When it comes to the security camera requirements of I-502, there is one line specifically that causes major problems in interpretation: Section 3 of WAC 314-55-083.
Its first sentence reads: “At a minimum, a complete video surveillance with minimum camera resolution of 640×470 pixel and must be internet protocol (IP) compatible and recording system for controlled areas within the licensed premises and entire perimeter fencing and gates enclosing an outdoor grow operation, to ensure control of the area.”
Yes, that is verbatim, so we’re going to ignore the fact that this sentence makes no grammatical sense. Instead, we’ll focus on interpreting it so we know what we are actually supposed to install in order to be compliant. To properly explain this, we must discuss the different types of technology used within the surveillance industry. There are a myriad of technologies available with varying benefits and detriments. For the purposes of this article, we will focus on the two most common, separated by the type of cable they use.
1. Analog: This is the traditional video surveillance technology. It uses analog cameras with digital video processing to transmit video from a camera over a single coaxial wire to a DVR, or digital video recorder (digital to analog to digital). The system itself may be IP compatible, but the cameras are not; they are “dumb” devices sending video over cable to be interpreted by the recorder. Newer versions of this technology have brought HD broadcast technology to the table using HD-SDI (high-definition serial digital interface), the same technology used to broadcast HDTV.
Costs are exceptionally reasonable and if going with HD, the video quality is stunning. Although HD-SDI is not technically analog video, it uses the same wire, so I will bundle it with analog.
2. IP video: With IP video, the cameras are transmitting encoded data instead of video over an IP connection using Cat5 or Cat6 network wiring. Using switches, multiple cameras can go over a single wire. Each camera has its own IP address, meaning the camera itself is IP compatible. The cameras are programmable for data rate, quality, resolution and other functions and the recorder is called an NVR (network video recorder). The signal stays digital from source to playback. Resolution can range from truly crappy 320×240 pixels, all the way up 10,240×2,048 pixels — an astounding 20 megapixels. The 20 megapixel resolution is approximately 7,000 percent higher quality than the minimum required by I502 (that’s not a typo). IP video is fully customizable, but, unfortunately, a bit more expensive.
You may already be seeing the conflict here. Based on the letter of the regulation, the requirement is “a complete video surveillance with minimum camera resolution of 640×470 pixel and must be internet protocol (IP) compatible.”
When I interpret this verbatim, my understanding is that the cameras themselves must be IP compatible, not just the system. Because this sentence is grammatically terrible, we may never know if its spirit is different than its meaning as written. Inspectors generally use the regulation as written, though as we all know, that can change depending on the inspector and the day. A simple comma would move the requirement over to the system instead of the camera itself and would save thousands of dollars. Because of this, care must be taken, as the pass/fail is generally up to the individual inspector, and saving some money during the install could potentially mean having to rewire the whole property with a different type of wire and all new cameras, power supplies and recorders.
I will be perfectly clear here: We have sold analog and HD systems to I-502 applicants, knowing and explaining to the applicant that they are not technically compliant and we have seen SOME of them pass. We have also received phone calls from infuriated I-502 applicants who installed an analog system, only to be forced to rewire their entire property, delaying their production by several weeks and inflating their costs unnecessarily. Unfortunately, there is no simple or inexpensive way to change from coax to IP. Plus, there is the added vulnerability to interference from lighting systems, complicated power systems, ballasts and industrial relays, especially in indoor grow operations where this is a genuine concern, regardless of system type.
If an applicant wants to take the risk of installing an analog system, I usually ask them to wire with Cat5 and use baluns to convert the signals. At least this way, if the inspector requires a change to IP cameras, the wiring itself can be reused. It does add some cost and a small amount of complexity, but it helps mitigate the risk and is way cheaper than rewiring. Still, we do not guarantee compliance with analog or HD systems, even if they are more than compliant on every single other requirement. Anyone who does guarantee it probably doesn’t understand the rest of the regulations either.
As stated by an I-502 client: “Every dollar spent on security cameras today is a dollar we can’t spend on dirt, lights, fertilizer and employees and will cost us a thousand dollars by the end of the year.”
This is frustrating, but it’s a decision that needs to be made, especially considering the cost of delays and rewiring due to technical non-compliance. Spend that money once, not twice.
There is more to this equation than just cost. IP camera systems tend to be much more flexible and customizable. With each camera having adjustable data rates, resolution, frame rates and quality levels, an IP camera system can be fine-tuned to ensure 45 days of consistent video. Calculating video storage is an art; cameras use different amounts of data depending on what they see.
Colors, movement and shapes all have varying effects on hard drive usage. So, today you’re getting 45 days, but when your plants are swaying in the wind, you may only get 30 — unless you can control the data rate, which IP cameras allow you to do. Your settings today that get you 45 days will still get you 45 days six months from now if you’re telling the camera exactly what file size to send to the recorder.
Because multiple cameras can be transmitted through a single wire, wiring costs, labor costs and power costs are considerably less with an IP camera system. Because each camera can be set to different resolutions, you can use economies of scale to buy multiple cameras of the same model and use the lowest resolution that provides adequate coverage in order to maximize hard drive storage and quality at the same time.
For outdoor grow operations, it is also important to note that a single recorder can run upwards of 100 cameras. If an inspector requests you to add an extra camera, it’s a piece of cake if you choose the right NVR to begin with.
Analog systems are generally limited to 32 cameras and HD systems to 16 cameras and require being stacked to get beyond those camera counts.
Probably the most interesting function to consider when it comes to IP cameras though, is the ability to turn the infrared night-vision on or off in the software without shutting the system down and becoming non-compliant. It has been speculated that the IR on a night-vision camera can confuse plants and cause them to stretch. The plants need 12 hours of darkness and it is unclear how infrared light used by IR cameras is seen from the plant’s perspective and how it affects production. Stay tuned for a future article as I am working with an approved I-502 farmer to run this exact experiment and get a definitive answer to this extremely important question.
Analog and HD systems have their advantages as well. It’s hard to beat the dollar-to-pixel ratio of an HD surveillance system. The great majority of our non-502 installations are HD because of the great value they provide. However, my interpretation of the regulations, as they are written, require the cameras themselves to be IP compatible.
If the regulation is reworded, or a comma added for clarification, we will be the first to guarantee compliance with analog and HD systems. Unfortunately, you can’t guarantee compliance with the spirit of the law, only the law itself.
The cost of IP camera systems can approach double that of an analog or HD system. However, with careful design and product selection, the cost difference can be contained to a difference of about 25 percent.
This is not a small problem, but one that must be considered carefully and approached in a manner that weighs your relationship with your inspector, your budget, your comfort level pushing the limits of the regulation and your willingness to risk having to do it all over again.
That is not a decision you should allow your provider to make for you and it’s not even one the security industry itself wholly agrees on. Just remember, at the end of the day, it’s the regulation and the inspector that decide, and nobody who is selling you something can predict their attitude on the day of your inspection or how they interpret the regulation.
Armando Perez is the general manager of CCTV Dynamics (www.i502CCTV.com), a surveillance equipment distributor with a focus on system design and custom security camera systems.