E-38—Program for granting conditional permission to install and use street lighting luminaires with adaptive controls without the approval, verification and sealing of their embedded measurement technology

Category: Electricity
Issue date: 2022-03-10
Effective date: 2022-03-10
Revision number: N/A
Supersedes: N/A

1.0 Scope
2.0 Purpose
3.0 Authority
4.0 Background
5.0 References
6.0 Definitions
7.0 Policy requirements
8.0 Program review

1.0 Scope

This bulletin applies to electricity trade transactions between a seller and a purchaser where the subject load is limited to street lighting luminaires incorporating adaptive controls with embedded measurement technology.

Typically in such transactions, the seller is an electricity utility and the end user (purchaser) is a municipality. This program does not apply in cases where the seller is also the end user (i.e. the electricity utility owns the luminaires).

2.0 Purpose

The purpose of this bulletin is to communicate the program requirements for granting a conditional permission for the installation and use of street lighting luminaires incorporating adaptive controls without the approval, verification and sealing of their embedded measurement technology.

This bulletin is intended to provide information and guidance for the use of MC staff and stakeholders. It is not a binding statement of what decision MC may render on any individual application.

3.0 Authority

A conditional permission may be granted by Measurement Canada (MC) in accordance with this bulletin under the authority of subsection 9(2) of the Electricity and Gas Inspection Act.

4.0 Background

Historically, street light energy usage was not metered and end users were billed at a flat rate based on power ratings (e.g. wattage) and hours of darkness. Today, adaptive controls allow luminaires to "adjust" to varying lighting conditions in real time, resulting in significant energy savings for the end users. To fully benefit from both energy and cost savings, it is necessary to measure the energy consumption of luminaires.

Adaptive controls with embedded measurement technology are designed to measure, record and transmit electrical energy usage data to a central management system (CMS) for the purpose of establishing the basis of a charge for electricity. However, the typical design of these devices generally does not comply with existing MC technical specifications. As such, MC is exercising authorities delegated pursuant to the Electricity and Gas Inspection Act (EGIA) to allow these devices to be installed and used without the approval, verification or sealing of their embedded measurement technology.

5.0 References

Additional references (for information only)

Electricity and Gas Inspection Act, (R.S.C. 1985, c. E-4), subsection 9(2)
Electricity and Gas Inspection Regulations, (SOR/86-131), subsection 11(2)
ANSI/NEMA C136.48-2018 - American National Standard for Roadway and Area Lighting Equipment -Wireless Networked Lighting Controllers
ANSI C136.41-2013 - Roadway and Area Lighting Equipment–Dimming Control Between an External Locking Type Photocontrol and Ballast or Driver
ANSI C136.58-2019 - American National Standard for Roadway and Area Lighting Equipment - Luminaire Four-Pin Extension Module and Receptacle - Physical and Electrical Interchangeability and Testing

6.0 Definitions

Note: To sell electricity to a purchaser, a seller must be registered as a contractor pursuant to the Electricity and Gas Inspection Act.

Adaptive control
(commande adaptative): A capability that enables a lighting system to modify its operation to achieve the best possible mode of operation or efficiency. In the case of light-emitting diode (LED) street lights, this capability allows lights to be dimmed, enhanced, or shut off and turned on at any predetermined interval or condition. Adaptive controls include integrated measurement and communication components which collect and transmit energy usage data to remote receivers in a central management system. Adaptive controls may be incorporated within the luminaire or attached to it through an external interface in accordance with ANSI C136.41 or ANSI C136.58.
Central management system
(système de gestion centralisé): A computer that functions as the processing core of the system by providing all shared system services and by consolidating and storing all system data.
Embedded measurement technology
(technologie de mesure intégrée): Components, such as measuring sensors, processors and transmitters that derive values in legal units of measurement and are built into a device's electrical system.
End user
(utilisateur final): An electricity purchaser, such as a municipality, city or town, that installs luminaires incorporating adaptive controls in order to take advantage of green energy initiatives and savings.
Legal unit of measurement
(unité de mesure légale): A unit of measurement prescribed under subsection 3(1) of the Electricity and Gas Inspection Act used as the basis of a charge where trade measurement occurs.
Luminaire
(luminaire): A complete street lighting unit consisting of one or more lamps and ballasts, where appropriate, together with the parts designed to distribute light, to position and protect the lamps, and to connect the lamps to a power supply. Reference: ANSI/IES LS-1-20.
Revenue meter
(compteur de facturation): A meter that has been approved by Measurement Canada, verified and sealed in accordance with the Electricity and Gas Inspection Act and can be used to establish the basis of a charge in a given trade transaction.
Seller
(vendeur): Typically, an electricity utility or a local electricity distribution company that supplies electrical energy to end users (purchasers) on the basis of measurement.
String (insert equivalent term): A string is a circuit of luminaires powered by one source.

7.0 Policy requirements

7.1 General requirements

Subject to the requirements and conditions established in this policy, an applicant may seek a conditional permission to place luminaires incorporating adaptive controls into service without the approval, verification and sealing of their embedded measurement technology. Such permission may be considered when a seller intends to use energy measurement data from these controls for establishing the basis of a charge for electricity usage.

Before applying for a conditional permission in accordance with this bulletin, the seller must obtain written consent from the end user of the luminaires incorporating the adaptive controls. MC will consider applications for new street lighting retrofit projects and for existing projects completed before this bulletin was issued.

Compliance with all the requirements of this bulletin will be assessed by MC prior to granting a conditional permission under this policy. Once a permission is granted, the adaptive controls may be used to derive values in legal units of measurement (LUM) for establishing the basis of a charge for electricity usage and generating a bill or invoice to the end user.

Upon granting a conditional permission, the permission will be valid up to five years at which time MC will review the application in consideration of any new information, including possible national and international standards. MC reserves the right to review any permission granted within the five-year term should information come to light that would warrant the intervention of MC.

MC may review this program periodically to evaluate its efficiency and adequacy, or to determine if regulatory amendments are warranted (see section 8.0 for further details).

Note: The granting of a conditional permission pursuant to this bulletin does not negate the legislative requirement for accuracy of trade measurement transactions. Limits of error for electricity trade transactions, including those covered by this program, are prescribed in the Electricity and Gas Inspection Regulations and are currently established at 3.0% of the amount of electricity supplied.

7.2 Specified conditions

MC will consider applications where the end user has installed or intends to install luminaires with adaptive controls. An application for conditional permission must be made for each make and model of adaptive controls.

For each permission granted, the seller must install a number of revenue meters from which to gather measurement data on the luminaries that is external to their embedded measurement technology.

The minimum number of revenue meters to be installed is provided in the table below and is based on the number of luminaires for a given conditional permission. However, if at least 5% of the total luminaire population can be monitored with fewer revenue meters, then the lower number of meters is acceptable. Refer to the rightmost column of Table 1 for these requirements.

Table 1—Number of revenue meters to be installed or luminaires to be monitored
Number of luminaires subject to the permission	Number of revenue meters to be installed	Number of luminaires to be monitored
1–100	1	5
101–200	2	10
201–300	6	15
301–500	7	25
501–700	8	35
701–1000	9	50
1001–1500	10	75
1501–2000	11	100
2001–3000	12	150
3001–5000	13	200
5001–7500	14	240
7501–10,000	15	275
10,000+	16	300

Example: A municipality has installed 30,000 luminaires incorporating one make and model of adaptive control, and 50 luminaires incorporating a different make and model of adaptive control. Sixteen (16) revenue meters are required to monitor the 30,000 luminaires and 1 revenue meter is required to monitor the other 50 luminaires. If the seller can monitor at least 300 luminaires from the population of 30,000 with fewer than 16 revenue meters, the seller can install the lower number of meters, provided the condition set out in paragraph b) iii below is met.

An end user or a seller may prescribe in the contractual agreement a greater number of revenue meters than the minimum required in Table 1.
A luminaire string to be monitored by a revenue meter must have a total load that falls within the nameplate rating of that revenue meter.
Note: In practice, approximately 10 luminaires designed for a residential street are required to meet the minimum nameplate rating of a revenue meter; however, this number may vary depending on the circuit and the make and model of luminaires.

The end user must ensure that all luminaire strings upon which a revenue meter is installed are free of other unmetered loads. The end user must satisfy the seller that this condition is met on an ongoing basis.
The seller and end user each reserve the right to inspect any such installations in order to gather data and ensure that the conditions established in this bulletin and the contractual arrangement are met.
The seller will monitor, obtain, compare and retain measurement data from the revenue meters and the corresponding strings of luminaires. Data must be retained for the entire period of the installation of the devices plus one year, and be made available to Measurement Canada on request.
Deviations of greater than 3.0% between the revenue meter values and the embedded measurement technology values must be documented and reported to MC for review. That 3% comparison will not include line losses or instrumentation losses. To ensure accuracy of measurement, the seller can establish and apply measurement error corrections (MEC). MEC will be established using electrical engineering principles accounting for system losses applicable to the subject string of luminaires (e.g. transformation and line loss). MEC will be maintained and traceable. A contractual or tariff agreement must specify the MEC applied and how they were calculated for each monitored string, as indicated in subparagraph 7.3 a) vii.
Cases where it is not possible for the seller to install revenue meters as prescribed in paragraphs a), b) and c) above fall outside the scope of this program.
The subject luminaires must meet the requirements of the local electrical authority and be manufactured in accordance with a recognized quality assurance program (e.g. ISO9001).
Manufacturers must provide evidence of a quality program and are expected to provide evidence of or attestation to measurement accuracy as per the condition set out in paragraph k) below.
Adaptive controls which attach externally to luminaires must be classified as conforming to the relevant sections of industry standard ANSI/NEMA C136.48-2018 - American National Standard for Roadway and Area Lighting Equipment -Wireless Networked Lighting Controllers;
Note: The 10% accuracy noted in ANSI/NEMA C136.48-2018 is superseded by the 3% limit of error prescribed by the Electricity and Gas Inspection Act and Regulations.
In addition to meeting the condition set out in paragraph j) above, adaptive controls (including their embedded measurement technology) must:
1. be physically located at each individual luminaire, either embedded within it or externally attached to it;
2. be secured against unauthorized intrusion;
3. be built to withstand environmental conditions as required by the end user;
4. be initially calibrated by the manufacturer:
  - using standards traceable to either MC, the National Research Council of Canada (NRC) or the National Institute for Standards and Technology (NIST);
  - at nominal voltage and frequency, and at expected current levels based on the installation configuration;
  - at any additional test points specified by the seller or end user in the contract;
  - using power sources that provide nominal voltage at ± 3%, and rated frequency ± 0.2 Hz, using supply voltages and currents that are sinusoidal with a distortion factor not greater than 3%;
  - at an ambient temperature of 23 °C ± 5 °C;
  - to result in registration of measured values within ± 3% compared to the reference calibration device;
  - to confirm repeatability of error of registration to be within 1.0% differential from the initial calibration error upon a subsequent calibration;
5. not impart a burden (or self-consumption of the adaptive control device containing the embedded measurement technology) greater than 5 VA;
6. be installed and used in accordance with the requirements or conditions identified in the manufacturer's specifications for installation and use;
7. be used only for trade transactions identified in the scope of the conditional permission granted to the parties.
The device manufacturer must provide to the end user documentation of calibrations performed.
Records of certified test results or statements of accuracy must be retained on file by the end user and made available to MC on request. Records must be retained for the entire period that the device is in service, plus one year.
Exceptions to the conditions set out in paragraphs i), k) iv and l) can be made according to the conditions established in paragraph o) below.
For luminaires installed before this bulletin was issued, a statement of accuracy may be considered where proof of external calibration pursuant to subparagraph k) iv is not possible. MC may request supporting documentation and technical information before accepting such a statement. This statement of accuracy may be provided by an accredited meter verifier. The number of adaptive controls to be tested is determined by Table 2 and must be selected at random from the total luminaire population.

Table 2—Adaptive controls to test
Luminaire population	Number of adaptive controls to be tested
1–500	50
501–1200	100
1201–3200	150
3201–10,000	200
10,000+	250

7.3 Contractual arrangements

Subject to paragraph b) below and subsection 7.1, a contractual or tariff agreement must exist between the parties involved in the energy trade transaction, and must contain the following information:
1. a statement which explains that the transactions are subject to the terms and conditions established in this bulletin, and that a copy of this bulletin may be accessed on MC's website;
2. a statement that the embedded measurement technology subject to the conditional permission will be initially calibrated in accordance with paragraphs 7.2 g) and/or 7.2 h) using a process and procedures acceptable to both parties to the transaction;
3. the jurisdiction (i.e. municipality, city or town) or geographical area to which the permission will apply;
4. a description of, or reference to, the process followed for resolving any measurement disputes arising between the parties (it may be similar to processes currently employed by the seller for non‑metered loads or may refer to provincially mandated processes);
5. a statement acknowledging that the conditional permission and use of unapproved devices will inhibit MC's ability to successfully conclude a measurement dispute investigation should MC's involvement be requested;
6. a statement that the parties involved have agreed to carry out the trade transactions in accordance with the requirements established in this bulletin and that either party has the right to request the revocation of the conditional permission in accordance with the requirements of subsection 7.8;
7. details of any measurement error correction (MEC) formulas and calculations for line losses and instrumentation losses on the luminaire strings monitored by a revenue meter.
  Note: It is recommended that end users and sellers stipulate operating parameters for the power factor and burden (parasitic load) when determining the values to which adaptive controls will operate. Both these factors may uniquely impact a given electrical grid.
Where a contractual or tariff agreement already exists between the parties of the subject trade transactions, the wording of that agreement does not need to be amended. However, the information required in paragraph a) above as well as any additional requirements established herein must be formally documented and agreed to by each party. As well, upon subsequent revision or renewal of the agreement, the conditions established in subsection 7.2 and the information required above must be added to the agreement.

7.4 Process to request a conditional permission

An applicant seeking a conditional permission under this policy must apply in writing to the applicable MC regional office.

The application must be addressed to the President of Measurement Canada and be signed by the applicant's authorized representative who is responsible for ensuring compliance with the EGIA (typically someone in a senior management or executive level position).

The application must include the following information:

the name and principal place of business (i.e. head office) of the seller, including their primary contact person;
the jurisdiction or geographical area where the subject trade transactions will be taking place;
the name and principal place of business (i.e. head office) of the end user (owner of luminaires), including their primary contact person;
the name of the manufacturer of the luminaires incorporating adaptive controls, along with the type, model, serial number (or other unique identifier) and operating ranges;
a list or count of the number of luminaires installed or to be installed by the end user within the jurisdiction or geographical area identified in the application; and
a written attestation of compliance with the requirements of this bulletin.

The MC regional office will review the application for completeness, then forward it to MC's Program Development Directorate for final review and written response to the applicant.

7.5 Reporting elements

For each conditional permission granted, the seller agrees to provide MC with annual reports for the duration of the contractual or tariff agreement. Reports must include the following information:

Results of the energy monitoring, including a comparison between registrations of the revenue meters and those of the embedded measurement technology of the luminaires being monitored. The seller may rely on the end user for some of this data and must inform MC of any impediments to obtaining the required data, and the nature and scope of any such impediments.
The number of embedded measurement technology failure rates and/or failure modes identified (i.e. known to the seller) for each year in service. For applications pertaining to existing installations, an initial report must be submitted identifying failure rates to date. Failures may include, but are not limited to, failed communications, erratic or irreconcilable LUM values, or catastrophic failures.
Any other data obtained by either party involved that may be of use or interest to MC for evaluation purposes.

7.6 Monitoring levels

Monitoring of luminaire energy registration and comparing it to the revenue meter registration is performed for the following purposes:

to provide data for future analysis of the accuracy, integrity and stability over time of the embedded measurement technology;
to provide supporting evidence where embedded measurement technology has not been calibrated by the manufacturer but instead, a sample has been assessed by an accredited meter verifier (AMV) according to paragraph 7.2 o);
to provide foundational evidence of in-service accuracy confidence and continued use where neither the manufacturer nor the AMV have calibrated the embedded measurement technology of the subject luminaires;
to guide future assessment of the program requirements and conditions, and subsequent possible policy directions for installation and use of adaptive street light metering applications.

Note: While not required for the purpose stated in item b, the AMV may make use of Measurement Canada's random sample generator.

A low level of monitoring is required for the purpose stated in item a).

A medium level of monitoring is required for the purpose stated in item b).

A high level of monitoring is required for the purpose stated in item c).

Table 3 below is to be used in conjunction with the outcome from Table 1 to further augment the minimum number of revenue meters or luminaires to be monitored per application.

Table 3—Number of revenue meters or luminaires to be monitored
	Number of revenue meters or luminaires to be monitored according to Table 1	Low level monitoring	Medium level monitoring	High level monitoring
Resulting final number	#	1 x	1.5 x	2 x

7.7 Granting of a conditional permission

The President of MC will grant a conditional permission where the review of the application by MC has concluded that the requirements of this bulletin have been satisfied. The permission will identify the parties involved and state any applicable conditions or limitations to which the parties must comply.

7.8 Revocation of a conditional permission

Failure by either party to comply with the requirements and conditions under which a conditional permission is granted may result in the permission being revoked pursuant to section 11 of the EGIA.

A request for revocation of the conditional permission granted by MC from either party must be made in writing to the other party involved as well as the appropriate MC regional office, and include the following information:

the name of the party seeking the revocation;
the jurisdiction or geographical area to which the revocation applies;
the scope of the request (i.e. whether it applies to all or only a certain number of the subject luminaires within the jurisdiction or geographical area);
the reason(s) or rationale for the proposal to revoke the permission.

A request made in accordance with the above requirements will result in the revocation of the conditional permission.

In cases where the contractual or tariff agreement between the parties is terminated, the owner of the subject luminaires must inform the MC regional office of the agreement's termination. The conditional permission will subsequently be revoked.

8.0 Program review

Measurement Canada will review the program framework, and any existing permissions granted, five years after the effective date of this bulletin. This five-year period will:

provide stability for the sellers and end users;
establish a robust history of comparative metrological data and failure rates; and
provide time to assess the level of satisfaction of the parties.

At the time of the review, if international specifications or other standards are well suited to address the scope of this program, MC may incorporate such specifications by reference or adapt requirements to the current program.

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