Utility Advisory Council
OBC changes
December 12, 2013
Agenda
•Current OBC rules pertaining to above
ground electrical conductors
•New OBC rules
2
Appropriate Use of ESA Computing Equipment and Services • September 2013
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”.
3
Ontario Building Code
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.
4
Ontario Building Code
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
5
Appropriate Use of ESA Computing Equipment and Services • September 2013
Ontario Building Code-Ont. Reg. 332/12
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.
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Appropriate Use of ESA Computing Equipment and Services • September 2013
Ontario Building Code-Ont. Reg. 332/12
(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.
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Appropriate Use of ESA Computing Equipment and Services • September 2013
Ontario Building Code-Ont. Reg. 332/12
•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
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Appropriate Use of ESA Computing Equipment and Services • September 2013
Ontario Building Code-Ont. Reg. 332/12
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.
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Appropriate Use of ESA Computing Equipment and Services • September 2013
Review of Audit
Results for 2012
December 12, 2013
Electrical Distribution Safety
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
Electrical Distribution Safety
Summary of
Audit Findings Life to Date
40
34
35
30
Total LDCs no
Findings
Avg # per LDC
25
27
26
24
20
14
15
12
10
8.4
5.3
5
0
3.3
1
2.6
2.0
1.5
1.3
0
2005
2006
Electrical Distribution Safety
2007
2008
2009
2010
2011
1.0
2012
Common audit findings
Section 6 – Equipment Approvals
• Process for approving equipment returned
from field or refurbished
• No process documented for approving equipment for reuse 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.
Electrical Distribution Safety
Common audit findings
Section 7 – Design
• Designs without certificates of approval
• Plan changes not approved /approval
not recorded
• Designs not reviewed / approved for recloser protection settings or no
Certificate of Approval
Electrical Distribution Safety
Common audit findings
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
Electrical Distribution Safety
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
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.
2. Penalties
4. Publication
Regulators would have discretion in their policy to
determine monetary amounts for violations within three
established levels.
Regulators would be required to publish information
about issuing AMPs.
3. Review process
5. Proceeds only to be used for education,
consumer awareness or public safety initiatives.
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.
13/12/2013
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.
5
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
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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
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3. Review Process
▪
▪
As proposed, the use of an AMP could be reviewed to ensure fairness
▪
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)
Legislation would set out when a review might take place, who would hear
and decide the review and the power of the reviewer.
▪ Review could confirm, deny or vary the original AMP
13/12/2013
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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
▪
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
▪
2.
▪
▪
▪
The board would publish an annual report that would include financial statements
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
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 consumerpolicy@ontario.ca 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
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.
1
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
2
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.
3
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.
4

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
5
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.
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.
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.
6
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.
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.
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
7
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’s8
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:
consumerpolicy@ontario.ca
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.
9
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
consumerpolicy@ontario.ca.
10
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.
11
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)
12
One Call to Dig
Overview of Regulatory Proposals
Utility Advisory Council Meeting
Electrical Safety Authority
December 12, 2013
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
2
Background
▪ 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. Nonmunicipal owners became members before or on June 19, 2013, and municipal owners
will be deemed members as of June 19, 2014.
Confidential
3
Current Status
▪ 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.
Confidential
4
Regulatory Proposals
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.
Confidential
5
Member Requirements
▪ 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.
Confidential
6
ON1Call’s Board and Governance Structure
▪ 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
7
Next Steps
▪ 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.
Confidential
8
UAC Membership
Review
Presented by Nancy Evans, Vice President
Communications & Stakeholder Relations
Presented to the Utility Advisory Council
December 12, 2013
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
2
UAC Membership Review • Dec 12 2013
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
3
UAC Membership Review • Dec 12 2013
Terms of Reference - Membership
The UAC will be comprised of a minimum of 18 members
and maximum of 26 members
Terms of Reference Specify:
Voting Members
Min.
Max
Licensed Distribution Company/Owner/Operator
9
13
General Interest
6
8
Government Regulatory
3
5
• representing those can advise and assist with reduction of
electrical safety incidents involving electrical distribution
system (Terms of Reference)
4
UAC Membership Review • Dec 12 2013
Overall Membership
Current Composition
5
Voting Members
Number
Licensed Distribution Company/Owner/Operator
14 (1 over max)
General Interest
9 (1 over max)
Government Regulatory
3 (at min)
UAC Membership Review • Dec 12 2013
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
6
UAC Membership Review • Dec 12 2013
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
7
UAC Membership Review • Dec 12 2013
LDC Membership
As agreed at February, 2013 UAC: will work over time to
achieve the following balance of LDC members
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
• And seek more Northern and Eastern participation
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
9
UAC Membership Review • Dec 12 2013
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
10
UAC Membership Review • Dec 12 2013
General Interest Members
• Terms of reference: 6-8
members; sectors not
designated
• Ont. Sewer & Watermain
Construction Assoc.
• Currently:
Trades & Professions:
Safety organizations:
• Bell Canada
• Infrastructure Health &
Safety Association
• Ont. Assoc. of Certified
Engineering Technicians and
Technologies
System infrastructure:
• Power Workers Union
• ORCGA
• OEL
• CSA
Consumers:
• ESA Consumers Advisory
Council
11
UAC Membership Review • Dec 12 2013
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
12
UAC Membership Review • Dec 12 2013
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
13
UAC Membership Review • Dec 12 2013
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
14
UAC Membership Review • Dec 12 2013
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
15
UAC Membership Review • Dec 12 2013
• Interesting Pictures
2013 - UAC Meeting
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.
Regulation 22/04
Serious Incident Reporting
Decision Flowchart
Report to
ESA
Incident
Occurs
Yes
Is Public
Involved?
Yes
Yes
Was there a contact
that resulted in a
death or critical
injury?
No
Not
reportable
to ESA per
Regulation
No
Was there inadvertent
contact with
Dist. system >=750v
causing or potential to
cause death or C/I ?
No
No
Was there Fire or
explosion in dist. system
>=750v causing or
potential to cause death
or C/I?
Yes
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 powerline 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
Transformers for Distributed Generation
• 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
© 2013 Mirus International | All Rights Reserved
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
© 2013 Mirus International | All Rights Reserved
Hydro One TOV Requirements
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: DG Technical Interconnection Requirements at Voltages 50kV and below, DT-10-015, Rev.3
© 2013 Mirus International | All Rights Reserved
Hydro One Grounding Requirements
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: DG Technical Interconnection Requirements at Voltages 50kV and below, DT-10-015, Rev.3
© 2013 Mirus International | All Rights Reserved
Typical Solar Inverter Application
Utility
Grid
SUB-ARRAY
COMBINER
High-Efficient
Isolation
Transformer
Step-Up DC/DC
with MPP Tracking
DC BUS
CAP
Grid-tied
Inverter
Sine-wave
Line Filter
EMI
FILTER
Fused DC
Disconnect
DC Surge
Protection
© 2013 Mirus International | All Rights Reserved
AC Surge
Protection
Neutral Circulating Current with Paralleled Power
Sources
• 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)
© 2013 Mirus International | All Rights Reserved
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
© 2013 Mirus International | All Rights Reserved
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
© 2013 Mirus International | All Rights Reserved
Transformer Failure on Solar Inverter Installation
due to Zero Sequence, Common-mode Currents
Scott T Transformer
© 2013 Mirus International | All Rights Reserved
Inverter Common-Mode Voltages
• 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
© 2013 Mirus International | All Rights Reserved
Measured Inverter neutral-to-ground voltage
Vng neutral-toground
voltage
Ilg CM
current
13/12/2013
© 2012 Mirus International | All Rights Reserved
40
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
Private and Confidential | Mirus International
Methods for limiting Circulating Currents
• 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
© 2013 Mirus International | All Rights Reserved
Grounded Wye (Utility), Grounded Wye (DG)
Advantages
Disadvantages
• Solid neutral reference
• 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
– No shifting on neutral
• Neutral reference for
Utility metering and DG
• Minimal concern for
ferroresonance
Ref: Distributed Generation Interconnecting Transformer and Grounding Selection, R.F. Arritt, R.C. Dugan, IEEE
13/12/2013
© 2013 Mirus International | All Rights Reserved
44
4-Wire Grounded Utility Connection: YGnd - YGnd
• Low impedance zero
sequence path
resulting in high
circulating currents
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
© 2013 Mirus International | All Rights Reserved
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
• 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
• May require neutral
grounding reactor to
increase zero seq.
impedance
13/12/2013
© 2012 Mirus International | All Rights Reserved
Ref: Distributed Generation Interconnecting Transformer and Grounding Selection, R.F. Arritt, R.C. Dugan, IEEE
46
4-Wire Grounded Utility Connection: YGnd - ∆
• Low impedance zero
sequence path
resulting in high
circulating currents
• 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
fault currents on DG
side and when
Islanded
© 2013 Mirus International | All Rights Reserved
Grounded-Zigzag (Utility), Delta (DG)
- Harmonic Mitigating Transformer
Advantages
Disadvantages
• Common-mode currents • Will attract common-mode
currents from Utility
generated by DG are
blocked by delta winding • Increases fault level by
providing very low zero seq.
• Neutral reference for
path for fault currents
Utility metering
– Will very likely change Utility
• Utility side faults easily
protection requirements
detected by DG
• May require neutral
grounding reactor to
increase zero seq.
impedance but this
defeats the purpose of
the zig-zag
13/12/2013
© 2012 Mirus International | All Rights Reserved
48
4-Wire Grounded Utility Connection: ZGnd - ∆
• Very low impedance
zero sequence path
resulting in high
circulating currents
• 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
fault currents on DG
side and when
Islanded
© 2013 Mirus International | All Rights Reserved
Grounded-T (Utility), Grounded-T (DG)
- Scott T
Advantages
Disadvantages
• Neutral reference for DG
and Utility metering
provided load is balanced
• Utility side faults easily
detected by DG
• Will directly pass zero
sequence currents
• DG may feed into any Utility
fault, increasing damage
• Utility will feed into internal
DG fault, increasing damage
• May require neutral
grounding reactor to
increase zero
sequence impedance
13/12/2013
© 2013 Mirus International | All Rights Reserved
50
4-Wire Grounded Utility Connection: TGnd - TGnd
• Very low impedance
common-mode path
resulting in high
circulating currents
• 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
© 2013 Mirus International | All Rights Reserved
Delta (Utility), Grounded-Wye (DG)
Advantages
Disadvantages
• Utility zero sequence
currents blocked by delta
winding
• Neutral reference for DG
• DG does not feed directly
into Utility side faults
• Provides a zero sequence
path for Inverter commonmode 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
13/12/2013
© 2013 Mirus International | All Rights Reserved
Ref: Distributed Generation Interconnecting Transformer and Grounding Selection, R.F. Arritt, R.C. Dugan, IEEE
52
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
© 2013 Mirus International | All Rights Reserved
Delta (Utility), Grounded-Zigzag (DG)
- Harmonic Mitigating Transformer
Advantages
Disadvantages
• Provides a very low zero
• Utility zero sequence
sequence path for Inverter
currents blocked by delta
common-mode currents
winding
• DG does not feed directly • Does not provide effective
grounding
into Utility side faults
• 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
13/12/2013
© 2013 Mirus International | All Rights Reserved
54
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 commonmode path for DG
inverter generated
common-mode which
could cause
problems for inverter
• Does not provide
ground path when
DG is Islanded
© 2013 Mirus International | All Rights Reserved
Recommendation #1: 4-Wire Connection
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
57
© 2013 Mirus International | All Rights Reserved
Recommendation #2: 4-Wire Connection
Delta (Utility), Grounded-Wye (DG)
•
•
•
•
•
•
•
Utility zero sequence currents blocked
Neutral reference for DG
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
58
© 2013 Mirus International | All Rights Reserved
Recommendation: 3-Wire Connection
Delta (Utility), Grounded-Wye (DG)
•
•
•
•
•
•
No path for Utility zero sequence currents
Neutral reference for DG
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
© 2013 Mirus International | All Rights Reserved
59
Hydro One Neutral Reactor and Grounding
Transformer Impedance Calculations – Appendix C
C.1 Interconnecting to HONI’s 4-Wire Distribution System
Hydro One: DG Technical Interconnection Requirements at Voltages 50kV and below, DT-10-015, Rev.3
© 2013 Mirus International | All Rights Reserved
Hydro One Neutral Reactor and Grounding
Transformer Impedance Calculations – Appendix C
C.1 Interconnecting to HONI’s 4-Wire Distribution System
Hydro One: DG Technical Interconnection Requirements at Voltages 50kV and below, DT-10-015, Rev.3
© 2013 Mirus International | All Rights Reserved
Hydro One Neutral Reactor and Grounding
Transformer Impedance Calculations – Appendix C
C.1 Interconnecting to HONI’s 4-Wire Distribution System
© 2013 Mirus International | All Rights Reserved
Hydro One Neutral Reactor and Grounding
Transformer Impedance Calculations – Appendix C
C.1 Interconnecting to HONI’s 4-Wire Distribution System
Hydro One: DG Technical Interconnection Requirements at Voltages 50kV and below, DT-10-015, Rev.3
© 2013 Mirus International | All Rights Reserved
Hydro One Neutral Reactor and Grounding
Transformer Impedance Calculations – Appendix C
C.2 Interconnecting to HONI’s 3-Wire Distribution System
© 2013 Mirus International | All Rights Reserved
Hydro One Neutral Reactor and Grounding
Transformer Impedance Calculations – Appendix C
C.2 Interconnecting to HONI’s 3-Wire Distribution System
Hydro One: DG Technical Interconnection Requirements at Voltages 50kV and below, DT-10-015, Rev.3
© 2013 Mirus International | All Rights Reserved
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): GroundedWye (DG) is best option
©
Private
2012 Mirus
and Confidential
International|| Mirus
All Rights
International
Reserved
102
Thank you!
Any Questions?
Private and Confidential | Mirus International
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.
Example: Scenario #2
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 #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.
Example: Scenario #3
Rationale
REGULATION 22/04 EXCERPT – SECTION 4
• (5) All underground distribution lines,
including secondary distribution lines, shall
meet the following safety standards:
• 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 nonLDC is responsible for installation of the
supporting structure (pole), down ground,
electrode(s) or similar grounding means.
Example: Scenario #4
Rationale
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
o Routine 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”.
o A 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
o Distributor 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