricity suppliers refer a customer to Measurement Canada whenever a dispute involving measurement performance of a meter cannot be resolved satisfactorily between themselves and the customer involved.

Considerations

• The ETSR Team understands that general stakeholder consensus has been reached on the continued need and value of Measurement Canada providing electricity meter dispute resolution services
  
• Buyers and sellers wish to have continued access to an independent third party to resolve measurement disputes
• Stakeholders say that Measurement Canada well fulfills this role
• Measurement Canada may not have to do all the associated meter testing but prefers to do so as one way to help preserve staff technical competence
• Measurement Canada encourages continued use of independent metering experts and utility personnel to examine a metering complaint and seek resolution
• MC needs to put into place procedures to create incentives towards resolution of meter complaints and disputes with their customers to the best of their ability.

2. INFORMATION FOR MARKETPLACE PARTICIPANTS

Stakeholder Consensus and ETSR Team Recommendation

1. Measurement Canada 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.
2. Electricity suppliers accept responsibility for satisfying their customers information needs about how meter accuracy is maintained and the recourse mechanisms available.
3. 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 Measurement Canada 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 Measurement Canada staff to explain and promote what Measurement Canada does, to stakeholders particularly consumers, at every opportunity.

Considerations

• The ETSR Team understands that the E-MAP proposal does not directly address marketplace participant information issues
  
• In previous consultation sessions, stakeholders indicated that there is increased need for information for consumers and that Measurement Canada rules and policies are not always well understood by those who must comply with them
• Consumer research conducted by Environics Inc. and Option Consommateurs indicates that marketplace confidence would increase if marketplace participants knew more about Measurement Canada's role, activities and services in overseeing accuracy and equity performance in electricity metering
• Residential consumers expressed the need to be reassured that their meter is accurate and wish to be better informed about the option of contacting Measurement Canada when seeking to resolve a meter dispute
• Entrants into the restructured marketplace may know very little about metering issues and their rights and responsibilities.
• Evidence exists that Contractor awareness, understanding and compliance with their legal responsibilities is a growing problem particularly in the area of submetering
• Stakeholders see Measurement Canada as the national champion of metering performance issues while manufacturers, utilities and meter service organizations have the technology expertise
• Technological change and restructuring of the marketplace increases the urgent need for plain language, relevant and timely educational information on Measurement Canada's role and activities
• Marketplace information must promote the positive side of things and avoid creating panic which could quickly lead to excessive demand for dispute resolution service

3. REQUIREMENTS FOR MAJOR POWER CONSUMERS

Stakeholder Consensus and ETSR Team Recommendation

1. A trade meter used in a metering installation at a single geographic location⁽²⁾ where the purchaser has a demand equal to or greater than three megawatts (3 MW), be exempted from current Measurement Canada approval requirements related to the functionality⁽³⁾ of the meter.
2. 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 Measurement Canada 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).
3. Any such exempted meter continue to require type evaluation and approval by Measurement Canada of its accuracy performance.
4. Any current and potential transformer used with any such exempted meter also continue to require type evaluation and approval by Measurement Canada.
5. 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.
6. If either party so wishes, a major power consumer and their electricity supplier have continued access to Measurement Canada's meter dispute resolution process if they have been unsuccessful in resolving a dispute themselves. However, Measurement Canada's ability to resolve a dispute without an event logger audit trail is greatly impaired.
7. A contract must exist between the electricity supplier and purchaser wherein they agree on the use of such exempted meter(s).
8. Measurement Canada 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.

Considerations

• Major power consumers are less vulnerable and do not need the same level of protection from Measurement Canada as small power consumers do
• 
  
• They seek more flexibility to modify their metering equipment and its functionality (e.g., ability to install a new firmware version without being subject to a new approval or reverification, to modify billing parameters and programs, etc.)
• They wish to have their meters approved to ensure that they measure accurately; they do not want Measurement Canada to enforce design (e.g. event logger, etc.) or sealing requirements
• They wish to have their meters verified and reverified to ensure that they measure accurately; they want their utility to be permitted to break the seals and replace them with their own seal in timely fashion without legal restriction when needed (to upgrade features, firmware, etc.)
• Major power consumers often use their own check meter to verify the accuracy of their electricity supplier's meter
• Major power users often seek higher accuracy performance, have increased metering expertise and resources at their disposal and have access to wholesale marketplace or contractual mechanisms for resolving disputes
• Certain EGIA rules or requirements such as billing record keeping or mandatory 'contractor' registration may be redundant and restrictive where equivalent contractual or wholesale marketplace metering rules exist
• Flexibility to adjust the proposed 3 MW threshold is needed as some countries have fixed this exemption threshold at 1 MW
• As an example of potential impact, one major utility in Canada has classified 280 of its clients as major power consumers; the smallest demand is 5 MW, the average 45 MW and one has 650 MW
• It is important for major power consumers to realize that the ability to replace seals would reduce Measurement Canada's ability to reach conclusions when conducting dispute investigations
• Electricity suppliers retain the right to offer usage of such an exempted meter as an option for qualified customers i.e., use in each qualifying situation is not mandatory
• Electricity suppliers and customers need to have in place a reverification schedule that exceeds the requirements of the EGIA/R, this should be written into the contract.

4. CERTIFICATION OF ELECTRICITY MEASUREMENT STANDARDS⁽⁴⁾

Stakeholder Consensus and ETSR Team Recommendation

1. Traceability of Canadian electricity measurement standards to international electricity measurement standards is necessary.
2. Measurement Canada and NRC⁽⁵⁾ continue to provide necessary standards calibration and certification services to maintain traceability of Canadian electricity measurement standards to international standards.
3. The frequency for electricity measurement standards recertification continue to follow the relevant rules set out in the Weights and Measures Act and Regulations.
4. Recognition of the equivalency of traceability to NRC and NIST⁽⁶⁾ be pursued using a suitable ASD mechanism as soon as possible.
5. The foregoing does not prevent Measurement Canada from pursuing additional ASD mechanisms for conducting standards calibration and certification future conditions warrant this.

Considerations

• General stakeholder consensus exists that electricity metering equipment used in trade transactions must be traceable to international measurement standards
• 
  
• Stakeholders support the continued role of NRC and Measurement Canada in providing standards calibration and certification services to accredited organizations in Canada
• Equivalency of the traceability of electricity measurement standards to NRC and NIST is desired by certain accredited stakeholders to reduce system costs meaning NRC and NIST should both be alternatives to Measurement Canada service (only NRC is now)
• Measurement Canada and/or NRC must continue to ensure integrity of measurement standards due to their fundamental importance
• Alternate service delivery is acceptable to consumers if Measurement Canada can guarantee conformance to requirements
• Accredited organizations seek to have increased regional capacity and choice for standards calibration service however there is insufficient demand at present to attract other ASD service providers beyond NIST, NRC and Measurement Canada to make this viable at present
• Consumers say that regardless of who calibrates standards, NRC/Measurement Canada must remain in direct control of the integrity of the standards system
• Usually NRC is responsible for recognizing international traceability chains equivalent to its own services however MC can play a role in ensuring this recognition is achieved in timely fashion
• If Measurement Canada pursues such additional ASD mechanisms in future for this, its calibration services laboratory should meet or exceed the same quality certification requirements required of alternate service providers

Stakeholder Consensus and ETSR Team Recommendation

1. Measurement Canada continue to initially test and certify electricity meter calibration consoles to independently establish their initial traceability.
2. Accredited organizations be permitted to re-certify their own calibration consoles under additional provisions of the Accreditation Program to be developed based on international quality management system principles and practices regarding the control of measuring and test equipment.

Considerations

• E-MAP proposes that organizations accredited by Measurement Canada should be accountable for maintaining the accuracy of the measuring and test equipment used for verifying meters, and that self-certification of meter calibration consoles (test boards) be permitted by accredited organizations registered to ISO 9000 using an appropriate procedure
• Consumer groups would like Measurement Canada to continue to have control over the certification of these measuring apparatus
• Some accredited organizations have said they want Measurement Canada to initially certify each of their test consoles to establish the performance curves
• Annual Measurement Canada legal/metrological audits will verify the ongoing integrity/accuracy of each meter test console performance
• This recommendation would eliminate duplication of Measurement Canada and accredited organizations' testing, reduce downtime when re-certifying meter test console performance and thus reduce consumer costs
• The electricity measurement standard used in each test board continues to be periodically recertified by Measurement Canada or NRC (see Recommendation 4)
• Accredited organizations must have the technical capability to certify their own equipment and proper processes and procedures in place in order to qualify
• Continued attention must be given to maintenance and/or repairs to test consoles
• Presently maintenance, repairs and modifications to test boards are monitored by Measurement Canada technical specialists through their relationships with accredited organizations
• Measurement Canada must retain sufficient resources to provide acceptable service response times for new console certification requests (6 to 12 weeks turnaround time not acceptable) and to provide recertification services for those accredited organizations who do not choose this self-certification option
• Stakeholders also requested that NRC and eventually NIST be encouraged by Measurement Canada to also provide electricity meter calibration console certification services

Stakeholder Consensus and ETSR Team Recommendation

1. Measurement Canada make increased use of the National Standards System (NSS) consensus based standards development process for its Specification development purposes.
2. Measurement Canada adopt a principle that new Canadian electricity meter requirements be performance based⁽⁷⁾ and aligned with American and other international standards.
3. Adoption of the National Standards System 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.
4. Measurement Canada remain in control of rule making through its participation and influence in the NSS electricity meter standards development process and through its Electricity and Gas Inspection Act (EGIA) regulatory amendment process, which can be used to mandate specific requirements by referencing a consensus based standard in whole or in part.

Considerations

• E-MAP proposes approval of type should be based on conformity with relevant North American or other international standards dealing with electricity meter accuracy (i.e., ANSI/IEEE, IEC, etc.)
• E-MAP advocates that performance requirements be used rather than design specifications since performance based requirements do not pre-empt technical solutions or impede technological progress
• Consumer groups feel strongly that Measurement Canada must maintain the rule setting role and not compromise Canadian standards
• CEA members, through their proposal wish to see Measurement Canada continue its role and responsibilities as regulator
• Continuous updating of prescriptive specifications (standards) has proven to be impractical, a new approach is needed
• Performance-based requirements rather than technology specific ones promote timely introduction of new technology while still protecting buyers and sellers
• Specifying the reliability standards of new metering designs must also be adequately addressed in performance standards
• Stakeholders and Measurement Canada must abide by Canada's obligations under NAFTA and WTO agreements which require reduction of technical barriers to international trade through use of international standards and other methods
• Under international standards development rules, unique Canadian requirements are still permitted in certain instances e.g., environmental related requirements
• Integration of the North American electricity marketplace is likely to continue
• MC s ability to protect proprietary information may be limited in an access to information request.

7. METER TYPE APPROVAL PERFORMANCE TESTING

Stakeholder Consensus and ETSR Team Recommendation

1. Measurement Canada continue to offer electricity meter type approval testing services for the foreseeable future in order to provide this service to manufacturers who require it.
2. The competency of other testing organizations including manufacturers to test meters and submit results for type approval decision making purposes be recognized by Measurement Canada in the medium term through an alternate service delivery (ASD) program e.g., this could include joint in-factory witness testing.
3. The criteria for the ASD program be developed based on relevant international standards and practices adapted to the Canadian context.
4. Measurement Canada continue to issue Notices of Approval on the basis of the current EGIA accuracy requirements (i.e. ±1%).
5. 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 3^rd party laboratory recognized by meter manufacturers and meter purchasers as being technically capable of performing the higher accuracy tests required.

Considerations

• Both E-MAP and consumer groups propose that Measurement Canada should continue to type approve new meters
• Technical integrity and capacity of the meter type approval process must keep pace with increases in sophistication and market demand for new technology.
• To remain competitive, electricity meter manufacturers require faster turnaround on regulatory meter type approval due to shorter product life cycles (3 to 4 years) inherent to electronic meter technology relative to the previous electro-mechanical models
• Considerable market forces exists which discourage major manufacturers from presenting low quality/high risk meters for sale in the Canadian marketplace
• Smaller metering device manufacturers may need continued access to Measurement Canada testing services for the foreseeable future
• Measurement Canada needs to maintain its testing capability to be able to verify the continued integrity of the testing system so Measurement Canada personnel must maintain their technical competencies to perform this work
• However, once this ASD mechanism has been established for the recognition of approval test data, this testing data could be used by Measurement Canada to reduce or even replace Measurement Canada approval testing but not the issuance of the Notice of Approval
• Manufacturers have expressed a desire to submit test results to be used as the basis for device approval decisions using witness testing by Measurement Canada staff and other mechanisms
• Product testing laboratory accreditation programs such as the SCC⁽⁸⁾ PALCAN⁽⁹⁾ may be of use to Measurement Canada in formally recognizing meter testing competency
• This ASD program may also include recognition of work done by other countries
• Manufacturers are willing to pay higher fees to Measurement Canada for type approval if this will improve service
• Stakeholders feel this is one area where Measurement Canada should consider increasing its resource utilization.

8. VERIFICATION AND REVERIFICATION OF METERING DEVICES

Stakeholder Consensus and ETSR Team Recommendation

1. Measurement Canada 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 minimised.
2. Mandatory initial verification and periodic reverification of meters be maintained using the Accreditation Program to protect purchasers and sellers.
3. Appropriate meter sampling plans, seal periods and testing specifications for electronic meters be developed on an urgent basis either by a Measurement Canada/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.

Considerations

• There is stakeholder consensus on the continued need for mandatory initial verification and periodic reverification of meters
• One reason marketplace confidence is high due to the existence of these mandatory initial verification and periodic reverification rules
• Mechanisms are needed to ensure new technology is not discriminated against due to prohibitive re-verification costs
• E-MAP proposes that revised sampling plans, seal periods and meter testing specifications be developed on an urgent basis to facilitate the introduction of new electronic meter technology
• Early submission of new technology reliability data by manufacturers and meter owner organizations to Measurement Canada could facilitate faster introduction of new technology
• Other jurisdictions such as Florida insist that a proposed sampling plan must include assessments of the plan's ability to detect the presence of inaccurate equipment, a cost analysis, the impact of having inaccurate meters used for billing purposes, the number of meters in the population, the historical performance of the type of equipment covered, etc...
• Stakeholders in other trade measurement sectors are recommending the introduction of similar mandatory measuring device reverification rules

9. CONSENSUS BASED STANDARDS DEVELOPMENT PILOT

Stakeholder Consensus and ETSR Team Recommendation

1. That Measurement Canada 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.
2. One or more pilot standards be developed using the NSS⁽¹⁰⁾consensus based standards development process to assess its effectiveness and efficiency in meeting Measurement Canada's long term needs and obligations for developing technical requirements in the electricity sector.
3. Measurement Canada 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.
4. That the subject matter of the pilot standard(s) be related to the introduction of new metering technology and measurement accuracy.
   
   

Considerations

• E-MAP proposes that a multi-stakeholder Electricity Meter Technical Committee (EMTC) be formed and managed by an SCC accredited Standards Development Organization (SDO) such as the CSA⁽¹¹⁾ to serve as a forum for discussing and adopting international standards and creating new standards where needed
• E-MAP proposes that Measurement Canada use the EMTC for managing the development of its electricity meter standards relating to measurement accuracy in the design, composition, performance, installation, use and testing of electricity meters
• EMTC membership would follow SCC rules for balance and include members from the electricity meter industry, interested consumer groups whose participation would be supported, and Measurement Canada
• EMTC would establish technical working groups composed of volunteers to draft a standard on a project by project basis where no acceptable international standard existed already
• Measurement Canada would retain its ability to protect the public interest by influencing the subject matter and content of consensus based standards and by subsequently mandating compliance with specific requirements through regulatory referral to a completed standard in whole or in part
• The lead time and associated costs and funding mechanisms to establish the EMTC and to develop an individual standard by this process require investigation
• The degree to which consumer groups wish to participate on the EMTC and in the development of an individual standard and funding mechanisms to support this participation require further discussion
• An implementation plan and time frames should be established for the pilot
• Measurement Canada's criteria for acceptance of its long term use of this process must be articulated in due course
• The Measurement Canada/CEA Joint Working Group on electronic meter testing continue its work to completion and be considered as a model of technical expert cooperation for evolution into this pilot program at an early date
  
  

10. ACCREDITATION PROGRAM

Stakeholder Consensus and ETSR Team Recommendation

1. Measurement Canada continue to accredit organizations to provide specific electricity meter testing services.
2. Measurement Canada recognize the QMS audit work performed by ISO Registrars. Measurement Canada immediately begin coordinating the timing and scope of its audits with those conducted by ISO Registrars.
3. In the medium term, Measurement Canada 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.

Considerations

• E-MAP proposes that a Standards Council of Canada (SCC) accredited ISO 9000 registrar should perform a single audit for an accredited organisation, that Measurement Canada should specify the metrological & legal requirements for this audit and train ISO registrars on these technical requirements or alternatively, contribute a member to ISO Registrar audit teams
• Consumer groups agree that the ISO 9000 standard is not sufficient in itself to cover the metrological and legal aspects of meter verification, reverification and sealing and insist on the continued participation of Measurement Canada in the legal/metrological audit process to maintain confidence in the system
• Not all accredited organizations support the E-MAP proposal that accreditation to be solely under SCC umbrella
• Measurement Canada must maintain its own accreditation program because organizations without an ISO registered QMS continue to need full auditing service by Measurement Canada
• Measurement Canada needs access to ISO/QMS audit results and wishes to build partnerships with ISO registrars to share information on non-conformances that affect legal/metrological activities or outcomes
• Through increased ISO Registrar/MC coordination, financial and operational burden of two QMS audits would be reduced for those accredited organizations who choose to pursue ISO registration
• Costs are unknown for a transition to an SCC sponsored program and potentially high for Measurement Canada and accredited organizations, a cost/benefit analysis is needed and Measurement Canada wants to investigate how well this approach is working with other regulators like Health Canada
• In future there may be a need to expand the Accreditation Program to international markets

11. METERING INSTALLATION⁽¹²⁾ INSPECTION

Stakeholder Consensus and ETSR Team Recommendation

1. Measurement Canada implement a national data collection project process to determine accuracy compliance levels of metering installations and the magnitude and types of measurement problems.
2. Standard check points, reporting format and reporting method be developed by E-MAP members in consultation with Measurement Canada, non E-MAP utilities and other suppliers.
3. Reporting be mandatory for E-MAP members (via CEA) and for utilities and other electricity suppliers (directly to Measurement Canada.)
4. That this not include submetering metering installations at this time pending completion of the submetering requirements review (see Recommendation 14).
5. Results of this monitoring program are to be discussed with the Advisory Panel on Electricity Measurement (see Recommendation 15) to decide next steps.
6. This not preclude Measurement Canada 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.

Considerations

• The ETSR Team proposed that initial inspection of a metering installation be mandatory using national requirements and procedures to be established using the NSS standard development process pilot
• Insufficient data exists to justify this without further fact gathering and analysis although it is acknowledged that improper installation, wiring or application of a meter can and does lead to significant undetected measurement error
• E-MAP proposed on-site testing of metering installations remain the responsibility of the applicable E-MAP participants
• Measurement Canada currently permits a meter to be put into service without installation inspection due to historical resource limitations
• No national standard for installation inspection procedure exists although there are some regional procedures
• Utilities and meter service providers wish to have their processes explored to develop an appropriate standard
• Flexibility is needed to ensure the cost effectiveness of inspection
• CEA (E-MAP) members own approximately 90% of installed meters in Canada while non-CEA members own approximately 10% of installed meters in Canada
• Personnel who install and inspect metering installations must be qualified under the provincial electrician training program in place in each province
• Some stakeholders suggest that licensing of the competency of meter personnel to perform meter installation, maintenance and testing work be looked at in future as a potential model

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. Means a single metering site or series of metering sites located in the same municipality and supplied by a single supplier. e.g., a municipal subway transit system is considered as being a single geographic location and would qualify to use such exempted meters. A business operating in multiple cities would not qualify because of the different geographic location of each of the individual customer load sites.
3. Functionality includes non metrological or billing calculation parameters or quantities such as power quality alarms, LAN or Internet communications, peak demand alarms, interface to load control centres etc., but does not include quantities which could affect the billing calculation.
4. 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.
5. NRC- National Research Council, Institute of National Measurement Standards (Canada's national standards laboratory)
6. NIST - National Institute of Standards and Technology (U.S. national standards laboratory)
7. Means accuracy requirements. Non-metrological functions or specific design features should be minimal or non-existent in regulatory requirements.
8. SCC- Standards Council of Canada
9. PALCAN - Program for Laboratory Accreditation in Canada
10. NSS - The National Standards System administered by SCC
11. CSA - Canadian Standards Association
12. 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.