The subject of jurisdictional demarcation between electrical design of installations required to be performed in accordance with the CE Code, Part I and work by power supply authorities (by electric utilities) is a very big (and very touchy) issue. This subject continuously rises in communication between a number of local utilities and their customers, and the extent of jurisdictional authority of a local utility in respect to the installations done as per the CE Code has been (and still remains) a subject of emotional discussions between electric utilities and electrical design community.
Perhaps, it should be noted at the outset of this article that the CE Code exempts utilities from its scope, (i.e., the scope of the CE Code does not apply to utilities), and installations undertaken by the utilities do not use equipment “approved” (certified) to the CSA safety standards for electrical products, but utilize equipment that is designed and constructed to a variety of engineering standards. As utilities are exempt from the scope of the CE Code, their installations do not have to meet the Code requirements, and utilities might apply their own technical criteria or might use IEEE or engineering standards in this regard.
It should be also noted that only very specific provisions to comply with the power supply authority requirements are articulated in the CE Code, and such provisions apply in respect to the following:
- location of service entrance equipment where “supply service conductors” are terminated;
- location of the revenue meters that must be accessible to the supply authority staff; or
- interconnection arrangements between IPP sources and the supply authority derived system.
These relevant CE Code requirements to comply with supply authority appear in Sections 6; 36; 64 and 84 of the Code as follows:
“6-206 Consumer’s service equipment location (see Appendices B and G)
(1) Service boxes or other consumer’s service equipment shall be
(a) installed in a location that complies with the requirements of the supply authority;“
“6-408 Location of meters
(1) Meters and metering equipment shall be
(a) located as near as practicable to the service box except as provided for in Subrule (2);
(b) grouped where practicable;
(c) readily accessible;
(d) not located in coal bins, clothes closets, bathrooms, stairways, high ambient rooms, dangerous or hazardous locations, nor in any similar undesirable places;
(e) if mounted outdoors, of weatherproof construction or in weatherproof enclosures; and
(f) in compliance with the requirements of the supply authority”.
“36-200 Service equipment location
Service equipment shall be installed in a location that complies with the requirements of the supply authority and, in the case of a building, shall be at the point of service entrance.”
“36-202 Rating and capacity
The type and ratings of circuit breakers, fuses, and switches, including the trip settings of circuit breakers and the interrupting capacity of overcurrent devices, shall be
(a) in compliance with Rule 14-012(a) and (b);
(b) in compliance with the requirements of the supply authority for consumer’s service equipment;“
“64-112 Utility-interactive point of connection (see Appendix B)
(1) The output of a utility-interactive inverter or power conditioning unit shall be connected to the supply authority system in accordance with Section 84” .
“84-002 General requirement (see Appendix B)
The interconnection arrangements shall be in accordance with the requirements of the supply authority.“
In light of such CE Code provisions, some of electrical permit application forms published by the local electrical safety authorities contain the following statement that must be confirmed by the applicant for an electrical permit:
“Electrical characteristic of the supply service, overhead service point of attachment and pole location, types of underground service raceways have been confirmed with and accepted by the electric utility/power supply authority.”
The significance of this statement is to emphasize very specific instances where compliance with the utility requirements is necessary in conjunction with the above-quoted Rules of the Code.
It should be noted that in addition to the criteria for compliance with the supply authority requirements, the CE Code defines “supply authority” and defines types of “services” in this regard as follows:
- “Service, consumer’s – all that portion of the consumer’s installation from the service box or its equivalent up to and including the point at which the supply authority makes connection”.
- “Service, supply – any one set of conductors run by a supply authority from its mains to a consumer’s service”.
- “Supply authority – any person, firm, corporation, company, commission, or other organization supplying electric energy”.
These Code definitions in conjunction with the above-stated requirements clearly indicate to an electrical permit holder that the supply authority/utility must be consulted on the following:
(a) electrical characteristics of a supply service provided by the utility (i.e., on a single or three phase supply and on the voltage of the supply service),
(b) location of overhead point of attachment,
(c) location of a consumer’s service and metering equipment, and
(d) types of underground consumer’s service raceways when such raceways are intended for the installation of “supply service” conductors (conductors installed by the utility).
It is interesting to note that the CE Code does not have a single requirement for installation of “supply services”, as “supply service” is undertaken by the supply authority/utility, and as such – is exempt from the scope of the Code.
A typical electric utility has a complete authority for development of technical standards and policies in respect to the installation of the utility owned electrical infrastructure, if such installation does not represent regulated work in accordance with the legal requirements of local AHJs.
These technical standards and policies developed by a utility are intended for the utility staff performing electrical work for installation of the utility-owned equipment.
However, there are many instances when technical standards published by a utility for installation of the utility-owned equipment, are mandated by the utility for use by the electrical designers and electrical installers, when such utility owned and operated equipment is located on a private property.
Usually, electrical designers are prepared to comply with the utility technical requirements, although these electrical designers cannot be held accountable if the utility technical standards or specifications are not consistent with the provisions of the legally adopted CE Code.
Thus, when, for example, the grounding of the utility owned high-voltage pad-mounted transformer is reflected in the electrical designers’ drawings during their electrical design project for a client, the electrical designers cannot attest that the grounding of the utility owned pad-mounted transformer located on the client’s property, does, indeed, comply with the relevant provisions of Section 36 of the CE Code, as such design was done not according to the CE Code, but in compliance with the utility standards.
Furthermore, when installation performed in accordance with the utility technical requirements is completed, electrical designers cannot state that the test of the HV station ground resistance meets provisions of Rule 36-304(1) of the CE Code, as in these cases – the grounding design for such HV station was not performed in accordance with the CE Code. Therefore, when a utility imposes on the electrical design community testing of the station ground electrode resistance to Rule 36-304 of the CE Code in order to validate that the technical requirements of the utility standards are not compromised, such utility requirements could be subjected to valid challenges.
Of course, it would be ideal, if the technical requirements of utilities would be consistent with technical provisions of the CE Code. Hopefully, this approach may be developed in the future.
Meanwhile, as it was mentioned at the outset of this article, heated discussions on this issue are taking place between utilities and the members of the electrical design community, until perhaps a legal challenge will set a precedent towards consistency between the utilities and design community on this matter across the country.
Meanwhile (as usual), local electrical safety regulatory authorities should be consulted when any discussions take place in respect to any regulated work for installation of regulated equipment.