utility advisory council presentations... · clearance requirements would meet both the csa 22.3...

Utility Advisory Council

OBC changes

December 12, 2013

Agenda

•Current OBC rules pertaining to above

ground electrical conductors

•New OBC rules

Appropriate Use of ESA Computing Equipment and Services • September 2013 2

Ontario Building Code-current Ont.

Reg 350/06

3.1.19. Above Ground Electrical Conductors

3.1.19.1. Clearance to Buildings

(1) Where a building is to be constructed in proximity to existing above ground

electrical conductors of a voltage not less than 2.5 kV and not more than 46 kV,

(a) the building shall not be located beneath the conductors, and

(b) the horizontal clearance between the building and the maximum conductor swing

shall be not less than 3 m.

(2) Where a building is to be constructed in proximity to existing above ground

electrical conductors of a voltage more than 46 kV, the clearances between the

building and the conductors shall conform to the requirements of CAN/CSA-C22.3

No.1, “Overhead Systems”.

Ontario Building Code

3

Ontario Building Code-current Ont.

Reg 350/06

Current cont’d

3.1.19.2. Exception

(1) Article 3.1.19.1. does not apply to buildings containing electrical

equipment and electrical installations used exclusively in the generation,

transformation or transmission of electrical power or energy intended for

sale or distribution to the public.

Ontario Building Code

4

Ontario Building Code-Ont. Reg. 332/12

•ESA submitted a code proposal to the OBC in which clearance requirements would meet both the CSA 22.3 No. 1 Overhead Systems and the OESC

•Existing 3.1.19 revised under Ont. Reg. 332/12

•Ont. Reg. 332/12 filed Nov 2, 2012

•Current Ont. Reg. 350/06 will be revoked as of January 1, 2014

•Horizontal clearance to be measured from any part of a building including balconies, fire escapes, etc.

•Now includes voltages below 750V



3.1.19. Above Ground Electrical Conductors

3.1.19.1. Clearance to Buildings

(1) A building shall not be located beneath existing above ground electrical conductors.

(2) The horizontal clearance measured from the maximum conductor swing to the building, including balconies, fire

escapes, flat roofs or other accessible projections beyond the face of the building, shall,

(a) be not less than 1 m, for electrical conductors carrying voltages 750 V or less, except where necessary to

connect to the electrical wiring of the building,

(b) be not less than 3 m, for electrical conductors carrying voltages greater than 750 V but not exceeding 46 kV,

(c) be not less than 3.7 m, for electrical conductors carrying voltages greater than 46 kV but not exceeding 69kV, or

(d) conform to the requirements of CAN/CSA-C22.3 No.1, “Overhead Systems”, for electrical conductors carrying voltages

greater than 69kV.



(3) Where the swing of an above ground electrical conductor not owned or operated

by an electrical supply authority is not known, a swing of not less than 1.8 m shall be

used.

(4) Sentences (1) to (3) do not apply to a building containing electrical equipment and

electrical installations used exclusively in the generation, transformation or transmission of

electrical power or energy intended for sale or distribution to the public.



•Existing OBC contained no rules regarding clearance from exterior signs to above ground conductors

•New OBC now references exterior signs to meet the same clearance as buildings

•Signs not included:

• Traffic signs

• Signs in display windows or other signs not affixed to the

building’s interior

• Signs painted directly on a building

• Incidental signs or other signs subject to municipal approval



3.15.5.2. Clearance for Exterior Signs

(4) A sign shall not be located in proximity to existing above ground electrical conductors, unless the sign meets the clearance requirements of Subsection 3.1.19.


Electrical Distribution Safety

Review of Audit

Results for 2012

December 12, 2013


Summary of

Audit Findings for 2012

• 34 LDCs - Full Compliance (76 Total Audits)

• 36 LDCs - Needs Improvement only

• 21 LDCs with only one Needs Improvement

• 5 LDCs had 1 Non-compliance

• 1 LDC had more than 1 Non-compliance


Summary of

Audit Findings Life to Date

0 1

12

14

24

27 26

34

8.4

5.3

3.3 2.6 2.0 1.5 1.3 1.0 0

5

10

15

20

25

30

35

40

2005 2006 2007 2008 2009 2010 2011 2012

Total LDCs no Findings

Avg # per LDC


Common audit findings

Section 6 – Equipment Approvals • Process for approving equipment returned

from field or refurbished • No process documented for approving equipment for re-

use from field or refurbished/repaired. • Some equipment is returned to inventory without

approval/ approval records not documented • The documented procedures/policies should be updated

to reflect current practice • There is discussions underway regarding the Cam Tran

C2C Program and similar programs.

• Approved equipment list • Unapproved equipment used • Not maintained / updated • Controls to ensure that only approved equipment is

purchased • Legacy equipment in inventory not on approved list.



Section 7 – Design

• Designs without certificates of approval

• Plan changes not approved /approval not recorded

• Designs not reviewed / approved for re-closer protection settings or no Certificate of Approval



Section 8 – Construction Inspection and sign-off

• Maintenance schedules (section 4) – Documentation incomplete;

– Lack of verification that entire system is reviewed on 3 or 6 year cycles.

– No schedule for some equipment/ records unavailable

• Incomplete/missing Records of Inspection and/or Certificate

• Not all work being signed off – meter replacements; small repairs; Trouble calls

• Work energized in stages – Need Record of Inspection & Certificate at each stage of

energization

• Missing Third Party attachment ROI/Certificates

• Not following approved CVP / CVP not updated to reflect new processes

Other Issues

Relevance of S250 in regards to the “reasonable information” clause on locates?

S250 is the CSA Standard for “Mapping of underground utility infrastructure”. The standard addresses “Reliability and Accuracy of Mapping Records” and other topics. ESA will continue to use its judgment of reasonable information and will not necessarily use S250 as the definition for reasonable information.

ADMINISTRATIVE MONETARY PENALTIES

PROPOSAL

Utility Advisory Council Meeting

December 12, 2013

Purpose

▪ To provide an overview of the Ministry of Consumer Services’ proposal for

an Administrative Monetary Penalties (AMPs) framework for consumer

protection and public safety statutes

13/12/2013 2

Context for Action

▪ An AMP is a financial penalty that may be issued against a business or other party operating in a regulated sector for failure to comply with the law

▪ The government is consulting on extending AMPs to some of the statutes administered by the Ministry and it’s administrative authorities to enhance consumer protection and public safety

▪ AMPs are in wide use across Canada. For example, AMPs are provided

for in:

Ontario’s Payday Loans Act and the Environmental Protection Act;

BC’s Business Practices and Consumer Protection Act allows for AMPs; and

The Canada Consumer Product Safety Act

▪ The purpose of an AMP is to reduce the risk of harm and level the field for

businesses that operate fairly and in accordance with the law

13/12/2013 l 3

Context for Action

An AMP is an intermediate penalty, with more force than a warning and

less serious than prosecution or suspension of a licence or registration

An AMP may be applied when there is clear evidence that a business or

individual is not complying with the law

13/12/2013 4

AMPs proposal

13/12/2013 5

1. Regulator’s responsibility

Each regulator choosing to implement an AMP would first be required to develop a policy prior to being granted the

legal authority to issue AMPs. Any decision by a regulator to use AMPs would be based on consultation with its sector.

4. Publication

Regulators would be required to publish information

about issuing AMPs.

2. Penalties

Regulators would have discretion in their policy to

determine monetary amounts for violations within three

established levels.

3. Review process

To ensure fairness, an AMP could be reviewed under

certain circumstances. Proposed legislation would

provide rules about when a review might take place and

who would hear and decide the review.

5. Proceeds only to be used for education,

consumer awareness or public safety initiatives.

Seek input on two options:

a. AAs flow proceeds directly to a fund established in

legislation. Proceeds would be accessed via grants.

b. AAs retain and earmark their proceeds.

1. Responsibility for the AMP framework

▪ Regulators would be responsible for:

Developing their own specific AMP policies that meet criteria that would be

established in legislation

Specifying which situations might be subject to an AMP and how AMPs would

be applied

▪ Proposed AMP implementation process:

Regulator develops an AMPs policy in consultation with its sector

Minister recognizes policies to give them the force of law

▪ The ministry would provide training materials and support to regulators

▪ AMP policies would be required to be available to the public

▪ Regulators to measure and report on the use and effectiveness of AMPs

13/12/2013 6

2. Penalties ▪ Regulators would have discretion to determine exact amount of AMP

penalty within levels set out in legislation. Current proposal:

▪ Level 1: $100 - $2,500

▪ Level 2: $1,000 - $5,000

▪ Level 3: $2,500 - $10,000

▪ Legislation would include criteria to consider when determining the penalty amount

▪ As proposed, criteria for choosing the appropriate penalty amount would include:

▪ Nature and severity of the violation

▪ Compliance history (first-time, ongoing or repeat contraventions)

▪ Scale of business

▪ Whether the violation was intentional or through negligence or recklessness

▪ Economic gain

▪ Evidence that the regulated party was actively working to achieve compliance

13/12/2013 7

3. Review Process

▪ As proposed, the use of an AMP could be reviewed to ensure fairness

▪ Legislation would set out when a review might take place, who would hear

and decide the review and the power of the reviewer.

▪ Review would generally be available to the person subject to the AMP on

limited grounds (e.g., level of penalty miscalculated or AMP was issued to

the wrong person)

▪ Review could confirm, deny or vary the original AMP

13/12/2013 8

4. Publication

▪ As proposed, regulators would be required to publish information about

issuing significant AMPs

▪ This would:

Inform the public about the risks of doing business with the parties involved

Create disincentives for non-compliance beyond the direct cost of an AMP

13/12/2013 9

5. Proceeds to enhance consumer

protection and public safety

▪ As proposed, AMP proceeds would be used exclusively for education, consumer awareness or public safety initiatives.

▪ The ministry is seeking input on two proposed options:

1. Pooled AMP fund

▪ AAs flow AMP proceeds to a fund established by legislation

▪ The fund would be administered by an arm’s-length board, with representation from the administrative authorities and the ministry

▪ The board would decide how to allocate the proceeds by reviewing grant applications from AAs and others; funding initiatives would strengthen the overall regulatory framework across sectors and benefit consumers

▪ The board would publish an annual report that would include financial statements

2. AAs retain AMP funds

▪ Funds to be earmarked for education, consumer awareness or public safety initiatives

▪ Retention is consistent with AA self-funding model

▪ The ministry would use oversight, performance and accountability arrangements in existing administrative agreements to ensure that proceeds are earmarked as required

13/12/2013 10

Next Steps

▪ Email comments on paper to Jana Chu at [email protected] with “AMPs

Consultation” in the subject line as soon as possible

▪ Regulatory registry closes on December 12, but your comments would be

considered if you send them by December 20, 2013

▪ Feedback will be analyzed and policy direction will be finalized for government

consideration

13/12/2013 11

1

Administrative Monetary Penalties

Ministry of Consumer Services October 4, 2013

Introduction

The purpose of this paper is to seek input from businesses and the public on how the

use of administrative monetary penalties (AMPs) might be adopted more broadly to

enhance consumer protection and public safety in Ontario.

An AMP is a financial penalty that can be established for a range of regulatory

violations. AMPs are an additional enforcement tool that helps regulators quickly deal

with non-compliance with the law. AMPs are used in several regulated sectors in

Ontario, as well as at the federal level and in other provinces.

This paper provides background information on AMPs, including how they are used in

Ontario and elsewhere. It sets out key considerations around broadening the use of

AMPs in areas overseen by the Ministry of Consumer Services. These areas include

sectors regulated by administrative authorities on behalf of the ministry, such as real

estate and travel sales, as well as a number of sectors the ministry regulates directly.

Each administrative authority would be able to decide whether to implement an AMP

framework.

We encourage you to provide feedback on this proposal by following directions on the regulatory registry at www.ontariocanada.com/registry by December 12, 2013.

Context for action

As an enforcement tool, the purpose of an AMP is to reduce the risk of harm and level

the field for businesses that operate fairly and in accordance with the law. An AMP is a

financial penalty that may be issued against a business or other party operating in a

regulated sector for failure to comply with the law.

An AMP may be applied when there is clear evidence that a business or individual is not

complying with the law (e.g., a business that fails to post a required notice to consumers

on its premises or omits required information from a consumer contract). An AMP can

be positioned as an intermediate penalty situated between a simple warning and

prosecution or suspension of a licence or registration (where available). It also provides

regulators with an added tool when working with licensees, registrants, non-licenced

sectors and others to deal with non-compliance with the law.

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Thus, AMPs complement existing compliance tools along a spectrum of compliance

actions. Prosecutions are at the higher end of the spectrum since prosecution may

result in imprisonment and/or fines. Slightly below prosecutions are administrative

actions such as revoking or suspending a licence in cases where a licence is required in

order to engage in a particular activity. In this case, such a business may be denied the

right to operate or required to significantly alter its service delivery model to comply. As

a result, these tools are generally only used for more serious violations. In addition, both

tools involve relatively expensive and time-consuming court or tribunal proceedings. At

the low end of the spectrum, examples of educational approaches include providing

written information to a business regarding their compliance with the law and sending

materials to a sector on new regulatory or policy requirements.

As the diagram above shows, AMPs represent a useful middle ground. They send a

stronger signal than a warning letter and can be less costly and more efficient than

more severe responses such as prosecution. They widen the range of enforcement

options available to regulators and allow them the flexibility to fine-tune responses to

specific compliance issues. This can better ensure that the regulator’s action is

proportionate to the situation.

Imposing an AMP may reinforce a non-compliant business or person to comply with the

law and motivate them to modify their behaviour facing additional AMPs, or more

3

serious enforcement measures. This provides regulators with a valuable tool which can

accomplish more than simply punish past behaviour.

There is additional value in giving regulators the authority to use AMPs. Those who

administer rules that apply to a particular sector are often in the best position to

understand the consumer protection or public safety impact, and calculate any

economic gain from not complying with the law. This information can be used to help

tailor the AMP amount to the specific circumstances. Consideration must also be given

to setting the AMP at an appropriate level so that an AMP does not simply become “a

cost of doing business” when breaking the rules.

Please see Appendix A for a list of current enforcement tools available to regulators.

The widening use of AMPs

AMPs fit very well in today’s modern approach to regulation. Using AMPs as a tool for regulators to respond quickly and effectively is important to reduce potential harm to the public and level the field for businesses that operate fairly and in accordance with the law.

AMPs increasingly are being used as an option in the regulator’s toolkit. AMPs are

quick, clear and tangible when compared to sanctions such as prosecutions. Typically,

an AMPs framework sets out the circumstances under which a monetary penalty may

be issued, the penalty amount or formula for determining that amount, and provision for

review.

Some examples of the use of AMPs in Ontario:

Under the Payday Loans Act, the Ministry of Consumer Services can issue an

AMP to licensees in a variety of non-compliance situations, such as failing to

provide required dates on a loan agreement, with AMP amounts varying from

$100 to $3,000.

The Ontario Energy Board can apply AMPs of between $5,000 and $20,000 per

day against energy marketers and retailers who violate licence conditions, rules

of conduct and orders.

Ontario’s Ministry of the Environment can issue penalties of up to $100,000 a

day, with the exact amount determined by a formula, for harmful spills from

facilities operated by a range of sectors that it regulates.

The Financial Services Commission of Ontario has recently introduced an AMPs

framework for unfair or deceptive insurance sector acts or practices by insurers,

agents, brokers and adjusters, with maximum penalties of $50,000 for an

individual and $100,000 for other entities.

4

Other provinces and the federal government also use this compliance tool. For

example:

The federal Competition Bureau includes AMPs as one of its tools to deal with

deceptive marketing practices, such as misleading advertising and misleading

claims about ordinary selling prices, with a maximum penalty of $1 million for a

serious, continuing violation.

The Canada Consumer Product Safety Act provides for AMPs for failing to

comply with various provisions of the act, or a Minister’s order under the act,

including those relating to product recalls, up to a $25,000 maximum.

Under British Columbia’s Business Practices and Consumer Protection Act,

which sets out the regulatory regimes for a number of sectors, AMPs can be

imposed for specific non-compliance situations, as well as for violations of

licence conditions, compliance orders and other undertakings, with the maximum

penalty for an individual set at $5,000 and for a corporation at $50,000.

Regulation of many other sectors, including transportation, agriculture, liquor licensing,

tax and securities regulation, includes provision for AMPs.

Extending AMPs in Ontario

The Ontario government is considering extending AMPs to some of the statutes

administered by the Ministry of Consumer Services as well as to statutes administered

by its regulatory administrative authorities. Each regulator choosing to implement an

AMP would first be required to develop a policy prior to being granted the legal authority

to issue AMPs. Any decision by a regulator to use AMPs would be based on

consultation with its sector. Appendix B lists the current acts and relevant regulators.

The administrative authorities and their areas of responsibility are:

The Board of Funeral Services, which oversees members of the funeral service

sector, such as funeral directors.

The Electrical Safety Authority, which enhances electrical safety in Ontario

including administering Part VIII of the Electricity Act and the Ontario Electrical

Safety Code, the licensing of electrical contractors and master electricians, and

the safety of electricity distribution systems and electrical products.

The Ontario Motor Vehicle Industry Council, which oversees motor vehicle sales

by automobile dealers and salespersons.

The Real Estate Council of Ontario, which oversees real estate salespersons and

brokers.

Tarion Warranty Corporation, which administers a new home warranty program,

as well as licensing of builders.

5

The Travel Industry Council of Ontario, which oversees travel retailers and travel

wholesalers.

The Technical Standards and Safety Authority, which oversees the safety of

amusement park rides and similar devices, fuels, pressure devices and boilers,

elevators, and upholstered and stuffed articles, and certifies persons who work

on equipment.

The Vintners Quality Alliance Ontario, which oversees an appellation of origin

system for Ontario-produced wines, as well as winemaking and labelling

standards.

The ministry also has direct regulatory responsibility for collection agencies, payday

lenders and loan brokers, bailiffs, cemeteries, professional athletic competitions and film

theatres.

Key elements of the proposed AMPs framework

The proposed AMPs framework would be set out in legislation. It would also reflect

several underlying key principles. The proposed framework would:

Deter non-compliance and future violations quickly and effectively.

Allow publication of information about the compliance records of businesses to

better inform consumers.

Ensure fairness to those being regulated.

Provide for the use of proceeds for education, consumer awareness and public

safety initiatives.

Details of Proposals

The following sections deal with a number of important proposals for the AMPs

framework.

1. Responsibility for the AMP framework

Regulators would be responsible for developing their own specific AMP policies that

meet criteria that would be established in legislation. Regulators would be responsible

for specifying which situations might be subject to an AMP and how AMPs would be

applied. Regulators could tailor their AMP policies to their specific mandate and

enforcement needs, while balancing enforcement with experience.

Each regulator choosing to implement an AMP would first be required to develop a

policy prior to being granted the legal authority to issue AMPs. Any decision by a

6

Example of how an AMP may be used – Certificate of registration After receiving a complaint, the regulator carried out an inspection and requested the salesperson’s certificate of registration. The law requires a salesperson to produce the certificate of registration at the request of any person. The salesperson failed to produce proof of registration on request of the inspector, claiming that she had forgotten it at home. The inspector verbally advised the salesperson of her duty to produce the certificate of registration. A week later, the same request was made of the salesperson who again indicated it was not available. The regulator issued a written warning about the salesperson’s obligations under the law. If AMPs had been available, the regulator may have been able to issue an AMP to the salesperson sooner, underlining the importance of meeting the requirements of the law.

regulator to use AMPs would be based on consultation with its sector. It is expected that

regulators would initially take a fairly narrow and focused approach to using AMPs. The

ministry would provide training materials and support to regulators. Administrative

authorities would be encouraged to share best practices with one another and work

collaboratively to develop consistent approaches. Once regulator policies were finalized,

proposed legislation would provide a means by which the policies would be recognized

by the government and then have the force of law.

The law would require regulators to make their AMP policies available to the public: for

example, by posting them on their website. In addition, requirements would be

established to measure and report on the use and effectiveness of AMPs. Those

requirements would be established by agreements between the ministry and

administrative authorities. This reporting would help the ministry to monitor and oversee

the regulators’ use of AMPs.

The ministry would also need to develop an AMP policy consistent with the principles

above for the areas that it regulates directly.

2. The monetary level of penalties

It is proposed that the legislation would set out three ranges of AMPs. Regulators would

have discretion to determine monetary amounts for violations within those levels.

Regulators would be given specific criteria, established in legislation, to consider when

determining a penalty amount. The criteria would include the nature and severity of the

violation, history of the business’ non-compliance, scale of the business, whether the

violation was intentional or through negligence or recklessness, and whether there was

an economic gain to the business from its behaviour.

7

Example of how an AMP may be used – Late financial statements

A company holding a registration as a travel agency was habitually late in providing mandatory financial statements to the regulator. In fact, the company had not sold travel services for some time, but wanted to keep its registration active. A notice of proposal to revoke registration was issued, the financial statements were eventually filed, and the notice was withdrawn. The company ultimately allowed the registration to lapse, but in the meantime, the regulator’s efforts to enforce compliance cost it time and money. If it had been possible for the regulator to issue an AMP, the registrant might have provided the statements on time, or might have decided sooner not to maintain the registration.

Conversely, evidence that the regulated party was actively working to achieve

compliance might be a mitigating consideration.

The ministry is proposing three penalty levels, the ranges for each and some indications

of when they might be used (amounts are per infraction):

Level 1 $100-$2,000: for minor non-compliance violations.

Level 2 $1,000-$5,000: for more serious instances of non-compliance creating a risk to

public safety, or financial or other potential harm to consumers, or where there has been

past non-compliance.

Level 3 $2,500-$10,000: for the most serious non-compliance cases resulting in a

significant risk to public safety or financial or other potential harm to consumers,

particularly in combination with ongoing or repeat contraventions and/or economic

benefit from non-compliance.

3. Review Process

To ensure fairness, an AMP could be reviewed under certain circumstances. Proposed

legislation would provide rules about when a review might take place and who would

hear and decide the review.

Depending on the nature of the non-compliance, a review might be permitted only if the

level of penalty was miscalculated or the AMP was issued to the wrong person. Beyond

those limited circumstances, regulatory requirements would include standards of

reasonableness or due diligence. An AMP issued for violating these provisions might be

reviewed on those grounds. For example, if a business or individual was required to

take “all reasonable steps” to avoid or mitigate a situation, then the AMP could be

reviewed and examined to verify whether it was issued for violating that provision. If

8

someone was supposed to exercise due diligence, then the examination would focus on

whether the individual ought to have known that he or she was not in compliance.

The legislation would establish who could conduct a review. The reviewers would be

independent of the enforcement chain: for example, a director of a branch not involved

in enforcement activities might review a case related to a statute administered directly

by the ministry. Legislation would establish the powers of the individual or body hearing

a review, which would include the ability to confirm, cancel or vary the AMP.

4. Publishing compliance information

It is proposed that regulators would be required to publish information about issuing

significant AMPs. An AMP would be “significant” if it fell into penalty level 2 or 3,

discussed in the section on the monetary level of penalties. Regulators would have

discretion to publish level 1 AMPs.

The information would remain public for a set period of time, e.g., two years, and would

appear on the Consumer Beware List if it related to statutes administered by the

Ministry of Consumer Services, or on the appropriate administrative authority’s website

for other statutes.

Publishing the more serious contraventions would provide relevant information to the

public about the risks of doing business with the parties involved. Additionally, publicity

involving more serious violations would create disincentives for non-compliance in

addition to those provided by an AMP. It is also in line with a graduated approach to

enforcement that places more emphasis on higher-risk and more serious violations. As

well, it would avoid drawing attention to relatively minor violations by businesses. The

proposed approach would also recognize that there may be circumstances where it may

be appropriate for the regulator to publish lower level AMPs.

5. Proceeds to enhance consumer protection and public safety

Proceeds from AMPs would be used exclusively for education, consumer awareness or

public safety initiatives (depending on the administrative authority’s area of

responsibility). The ministry is seeking input on two proposed options.

One option would allow the administrative authorities to retain and earmark funds

generated by issuing AMPs. Retaining proceeds is consistent with the administrative

authority self-funding model. The ministry would use oversight, performance and

accountability arrangements in existing administrative agreements to ensure that

proceeds are earmarked as required.

An alternative option would require administrative authorities to flow proceeds to a

pooled fund established by legislation. The fund would be administered by an arm’s-

9

length board whose members would represent the administrative authorities and the

ministry.

The board would decide how to allocate the proceeds received by reviewing grant

applications from administrative authorities and others. The applications could propose

initiatives to improve consumer protection and public safety, and the board of the fund

would decide which proposals to support. Proceeds used for these initiatives would

strengthen the overall regulatory framework across sectors and benefit consumers. This

approach could also alleviate concerns that AMPs might be used simply to generate

revenue for the regulator. The board would publish an annual report that would include

financial statements and dispersal of funds, thus increasing public awareness.

Next steps

The Ministry of Consumer Services welcomes feedback and encourages anyone interested to provide comments on its proposal, which will be posted on the government’s regulatory registry website from October 28 to December 12, 2013.

To submit directly through the Regulatory Registry website, please visit:

www.ontariocanada.com/registry

Submissions may also be sent by email with “AMPs Consultation” in the subject line, to:

[email protected]

or by regular mail to:

Administrative Monetary Penalties Consultation

Consumer Policy and Liaison Branch

Ministry of Consumer Services

777 Bay St, 5th Floor

Toronto, ON M7A 2J3

The Ministry of Consumer Services plans to review and analyze the feedback it receives during the consultative process and then clarify any outstanding concerns in fall 2013 with stakeholders, industry and other interested parties.

10

Privacy Statement

Please note that unless agreed otherwise by the Ministry of Consumer Services, all responses received from organizations in response to this consultation will be considered public information and may be used and disclosed by the ministry to assist the ministry in evaluating and revising the proposal. This may involve disclosing any response received to other interested parties. An individual who provides a response and who indicates an affiliation with an organization will be considered to have submitted the response on behalf of that organization. Responses received from individuals who do not indicate an affiliation with an organization will not be considered public information. Responses from individuals may be used and disclosed by the ministry to assist in evaluating and revising the proposal. Any personal information such as an individual's name and contact details will not be disclosed by the ministry without the individual’s consent unless required by law. If you have any questions about the collection of this information, please contact [email protected].

11

Appendix A: Current Enforcement Tools

A number of tools are currently available to regulators in Ontario. Examples of the more

common compliance tools include:

In some sectors, issuing an order to stop the circulation of advertising or other

public materials believed to be false or misleading, and requiring

retraction/correction.

Where the party being regulated has access to a trust or similar fund, issuing a

“freeze order” that prevents assets from being withdrawn from the fund.

In some sectors, referring matters to a disciplinary committee with the power to

impose fines, or require further professional education.

Applying for a court order directing compliance with a provision of the relevant

act or related regulations.

In those sectors requiring registration or a licence, suspending, revoking, or

refusing to renew a registration/licence, or refusing to register/license an

applicant.

Pursuing a provincial regulatory prosecution where legislation allows.

12

Appendix B: Current Regulators and Acts

Regulator Act

Board of Funeral Services (BOFS)

Funeral, Burial and Cremation Services Act (in conjunction with MCS)

Electrical Safety Authority (ESA)

Electricity Act

Ontario Motor Vehicle Industry Council (OMVIC)

Motor Vehicle Dealers Act

Real Estate Council of Ontario (RECO) Real Estate and Business Brokers Act

Tarion Warranty Corporation (Tarion) Ontario New Home Warranties Plan Act

Travel Industry Council of Ontario (TICO) Travel Industry Act

Technical Standards and Safety Authority (TSSA)

Technical Standards and Safety Act

Vintners Quality Alliance Ontario (VQAO) Vintners Quality Alliance Act

Ministry of Consumer Services - Consumer Protection Branch (CPB)

Consumer Protection Act, Collection Agencies Act, Payday Loans Act, Consumer Reporting Act, Bailiffs Act, Athletics Control Act, Film Classification Act, and Funeral, Burial and Cremation Services Act (in conjunction with BOFS)

One Call to Dig

Overview of Regulatory Proposals

Utility Advisory Council Meeting

Electrical Safety Authority

December 12, 2013

Confidential 2

Purpose

▪ To provide an overview of regulatory proposals that the ministry, in cooperation with

Ontario One Call (ON1Call), has developed under the Ontario Underground

Infrastructure Notification System Act, 2012 (the act).

▪ To obtain feedback on potential impacts of the proposals on infrastructure owners.

Confidential 3

▪ The act was a Private Member’s Bill that came into force on June 19, 2012 and was

assigned to MCS on September 12, 2012.

▪ The act makes ON1Call, a not-for-profit corporation, the single point of contact in

Ontario to request the location of underground infrastructure prior to digging and the

corporation responsible for administering the requirements of the act.

▪ ON1Call had previously been a call centre service provider with voluntary members and

has operated since 1996.

▪ All owners or operators of underground infrastructure are required to join ON1Call. Non-

municipal owners became members before or on June 19, 2013, and municipal owners

will be deemed members as of June 19, 2014.

Background

Confidential 4

▪ The one-call system is not fully operational, as municipalities have until June 19, 2014 to

join ON1Call.

▪ On June 4, 2013, the Deputy Minister sent a letter to all stakeholders reminding them of the

requirement to join ON1Call and provided a status update on timing for regulatory

proposals.

▪ In response to issues raised during the consultation in February 2013, ON1Call:

In May 2013, revised their current fee schedule to respond to stakeholder concerns. For example,

members who have smaller infrastructure systems will not be required to pay ON1Call notification

fees if they receive less than 400 billable notifications per year.

In June 2013, issued an interpretation bulletin to clarify membership (i.e., who are members under

the act); and

In October 2013, finalized their proposed board and governance structure and communicated the

new structure to existing and prospective members.

▪ MCS staff met regularly with ON1Call to develop regulatory proposals to implement the act.

▪ The regulatory proposals were posted on the Regulatory Registry for comment from

November 1, 2013 to December 16, 2013.

Current Status

Regulatory Proposals

Confidential 5

The regulatory proposals address the following matters:

▪ Enabling ON1Call to set requirements for members through corporate by-laws (i.e.,

membership terms and conditions).

Enables the corporation to effectively administer its service with its members.

▪ Allowing ON1Call to use a range of tools to promote members’ compliance with the

act and the specified requirements of the corporate by-laws.

Enables a range of tools, from taking no action, to member education or issuing a written

warning, to imposing an Administrative Monetary Amount ($100 to a maximum of $10,000)

after a review and appeal process.

▪ Setting the maximum fine upon prosecution of an offence at $10,000.

This fine would be applicable to offences by both members of ON1Call and excavators.

It is anticipated that ON1Call would use prosecution only in very rare circumstances. There

are other regulators (i.e., Ministry of Labour, Technical Standards and Safety Authority, and

the Electrical Safety Authority) who could consider taking enforcement action, as

appropriate, under their acts. ON1Call is working with these regulators to coordinate

approach to enforcement.

Member Requirements

Confidential 6

▪ The provisions in the act require members to:

make all reasonable attempts to provide a locate within five business days, or work

with the excavator to negotiate a different delivery date, and

provide information to the corporation related to the location of its underground

infrastructure.

▪ The by-laws enabled by the proposed regulations would also require members to:

take all reasonable steps to provide an emergency locate within two hours,

report when locate is completed within two business days using an online system,

provide contact information to receive locate requests,

have liability insurance or alternative liability protection of $2,000,000,

assist ON1Call in resolving complaints,

work with ON1Call to comply with requirements (e.g., participate in member

education), or, if ongoing non-compliance, may be assessed an administrative

monetary amount following review and appeal processes, and

pay fees for routing locate requests (e.g., $1.60 per request). Members will have

the right to vote on changes to fees.

ON1Call’s Board and Governance Structure

Confidential 7

▪ Timed to align with the implementation of the proposed regulations, ON1Call will be

moving to an open membership model that will give each member the right to vote

on board members and on important decisions of the corporation (e.g., changes to

fees and changes to bylaws).

▪ The proposed governance structure will include:

One class of membership

End to the preferred selection of the Chair by 2015 (i.e., the Chair will no longer have to be

a representative from one of the three founding companies – Bell, Enbridge Gas and Union

Gas)

Directors’ terms to increase from the current one-year to three-year terms

Size of the board to expand from 12 to 15 members, including two excavator positions

Member votes will be representative (i.e., each member will have one vote, and the total

votes for each sector will be weighted equally across the five sectors to balance

stakeholder interests).

▪ In October 2013, ON1Call held information sessions regarding these changes to

governance in Thunder Bay, Sudbury, Ottawa, Toronto, Windsor and London.

Confidential 8

▪ Consultation feedback is due December 16, 2013.

▪ Ministry staff and ON1Call have met with interested stakeholders during the

consultation period and will continue to meet with stakeholders as requests are

received.

▪ The ministry will prepare regulations and seek Cabinet approval in early 2014.

▪ The ministry’s target is to have regulations in effect by June 19, 2014.

Next Steps

Presented by Nancy Evans, Vice President

Communications & Stakeholder Relations

Presented to the Utility Advisory Council

December 12, 2013

UAC Membership Review

Membership Initiative

UAC Working Well and Productive

• Advancing membership to ensure reflective of sector; part of

ongoing governance management

• Various UAC members retiring, changing jobs; need to manage

appointment process

• Opportunity to ensure UAC continues to be well-represented for

future

• Act in accordance with Terms of Reference

UAC Membership Review • Dec 12 2013 2

Our Goals

Continued effectiveness and engagement of group

Continued productive meetings that serve purpose of:

• providing good advice to ESA

• providing comment from industry perspectives

• effective sharing of information by ESA


Terms of Reference - Membership

The UAC will be comprised of a minimum of 18 members and maximum of 26 members

Terms of Reference Specify:

• representing those can advise and assist with reduction of electrical safety incidents involving electrical distribution system (Terms of Reference)


Voting Members Min. Max

Licensed Distribution Company/Owner/Operator 9 13

General Interest 6 8

Government Regulatory 3 5

Overall Membership

Current Composition


Voting Members Number

Licensed Distribution Company/Owner/Operator 14 (1 over max)

General Interest 9 (1 over max)

Government Regulatory 3 (at min)

Membership

• Member is held by organizations, not individuals

• Organizations send delegate

• Terms:

• Three years each

• Reappointment for up to two additional terms

• Members who do not send delegates regularly will be asked to

resign seat

• In October, 2012 “clock restarted”

• Current members started first three-year term

• Therefore first term renewals: October, 2015


LDC Membership

Evolution over time with natural departures to rebalance structure of members, align with TOR

• Memberships do not stay with an LDC in perpetuity; need to be

able to cycle in new viewpoints

• Need to restore the member structure to align with TOR

• When a term ends or member elects to give up seat or seat is

resigned:

• ESA to review UAC composition, request nominations, fill

vacancies according to balanced membership model

• Including: size, geography, coverage of province, interest

and/or ability to participate


LDC Membership

As agreed at February, 2013 UAC: will work over time to achieve the following balance of LDC members

• And seek more Northern and Eastern participation

Voting Members - Target

Voting Members - Current

Hydro One 1 2

Next largest LDC 1 1

Large (>100,000 customers) 2 5

Medium (20,000 – 99,999) 5 5

Small (< 20,000) 4 1

8

LDC Membership

Process in Advance of October, 2015:

• Explore interest and willingness of smaller, Eastern and

Northern LDCs to seek membership;

• Invite others to attend as guests, get exposure to UAC

• Receive nominees, suggestions from industry

• Existing members: indicate intent to stand for renewal as

member

• Develop pool of nominees, aligned with target structure


Government/Regulatory Members

• Terms of reference: 3 -5 members

• Currently:

• Ministry of Labour

• Ontario Energy Board

• Ministry of Energy

• Proposed

• Maintain status quo i.e. no additional members

• Follow-up by ESA with each organization to ensure regular

participation


General Interest Members

• Terms of reference: 6-8

members; sectors not

designated

• Currently:

Safety organizations:

• Infrastructure Health &

Safety Association

System infrastructure:

• ORCGA

• CSA

• Ont. Sewer & Watermain

Construction Assoc.

• Bell Canada

Trades & Professions:

• Ont. Assoc. of Certified

Engineering Technicians and

Technologies

• Power Workers Union

• OEL

Consumers:

• ESA Consumers Advisory

Council


General Interest Members

• Proposal:

• Maximum 8 (as per Terms of Reference)

• Maintain allocation among: safety organizations, system

infrastructure, trades & professions, and consumer reps

• Follow-up by ESA with each organization to ensure regular

participation

• Non-attending members to resign seats

• At first term expiry (October, 2015), review of whether other

sectors or organizations should be represented


Guests

• As per Terms of Reference:

• Guests welcome

• At discretion of Chair and ESA management so advance

notification to attend required

• No voting rights

• Can include additional staff of current members (but no

additional votes)

• Can participate in meeting at discretion of Chair and ESA

management

• Identified at beginning of meeting and in minutes


Other

• ESA staff and consultants, etc. retained by ESA are not

considered guests; required attendees to ensure achievement of

purpose

• Identified by Chair at start of meeting


Chair & Vice Chair

• Terms of Reference:

• Chair and Vice Chair roles are held by individuals not organizations

• Clock restarted on terms: May, 2012

• Chair

• Term is two years with up to one additional two-year term

• Therefore current Chair’s term up for renewal in May, 2014

• Vice Chair

• No term limit


2013 - UAC Meeting • Interesting Pictures

Interesting Pictures December 12, 2013

Cracked Cable Guard – Schedule 40

Cable Guards – Protect from serious

mechanical damage

Cable Guards

Signed off – No Undue Hazard

New Transformer Foundations

How to open?

Adequate Support?

Municipality Re-grading?

Anchor Rod Bending

Built Right Over Transformer

Serious Electrical Incident Reporting

December 12, 2013

Is it Reportable?

• An accident at a construction site causes distribution system equipment located in the public right-of-way to be damaged. The result is that both construction workers and members of the public are exposed to the hazard of energized conductors.

– Is it Reportable?

– Yes. Members of the public make it mandatory to report.

Is it Reportable?

• A fire in some distribution system equipment located in a customer-owned vault causes an explosion, resulting in an object from the vault being ejected and flying across a public space.

• Is it Reportable?

– Yes. The fact that the protective barrier is customer owned does not relieve the utility of responsibility for safe operation of the equipment and reporting any incidents involving their equipment.

Incident Occurs

Regulation 22/04 Serious Incident Reporting

Decision Flowchart

Is Public Involved?

Was there a contact that resulted in a death or critical

injury?

Was there inadvertent contact with

Dist. system >=750v causing or potential to

cause death or C/I ?

Report to ESA

Not reportable to ESA per Regulation

Was there Fire or explosion in dist. system

>=750v causing or potential to cause death

or C/I?

Yes

No

Yes

No

Yes

Yes

No

No

Criteria for Reporting to ESA per Regulation 22/04

• Is Public involved?

– If incident involves workers only and it has been reported to MOL and the MOL has taken control of scene, then not required to report to ESA.

– If incident involves workers and public then it is reportable to ESA

– If public only, then report to ESA

Criteria for Reporting to ESA per Regulation 22/04

• Definition of Serious Electrical Incident

– Any electrical contact that caused death or critical injury to a person (includes arc flash)

– Any inadvertent contact with any part of the distribution system operating at 750 volts or above that caused or had the potential to cause death or critical injury

– Any fire or explosion in any part of the distribution system operating at 750 volts or above that caused or had the potential to cause death or critical injury

Non-Mandatory Incident Reports

• ESA receives many reports that do not involve members of the public, but involve workers from non-electrical trades or involve secondary voltage contacts.

• Although these are not mandatory to report, the information gathered is used to focus our power-line safety campaigns and provides important information for the Ontario Electrical Safety Report.

• Please Keep It Up!

On-Line Incident Reporting Form

• Reports are received in various forms and formats. Most utilities have developed a process to either report electronically or by fax, and use the form provided in the guideline. Others will provide a report to ESA that is generated from their own system.

• If ESA developed an on-line form as an option for reporting Serious Electrical Incidents would you use it?

Should this be a Bulletin?

• Does UAC see value in issuing a bulletin reminding LDCs of the obligations under the Regulation for reporting incidents?

Harmonic and Energy Saving Solutions

Power Quality You Can Trust | Real World Experience | A History of Innovation

Harmonic and Energy Saving Solutions

Selecting Transformers for

Distributed Generation

© 2013 Mirus International | All Rights Reserved

• Many considerations need to be made when selecting a transformer for DG connection with the Utility

– Ground fault path both when connected and islanded

– Limiting Temporary Over-voltage (TOV) during fault conditions

– Blocking common-mode circulating currents (zero sequence) from Utility due to paralleled power sources or unbalanced voltages

– Blocking of Inverter common-mode currents

– High efficiencies, especially when high buy rates apply

– Meeting Utility harmonic voltage and metering requirements

• Transformer selection requires compromises

• Few transformer manufacturers have the power system expertise to advise properly

Transformers for Distributed Generation


References:

1. Hydro One: DG Technical Interconnection Requirements

at Voltages 50kV and below, DT-10-015, Rev.3

2. Distributed Generation Interconnecting Transformer and

Grounding Selection, R.F. Arritt, R.C. Dugan, EPRI

3. IEEE Std. 142, Recommended Practice for Grounding of

Industrial and Commercial Power Systems, IEEE Green

Book

Transformers for Distributed Generation


2.1.10 TEMPORARY OVER-VOLTAGE (TOV)

i. Grounding of DG Facilities and connection systems shall be in

accordance with Section 2.1.11 and not cause any voltage

disturbances.

ii. When connecting to Hydro One’s 4-wire Distribution System, TOV

that may be caused by the DG Facility connection should not exceed

125% of nominal system voltage (line to neutral) anywhere on the

distribution system and under no circumstance shall exceed 130%.

iii. Hydro One may advise on action needed to reduce TOV to limits by

specifying the requirement of grounding transformer on the HV side.

Example calculations of acceptable grounding connections

that meet these requirements are provided in Appendix C

Hydro One TOV Requirements

Hydro One: DG Technical Interconnection Requirements at Voltages 50kV and below, DT-10-015, Rev.3


EFFECTIVE GROUNDING

Multi-grounded 4-wire distribution feeders are effectively grounded and

the DG Facility shall appropriately size its neutral reactor such that for the

entire feeder and for all system conditions the ratio of zero-sequence

reactance to positive-sequence reactance (X0 ⁄X1) is positive and less

than 3, and the ratio of zero-sequence resistance to positive-sequence

reactance (R0 ⁄X1) is positive and less than 1. Further, to restrict ground

fault contribution, a lower limit is placed on X0 ⁄X1.

This definition is similar to that described in ‘IEEE Std. 142,

Grounding of Industrial and Commercial Power Systems’

Hydro One Grounding Requirements



Typical Solar Inverter Application

Grid-tied Inverter

DC BUS CAP

EMI FILTER

Sine-wave Line Filter

High-Efficient Isolation

Transformer

Utility Grid

Fused DC Disconnect

SUB-ARRAY COMBINER

DC Surge Protection

AC Surge Protection

Step-Up DC/DC with MPP Tracking


• Power sources can have differing voltage waveshapes even

when RMS voltages are matched

• Differences in Phase-Neutral (Ph-N) or Phase-Gnd

instantaneous voltages will appear as triple frequency (180Hz)

Neutral Circulating Current with Paralleled Power

Sources


• Difference in instantaneous voltages drives neutral circulating current

• Flow is restricted only by zero sequence impedance of power system

Neutral Circulating Current with Paralleled Power

Sources


Circulating Current in DG Application

• A low impedance

zero sequence path

will result in high

circulating currents

• These are referred to

as common-mode or

zero phase sequence

currents

• They are often triple

frequency (180 Hz)

but are actually not a

harmonic by the true

definition


Transformer Failure on Solar Inverter Installation

due to Zero Sequence, Common-mode Currents

Scott T Transformer


• In a balanced 4-wire sine-wave system, the neutral

voltage is zero

• The neutral voltage on an inverter system is not zero

due to the pulsed PWM voltages

– Although the sum of rms 3-ph voltages is zero an

instantaneous sum of 3-ph voltages is not zero,

resulting in common-mode voltages

• Common-mode voltage induces circulating currents

between the phases and common-neutral or ground

• These common-mode voltages and currents are

typically highest at the IGBT switching frequency

Inverter Common-Mode Voltages

Private and Confidential | Mirus International

Common Mode Current and Voltage Problems

• Common mode (CM) voltages cause voltage stress on the lines and switches (reduction of lifetime)

• High amplitudes of CM current through the ground circuit create an operational electrical hazard and EMI

• Common mode currents result in nuisance tripping of ground fault protection systems

• If severe enough, common mode currents can cause transformers to overheat and fail

• Inverter common-mode voltages and currents are of harmonic frequencies and would cause the PV system to exceed Utility voltage distortion requirements if not attenuated


• Use connecting transformers that introduce high zero sequence impedance

• Add impedance in the common neutral – Neutral Reactors or Neutral Grounding Resistors can be used

but the effect on 1-ph fault level needs to be taken into consideration

• An ungrounded 3-wire system can be used where neutrals are not connected together or grounded – No neutral return path is available for 1-ph loads

Methods for limiting Circulating Currents

Grounded Wye (Utility), Grounded Wye (DG)

Advantages

• Solid neutral reference – No shifting on neutral

• Neutral reference for Utility metering and DG

• Minimal concern for ferroresonance

Disadvantages

13/12/2013 © 2013 Mirus International | All Rights Reserved 44

• Will directly pass zero

sequence, common-mode

currents

• DG may feed into any Utility

fault, increasing damage

• Utility will feed into internal

DG fault, increasing damage

Ref: Distributed Generation Interconnecting Transformer and Grounding Selection, R.F. Arritt, R.C. Dugan, IEEE


4-Wire Grounded Utility Connection: YGnd - YGnd

• Low impedance zero

sequence path

resulting in high


unless DG has Y-Y

ungrounded isolation

transformer

• Could also take

neutral path if neutral

is connected

• Ungrounding the

neutrals would

eliminate this path

but create a

dangerous, high

impedance path for

fault currents on DG

side and when

Islanded

Grounded-Wye (Utility), Delta (DG)

Advantages • Common-mode currents

generated by DG are

blocked by delta winding

• Neutral reference for

Utility metering

• Utility side faults easily

detected by DG

Disadvantages


• May require neutral

grounding reactor to

increase zero seq.

impedance

• Can attract zero sequence

currents from Utility

• No neutral reference for DG

• Provides alternate zero seq.

path for fault currents

– May change Utility protection

requirements



4-Wire Grounded Utility Connection: YGnd - ∆

• Low impedance zero

sequence path

resulting in high


• These currents could

also take neutral path

if neutral connected

• Ungrounding the

neutral would

eliminate this path

but create a

dangerous, high

impedance path for


side and when

Islanded

Grounded-Zigzag (Utility), Delta (DG) - Harmonic Mitigating Transformer

Advantages

• Common-mode currents

generated by DG are

blocked by delta winding

• Neutral reference for

Utility metering


detected by DG

Disadvantages


• Will attract common-mode

currents from Utility

• Increases fault level by

providing very low zero seq.

path for fault currents

– Will very likely change Utility

protection requirements



increase zero seq.

impedance but this

defeats the purpose of

the zig-zag


4-Wire Grounded Utility Connection: ZGnd - ∆

• Very low impedance

zero sequence path

resulting in high


• These currents could

also take neutral path

if neutral connected

• Ungrounding the

neutral would

eliminate this path

but create a

dangerous, high

impedance path for


side and when

Islanded

Grounded-T (Utility), Grounded-T (DG) - Scott T

Advantages

• Neutral reference for DG

and Utility metering

provided load is balanced


detected by DG

Disadvantages


• Will directly pass zero

sequence currents

• DG may feed into any Utility

fault, increasing damage

• Utility will feed into internal

DG fault, increasing damage



increase zero

sequence impedance


4-Wire Grounded Utility Connection: TGnd - TGnd

• Very low impedance

common-mode path

resulting in high


• Could also take

neutral path if neutral

connected

• Ungrounding the

neutrals would

eliminate this path

but create a

dangerous, high

impedance path for

fault currents when

Islanded

Delta (Utility), Grounded-Wye (DG) Advantages

• Utility zero sequence

currents blocked by delta

winding


• DG does not feed directly

into Utility side faults

Disadvantages


• Provides a zero sequence path for Inverter common-mode currents

• Does not provide effective grounding

• Can be difficult to detect Utility side 1-ph faults – Primary side relaying may be

required

• No neutral reference

for Utility metering

• More susceptible to ferroresonances during a fault condition



4-Wire Grounded or 3-Wire Ungrounded Utility

Connection: ∆ - YGnd

• Very high impedance

common-mode path

resulting in very low

or no circulating

currents

• DG will often include

an ungrounded Y-Y

isolation transformer

or common-mode

blocking filter for

inverter generated

common-mode

• Does not provide

ground path when

DG is Islanded

Delta (Utility), Grounded-Zigzag (DG) - Harmonic Mitigating Transformer

Advantages

• Utility zero sequence

currents blocked by delta

winding

• DG does not feed directly

into Utility side faults

Disadvantages


• Provides a very low zero sequence path for Inverter common-mode currents

• Does not provide effective grounding

• Can be difficult to detect Utility side 1-ph faults – Primary side relaying may be

required

• No neutral reference

for Utility metering

• More susceptible to ferroresonances during a fault condition


4-Wire Grounded or 3-Wire Ungrounded Utility

Connection: ∆ - ZGnd

• Very high impedance

common-mode path

resulting in very low

or no circulating

currents

• Very low common-

mode path for DG

inverter generated

common-mode which

could cause

problems for inverter

• Does not provide

ground path when

DG is Islanded


Grounded-Wye (Utility), Delta (DG)

• Common-mode currents generated by DG are blocked by delta winding

• Neutral reference for Utility metering

• Utility side faults easily detected by DG

• Requires addition of neutral grounding reactor to meet effective

grounding requirements and block path for Utility zero sequence

currents

– Must be sized for fault currents and residual circulating currents

Recommendation #1: 4-Wire Connection

57


Delta (Utility), Grounded-Wye (DG)

• Utility zero sequence currents blocked


• DG does not feed into Utility fault

• Difficult for DG to detect a Utility side fault

– May require additional protection

• Requires addition of zigzag grounding transformer and neutral reactor

to meet effective grounding requirement

– Zigzag grounding transformer will provide a zero sequence path for

Utility common-mode currents

– Must be sized for fault currents and residual circulating currents

• Requires other means to

block DG common-mode

currents

• Potential for ferroresonance

exists

Recommendation #2: 4-Wire Connection

58


Delta (Utility), Grounded-Wye (DG)

• No path for Utility zero sequence currents


• DG does not feed into Utility fault

• Requires other means to block DG common-mode currents

• Potential for ferroresonance exists

• If the DG requires a grounded connection to the Utility, a zigzag grounding transformer must be added and meet the following requirements:

– For conventional generators

– For Inverters

Recommendation: 3-Wire Connection

59


C.1 Interconnecting to HONI’s 4-Wire Distribution System

Hydro One Neutral Reactor and Grounding Transformer Impedance Calculations – Appendix C


© 2012 Mirus International | All Rights Reserved Private and Confidential | Mirus International

Summary • Many factors go into selecting the proper transformer for DG

connection to Utility – Ground fault path both when connected and islanded

– Prevention of TOV

– Prevention of circulating common-mode (zero sequence) currents both from Utility and Inverter

– High efficiency for highest revenues

• Paralleling of different power sources can cause neutral circulating current – Typically triple frequency

– Transformer must not provide a zero sequence path on the Utility side

• For 4-Wire systems, Grounded-Wye (Utility): Delta (DG) with neutral grounding reactor is best option

• For 3-Wire ungrounded systems, Delta (Utility): Grounded-Wye (DG) is best option

102

Private and Confidential | Mirus International

Thank you!

Any Questions?

Barriers / Support Structures and Grounding

PURPOSE • ESA is requesting advise from the UAC with regards to the DRAFT

Bulletin entitled: – Safety Barrier/Supporting Structures & Grounding Requirements of

LDC Energized Conductors and Live Parts

• The DRAFT Bulletin was included in the pre-meeting material.

• The Bulletin seeks to clarify the requirements found under Regulation 22/04 Section 4 specifically: – Safety Barriers – Support Structures – Grounds

• KEY CONCEPT: Even if the LDC does not install or own certain safety equipment, if it is used to protect LDC owned equipment the LDC has some responsibility for it under Regulation 22/04.

Example: Scenario #1

• Underground Residential Service where the ownership demarcation point is declared at the line side of the customer’s meter base.

– In this scenario the LDC is responsible for ensuring that all infrastructure and equipment providing a barrier to LDC owned energized conductors, including conduit to the meter base, duct system and trench backfill are adequate. Even in the event that a non-LDC is responsible for the work.

Example: Scenario #1 Rationale

REGULATION 22/04 EXCERPT – SECTION 4

• (5) All underground distribution lines, including secondary distribution lines, shall meet the following safety standards:

• 3. Energized conductors and live parts shall be barriered such that equipment or unauthorized persons do not come into contact with them or draw arcs under reasonably foreseeable circumstances.

Example Scenario #2

• Chamber (Vault) or LDC Owned Pad-mounted Transformer where the LDC sets the ownership demarcation point at the secondary terminal(s) of the transformer(s).

– In this scenario the LDC is responsible for ensuring adequate barriers to all energized conductors and live parts of the LDC equipment, including: the ability of the chamber (vault) or transformer’s foundation to act as a barrier to the energized equipment; and any required grounding and bonding of LDC equipment.




• 3. Energized conductors and live parts shall be barriered such that equipment or unauthorized persons do not come into contact with them or draw arcs under reasonably foreseeable circumstances.

Example Scenario #3

• LDC Owned Pad-mounted Transformer

– In this scenario the LDC is responsible for ensuring that the transformer(s) is effectively grounded for safety. Even in the event that a non-LDC is responsible for installation of the ground loop, electrodes or similar grounding means.




• 4. Metal parts of the installation that are not intended to be energized and that are accessible to unauthorized persons shall be effectively grounded.

Example Scenario #4

• LDC Owned Embedded Pole-mounted Transformers

– In this scenario the LDC is responsible for ensuring that the transformer is structurally supported and effectively grounded. Even in the event that a non-LDC is responsible for installation of the supporting structure (pole), down ground, electrode(s) or similar grounding means.


REGULATION 22/04 EXCERPTS – SECTION 4

• (4) All overhead distribution lines, including secondary distribution lines, shall meet the following safety standards:

• 3. Energized conductors and live parts shall be barriered such that vegetation, equipment or unauthorized persons do not come in contact with them or draw arcs under reasonably foreseeable circumstances.

• 5. Structures supporting energized conductors and live parts shall have sufficient strength to withstand the loads imposed on the structure by electrical equipment and weather loadings.

Questions/Advice

Major Equipment Refurbishment Programs

Example: CamTran C2C

1

HISTORY

• Regulation 22/04 Audits are finding that some LDC’s current Transformer Refurbishment Programs do not meet any of the recognized methods for approving major equipment.

• Typically P.Eng is not signing off Test Reports.

• LDC requested ESA recognize an additional method for approving major equipment which is refurbished.

• Current, recognized methods are currently documented in the “Technical Guideline for Equipment, Design and Construction”, under Section 2.7.6.

• Section 2.7.6 was revised and received advice from the UAC in 2008. No objections were noted at the time.

2

PROPOSED DEVIATIONS

• The following items were requested to be recognized as acceptable

oRoutine Tests signed by “Authorized Person”, this is not a P.Eng. This is recognized as acceptable for Routine Tests in CAN/CSA-C2.1.

o “Authorized Person” qualifications, the LDC is looking to make the manufacturer responsible for the qualification of “Authorized Person”.

oA number of references to “Expectations” within the “Distributor Developed Specification”.

3

POSSIBLE: PROPOSED DEVIATIONS

• The following items were possibly being requested to be recognized as acceptable

oDistributor Specification for the major equipment to be signed off by a professional engineer, but not a P.Eng (Ontario).

4

UAC Advice

Questions/Comments

5

utility advisory council presentations... · clearance requirements would meet both the csa 22.3...

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