It should be done through a connection authorization - Should be consistent for all LDCs, to avoid interpretation, public safety risk and liability

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1 Company/ Organization/ Individual Local Distribution Company (LDC) Electro Federation Canada (EFC) Rule # Stakeholder Comment/ Feedback Submitted to ESA & Suggestions for Improvement/ Alternatives It should be consistently applied for all utilities in the province - Code side work should not be at the direction of LDC - Having no proof of whether licensed electrician is done is difficult and would add administrative burden on management of the process - in the installation example TH tried in the field along with Steve Smith, ESA GM, there was work required to install this device to the meter-base neutral bar, which would require a connection authorization in order to ensure public safety and manage liability It should be done through a connection authorization - Should be consistent for all LDCs, to avoid interpretation, public safety risk and liability We still have issues with deletion of the majority of , contrary to text in red below. The red text is withdrawn but the rest related to rule 02-xxx does stand as acceptable to EFC. Our concerns may now actually been increased with the much more narrowly limited The concern related to flammability, which was the too vague aspect of , (1)(a), but was somewhat salvaged by (2). As noted in the earlier , a member told me during the breakfast meeting last week that a contractor strung together in series about 100 of LED decorative lighting strips, installing a larger driver to boast the current, not even thinking that the tiny wiring in those strips would NOT be able to handle to higher current. It started a fire and they complained back to the member looking for redress. The contractor realized the error once explained. So, while the change to rule 02-xxx provides greater clarity, the deletions to rule may imply even greater latitude for load side Class 2 circuits not requiring approval. ESA Response Rule (f) that exempts a meter mounted transfer device from an application for inspection was introduced into the Ontario Electrical Safety Code in The installation of a meter-base plug-in transfer device without application for inspection is only permitted if the work is done by Licensed Electrical Contractor (LEC). If a supply authority cannot determine that LEC has done the installation, Subrule (2) gives the option to ask for application for inspection. Also, if a supply authority does not permit the installation of a meter-base plug-in transfer device, Subrule (2) gives the option to reject that installation. The suggestion has been considered and certain changes in part have been made based on the comments. Specifically, the changes are made in the Appendix B note based on the comments. The purpose of the proposed amendment is based on the requirements in the updated CSA standard C22.2 No. 37 Christmas tree and other decorative lighting outfits. In accordance with the updated standard, decorative lighting strings are required to be marked with the warning label to prevent overloading the circuit.

2 Licensed Electrical Contractor (LEC) Instead I recommend being specific on (1)(a) as follows, plus a modified Appendix B. Sentence (2) can still be deleted as rule is now clear enough Equipment located on the load side of overcurrent protection, transformers, or current-limiting devices for Class 2 circuits (1) Equipment located on the load side of overcurrent protection, transformers, or current-limiting devices for Class 2 circuits shall (a) for Class 2 circuits operating at not more than 42.4 V peak or dc, but may carry power greater than 100 VA requires approved for that purpose be acceptable for the particular application; and (b) for Class 2 circuits operating at more than 42.4 V peak or dc be arranged so that no live parts are accessible to unauthorized persons. (2) Notwithstanding Subrule (1), lighting products, electromedical equipment, equipment for hazardous locations, and thermostats incorporating heat anticipators shall be approved. Delete Replace the CE Code Appendix B Note to Rule (1)(a). Rule (1)(a) With respect to the acceptance of equipment for connection to Class 2 circuits operating at not more than 42.4 V peak or dc, consideration should be given to the fact that while Class 2 circuits limit the power that can be dissipated in the circuit continuously, this power is more than sufficient to be a fire hazard if dissipated in a fault within improperly designed equipment, e.g., shorted turns in a coil, or too many decorative light strings are serially connected to exceed their rating Most quality gas ranges that include convection and or self-cleaning options require the 50-A receptacle or similar to power those features. The information regarding these options is rarely available at the time of roughing-in and is often not determined until the delivery

3 Contractor Advisory Council (COAC) of the appliance. Rough-in box, cover, and empty conduit (FNMC or other) to close proximity of service panel for installation of wiring if required at a later date The COAC does not agree with the proposal of the requirement to remove the stove outlets. Consumer As the second consultation seeks feedback on "all other" Ontario amendments to the Ontario Electrical Safety Code, and a recommendation for: "Removal of the mandatory requirement to install an electric range receptacle for all dwelling units. This amendment harmonizes with CEC and aligns with the Building Code requiring one source of energy; electrical, propane or natural gas, for cooking appliances." Consumer Advisory Council Consumer Advisory Council Again, I sense the cooperation of another organization to support an E.S.A. and business interest. What about the Ontario consumer's preference to have an electrical source as mandatory while requesting an other option? It is better to make the investment to add receptacles first than try to retrofit later. The Council agreed that the OESC should not be changed and that an electrical outlet should still be required This amendment will have to be communicated to consumers. ESA is working with CSA to update the requirements in the certification standard in order to require proper luminaire marking for luminaires suitable for installation in clothes closets. Advances in LED technology broadened the application of this

4 Licensed Electrical Contractor (LEC) (e) The code rule consideration for installing smoke detectors on a arc fault bedroom circuit, should not happen. My reason for this is under the event of a power outage, ppl use a generator, which is fine but some of the inrush voltage is too much for the breaker and inadvertently trips, there for leaving the smoke detectors running on simply the battery. This will cause nuisance calls, and we are going the wrong way with our life safety devices. This isn't a theory, we have run across this a good many times just finding arc fault breakers tripped after an outage The other matter is trying to work with the building departments more in regards to smoke detectors. Now they are asking for a flashing device to be added to all smoke detectors. the is a building code rule not a CEC issue. Bottom line is that the end user is going feel taken or mislead with the 2 departments can't seem to commutate. I feel that these devices do not needed to be added throughout every home for the hearing impaired. I understand the purpose. I feel that yes the hearing impaired should have an additional life safety device, but not for every home across the province. They could be installed on a special request basis under a grant program perhaps. I just think we are over complicating things. RV Park While we welcome the guidance on this very important issue and agree with the proposal to have standardized rules for campground owners to follow, detailed discussions need to cover off acceptable expectations where availability of equipment and timelines for upgrades are concerned. Compliance will be dependent on reliable supply sources and availability of technicians to perform what will be a costly upgrade for the industry. Please consider these very important aspects of bringing the industry into compliance. type of illumination so the heat emission may not be the issue in the future. Although the ESA proposal was based on the updated Building Code and product standard requirements, considering the progress with the proposal at Canadian Code, we feel that it is prudent to wait with this permission until the next Canadian Electrical Code (CEC) when products with battery backup are widely available. Please be advised that the OESC is not retroactive. The proposed amendment will not be enforced retroactively, that is to say existing RV parks will not be required to update their infrastructure to comply. The proposed amendments would only apply to new installations where a power pedestal has been provided for on an RV lot.

5 Camping in Ontario/ Ontario Private Campground Association RMOH/ Wastewater Infrastructure Change wording of recreational vehicle parks to campgrounds. Campground is the word used by the industry and Ontario government to describe "trailer parks, or travel trailer parks or RV parks". The Actual length of the Electrical Supply cord and the position of the exit point from the recreational vehicle (Park model, Travel trailer, Motor home, Tent Trailer or Hybrid) The longer the unit is the more imperative that the exit point be on the left side and more removed from the rear of the unit. Appendix B Notes on Rules, Rule Sewage lift and treatment plants Make Wording more inclusive by adding the word Campground to preamble so that it is consistent with the other documentation. You could also increase the length of the electrical cables required on any unit over a certain length, say 8.53m. Every meter in length over 8.53 would require a corresponding 1.5 meter increase in the length of the electrical cord The applicability and application of NFPA 820 Standard for Fire Protection in Wastewater Treatment and Collection Facilities has been causing confusion during the design of wastewater infrastructure. This confusion is realised in discordant infrastructure designs, deviation from the Ontario Electrical Safety Code (OESC), and designs incongruent with Occupational Health and Safety Act protections for worker safety (e.g. Confined Spaces Regulation) and Environmental Protection Act for regulated process emissions (s.9). NFPA 820 does not address corrosion protection, advocates for non-essential equipment within Class 1, Zone 1, Category 2 areas, relies on continuous ventilation of process emissions in conflict with Provincial regulations, and does not address worker safety protections. NFPA 820 advocates for CGD as a fire protection The word campground is used by the industry and Ontario government to describe trailer parks, or travel trailer parks or RV parks. To change from park to campground would be in conflict with the various standards used throughout North America with respect to recreational vehicles ((RV) and recreational vehicle parks. With respect to the length and location of the electrical cord on the RV, this has already been addressed within the certification standard for RVs (Z240 RV). Provided the RV is approved for use, the electrical cord will always be able to reach the power pedestal, regardless of RV length, provided the power pedestal is installed as per the proposed Ontario amendment, which harmonizes the manufacturing standard (length and location) with the power pedestal location on the RV lot. Unfortunately we are unable to consider new code proposals at this point in the process. Should you wish to submit a code change proposal to the CEC, it will be reviewed through the normal process for the next code cycle, and will be considered for adoption in Ontario.

6 measure, the Electrical Safety Code only requires their use under Rule and suggests proper area classification should eliminate the need in most situations,[1] and identifies limitation with their use as a failure to perform may give a false indication that an area is safe.[2] Halton s operational practices require the use of handheld (calibrated/tested) multi-gas detectors to properly determine the atmospheric hazards of a confined space. Combustible Gas Detection in the wet well does not further electrical safety or fire prevention as the location has been designated Class 1, Zone 1, Category 2 and fails to address the human health and life-safety risk of entering a confined space, most notably hydrogen sulphide and oxygen deficiency; however by its very presence may be inadvertently judged as an indication of safe conditions within the confined space. Rule should further clarify that conformance with NFPA 820 is not implied and does not satisfy the OESC Rule 18 or 22 (including Bulletin & ), and should not be considered a substitute for proper hazard assessment further adding NFPA 820 is not adopted by the Authority Having Jurisdiction in Ontario and does not conform to the OESC, technical bulletins, and relevant Provincial legislation for worker safety and air emissions. The ESA should clarify that it does not encourage continuous ventilation of wet wells, for de-rating of electrical classification, fire protection, or corrosion prevention, as this process exhaust would be a prohibited discharge of contaminants(environmental Protection Act, R.S.O c. E.19, s. 6 (1)). Remove references to NFPA 820 (Appendix B and Bulletins). Example: A dry well should be suitably cut-off from the wet well, providing a location classification for the below grade

7 portion of dry wells as Category 1 in accordance with the Electrical Safety Code.[3] The classification recommendations include Class I, Div 2 under NFPA 820 for a dry well without continuous ventilation. Master Electrician General I find that there are too many legal and unintelligible phrases in the electrical code and request that the electrical code be re-written in a more understandable grammatical format. I understand that the building code uses a more understandable phraseology, so why shouldn't the electrical code? The code is undergoing continuous changes to clarify wording. If you have changes to suggest, please refer to Appendix C of the OESC.