Requirements for Major Power Consumers Results of Pilot Project

Requirements for Major Power Consumers Results of Pilot Project (PDF, 32 KB, 3 pages)

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2004-06-23

Background

In 2000 Measurement Canada initiated a review of the Electricity Measurement Trade Sector. The Trade Sector Review, which consisted of comprehensive consultation with a broad cross-section of electricity measurement stakeholders, resulted in 16 recommendations. One of the recommendations proposed that meters which are used in installations where the demand exceeds three megawatts, (3 MW), be exempted from certain specified requirements.

Measurement Canada and the Canadian Electricity Association (CEA) formed a joint working group in order to determine the most appropriate mechanism to implement the recommendation. The working group met via conference several times to set goals, identify impediments to the process, establish parameters, and clarify all misinterpretations or outstanding issues.

A pilot project involving a number of participants was initiated in order to review and test the implementation of the proposed process.

Process

Measurement Canada established Bulletin E-25 which granted a temporary permission for putting a meter into service without verification and sealing. This permission initiated a pilot project which would allow electricity distributors and major power consumers (MPC) to make modifications to certain meter functions without requiring mandatory re-verification and re-sealing of the meter. The scope of the permission was limited to three electricity distributors and four major power consumers whose aggregate minimum demand usage meets or exceeds 3 000 KW, or 3 300 KVA. The temporary dispensation was authorized for a period of six (6) months. The bulletin also established clear criteria and parameters that the participants were required to follow while conducting activities pertaining to the pilot project.

Over the duration of the pilot project, the participants had planned to perform modifications to various functions or parameters of the identified meters, at the in-service location, which would necessitate breaking of the meter seal. The process, procedures and results of each modification exercise were to be documented by the electricity distributors. The electricity distributors were expected to communicate all aspects of the pilot project to the MPC participants. This included an explanation of the scope and purpose of the project, provision of the information contained in Bulletin E-25 and an explanation of it's requirements, identification of the types of modifications to be performed and the methodology for making those modifications.

In order to evaluate the results of the pilot project Measurement Canada established key factors which must be met in order for the project to be considered a success. The "Success Criteria" document was developed in consultation with the joint working group. Evaluation was performed by analysis of data obtained during the modification activities, and by determination of answers to seven (7) identified fundamental questions. Decision criteria were established to be applied to the results of the evaluation in order to conclude on the success of the project, and to assist in the development of final recommendations.

Following completion of the pilot project, all related data was provided to Measurement Canada and the joint working group members for discussion and clarifications where necessary. Measurement Canada performed interviews with representatives from each of the pilot project participants. The goal of the interviews was to obtain answers to the fundamental questions, and to determine how participants felt about the success of the process itself.

Conclusions

Every little quantitative test data was obtained through activities conducted pursuant to the pilot project. The data that was obtained did tend to support the philosophy that modifications could be made to certain identified meter functions while resulting in no unintentional or adverse affect on other functions. However there was not enough data obtained to categorically claim that this would be true in all, or any other cases. The quantitative data complied with the requirements of Bulletin E-25.

No contracts were established, therefore none were reviewed by the joint working group or by Measurement Canada.

The interviews were very successful in providing answers to the fundamental questions as well as providing additional information for Measurement Canada to consider in determining if this initiative is to be fully implemented.

While the pilot project did not result in as much data to evaluate as was originally anticipated, the overall results were quite valuable and greatly assisted in the formation of recommendations and proposals in this report. With respect to our ability to determine conclusions and make recommendations, we consider the pilot project a success.

The results of the pilot project clearly demonstrated that where a dispensation from legislated requirements is authorized under specified conditions, Measurement Canada must be involved to ascertain whether those conditions are being met. Measurement Canada should only consider authorizing such a dispensation in cases where it is clear that all specified requirements have been complied with.

The purchasers are generally comfortable with the process in place, however in some cases this level of comfort was due to longstanding relationships between the parties, and more caution would be warranted between parties where no such relationship exists.

In all cases the purchasing parties stated that there is a need for some established process, standards and minimum test criteria. The purchasers also want to be present when such modifications occur. There needs to be a clear indication of the responsibilities of each party with regards to access and modification of the meters. There must be assurances that all participating parties are aware of all aspects of the dispensation.

Where a dispensation from established legal requirements is to be considered based on certain specified conditions, there must be some mechanism to ensure that all the parties are aware of, and agree to those conditions. In addition there must be some legal mechanism to establish any additional conditions as deemed necessary by the involved parties.

It was suggested by one electricity distributor that modifications permitted under the dispensation should be restricted to parameters which have no impact on billing. This suggestion would not be feasible in most cases since the verification seal must be broken to access those parameters. It is not possible to allow a seal to be broken, yet still be assured that the meter meets MC verification requirements since the seal is the only means of integrity.

These points strongly support and justify the need for a contract and terms of reference to be clearly established and understood by the participating parties. The contract would be the best mechanism for participating parties to make clear between themselves what can or cannot be modified. The establishment of contract is only one of a number of conditions which are necessary for Measurement Canada to grant a dispensation from verification and sealing. Clearly Measurement Canada needs to be involved to the extent of ascertaining whether those conditions are satisfied initially as well as through the duration of the agreement between the parties involved in such transactions.

Recommendations

Based on the results and conclusions reached upon completion of the pilot project, the ETSR Implementation Leaders were able to prepare a viable and appropriate proposal for the mechanism to implement ETSR recommendation # 3.

The proposal recommends using a similar mechanism as was used in the pilot project. Measurement Canada may grant a temporary permission for the placing into service without verification and/or sealing of any class, type of design of meter under terms and conditions as stipulated by the Director. The Director is authorized to grant this permission under subsection 9(2) of the Act. This permission would not exempt meters from Measurement Canada approval requirements. A meter must still be approved, pursuant to all Measurement Canada approval requirements, for use with each activated metrological function.

Implementation will be achieved in the following manner. Bulletin E-25 has been revised to authorize a similar temporary dispensation, and will establish specific conditions which must be satisfied in order for the dispensation to be granted. Many of the original conditions still apply and additional conditions have been established based on the results of the pilot project. The participating parties will not be specifically identified in the Bulletin, but rather through their submissions to Measurement Canada requesting a permission pursuant to the requirements of the Bulletin. The submission must include all information as required in the Bulletin, as well as objective evidence that the requirements of the Bulletin are complied with.

Measurement Canada will evaluate each submission for compliance with the Bulletin's requirements. Consequently Measurement Canada may grant dispensations on a case-by case basis through a letter of authorization, (pursuant to section 9(2) of the Act), from the President (Director).

Mike Abraham
Senior Program Officer, Electricity
Measurement Canada
Tel.: 613-946-3387
Fax: 613 952-1736
E-Mail: Michael.abraham@ic.gc.ca