Canadian Electrical Code, Part I Full Impact Assessment

Copyright CSA Group 2015 Canadian Electrical Code, Part I Full Impact Assessment Subject 3840 Section 8 Revisions to load calculations

CONTENTS 1 INTRODUCTION TO THE FULL IMPACT ASSESSMENT... 3 2 PURPOSE OF THE FULL IMPACT ASSESSMENT... 3 3 BACKGROUND OF THE CHANGE... 3 4 THE NATURE OF THE CHANGE... 4 4.1 The change... 4 4.2 How is it different from the status quo?... 7 5 PURPOSE/REASON FOR THE CHANGE... 8 5.1 What is the issue that the change is intended to address?... 8 5.2 How does the change accomplish the desired results?... 8 5.3 What are the implications/consequences if action is not taken?... 9 6 WHY IS ACTION REQUIRED AT THIS TIME?... 9 7 (14) PREVALENCE OF RULE USE IF ACCEPTED... 9 8 IMPACT ON KEY STAKEHOLDERS... 9 8.1 (16) Largest type of stakeholder who would benefit... 9 8.2 (24) Largest type of stakeholder who would be negatively affected... 10 8.3 (15) Other stakeholders affected on a frequent basis... 10 8.4 Is the proposed change limited to a specific group/geographic area?... 10 8.5 What is the affected stakeholders readiness to act on the change(s)?... 11 8.6 Recommended stakeholder management strategy... 11 8.7 Communication and implementation plan... 11 9 ANALYSIS OF ANTICIPATED ECONOMIC IMPACT... 11 9.1 (20) The jurisdiction or stakeholder s ability to compete, based on incompatibility with other standards... 11 9.2 (21) Complexity of implementation (is training required to implement the Rule?)... 11 9.3 (22) Total costs to implement (for example, cost to install, educate, manufacture, inspect, purchase additional product, and of the increased use of electricity)... 11 10 IMPACT ON BUSINESS: LARGE AND SMALL (IF APPLICABLE)... 11 11 WHAT IS THE PRACTICE/EXPERIENCE IN OTHER JURISDICTIONS?... 12 Page 1 19/12/2014

11.1 Are standards consistent with (or lesser/greater than) other jurisdictions?... 12 11.2 (23) Conflict with other Ministries or Codes... 12 11.3 Consequences for other Departments/Ministries, e.g., apprentice training... 12 11.4 Consequences for other Codes from other jurisdictions (US, European standards)... 12 12 CONSULTATION PROCESS... 12 13 PROPOSED EFFECTIVE DATE OF CHANGES... 13 APPENDIX 1 CODE RANKING TOOL VALUES... 14 Page 2 19/12/2014

1 INTRODUCTION TO THE FULL IMPACT ASSESSMENT The Full Impact Assessment follows the rationale of the Canadian Electrical Code Ranking Tool (CRT) and provides supporting information to validate the rankings of the CRT. It includes all the questions of the CRT either verbatim or modified. However, the scope of the Full Impact Assessment extends beyond that of the CRT and, therefore, the assessment includes additional questions that may help to substantiate the rankings. The CRT is referenced throughout the Full Impact Assessment. The questions from the CRT are identified in the Full Impact Assessment by numbers in parentheses. Whenever applicable, chapter titles also include references to the relevant sections of the CRT. The Full Impact Assessment follows the sequence of the CRT as closely as possible but, to enhance the analytical function of the document, risk-related and benefits-related questions have not been separated in the Full Impact Assessment. 2 PURPOSE OF THE FULL IMPACT ASSESSMENT The purpose of the Full Impact Assessment is to provide the provinces and territories with an enhanced rationale and detailed assessment of a particular change to the Canadian Electrical Code, Part I (CE Code, Part I). This assessment is submitted for review to provincial and territorial regulatory authorities to aid with their adoption process for the Code. Jurisdictions may decide to conduct further analyses or to hold additional consultations. 3 BACKGROUND OF THE CHANGE Section 8 is a general Section of the Code that specifies ratings for electrical equipment supplying various types of loads and calculates conductor ampacities for consumer s services, feeders, and branch circuits. Section 8 deals with a variety of situations and environments and assigns demand factors to various loads, recognizing that some loads are not likely to attain maximum loading at the same time as certain other loads (e.g., electric heating and air conditioning do not operate in a building at the same time). Section 8 applies demand factors for sizing conductors and overcurrent protection devices that serve a number of different loads. Because it is highly unlikely that all loads would draw maximum current simultaneously, demand factors are used to scale back the full loads of the combined downstream equipment to a lower level Page 3 19/12/2014

The following Rules in the current Code are being affected by the change: (A) Rules 8-204, 8-206, and 8-208 establish a standard method for determining the minimum ampere rating for a service or feeder conductor supplying, respectively, schools; hospitals; and hotels, motels, dormitories, and buildings of similar occupancy. In each Rule, Subrule (1) describes the method of calculating the minimum acceptable ampacity of service or feeder conductors, and Subrule (2) lists the allowable demand factors to be applied to the minimum service or feeder conductor ampacities calculated in Subrule (1). (B) Rule 8-210 provides requirements for determining minimum ampacities for service or feeder conductors for building occupancies other than those covered in Rules 8-200 to 8-208. (C) The method of calculating load by area is not practical when lighting loads on a feeder are not confined to one location within a building. Rule 8-212 establishes an alternative method to the watts per square metre method for calculating loads that are supplied from a single panelboard but not located in one area within a building. (D) Rule 8-302(1) sets requirements for calculating the demands for show window lighting installations. The length of the window is measured at the base and a value of 650 W/m is applied to establish demand. Subrule (2) recognizes that some cycling loads are also continuous. 4 THE NATURE OF THE CHANGE 4.1 The change (A) Add a new Rule 8-002 as follows: Basic load the load of lighting and receptacle circuits, based on the outside dimensions of a specific area of building occupancy, as listed in Table 14. Calculated load the load calculated in accordance with the applicable requirements of this Section. Demonstrated load historical maximum demand watt information recorded over at least a 24-month period for the same type of facility as the one in question, equated to watts per m 2. Page 4 19/12/2014

(B) Add a new Appendix B Note to Rule 8-002 as follows: Rule 8-002 Basic load It is intended by this definition that only a typical lighting and receptacle load within an area bound by the outside dimensions of that area signifies basic load. Such loads as outside lighting, specialty lighting (i.e., stage, show window lighting, etc.), electric space heating, or air-conditioning loads are not intended to be part of the basic load. Code users should be aware that the value of basic load for each particular building occupancy is different and is dependent on the type of occupancy from Table 14 and on load calculation requirements for residential occupancies. Demonstrated load The intent of this definition is to allow comparison of loads that are used in a similar fashion based on the type of fuel source for heating and cooling, type of occupancy, type of occupancy load, and type of operational requirements. It is intended by this definition that comparison may need to be made between facilities in the same geographic area and also in similar climatic conditions. With respect to determining demonstrated load and recognition of qualified persons, Code users should be aware that it may be advisable to consult with the regulatory authority having jurisdiction. (C) Relocate Subrule 8-302(2) to new Subrule 8-104(4) as follows: 8-104(4) A load of a cyclic or intermittent nature shall be classified as continuous unless it meets the requirements of Subrule (3). (D) Add a new Rule 8-106(6) as follows: (6) Where a feeder or service supplies motor or air-conditioning loads, a demand factor as determined by a qualified person shall be permitted to be applied to these loads, provided that a deviation has been allowed in accordance with Rule 2-030. (E) Add a new Rule 8-106(10) as follows: (10) For loads other than those calculated in accordance with Rules 8-200 and 8-202, feeder and service load calculations shall be permitted to be based on demonstrated loads, provided that such calculations are performed by a qualified Page 5 19/12/2014

person, as determined by the regulatory authority having jurisdiction. (F) Add a new Appendix B Note to Rule 8-106(10) as follows: Rule 8-106(10) It is intended by this Subrule that demonstrated load data could be used for the purpose of sizing of services or feeders. It is also intended by this Subrule that the qualified person, as determined by the regulatory authority having jurisdiction, who is responsible for the design should be able, upon request, to demonstrate to the regulatory authority having jurisdiction that historical data related to actual demand substantiates the fact that this historical demand is the maximum possible demand for the specific application. (G) Revise Rules 8-204(1)(c), 8-206(1)(c), and 8-208(1)(c) as follows: 8-204 Schools 8-206 Hospitals 8-208 Hotels, motels, dormitories, and buildings of similar occupancy (see Appendix B) (1) The minimum ampacity of service or feeder conductors shall be based on the following: (a) no change (b) no change (c) electric space-heating, air-conditioning, and power loads total loads of other permanently connected equipment based on the rating of the equipment installed; plus (d) cord-connected equipment intended for connection to receptacles rated more than 125 V or 20 A based on (i) 80% of the rating of the receptacle; or (ii) the rating of the equipment intended for connection to the receptacle. (H) Revise Rule 8-210 as follows: 8-210 Other types of occupancy The minimum ampacity of service or feeder conductors for the types of occupancies specified listed in Table 14 shall be based on the following: (a) a basic load to be calculated on the basis of in watts per square metre as required by Table 14 for the area of the occupancy served based on the outside dimensions of the occupancy, with application of demand factors as indicated therein in Table 14; plus (b) special loads such as electric space-heating, air-conditioning, motor loads, power Page 6 19/12/2014

loads, show window lighting, stage lighting, etc., based on the rating of the equipment installed with demand factors permitted by this Code. (I) Move Rule 8-302(1) to 8-212(2) and revise Rule 8-212 as follows. Rule 8-212 Exit sign, emergency lighting, and show window loads Special lighting circuits (1) Where a panel is supplying specific special types of lighting, such as exit signs lights or emergency lighting lights, which may be located throughout a building such that it is impossible to calculate the area served, the connected load of the circuits involved shall be used in determining a feeder size. (2) For show window lighting installations, the demand load shall be determined on the assumption that not less than 650 W/m will be required measured along the base of the window(s), except a lower figure shall be permitted where a deviation has been allowed in accordance with Rule 2-030. Rule 8-302 connected loads (1) For show window lighting installations, the demand load shall be determined on the assumption that not less than 650 W/m will be required measured along the base of the window(s), except a lower figure shall be permitted where a deviation has been allowed in accordance with Rule 2-030. 4.2 How is it different from the status quo? (A) Currently, Rules 8-204(1), 8-206(1), and 8-208(1) read as follows: 8-204 Schools 8-206 Hospitals 8-208 Hotels, motels, dormitories, and buildings of similar occupancy (see Appendix B) (1) The minimum ampacity of service or feeder conductors shall be based on the following: (a) no change (b) no change (c) electric space-heating, air-conditioning, and power loads based on the rating of the equipment installed. (B) Currently, Rule 8-210 reads as follows: 8-210 Other types of occupancy The minimum ampacity of service or feeder conductors for the types of occupancies Page 7 19/12/2014

specified in Table 14 shall be based on the following: (a) a basic load to be calculated on the basis of watts per square metre required by Table 14 for the area served based on the outside dimensions, with application of demand factors as indicated therein; plus (b) special loads such as electric space-heating, air-conditioning, power loads, show window lighting, stage lighting, etc., based on the rating of the equipment installed with demand factors permitted by this Code. (C) Currently, Rule 8-212 reads as follows: 8-212 Special lighting circuits Where a panel is supplying special types of lighting, such as exit lights or emergency lights, which may be located throughout a building such that it is impossible to calculate the area served, the connected load of the circuits involved shall be used in determining a feeder size. 5 PURPOSE/REASON FOR THE CHANGE 5.1 What is the issue that the change is intended to address? The actual load demand in commercial and industrial facilities can be significantly smaller than the calculated load as mandated by the current Code; this has been documented by data available from utilities. Under the current Code, all locations are treated in the same way for the purposes of load calculations and have to meet the same load minimums. As a result, many services end up under-loaded, with the actual load rarely above 50% of maximum. The industry has voiced a concern that the current Code Rules are unnecessarily limiting with regard to calculating building loads, resulting in greatly oversized electrical service equipment. This leads to the inefficient use of equipment and a greater environmental footprint. In addition, retrofitting more energy-efficient equipment is now possible, and the lack of a demonstrated load option has prevented users from fully exploiting the savings and the environmental advantages. 5.2 How does the change accomplish the desired results? The change is intended to clarify the terminology used in the Code and to improve consistency in its application. It will also allow the use of the new defined terms, Basic load, Calculated load, and Demonstrated load, under special application conditions introduced in Section 8. The introduction of the demonstrated load concept is designed to assist users in implementing a more energy-efficient installation, based on historical maximum demand load data over at least a 2-year period; these data are available from utilities. This change provides engineers/designers with an option for optimizing the size of service equipment and Page 8 19/12/2014

ensuring a more efficient and sustainable electrical installation. A qualified person is required to perform the calculations necessary to demonstrate to the regulatory authority having jurisdiction that the safety objectives of the Code are not compromised. 5.3 What are the implications/consequences if action is not taken? If the status quo persists, it will not be possible to design and install more energy- and costefficient electrical installations with regard to demand load calculations for commercial and industrial facilities. 6 WHY IS ACTION REQUIRED AT THIS TIME? This initiative is not driven by a particular deadline. The industry has asked for the change to permit more efficient and sustainable installations. 7 (14) PREVALENCE OF RULE USE IF ACCEPTED This change will apply to commercial and industrial facilities. Data for residential dwellings are not available. 8 IMPACT ON KEY STAKEHOLDERS 8.1 (16) Largest type of stakeholder who would benefit In the short term, electrical engineers/designers, contractors, and installations owners/ owners of commercial or industrial facilities are the largest groups who will benefit from the change. Engineers/Designers: This stakeholder group will be directly affected by the change because it is their responsibility to specify the minimum required demand load. This group is interested in providing cost-effective and safe designs and installation requirements to minimize the risk of injury to personnel, damage to facilities, and insurance and legal costs. As such, engineers/designers will need to receive a communication about the change (e.g., a formal letter from the authority having jurisdiction). Electrical contractors: This group of stakeholders is responsible for the application of the Code. As such, they need to be informed about changes to it to help ensure full compliance with its requirements. The updates can be delivered through formal training or through industry literature, depending on current practices in a particular jurisdiction. It is the responsibility of individual contractors to keep themselves informed about changes to the Code. Installation owners: This group of stakeholders will benefit immediately from the cost Page 9 19/12/2014

savings resulting from a more efficient use of electrical equipment, the potential for reduced installation costs, and a smaller environmental footprint. They will also benefit from incremental savings derived from operating equipment closer to its optimal load and temperature, resulting in reduced running and maintenance costs. In the long term, the environmental benefits may extend to the community as a whole. 8.2 (24) Largest type of stakeholder who would be negatively affected A stakeholder group that would be negatively affected was not identified. 8.3 (15) Other stakeholders affected on a frequent basis The change will affect a broad range of stakeholder groups, as follows: Trainers: This is a broad group that may include those providing training to other stakeholder groups, such as electrical contractors and installers of equipment as well as repair and maintenance personnel where applicable. Training programs and literature, including electronic content, will need to be updated to include the change. Other standards development organizations (SDOs): All references to the provisions of the Code that are being changed will need to be updated in documents published by other SDOs. Provincial/territorial electrical regulatory authorities: This group of stakeholders is responsible for enforcement of the Code and will, therefore, need to be informed of changes to it. Insurance: Insurance policies contingent on following the Code will need to be updated. Builders: This group will need to be informed of the change because the new requirements will have to be implemented in new construction. Inspectors: This group of stakeholders is accountable for enforcing compliance with the Code and needs, therefore, to stay informed about changes to it. It is the responsibility of a particular province or territory to make the information on Code changes available to electrical inspectors. Depending on the practice in a particular jurisdiction, changes can be communicated through training (provided by the jurisdiction or a third party) or through jurisdiction-specific or national industry literature. 8.4 Is the proposed change limited to a specific group/geographic area? The change will have nationwide application. Page 10 19/12/2014

8.5 What is the affected stakeholders readiness to act on the change(s)? Research has not revealed any evidence of the market not being ready to implement this change. 8.6 Recommended stakeholder management strategy Not applicable. 8.7 Communication and implementation plan Not applicable. 9 ANALYSIS OF ANTICIPATED ECONOMIC IMPACT 9.1 (20) The jurisdiction or stakeholder s ability to compete, based on incompatibility with other standards The change should not negatively affect a jurisdiction s competitive position. On the contrary, in the long run, competitiveness should be boosted by greater sustainability. 9.2 (21) Complexity of implementation (is training required to implement the Rule?) For the most part, the change can be included as an update in existing training programs. The only group who may require targeted training is engineers/designers, but such training can be kept to a minimum if it is provided as routine professional development training. 9.3 (22) Total costs to implement (for example, cost to install, educate, manufacture, inspect, purchase additional product, and of the increased use of electricity) The change is expected to reduce implementation costs. With regard to training, while it is important that the change be communicated to all the relevant stakeholder groups, this can be done in the course of routine training on changes to the Code. No dedicated training is necessary. 10 IMPACT ON BUSINESS: LARGE AND SMALL (IF APPLICABLE) Compliance costs: No additional costs are expected to result from compliance with the change. In fact, compliance may help to reduce project costs. Change of investment: Not applicable. Job creation/job loss. Not applicable. Page 11 19/12/2014

Labour mobility: Not applicable. Impact on import/export of goods: Not applicable. Certification and licensing: Not applicable. Insurance: Not applicable. Canadian Electrical Code, Part I Full Impact Assessment 11 WHAT IS THE PRACTICE/EXPERIENCE IN OTHER JURISDICTIONS? 11.1 Are standards consistent with (or lesser/greater than) other jurisdictions? Currently, there are no deviations from this requirement of the national Code in provincial electrical codes. Input from other jurisdictions is pending. 11.2 (23) Conflict with other Ministries or Codes No conflict has been observed. 11.3 Consequences for other Departments/Ministries, e.g., apprentice training Not applicable. 11.4 Consequences for other Codes from other jurisdictions (US, European standards) Not applicable. 12 CONSULTATION PROCESS Representatives from the following groups of stakeholders were involved in the consensus approval of this change as part of CSA Group s standards development process: Note: For details about the standards development process as it applies to the CE Code, Part I, please refer to Appendix C of the Code. Regulatory authorities from various provincial, territorial, and municipal electrical inspection authorities Owners/Operators/Producers from groups with national stature, representing the viewpoints of electrical equipment manufacturers, electrical installation designers and installers, and electrical installation users General interest groups with national stature, representing the viewpoints of (a) fire chiefs; (b) electric utilities; (c) committees responsible for related electrical codes and standards; (d) fire insurers; (e) labour; (f) issuers of building codes; and Page 12 19/12/2014

(g) educators. Canadian Electrical Code, Part I Full Impact Assessment A regulatory/legislative body may want to hold additional consultations with all or some of these groups within its jurisdiction to clarify issues specific to the jurisdiction. 13 PROPOSED EFFECTIVE DATE OF CHANGES The change will be included in the 2015 edition of the CE Code, Part I, to be published in January 2015. Page 13 19/12/2014

APPENDIX 1 CODE RANKING TOOL VALUES Reason for Change Safety consideration (Severity) Safety consideration (Frequency) Subject # 3840 1 0 For clarity 6 Crucial to harmonize Purely administrative 0 5 Community's desire to change - Environment, Health, Safety 7 Technological change/new Rule 8 Total Score for Reason for Change Extent of Use & Value Add Prevalence of rule use if accepted 27 10 Number of stakeholders affected on frequent basis 10 Largest type of stakeholder who would benefit 10 Benefit to society Total Score for Extent of Use Risk for Changing Rule/Staying Status The jurisdiction or stakeholder's ability to compete based on incompatibility with other standards 10 40 0 Complexity of implementation 8 Total costs to implement, e.g. cost to install, to educate, to manufacture,or inspect, increased product cost, increased cost of electricity. 7 Conflict with other Ministries or Code 0 Largest type of stakeholder who would be negatively affected 1 Total Score for Risk of Changing Rule/ Staying Status Quo 16 Total 83 Page 14 19/12/2014