P-EG-01 — Electricity & Gas Measurement Dispute Investigation Procedure

P-EG-01—Electricity & Gas Measurement Dispute Investigation Procedure (PDF, 69 KB, 39 pages)

Information Bulletin—New Directives for the Investigation of Electricity and Gas Measurement Disputes by Inspectors of Measurements Canada

Revision 1
2001-04-20

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Part I: Table of Contents

Part II: Purpose and Scope

1 Purpose

1.1 The Purpose of this document is to provide procedure for an effective and efficient conduct of measurement dispute investigations requested pursuant to Section 23 of the Electricity and Gas Inspection Act.

2 Scope

2.1 This document shall apply to the conduct of measurement investigations pursuant to requests by the purchaser or supplier dissatisfied with the condition or registration of a meter or with the amount of the resulting charge and to requests by a contractor in a need for assistance in dealing with dissatisfied purchasers, investigation of detected or suspected measurement errors, or a need for an expert opinion for use in legal investigations, related to detected or suspected tampering with a meter.

2.2 The procedure in this document describes administrative and technical requirements for the conduct of measurement dispute investigations and appeals.

2.3 The procedure in this document shall apply to all electricity or gas meters, regardless of their compliance status with the requirements of the Electricity and Gas Inspection Act, including but not limited to the registration of the Contractor, and the approval and verification of the meter, which may constitute grounds for the outright rejection of the meter and a prosecution under the Act.

Part III: Definitions

For the purposes of this document, the following definitions shall apply:

"Act"

means the Electricity and Gas Inspection Act.

"Accredited Meter Verifier"

means an organization which has been accredited by the President of Measurement Canada in a specific field(s) of metrological verification.

"AMV"

means Accredited Meter Verifier - see above

"adjustment"

means a correction to a purchaser's account pursuant to Section 24 of the Electricity and Gas Inspection Act, in the contractor's favor.

"appeal"

means the process of re-consideration of the investigation findings by the President

"characteristic"

means any distinct property or attribute of a meter that can be described and measured to determine conformance or nonconformance to specified requirements.

"contractor"

includes any person or body that undertakes any responsibilities required under the legislation with respect to a transaction involving the sale of electricity or gas. Where a contractor's responsibilities are distributed among more than one person or body, the principal party in the contract shall be required to secure and provide all information and assistance required by MC in the administration of the dispute resolution process.

"defect"

means a departure of a characteristic from its intended level or state that occurs with a severity sufficient to cause a meter not to satisfy normal usage requirements.

"full error"

means the aggregate effect on the determination of a charge for a billing quantity of all the individual component errors due to the associated measurement and administrative processes.

"integrity of measurement"

means compliance with prescribed method of sealing of a meter or presence of other safeguards designed to prevent or record modifications to their metrological adjustments, settings or configuration.

"metering installation"

means an installation that consists of more than one meter installed at the same location and that is used for the purpose of obtaining the basis of a charge for electricity or gas supplied to a purchaser.

"MC"

means Measurement Canada.

"non-complying meter"

means a meter failing to satisfy any requirements of the Act, Regulations and Specifications.

"nonconformity"

means a departure of a quality characteristic from its intended level or state that occurs with a severity sufficient to cause a meter not to meet a requirement.

"President"

means the director appointed under subsection 26(1) of the Act.

"rebate"

means a correction to a purchaser's account pursuant to Section 24 of the Electricity and Gas Inspection Act, in the purchaser's favor.

"Regulations"

means the Electricity and Gas Inspection Regulations.

"request date"

means the date the request for investigation as per section 23(1) of the Act is received by MC office by any form of communication.

"tampered meter"

is a meter that is showing signs or is suspected of being intentionally modified.

Part IV: References

Measurement Investigations include an independent evaluation of the use, application and functioning of an electricity or gas meter, which may require references to any documentation issued or officially recognized by Measurement Canada, including but not limited to the documentation, or it's current authorized equivalent as follows:

  • Electricity and Gas Inspection Act and Regulations
  • Specifications for Approval of Type of Electricity Meters, Instrument Transformers and Auxiliary Devices
  • Specifications for Approval of Type of Gas Meters and Auxiliary Devices
  • Any other Measurement Canada Specification.
  • Any Measurement Canada Notices of Approval
  • Any Measurement Canada Bulletins, circulars & memoranda
  • Any official class, type or device specific inspection procedures.

Part V: Responsibilities

Pursuant to s.23, 24 and ss.26(1) to (4) of the Act and s.32 of the Regulations:

  • The President is responsible for the conduct of the appeal process in this document.
  • The Program Development Division is responsible for approval and maintenance of this document and to provide assistance to the President during the appeal process.
  • The Regional Director is responsible for processing of the client feedback, as described in this document.
  • The Regional Electricity and / or Gas Specialist is responsible for providing training and technical assistance to the inspector and to recommend procedural amendments required as a result of the client feedback and other.
  • The District Manager is responsible for implementation of the procedure contained in this document.
  • The Inspector is responsible for carrying out any enquiries, investigations, tests, inspections, analyses, and such other functions required for completion of the procedure described in this document.
  • The Administrative Assistant is responsible for communication with, and provision of information to clients and securing, recording, distributing and filing of pertinent information and documents as required for effective implementation of this procedure.

Part VI: Procedure

1 Receipt of Request

1.1 Selection of Process

1.1.1 Treat all enquiries, involving any degree of concern about the performance or condition of a meter, or the amount of charge, related to a specific service or account, as a potential request for a measurement dispute investigation as per subsection 23(1) of the Act.

1.1.2 Subject to 1.1.2.1, proceed according to the circumstances described:

  1. dissatisfied purchaser (or their representative) may submit a request at:
    1. MC Office - proceed to 1.2, or
    2. via Contractor's Office, proceed to 1.3,
  2. in all cases of contractor requests, proceed to 1.4,
  3. refer all enquiries related to ongoing, or recently completed investigations to the inspector responsible for the case.

1.1.2.1 Special arrangements may be required for requests involving investigations of alleged "theft of energy" or other cases of acting in the role of an expert witness.

1.2 Purchaser Request at MC Office

1.2.1 Assign a Case Number to every new request. Refer to T-1.

1.2.2 Record particulars for inclusion in the District's (Dispute) Case Register:

  1. Case Number assigned above
  2. initiated by (purchaser or contractor)
  3. the date of call,
  4. client's name,
  5. account number,
  6. mailing address
  7. contractor's name
  8. service location - if different
  9. service type - E or G
  10. caller's daytime telephone number; or other means of contact,

1.2.3 Ask purchaser to contact their contractor, if not done so, and instruct them to call back, if contractor is unable to satisfy them.

1.2.3.1 Recommend completion of the Statement of Complaint / Dispute Application supplied by contractor, in cases where suitable arrangement exists as per 1.3.1.

1.2.4 Explain the dispute process.

1.2.5 Attempt to satisfy the client by:

  1. answering any questions in an attempt to resolve their concerns,
  2. discussing common situations leading to unusually high bills.

1.2.6 Issue forms to the purchaser for completion:

  1. applicable Statement of Complaint form (App. A or B), with the assigned Case Number entered,
  2. any additional information for customer.

1.2.6.1 Instruct the customer to return completed forms together with the utility statements (bills) covering the period in dispute, if available.

1.2.6.2 If the purchaser is requesting an investigation, but is unable or unwilling to complete forms, ensure that all applicable information as per the Statement of Complaint is recorded and included in the case file.

1.2.7 Proceed to 2.1.

1.3 Purchaser Request via Contractor's Office

1.3.1 Subject to a suitable arrangement between the MC District Office and the contractor, if all contractor's efforts to resolve purchaser's concerns fail, the contractor may provide the applicable Statement of Complaint (App. A or B), or an approved equivalent form to the purchaser for completion, and submit it to the MC office, together with all applicable information and records as per T-2.

1.3.1.1 If purchaser is not willing to complete forms supplied by the contractor, the contractor shall direct the purchaser to the local MC Office - go back to 1.2.

1.3.2 On receipt of the forms at MC Office, assign a Case Number, and make appropriate entries in the District's Case Register.

1.3.3 The date of receipt of the forms shall be treated as the request date for this investigation, unless an earlier contact with MC regarding the matter is on record.

1.3.4 Proceed to 2.1.

1.4 Request By Contractor

1.4.1 If a contractor requests an investigation:

  1. assign a case number and provide it to the contractor for inclusion on all submitted documentation,
  2. record all information as per 1.2.2.,
  3. instruct the contractor:
    1. to provide all relevant records and information as per T-2,
    2. not to modify any metering equipment at the affected purchaser's service pending MC's evaluation of the need for an installation inspection.

1.4.2 Once received, review submitted documents for completeness, and follow-up any omissions.

1.4.3. Proceed to 2.3.

2 Administrative Review

2.1 Statement of Complaint Received

2.1.1 On receipt of the Statement of Complaint, or an equivalent, ensure that:

  1. the reasons for dissatisfaction are clear, and
  2. the purchaser's witnessing preference is known, and follow-up with client, if necessary.

2.2 Contractor Requested for Information

2.2.1 Contact the contractor and:

  1. notify of initiation of a measurement dispute investigation,
  2. provide the assigned Case Number, for use in any related future communications.
  3. request all applicable records and information as per T-2, and
  4. instruct not to modify any metering equipment at the affected service, until it is determined that an in-situ inspection is not required.

2.3 Documentation Review

2.3.1 Review submitted forms, records and information for completeness.

2.3.2 Ensure relevance of all submissions to the investigation by comparing the account / service information in contractor's records with the information provided by purchaser.

2.3.2.1 Request additional information from either party, if necessary.

2.3.3 Examine all records for existence of administrative or clerical errors, like:

  1. application of a wrong rate structure,
  2. wrong application of a rate structure,
  3. application of a wrong formula,
  4. application of wrong measurement results (wrong reading),
  5. error in the use of a multiplier,
  6. use of estimating methods which results in excessively fluctuating bills.

2.3.3.1 Record particulars of any detected administrative error and note which billing quantities are affected and how.

2.3.4 Attempt to prevent un-necessary investigations through evaluation of the reasons for complaint, while respecting the client's right to request an investigation under ss. 23(1) of the Act.

2.3.4.1 If an administrative error is found, which accounts for client's dissatisfaction, discuss the findings with interested parties and propose a closure of the investigation.

  1. Do not assure either client that no other error exists or is possible, under any circumstance.

  2. Record:

    1. the date and time of the above communication,
    2. all particulars of agreements reached,

    for use in reporting of findings. Proceed to 4.1.2.

2.3.4.2 In cases where the analysis of provided information indicate that the billing is representative of the purchaser's consumption, investigation may be terminated. Proceed to 4.1.2. to issue the Certificate of Measurement Dispute Investigation Findings (app. D).

2.3.5 Secure all available information needed for effective planning of the next stages of the investigation, namely the installation inspection and / or testing of meter(s):

  1. ensure that purchaser's witnessing preference is known at this time,
  2. evaluate all available information to determine the need for the conduct of an installation inspection (refer to T-3) and evaluate the following:
    1. need for interruption of energy supply to purchaser for the purpose of an installation inspection,
    2. level of expertise required to complete all inspections and testing,
    3. type of standards and / or measuring apparatus required,
    4. documentation needs (inspection procedures, device specific manuals),
    5. need for any specialized equipment (software, connectors for test equipment, etc.),
    6. suitable loading needed for effective inspections and testing (peak, typical or seasonal loads or the time of day the disputed condition occurs),
    7. presence of safety hazards and the safety equipment needed,
  3. consider the denial or delay of the "reasonable notice" as per subsection 29(1)(c) of the Regulations to suspected parties and other special arrangements in investigations involving "theft of energy" or other cases of acting in the role of an expert witness.

2.3.6 Make note of any need to verify administrative items during the conduct of inspections and testing.

2.3.7 Consider need for additional audit of contractor's records and practices as required for MC's administration of the Act.

3 Measurement Investigation

3.1 Measurement Investigation Planning

3.1.1 Plan an installation inspection, addressing findings in 2.3.5b) above, in co-operation with the contractor and purchaser, as applicable, to:

  1. agree on a date and time of inspection,
  2. ensure that suitable date and time is arranged for needed load at the service location as determined in 2.3.5b)vi), if applicable,
  3. arrange for interruption of the service, if required, or make arrangement for alternate method of inspection, if interruption of service is not possible,
  4. be able to perform an overall inspection of telemetering systems at the time of the installation inspection,
  5. make contingency plan for cases of finding of stray loads and miss-matched meters in multi-tenant properties, as investigation of other services may be necessary,
  6. communicate MC's expectations of the contractor related to installation inspections - like: provision of connectors, specialized safety equipment, assistance during testing, replacement meter, etc.,
  7. make suitable travel arrangements, while considering inclusion of other required work in the same area.

3.1.2 Schedule meter test, if an installation inspection is not required:

  1. determine suitable location for meter test:

    1. the contractor's premises, or
    2. the District Office, or
    3. other MC facilities, or
    4. any other location where needed test apparatus is available to test the meter type or a function, as determined in consultation with a Regional Specialist, if necessary,

    except where the meter is normally subject to (re-)verification in the operational location.

  2. accommodate purchaser's witness preference as reasonably practical. Set a date and time as per established service standards, if an agreement on mutually convenient date and time of inspection and testing cannot be reached.

3.1.3 Ensure proper handling of meters, by advising the contractor of their responsibility:

  1. to remove meter from service and deliver it to the location specified on the "Notice" not later than one day prior to the agreed on date and time,
  2. to record all meter readings, and the date of meter change and to provide this information to the investigating inspector, prior to the meter test,
  3. to transport and store the meter in a manner that will not affect its in-service condition and performance,
  4. to report any accidental damage or mishandling of the meter to MC at the earliest opportunity,
  5. not to perform any tests or inspections of any meter, which has become a subject of a measurement investigation by MC

3.1.4 Plan to address any special needs as per 2.3.6 and 2.3.7 above.

3.2 Notice Issued

3.2.1 Complete and mail the Notice of Measurement Dispute Investigation (App. C) to both, the contractor and the purchaser in every case.

3.2.1.1 Consider a verbal notification of scheduled inspection and test time and location to all interested parties, in addition to the mailing of the Notice above, to enhance the efficiency of the investigation.

3.2.1.2 Document all particulars of any verbal notification and agreements in the case file.

3.2.1.3 Consider special arrangements for notification, as not to compromise alleged "theft of energy" or other legal investigations.

3.2.2 If an installation inspection is not required, proceed to 3.4.

3.3 Installation Inspection

3.3.1 Record all meter readings together with exact time prior to proceeding with inspection.

3.3.2 Encourage questions by interested parties. Note client's presence during any inspection or testing, in the case file, together with:

  1. any significant items of discussion,
  2. any new information, which may affect the results of the investigation.

3.3.3 Use established procedures and practices for the conduct of the installation inspection.

3.3.3.1 Record all results, findings and observations during all stages of the installation inspection. Note the following information for findings which have adverse effect on the registration, or on the calculation of charge, for use in reporting:

  1. the description of observed condition,
  2. the billing quantity(s) affected,
  3. the magnitude and direction of the resulting error for each billing quantity affected, based on the tests performed at the present load conditions,
  4. whether the error resulting from the detected condition is subject to varying load characteristics at the service, and the probable / theoretical range of the resulting error, if obtainable.

3.3.3.2 Support recorded findings by sketches, diagrams or photographs, as appropriate.

3.3.4 Perform as-found installation inspection of the installation in the state it was used to establish a charge during the period in dispute, with the original meter(s) in place. Document all findings sufficiently before proceeding.

3.3.4.1 Assess the level of fluctuation of the load on electricity services. Attempt to perform all stages of the installation inspection at comparable loads, to be able to use comparative analysis of the results is determining of the installation error.

If a sufficiently steady load of suitable magnitude is not achievable, an alternate method of establishing of the installation error may be considered, like:...

  1. load survey equipment, while ensuring that the accuracy of such equipment is established immediately prior to or following the inspection,
  2. past and/or future consumption records may be analyzed, in view of findings, to provide the basis for an expert / professional opinion about the size of the error and the resulting inequity,
  3. production records may be analyzed to establish probable consumption during a period,
  4. any other available methods, which may provide useful information.

3.3.4.2 Consider unusual loading and ambient conditions and influences, which may affect the registration of consumption at the service for use in selection of meter accuracy test-points and in weighing of their results in the determination of the meter error.

3.3.4.3 Ensure completeness of inspection by sufficiently evaluating all components of complex metering systems.

3.3.5 Instruct the contractor to correct any unacceptable conditions, if required, while leaving the original meter in place.

3.3.6 Repeat installation inspection, prior to the replacement of the meter, to determine any measurement error caused by the corrected condition.

3.3.7 Instruct the contractor to replace meter(s) in cases where one of the following is true:

  1. a resolution to the dispute is not found and / or agreed on with interested parties,
  2. a reasonable doubt in the accuracy of the meter exists,
  3. non-compliance of the meter with the approval or other legislated requirements is found.

3.3.7.1 If a meter is removed:

  1. apply the Quarantine Seal to any meter without an effective IC verification seal, regardless of any exemption from sealing requirement applicable to the meter class,
  2. attach Quarantine Status Tag (App. E) to removed meter.
  3. take meter into MC custody, unless an alternate agreement between MC District Office and the contractor is in place.
  4. agree on suitable time and location for the meter test, as per 3.1.2.

3.3.7.2 If the meter is left in service:

  1. perform a visual inspection of the meter,
  2. affix Quarantine Status Tag (app. E) to meter and enter the release date for 90 days later in the "Installation under Investigation" section,
  3. apply the Quarantine Seal to any meter without an effective IC verification seal, regardless of any exemption from sealing requirement applicable to the meter class.

3.3.8 Perform as-left installation inspection, to prevent unintentional modification of measurement, and to provide further information to be used in determination of installation errors, in all cases where the meter has been replaced.

3.3.9 Perform any additional tasks required as per 2.3.6 & 2.3.7

3.3.10 Date and sign all worksheets, sketches, notes etc. prior to leaving the inspection site.

3.3.11 If no meter test is required, proceed to 4.1.

3.4 Meter Test

3.4.1 Record all meter readings prior to proceeding with inspection

3.4.2 Encourage questions by interested parties. Refer to 3.3.2.

3.4.3 Ensure that any test equipment used to determine accuracy of measurement shall not contribute to the magnitude of recorded test-results:

  1. use test equipment with known accuracy, and with appropriate rating for the specific task;
  2. apply all known correction factors applicable to each test-point, if any,
  3. record the number designation of any standard and / or test apparatus used for all test results.

3.4.4 Perform visual inspection of meter prior to accuracy testing, while addressing any additional needs as per 2.3.6 & 2.3.7.

3.4.4.1 Record legal status of meter based on observations during the visual inspection above, related to:

  1. meter approval status: Approved / Not Approved
  2. meter seal:
    1. regarding presence and effectiveness in ensuring integrity of measurement:
      1. Present and Effective
      2. Present but Not Effective (broken , miss-applied)
      3. Missing
      4. Not Required (if subject to dispensation from sealing)
    2. regarding prescribed seal period, if i)A) above applies:
      1. Valid
      2. Expired
    3. note evidence of tampering, if i)B) or C) above applies.

3.4.5 Perform dynamic testing of the meter according to established procedures and practices, performing the following tests:

  1. all accuracy test-points selected as per T-4.
  2. other functionality tests, which may result in a need for billing adjustment, like:
    1. dial (register) test,
    2. creep test; see T-5 for creep test dispute acceptance criteria,
    3. element association test, and others if necessary.

3.4.5.1 Break any verification seal for the purpose of measurement dispute investigation only if necessary for effective inspection and testing.

3.4.5.2 Record all test results on appropriate worksheets, together with any observations relevant to the validity of test results.

3.4.5.3 For unrepeatable test results, attempt to establish and record the cause and the range of the resulting error, if feasible.

3.4.5.4 Test un-approved meters only where:

  1. it is safe, and technically practical to do so,
  2. the units of measurement used can be converted to units defined in the Act.

3.4.6 Calculate %error in the format of the verification tolerance to which the result is being compared, and evaluate compliance of the meter with such tolerance, for each test-point. For non-verification test-points, apply the tolerance applicable to the nearest verification test-point.

3.4.7 Record the legal status of the meter as related to verification and other requirements of the Act (refer to T-6).

3.4.7.1 Record the reasons and other concerns for meters rated "Rejected", "Non-complying" or "Tampered".

3.4.8 Calculate and record the meter error for each metering quantity tested, to represent its influence on the registration for the billing quantity affected, as follows:

  1. for energy, mass and volume, the meter error equals the arithmetic average of the errors at all test points used;
  2. for demand, the meter error equals the error established for the point of billing demand;
  3. for other metered quantities and functions, the meter error shall be the result of the test representing the prevailing load conditions.

3.4.8.1 For each meter error, record any limitations to the validity of the error, based on observations recorded in 3.4.5.2 above, relevant to the validity of test results.

3.4.8.2 For meters with zero or intermittent registration at any test-points, a professional opinion about the possible range of the resulting meter error may be provided.

3.4.9 Record all nonconformances / defects, which are normally subject to completion of the Meter Nonconformity - Defect Report.

3.5 Meter Quarantined

3.5.1 Quarantine all meters subjected to testing or removed from service during a measurement investigation by taking them into MC custody, or by letting the contractor keep it in secured storage on MC behalf, subject to MC District Manager's direction.

3.5.2 Attach Quarantine Status Tag (App. E) to every quarantined meter and.

3.5.2.1 Make appropriate entries to reflect findings in 3.4.7 above. Refer to T-6.

3.5.3 Seal all meters without an effective IC verification seal with Quarantine Seal, unless stored in secured MC storage.

4 Communication of Findings

4.1 Findings Analyzed

4.1.1 Evaluate all findings recorded during the investigation to ensure that:

  1. all planned steps of the investigation were completed,
  2. the investigation was effective.

4.1.1.1 Consider further investigation if:

  1. the answers to client's concerns are not obtained, and
  2. all practical means of investigation are not exhausted.

4.1.2 Prepare a brief, but complete statement for inclusion on the Certificate of Measurement Dispute Investigation Findings (App. D), describing the extent of the investigation with a general summary of findings, by addressing:

  1. enquiries made,
  2. examination of records,
  3. testing of meter(s) and / or metering installation.

4.1.2.1 For investigations resolved as per 2.3.4.1, this statement shall consist of the reference to the time of communication of the proposal to close the investigation and the details of the agreement reached.

4.1.2.2 For investigations terminated as per 2.3.4.2, state the reason for suspension of the investigation.

4.1.3 Calculate the full error, for each billing quantity used, by combining relevant administrative, installation and meter errors, as recorded in 2.3.3.1, 3.3.3.1 and 3.4.8 respectively, while considering applicable adjustment period for each partial error (refer to T-8c)). Express each full error in the format of the applicable dispute tolerance (refer to T-7).

4.1.4 For every full error in excess of the prescribed limit, determine it's validity based on adverse observations recorded for each component of such error.

4.1.4.1 For every valid full error with negligible or known range, ensure that the following information is provided:

  1. error attributes:

    1. the magnitude of
      1. the error expressed as % of the true (calculated) value of delivered commodity, or in other, mutually agreed on format, expressed to one decimal place, and / or
      2. the correction factor, expressed to three decimal places,
    2. any significant known range of such error.
    3. the direction of the error - whether adjustment or rebate will result,
    4. the adjustment period (Refer to T-8), including note of any adjustment period extending prior to current purchaser's tenancy, if applicable,

    OR

  2. the absolute error ( the exact amount of the resulting inequity), if readily available.

4.1.4.2 For every full error with reduced validity due to adverse observations during testing and inspection, summarize such observations, and consider providing the following information, to enable settlement of the inequity by the affected parties:

  1. error attributes:

    1. the magnitude and direction of the error as per 4.1.4.1a)i) and ii), and / or
    2. the probable / theoretical range of the resulting error, if obtainable, or a clear statement that the possible range of the error is unknown, and / or
    3. your professional opinion about the period affected by the condition found, while clearly indicating that the stated error may not be representative of the billing error during such period, and

  2. any other pertinent information useful to the affected parties, if available,

    OR

  3. your professional opinion about the magnitude of the resulting inequity.

4.1.5 Summarize any findings of contractor's non-compliance with any legal requirements.

4.2 Findings Reported

4.2.1 Complete the Certificate of Measurement Dispute Investigation Findings (App. D):

  1. make needed corrections, if any, to the sections shared with the Notice of Measurement Dispute Investigation,
  2. indicate whether client was actually present or represented,
  3. complete "Meter Observations" section to reflect findings of the investigation,
  4. mark the "Dispute rating":

    1. "Upheld" - in all cases of findings of:

      1. a full error in excess of dispute tolerance, or
      2. a multiplier / billing calculation error, including excessively erratic billing due to inappropriate estimating of consumption,
      3. un-acceptable condition of meter, if it was the subject of the request for the measurement dispute investigation,

      regardless of a need for a billing correction,

    2. "Not Upheld" - in all other cases.

  5. check appropriate space for "Transaction acceptable",
  6. in the "Findings Particulars" section, include:
    1. statement as per 4.1.2,
    2. as applicable:

      1. "The full error, as determined by this investigation, is within the prescribed limits as per section 31 of the Electicity and Gas Inspection Regulations", if true for all billing quantities,

        OR

      2. "The full error(s) for (energy or volume or mass and/or demand - as applicable), as determined by this investigation is(are) in excess of limits prescribed by section 31 of the Electricity and Gas Inspection Regulations", if any full error is in excess,

      3. all applicable information per 4.1.4, if ii)B) above is true,

      4. instruction to the contractor to provide to the MC District Office:

        1. the amount and date of adjustment or rebate,
        2. the details of calculations of the adjustment or rebate and other information required to perform effective and efficient verification, and
        3. the calculated amount of the inequity, if actual billing correction is different, as appropriate,
  7. in appropriate fields, enter the MC District and Regional Office information,
  8. enter issue date of the certificate,
  9. the investigating inspector signs the purchaser's, contractor's and meter owner's copies of the certificate, as applicable.

4.2.2 Distribute copies of the Certificate by mail as follows, to the:

  1. contractor,
  2. purchaser,
  3. meter owner, if not the same as the contractor, and
  4. include a copy in the case file.

4.2.3 Do not issue an Inspection Certificate, pursuant to section 14 of the Act, except if services external to the requirements of ss. 29(1) of the Regulations were provided during the conduct of the investigation.

4.2.4 Refer all findings of contractor's non-compliance with any legal requirements to the District Manager for consideration of a need for a corrective / enforcement action.

4.3 Quarantine Period Started

4.3.1 Enter "Release Date" on the Quarantine Status Tag of any quarantined meter for release 60 days from the date of mailing of the Certificate of Measurement Dispute Investigation Findings.

4.4 Settlement of Inequity

4.4.1 Do not order or arbitrate a settlement of any inequities.

4.4.2 Provide mediation assistance only if authorized by the District Manager, and all interested parties agree to the process.

4.4.3 Verify the calculation of the adjustment or rebate by the contractor, if requested to do so by either interested party, or if considered necessary due to complexity of findings, etc.

Ensure that the calculations reflect:

  1. the full error(s) provided, or
  2. an acceptable estimation of inequity, if an error is not available, and
  3. an adjustment period(s) established, or agreed on, by MC.

4.5 Findings Contested

4.5.1 If a dissatisfaction with findings is expressed by any recipient of the Certificate of Measurement Dispute Investigation Findings within 30 days from the receipt of the certificate:

  1. extend the Release Date on the Quarantined Status Tag on any previously tested quarantined meter by 60 days,
  2. explain the appeal process and offer to perform the following in an attempt to satisfy the client:
    1. verify calculation of rebate or adjustment, if not done so previously,
    2. test quarantined meters, which were not tested during the investigation, including any meters left in service as per 3.3.7.2,
    3. repeat applicable steps in 4.1, above, to reflect any new findings and information provided by the objecting client,
    4. communicate any new conclusions to interested parties,

4.5.1.1 Record particulars of the above actions and their results in the case file.

4.5.1.2 Re-issue the Certificate of Measurement Dispute Investigation Findings, to reflect increased scope of the investigation and any new findings.

4.5.1.3 Secure and document a withdrawal / cancellation of any written notice of dissatisfaction with findings, if such dissatisfaction was resolved by actions in 4.5.1 above, and if the client does not wish to proceed with a formal appeal process.

4.5.2 If no satisfactory resolution to concerns of the dissatisfied party is achieved by the actions above, proceed to 5, otherwise proceed to 6.

5 The Appeal Process

5.1 Offer of Reconsideration by the President

5.1.1 Offer to refer matter to the President for reconsideration.

5.1.2 Instruct the client to document the reasons for the dissatisfaction in writing (if not done so in 4.5.1 above), and to submit it to the District Office within 30 days.

5.1.3 If no written statement is received within the 30 day period above, proceed to 6.

5.2 District Manager's Report

5.2.1 On receipt of the written statement, as requested above, the District Manager shall prepare a report on the investigation and forward it to the President, together with a complete copy of the case file

5.2.1.1 Check the contents of the case file against the list in T-9 and secure any missing information for inclusion in the report..

5.3 Meter Quarantine Extended

5.3.1 Extend the quarantine period for any meter(s) or other contractor's equipment, quarantined due to the measurement dispute investigation, until after the release of the President's decision.

5.3.1.1 Mark "Appeal Initiated" and cross out the Release Date on the Quarantined Status Tag on any quarantined meter.

5.4 Notice Issued by the President

5.4.1 The President shall issue a notice addressed to all recipients of the Certificate of Measurement Dispute Investigation Findings, containing:

  1. the acknowledgment of request to refer the matter to the President for reconsideration;
  2. the reasons for dissatisfaction; a copy of the original written request as per 5.1.2 may be attached and referred to,
  3. an invitation of further submissions in writing, relating to the matter and to be received by the President within 30 days after the date of the notice.

5.5 Review by a Program Officer

5.5.1 Following the 30 day period for submission of additional information, as per 5.4 above, the President forwards all related documentation to the Program Development Division to be assigned to a Program Officer for review of the measurement dispute investigation.

5.5.2 The Program Officer shall review the district report, inspection findings, and any additional information received from interested parties to determine if the measurement dispute investigation was performed in accordance with the requirements of this document.

5.5.3 The Program Officer may request additional information or test results from the District Office to complete the review.

5.5.4 At the completion of the review, the Program Officer shall prepare a preliminary report containing the results of the review and recommended actions.

5.5.5 The Program Officer shall forward the above report to the responsible District Office, to allow the investigating inspector to comment, prior to finalizing it and submitting it to the President.

5.6 The President's Decision

5.6.1 Once the recommendations of the Program Officer's review have been received, reviewed and approved, the President shall issue the decision to all persons identified in the initial notice.

5.6.1.1 The MC District office responsible for the investigation is notified of the release of the President's decision.

5.6.1.2 The President's decision is final and conclusive.

6 Closure of Investigation

6.1 Release of Quarantined Meters

6.1.1 Return all quarantined meters, subject to 6.1.2 and 6.1.3 below, to the contractor / owner, on or after the last Release Date marked on the meter's Quarantine Status Tag (app. E) or after the President's decision is issued.

6.1.1.1 Remove all verification seals from all meters which are not marked "Accepted".

6.1.1.2 Remove any quarantine seals.

6.1.1.3 Leave the Quarantine Status Tag attached to the meter being released.

6.1.2 Dispose of all meters marked "Non-complying" in accordance with the District Manager's direction.

6.1.3 Consult with interested parties before release of meters marked "Tampered" as not to compromise other legal investigations.

6.1.4 Complete the Quarantine Release Form (app. F) for each meter released from MC custody and include it in the case file, unless other district procedure for release of such items is used.

6.2 Closure of Case File

6.2.1 Ensure that all pertinent items related to the investigation are contained in the case file:

  1. all contractor's records and information received by the district office.
  2. all correspondence with clients, including forms and certificates, received and sent,
  3. all inspection, test and analyses work sheets, forms and other notes made during the investigation, dated and signed,
  4. all worksheets related to calculation and verification of billing adjustment, and
  5. a copy of any client's feedback and the Regional Director's reply, as per 6.4.4.

6.3 Follow-up to Non-compliance

6.3.1 Ensure any corrective / enforcement action, addressing findings of contractor's non-compliance with any legal requirements, reported in 4.2.4, is implemented and effective.

6.4 Addressing Client Feedback

6.4.1 The MC Regional Director shall ensure that all comments from recipients of the Certificate of Measurement Dispute Investigation Findings, received at the Regional Office, are appropriately addressed.

6.4.1.1 Refer all client's concerns involving a dissatisfaction with findings of the investigation to the investigating inspector to proceed as per 4.5 above.

6.4.2 The Manager of the District Office involved and / or a Regional Specialist, as appropriate, shall

  1. evaluate the client's comments for:
    1. a need for immediate communication with the client,
    2. a need for a corrective action regarding the implementation of the procedures contained in this document,
    3. a need to modify the procedure in this document,
    4. a need to modify service standards applicable to measurement dispute investigations, and
  2. recommend corrective actions:
    1. to the Regional Director, if relating to the implementation of the procedure in this document, or
    2. to the appropriate Standing Committee if relating to a need for procedural amendments, as required.

6.4.3 Acknowledge all client feedback by a letter issued by the Regional Director, containing a brief summary of any implemented or proposed corrective action, if applicable.

6.4.4 Forward a copy of client's communication and the Regional Director's letter to the appropriate District Office for inclusion in the case file.

Part VII: Technical References

T-1 Case Number Format

The following format is to be used in assigning Case Numbers to any measurement dispute investigation in Canada:11A223333

Where:

  • 11 = the STARS identification number for the MC District (Strategic Tracking and Reporting System)
  • A = E or G to represent Electricity or Gas service
  • 22 = the last two digits of the calendar year
  • 3333 = Sequence Number

T-2 Contractor's Records & Information Required for Investigation

Pursuant to section 29(1)(b) of the Regulations, when requested by the MC District Office, the contractor shall provide records containing all applicable information, as follows:

  1. Reason for Request:

    1. contractor's interpretation of purchaser's dissatisfaction,
    2. description of measurement / billing error in excess of legal limit, detected by contractor's representative,
    3. description of detected or suspected legal infraction.

  2. Summary of Contractor's Efforts to Resolve the above:

    Document customer service efforts as applicable, like:

    1. summary of communication with the customer:
    2. list of information provided to the customer;
    3. results of examination of the customer's billing records,
    4. list of recent service calls at the service involved:
      • date of service call
      • reason for the service call
      • tests and other tasks performed and their results,
    5. results of a load survey and analysis,
    6. results of comparison with check meter,
    7. results of any metering installation examination,
    8. description of any implemented or scheduled corrective actions,
    9. any other actions in attempt to resolve concerns,
    10. any other information relevant to the matter,
    11. name(s) of contractor's representative(s) involved in the tasks above.

  3. Contractor Information:

    1. name and address of contractor,
    2. registration number
    3. name and telephone number of representative assigned to this investigation,

  4. Dispute service charges: State what service charges will be applied to customer's account as a result of this investigation, and under what circumstances.

  5. Meter Data (for each meter and auxiliary device)

    1. approval number
    2. inspection number (assigned by contractor)
    3. manufacturer,
    4. manufacturer's serial number,
    5. manufacturer's type designation,
    6. meter configuration,
    7. meter's operational parameters,
    8. software / firmware version,
    9. internal and external multiplier(s),
    10. date of last (re-)verification,
    11. initial verification year,
    12. compliance lot number,
    13. last Field Note or Inspection Certificate number,
    14. seal year and expiry date,
    15. seal origin (MC or AMV),
    16. latest Inspection Certificate (upon request),
    17. maintenance and calibration records,

  6. Installation Data

    1. installation number
    2. location
    3. initial and last verification date
    4. maintenance and calibration records
    5. printout of available event logs (on request)
    6. installation specific multipliers
    7. operational parameters / factors, i.e.:
      • atmospheric pressure (PFM measurement)
      • pressure factor (PFM)
      • gas quality information for gas source (Fpv calculation method)
      • service voltage and current capacity,
      • supply pressure (whether and how regulated)

  7. Billing Data (for a period of 2 years, or longer if instructed by MC)

    1. customer's name,
    2. account number,
    3. address (both mailing and service addresses if different),
    4. applicable rate schedule(s),
    5. install date and meter readings for each meter,
    6. explanation of all billing algorithms used to calculate charge,
    7. billing factors,
    8. meter readings and billing amounts in units and dollars for each billing period,
    9. particulars of any recent (manual) billing adjustments,
    10. explanation of any codes used in billing documentation
    11. flat charges
    12. other charges (with explanation of charge)

  8. Other pertinent information needed for the investigation, as requested by the District Office.

T-3 Considerations for Conduct of Installation Inspection

  1. Consider conduct of an installation inspection, in all cases, where:
    1. measurement accuracy at the disputed service is dependent on the method of installation, special piping, wiring or other requirements for use,
    2. more than one metering device is present, like:
      1. metering transformers,
      2. pulse devices, totalizing, complex telemetering systems,
      3. high pressure gas metering (including PFM),
    3. documentation review results in a need to verify information in service location,
    4. self-contained electricity complex meters with internal defects (like blown potential coils) will register with errors of various magnitude dependent on connected load,
    5. self-contained electricity meters on 4 wire delta services, where service phasing is critical to correct measurement,
    6. multi-unit properties exhibit occurrence of stray loads or miss-assignment of meters to tenant apartments.
    7. it is necessary for the administration of the Act.
  2. Findings of stray loads and miss-assigned meters in multi-unit properties may require consideration of a need for measurement investigation of other affected services.
  3. The installation inspection shall be performed with the original meter(s) in place, except for exceptional circumstances, where an immediate installation inspection is not feasible due to remote locations, seasonal loads or other exceptional situations. Under such circumstances, the installation inspection may be delayed, for the maximum of one year. The investigation may be completed and documented with a note of pending installation inspection.

T-4 Accuracy Test-Points

The accuracy test-points for use in measurement dispute investigations shall include: .

  1. verification test points prescribed for each measurement quantity, other than a demand function, of the meter being evaluated, unless:
    1. it is known that they fall outside the normal / prevailing load conditions at the disputed service, or
    2. their inclusion would be detrimental to the calculation of the full error, or
    3. the measurement function is not used to determine a charge under the billing rate structure applicable to the disputed service.
  2. additional test points, which are determined as follows, subject to conditions in a) above, for:
    1. Electricity Energy Meters: 70% and 35% of "full load series" tests
    2. Gas Diaphragm Meters: 25% of rated capacity
    3. Gas Rotary and Turbine Meters 50% and 10% of rated capacity
  3. test points representative of typical / prevailing load conditions on disputed service.
  4. demand is to be tested only at the metering point(s) which have resulted in the billing demand, as determined from the billing records. The demand tests are to use the scale / display which is used for billing purposes.
  5. any other necessary test-points:
    1. for establishment of the accuracy of the meter, or
    2. for use in the administration of the Act, as directed by the District Manager or by a Regional Specialist.

T-5 Creep Test

For measurement dispute investigation purposes, a meter is considered to creep, if with voltage only applied to it:

  1. the disc completes one full revolution in less than 10 minutes, or
  2. the meter registers more than 10 Wh in less than 10 minutes, for meters without a rotating disc.

For inequity calculation, any creep is deemed to exist for 12 hours a day during the adjustment period, unless an information to determine a more appropriate assessment is available.

For determination of adjustment period, use the same criteria as for calibration errors.

T-6 Legal Status of Meter

The following are designations to be used on the Quarantine Meter Tag. Check all applicable categories:

  1. "Accepted" - meters for which the investigation found no non-compliance with any verification criteria, and with valid and effective verification seal in place,
  2. "Rejected" - meters which
    1. were found with calibration errors in excess of verification tolerance, or
    2. had their verification seal broken by the inspector during the investigation.
  3. "Non-complying" - any meters which were found in service
    1. un-approved,
    2. not verified or reverified as required,
    3. not sealed as required,
    4. not installed or used as approved, or
    5. in non-compliance with any other requirement of the Act,
  4. "Tampered" - meters which are found or suspected of being tampered with, and those which may be used as evidence in "theft of power" or other legal investigations.

T-7 Dispute Tolerances

Pursuant to section 31 of the Regulations, the limits of error for the purpose of section 24 of the Act are as follows, for:

  1. Energy / Volume / Mass: The maximum permissible error is +/-3.0% of the electricity or gas registered by the meter.
  2. Demand: The maximum permissible error is +/-2.5% of the maximum point of the meter's demand scale, or of the maximum rated demand of the meter.
  3. Multipliers: No error due to meter multipliers or billing factors is allowed.

T-8 Adjustment Period

  1. Pursuant to section 24 of the Act, in determining the period for which a billing error is considered to have existed, the following shall apply:

    1. the period of 3 months prior to the request date, or
    2. from the date the meter was last installed or verified, whichever is later, if less than 3 months, or
    3. from the date the meter's seal period expired, if more than 3 months,
    4. from the date of incorrect connection or incorrect use of the meter,
    5. during a period that an incorrect multiplier was used,
    6. from the date on which an incorrect meter was installed,
    7. from the date a metering fault occurred,
    8. for a period as determined through review of billing history, if conclusive.

  2. The E&G Inspection Act does not provide a limitation for the retroactivity of the adjustment period determined above and MC shall report the full adjustment period as determined.

    It is the contractor's responsibility to apply any limitations flowing from a provincial or other statute.

  3. Where more than one error requiring billing correction exists, the applicable adjustment period is determined for each. Such periods shall then be combined and a full error for each unique part of such period shall be determined.

T-9 Information Required for Reconsideration by the President

The District Manager shall ensure that all applicable information below is contained in his report required by section 5.2 of the Procedure or in the attached Case File:

  1. General Information

    1. date of the report;
    2. case number assigned to the investigation;
    3. name of the person(s) who prepared the report;
    4. name of the city and province of the district;

  2. Contractor Information

    1. name,
    2. registration number
    3. address,
    4. telephone number;

  3. Replacement Meter and Auxiliary Device Information

    1. manufacturer,
    2. type designation,
    3. serial number,
    4. inspection number,
    5. approval numbers,
    6. seal year,
    7. install reading(s),

  4. Investigation Information

    1. date of initial complaint,
    2. date on which the Statement of Complaint was received,
    3. contractor or purchaser's reasons for requesting the measurement dispute investigation,
    4. date on which the Notice of Measurement Dispute Investigation was sent,
    5. date on which the metering installation was inspected,
    6. as found and as left meter readings taken during the installation inspection,
    7. date on which the meter was inspected,
    8. address or location at which the meter was inspected,
    9. identification number of any standards and measuring apparatus used
    10. date of certification of standards and measurement apparatus,
    11. meter reading taken prior to its removal from the installation,
    12. meter reading taken prior to testing,
    13. name(s) of the person(s) who were present during the meter and installation inspections,
    14. identification number of any inspection certificate(s) issued following the inspection
    15. date on which the Certificate of Measurement Dispute Investigation Findings was released
    16. date on which the dissatisfaction with findings was expressed,
    17. date on which the written request for appeal was received by the District Office,
    18. contractor or purchaser's reasons for requesting appeal,

  5. Meter Performance Information

    1. evaluation of the meter's seal, inscriptions, and physical components prior to testing;
    2. accuracy and register test results;
    3. overall evaluation of meter and disposition of the meter seal;

  6. Billing Calculation

    1. equation used to convert meter readings to dollars showing all multipliers and rates;
    2. accuracy of the equation;
    3. overall evaluation of billing calculation;

  7. Load Summary

    analysis of the purchaser's load describing present loads and new equipment additions;

  8. Problem Description, Summary of Actions, Communications and Conclusions

    1. description of the actual or probable causes of the problem, if any;
    2. summary of the actions taken by the contractor to resolve the problem;
    3. summary of communication between district office and purchaser;
    4. conclusions.

  9. Documents

    the complete case file, including pertinent documents, like:

    1. Statement of Complaint,
    2. Load Survey Questionnaire,
    3. inspection certificates
    4. inspection and test work sheets,
    5. billing records,
    6. billing rate schedule(s),
    7. Certificate of Measurement Dispute Investigation Findings,
    8. written request for appeal
    9. copies of any correspondence with clients relating to the investigation, in chronological order.