national fire protection association · public comment no. 995 section no. 690.7(a) bill brooks...

National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org

NEC Code-Making Panel 4

Second Draft Meeting Agenda

November 2-7, 2015

San Diego, CA

Item No. Subject 15-11 -1 Call to Order 15-11-2 Introduction of Members and Guests 15-11-3 Approval of A2016 First Draft Meeting Minutes 15-11-4 Review of Meeting Procedures and Revision Schedule 15-11-5 Task Group Reports 15-11-6 Process Public Comments and Develop Second Revisions 15-11-7 Fire Protection Research Foundation Requests 15-11-8 Old Business 15-11-9 New Business 15-11-10 Adjournment

Public Comment No. 1063 Global Input submitted

Public Comment No. 626 Section No. 100, Field Labeled (as MARVIN HAMON

Public Comment No. 715 Section No. 100, Field Labeled (as Scott Humphrey

Public Comment No. 917 Section No. 100, Field Labeled (as MARK BALDASSARI

Public Comment No. 1258 100, Energy Storage System, Pre‐e submitted

Public Comment No. 125 Article 225 Aaron Adamczyk

Public Comment No. 1754 Section No. 225.10 submitted

Public Comment No. 526 Section No. 225.18 J. Grant Hammett

Public Comment No. 527 Section No. 225.19(D)(2) J. Grant Hammett

Public Comment No. 332 Section No. 225.22 DON GANIERE

Public Comment No. 1134 Section No. 225.27

Public Comment No. 306 Section No. 225.27 TIMOTHY CROUSHORE


Public Comment No. 37 Section No. 225.30(F) J GRANT HAMMETT

Public Comment No. 793 Section No. 225.30(F) JOHN MASARICK

Public Comment No. 813 Section No. 225.32 James Dollard

Public Comment No. 1756 Section No. 225.38(C) submitted

Public Comment No. 1091 Section after 225.40 Vincent Saporita

Public Comment No. 823 Section after 225.40 VINCE BACLAWSKI

Public Comment No. 304 Section after 230.2(A) TIMOTHY CROUSHORE

Public Comment No. 346 Section after 230.3 DARRELL SUMBERA


Public Comment No. 528 Section No. 230.9(B) J. Grant Hammett


Public Comment No. 360 Section No. 230.29 MIKE HOLT

Public Comment No. 967 Section No. 230.29 Christine Porter

Public Comment No. 1758 Section No. 230.30(A) submitted


Public Comment No. 858 Section No. 230.41 L. Keith Lofland

Public Comment No. 1120 Section No. 230.42(A) JEFFREY FECTEAU



Public Comment No. 1148 Section No. 230.44 Christel Hunter


Public Comment No. 700 Section No. 230.44 Richard Loyd

Public Comment No. 864 Section No. 230.53 L. Keith Lofland

Public Comment No. 333 Section No. 230.54(C) DON GANIERE

Public Comment No. 1122 Section No. 230.66 JEFFREY FECTEAU






Public Comment No. 406 Section No. 230.66 ROLAND DEIKE

Public Comment No. 772 Section No. 230.66 JOHN MASARICK

Public Comment No. 1265 Section after 230.66 submitted

Public Comment No. 979 Section after 230.70(A)(1) Matthew Paiss

Public Comment No. 1082 Section No. 230.70(A)(1) Vincent Saporita

Public Comment No. 1591 Section No. 230.70(A)(1) submitted



Public Comment No. 334 Section No. 230.95(C) DON GANIERE

Public Comment No. 126 Section No. 230.200 Aaron Adamczyk

Public Comment No. 643 Section No. 690, Part VIII. Ward Bower



Public Comment No. 647 Section No. 690.1 Ward Bower

Public Comment No. 1360 691.2, Engineering Supervision. submitted





Public Comment No. 648 Section No. 690.2, Generating Cap Ward Bower

Public Comment No. 1847 690.2, Photovoltaic System Voltagesubmitted

Public Comment No. 1018 Section No. 690.2, Reference GrouBill Brooks

Public Comment No. 1324 Section No. 690.4(B) submitted

Public Comment No. 586 Section No. 690.4(B) MARK BALDASSARI

Public Comment No. 649 Section No. 690.4(D) Ward Bower

Public Comment No. 889 Section No. 690.4(D) MARK BALDASSARI




Public Comment No. 1074 Section No. 690.7 JIM EICHNER

Public Comment No. 1883 Section No. 690.7

Public Comment No. 587 Section No. 690.7 MARK BALDASSARI

Public Comment No. 1198 Section No. 690.7(A) BRIAN LYDIC

Public Comment No. 276 Section No. 690.7(A) MARVIN HAMON

Public Comment No. 588 Section No. 690.7(A) MARK BALDASSARI

Public Comment No. 995 Section No. 690.7(A) Bill Brooks

Public Comment No. 492 Section No. 690.7(B) MARVIN HAMON


Public Comment No. 1169 Section No. 690.10 Bill Brooks

Public Comment No. 499 Section No. 690.10 MARVIN HAMON






Public Comment No. 1081 Section No. 690.12 P Cocker

Public Comment No. 1210 Section No. 690.12 Richard Davis












Public Comment No. 483 Section No. 690.12 Corey Condren


Public Comment No. 887 Section No. 690.12 JOHN JUSTICE



Public Comment No. 1104 Section No. 690.12(B) Geoffrey Kinsey













Public Comment No. 1224 Section No. 690.12(B) CHARLES PICARD

Public Comment No. 1693 Section No. 690.12(E) submitted

Public Comment No. 502 Section No. 690.12(F)(2) MARVIN HAMON

Public Comment No. 891 Section after 690.12(F)(2) James Penn



Public Comment No. 924 Section No. 690.13(B) Todd Fries

Public Comment No. 927 Section No. 690.13(B) MARIA BAYLIS

Public Comment No. 653 Section No. 690.13(C) Ward Bower


Public Comment No.1001 Section No. 690.13(F)

Public Comment No. 922 Section No. 690.15 Todd Fries

Public Comment No. 1269 Section No. 690.15 [Excluding any submitted





Public Comment No. 1002 Section No. 690.15(D) Bill Brooks

Public Comment No. 1598 Section No. 690.15(D) submitted

Public Comment No. 654 Section No. 690.15(D) Ward Bower

Public Comment No. 925 Section No. 690.15(D) Todd Fries


Public Comment No. 511 Section No. 690.31(B)(1) MARVIN HAMON

Public Comment No. 1003 Section No. 690.31(C) Bill Brooks

Public Comment No. 1163 Section No. 690.31(C) Christel Hunter



Public Comment No. 478 Section No. 690.31(C) MIKE HOLT

Public Comment No. 479 Section No. 690.31(C) MIKE HOLT

Public Comment No. 1163 Section No. 690.31(C) Christel Hunter

Public Comment No. 1398 Section No. 690.31(D) submitted



Public Comment No. 670 Section No. 690.31(E) Ward Bower

Public Comment No. 1004 Section No. 690.31(G) Bill Brooks

Public Comment No. 897 Section No. 690.31(G)(3) MARK BALDASSARI

Public Comment No. 898 Section No. 690.31(G)(4) MARK BALDASSARI

Public Comment No. 519 Section No. 690.31(J) MARVIN HAMON



Public Comment No. 513 Section No. 690.34 JEFFREY FECTEAU



Public Comment No. 493 Section No. 690.8(A)(1) MARVIN HAMON

Public Comment No. 996 Section No. 690.8(A)(1) Bill Brooks

Public Comment No. 1085 Section No. 690.8(B) JIM EICHNER



Public Comment No. 1090 Section No. 690.9(B) JIM EICHNER


Public Comment No. 989 Section No. 690.9(B) PHIL UNDERCUFFLER


Public Comment No. 999 Section No. 690.9(C) Bill Brooks



Public Comment No. 1562 Section No. 690.41(B)(1) submitted

Public Comment No. 1631 Section No. 690.41(B)(2) submitted

Public Comment No. 671 Section No. 690.41(B)(2) Ward Bower

Public Comment No. 900 Section No. 690.41(B)(2) MARK BALDASSARI








Public Comment No. 936 Section No. 690.47(A) MARK BALDASSARI

Public Comment No. 1179 Section No. 690.47(B) DAVID CLEMENTS








Public Comment No. 619 Section No. 690.56(C) MARVIN HAMON

Public Comment No. 997 Section No. 690.56(C) PHIL UNDERCUFFLER


Public Comment No. 1158 Section No. 690.61 PHIL UNDERCUFFLER






Public Comment No. 1146 Sections 690.72(B), 690.72(C) PHIL UNDERCUFFLER

Public Comment No. 915 Section No. 690.72(B)(3) MARK BALDASSARI






Public Comment No. 1711 Article 691 submitted





Public Comment No. 730 Section No. 691.1 Scott Humphrey

Public Comment No. 702 691.2, Engineering Supervision. Scott Humphrey

Public Comment No. 713 691.2, Engineering Supervision. Scott Humphrey

Public Comment No. 1149 Section No. 691.2, Engineering SupBill Brooks

Public Comment No. 620 Section No. 691.2, Engineering SupMARVIN HAMON

Public Comment No. 621 Section No. 691.2, Generating Cap MARVIN HAMON

Public Comment No. 628 Section No.691.2, Generating StatiMARVIN HAMON

Public Comment No. 716 Section No. 691.2, Utility DistributiScott Humphrey

Public Comment No. 622 Section No.691.2, Utility Dis... to UMARVIN HAMON

Public Comment No. 717 Section No. 691.2, Utility Transmis Scott Humphrey



















Public Comment No. 1708 Section No. 694, Part after I. submitted



Public Comment No. 656 Section No. 694.1 Robert Wills

Public Comment No. 809 Section No. 694.2 Tower Marcelo Hirschler

Public Comment No. 808 Section No.694.2, Guy+B278 Marcelo Hirschler


Public Comment No. 1403 Section No. 694.7(F) submitted



Public Comment No. 1521 Section No. 705, Part IV. submitted



Public Comment No. 1638 705.2 Intentionally Islanded Systemsubmitted

Public Comment No. 1864 705.2, Intentionally Islanded Syste submitted

Public Comment No. 1457 705.2, Island Interconnection Devicsubmitted

Public Comment No. 1484 705.2, Island Interconnection Devicsubmitted

Public Comment No. 1006 Section No. 705.2, Intentionally IslaPHIL UNDERCUFFLER

Public Comment No. 919 Section No. 705.2, Multimode InveMARK BALDASSARI

Public Comment No. 1506 705.2, Stand‐Alone System. submitted











Public Comment No. 1076 Section No. 705.12(D) [Excluding a MARVIN HAMON

Public Comment No. 1162 Section No. 705.12(D)(2) Bill Brooks

Public Comment No. 1164 Section No. 705.12(D)(2) JOEL FRANGQUIST]

Public Comment No. 1356 Section No. 705.12(D)(2) submitted

Public Comment No. 1164 Section No. 705.12(D)(2) [ Not Specified ]

Public Comment No. 1079 Section No. 705.12(D)(5) MARVIN HAMON












Public Comment No. 1014 Section No. 705.175 [Excluding anyPHIL UNDERCUFFLER

Public Comment No. 1063-NFPA 70-2015 [ Global Input ]

Article 100 Definitions

Voltage, Nominal…..Informational Note No. 3: Certain 48-volt DC battery units have a charging float voltage up to 58 volts. In DCapplications 60 volts is used to cover the entire range of float voltages.

Article 110

110.27 Guarding of Live Part(A) Live Parts Guarded Against Accidental Contact. Except as elsewhere required or permitted by this Code, live parts ofelectrical equipment operating at 50 volts AC/60 volts DC or more shall be guarded against accidental contact by approvedenclosures or by any of the following means:

Article 200 Use and Identification of Grounded Conductors

200.7

(B) Circuits of Less Than 50 Volts AC. A conductor with white or gray color insulation or three continuous white stripes orhaving a marking of white or gray at the termination for circuits of less than 50 volts AC shall be required to be grounded only asrequired by 250.20(A).C) Circuits of 50 Volts AC or More. The use of insulation that is white or gray or that has three continuous white or gray stripesfor other than a grounded conductor for circuits of 50 volts AC or more shall be permitted only as in (1) and (2).

Article 215 Feeders

215.12(C)(2) Feeders Supplied from Direct-Current Systems.Where a feeder is supplied from a dc system operating at more than 50 60 volts, each ungrounded conductor of 4 AWG orlarger shall be identi?ed by polarity at all termination, connection, and splice points by marking tape, tagging, or otherapproved means; each ungrounded conductor of 6 AWG or smaller shall be identi?ed by polarity at all termination,connection, and splice points in compliance with 215.12(C)(2)(a) and (b). The identi?cation methods utilized forconductors originating within each feeder panelboard or similar feeder distribution equipment shall be documented ina manner that is readily available or shall be permanently posted at each feeder panelboard or similar feederdistribution equipment.Article 430 Motors, Motor Circuits, and Controllers

430.232 Where Required. Exposed live parts of motors and controllers operating at 50 volts DC or more between terminalsshall be guarded against accidental contact by enclosure or by location as follows:

430.233 Guards for Attendants. Where live parts of motors or controllers operating at over 50 volts AC to ground are guardedagainst accidental contact only by location as specified in 430.232, and where adjustment or other attendance may benecessary during the operation of the apparatus, suitable insulating mats or platforms shall be provided so that the attendantcannot readily touch live parts unless standing on the mats or platforms.

Article 445 Generators

445.14 Protection of Live Parts. Live parts of generators operated at more than 50 volts AC/60 volts DC to ground shall notbe exposed to accidental contact where accessible to unquali?ed persons.

Article 460 Capacitors

460.6 (A) Time of Discharge. The residual voltage of a capacitor shall be reduced to 50 volts DC , nominal, or less within 1minute after the capacitor is disconnected from the source of supply.

460.28(A) Means for Discharge. A means shall be provided to reduce the residual voltage of a capacitor to 50 volts DC or lesswithin 5 minutes after the capacitor is disconnected from the source of supply.Article 480 Storage Batteries

480.5 Overcurrent Protection for Prime Movers. Overcurrent protection shall not be required for conductors from a batterywith a nominal voltage of 60 volts DC or less if the battery provides power for starting, ignition, or control of primemovers. Section 300.3 shall not apply to these conductors.

480.6 DC Disconnect Methods. (A) Disconnecting Means. A disconnecting means shall be provided for all ungroundedconductors derived from a stationary battery system with a nominal voltage over 60 volts DC. A disconnecting meansshall be readily accessible and located within sight of the battery system.

Article 522 Control Systems for Permanent Amusement Attractions

522.25 Ungrounded Control Circuits. Separately derived ac and 2-wire dc circuits and systems 50 volts AC/60 volts DC orgreater shall be permitted to be ungrounded, provided that all the following conditions are met:

Article 625

625.18 Interlock. Electric vehicle supply equipment shall be provided with an interlock that de-energizes the electricvehicle connector whenever the electrical connector is uncoupled from the electric vehicle. An interlock shall not berequired for portable cord-and-plug-connected electric vehicle supply equipment intended for connection to

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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receptacle outlets rated at 125 volts, single phase, 15 and 20 amperes. An interlock shall not be required for dcsupplies less than 50 60 volts dc.

625.19 Automatic De-Energization of Cable. The electric vehicle supply equipment or the cable-connectorcombination of the equipment shall be provided with an automatic means to de-energize the cable conductors andelectric vehicle connector upon exposure to strain that could result in either cable rupture or separation of the cablefrom the electric connector and exposure of live parts. Automatic means to de-energize the cable conductors andelectric vehicle connector shall not be required for portable cord-and-plug-connected electric vehicle supplyequipment intended for connection to receptacle outlets rated at 125 volts, single phase, 15 and 20 amperes. Aninterlock shall not be required for dc supplies less than 50 60 volts dc.

625.44 Electric Vehicle Supply Equipment Connection.

Electric vehicle supply equipment shall be permitted to be cord and plug-connected to the premises wiring system inaccordance with one of the following:

(A) Connections to 125-Volt, Single-Phase, 15 and 20-Ampere Receptacle Outlets. Electric vehicle supply equipment intendedfor connection to non-locking, 2-pole,3-wire grounding-type receptacle outlets rated at 125 V, single phase, 15 and 20 amperesor from a supply of less than 50 60 volts dc.

(4) Supply Circuits. The supply circuit to the mechanical ventilation equipment shall be electrically interlocked withthe electric vehicle supply equipment and shall remain energized during the entire electric vehicle charging cycle.Electric vehicle supply equipment shall be marked in accordance with625.15. Electric vehicle supply equipmentreceptacles rated at 125 volts, single phase, 15 and 20 amperes shall be marked in accordance with 625.15 andshall be switched, and the mechanical ventilation system shall be electrically interlocked through the switch supplypower to the receptacle. Electric vehicle supply equipment supplied from less than 50 60 volts dc shall be marked inaccordance with 625.15(C) and shall be switched, and the mechanical ventilation system shall be electricallyinterlocked through the switch supply power to the electric vehicle supply equipment.

Article 669 Electroplating

669.6 Wiring Methods. Conductors connecting the electrolyte tank equipment to the conversion equipment shall bein accordance with 669.6(A) and (B).

(A) Systems Not Exceeding 50 60 Volts Direct Current. Insulated conductors shall be permitted to be run without insulatedsupport, provided they are protected from physical damage. Bare copper or aluminum conductors shall be permitted wheresupported on insulators.

(B) Systems Exceeding 50 60 Volts Direct Current. Insulated conductors shall be permitted to be run on insulatedsupports, provided they are protected from physical damage. Bare copper or aluminum conductors shall be permittedwhere supported on insulators and guarded against accidental contact up to the point of termination in accordancewith 110.27.

A rticle 720 Circuits and Equipment Operating at Less than 50 Volts

Circuits and Equipment Operating at Less Than 50 Volts AC/60 Volts DC.

720.1 Scope. This article covers installations operating at less than 50 volts, alternating current, or 60 volts direct current oralternating current .

720.11 Mechanical Execution of Work. Circuits operating at less than 50 volts AC or 60 volts DC shall be installedin a neat and workmanlike manner. Cables shall be supported by the building structure in such a manner that thecable will not be damaged by normal building use.Type your content here ...

Statement of Problem and Substantiation for Public Comment

Over the past decade numerous code articles have been placed into the NEC as a result of the increased resurgence of DC systems. These systems, similar to their AC counterpart, have mandated code requirements that must be met when the system voltage exceeds a certain threshold. For years the system threshold for many of the requirements has been kept at the 50 volt level. While this is appropriate for AC systems, it can create confusion to the user of the document when applied to a 48 DC batteries during charging where a “float voltage” is common at 58 volts. The float voltage can vary significantly depending on battery chemistry, battery construction, and the actual ambient temperature. This voltage may be constant for the entire duration of the charge or can fluctuate. Some 48 volt DC systems stay above the 50 volt threshold for 99% of the time for applications such as telecommunications, UPS systems and emergency lighting.

This elevated voltage may create confusion since various AHJ’s might see 58 volts and mandate that a code rule must be followed since the 50 volt threshold has been increased. To resolve these issues a DC task group was formed to research the DC systems found in the NEC and to correlate the various DC topics that were being added to the NEC. The task group recommended the use of 60 volt DC throughout the code to eliminate the confusion that could arise from the elevated float voltage. The intent of the task group was to provide a consistent use of the voltage threshold within the NEC document.

For the 2017 NEC Revision Cycle, a task group was formed to correlate the use of the 50/60V threshold and provide public comments for the second draft. The task group members Larry Ayer (Chair), Bill Cantor, Donny Cook, Jim Dollard (Co-Chair), John Kovacik (DC Task Group Chair), Ernie Gallo, Vince Saporita, and Jim White provided input and guidance for these recommendations.

To correlate the use of 50 volts for AC systems and 60 volts for DC systems, the recommended NEC changes are based on the following:


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1. Where a code section refers to AC systems only and indicates 50 volts the acronym “AC” was added to provide clarity. 2. Where a code section refers to a requirement used only in a DC system at a 50 volt threshold, the voltage is revised to 60 volts and the term “DC” is added3. Where a code section indicates a 50 volt threshold, and the section is a requirement for both AC and DC systems, the text is revised as “50 volts AC/60 volts DC”.4. When a code section refers to DC systems, and the term “nominal” is used, it will be deleted since the voltage threshold is increased to 60 volts.5. A fine print note is being recommended in Article 100 below the definition for “Nominal Voltage” to provide additional information on float voltage.

NEC changes are being recommended for the following code sections:

1. *Add informational note after “Voltage, Nominal”. Informational note to read as follows:*

*Informational Note No. 3: Certain 48-volt DC battery units use a charging float voltage up to 58 volts. In DC applications 60 volts is used to cover the entire range of float voltages.*

2. For section 110.27, “50 volts” is being changed to “50 volts AC/60 volts DC”. This will clarify the voltage threshold for AC and DC systems.

3. Section 200.7 (B) and (C) applies to conductor marking for AC systems only. “AC” is added after 50 volts to clarify that this requirement is only for AC systems.

4. Section 210.5(C)(2) was revised in the First draft that changed “50 volts” to “60 volts” to correlate with the new microgrid article. Revise section 215.12(C) from“50 volts” to “60 volts” to correlate with section 210.5(C)(2).

5. In section 445.14, revise “50 volts” to 50 volts AC/60 volts DC” to clarify that this requirement pertains to both AC and DC systems.

6. In sections 480.5 and 480.6 “50 volts” was changed to “60 volts” since these pertain to DC batteries and DC systems.

7. In section 522.25, “50 volts” is being changed to “50 volts AC / 60 volts DC” to clarify that this section pertains to both AC and DC systems and distinguishes between the two voltage systems and thresholds.

8. Article 625, Electrical Vehicle Charging System. Revise the text from “50 volts” to“60 volts” since these are DC systems.

9. Section 669.6(A) and (B) are DC systems. Revise the text from“50 volts” to “60 volts”

10. Section 690.71 (B) is a DC system with a threshold of 50 volts. Revise the text from “50 volts” to “60 volts DC”.

11. Article 720 Circuits and Equipment Operating at Less Than 50 Volts covers both AC and DC systems. To correlate the Title has been changed to “50 Volts AC/60 Volts DC”. The Scope 720.1 and section 720.11 have been modified to clarify that this Article applies to both systems with the corresponding voltage.

Related Item

Public Input No. 3681-NFPA 70-2014 [Global Input]

Submitter Information Verification

Submitter Full Name: Lawrence Ayer

Organization: Biz Com Electric, Inc.

Affilliation: IEC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Sep 23 14:39:50 EDT 2015


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Public Comment No. 626-NFPA 70-2015 [ Definition: Field Labeled (as applied to evaluated products... ]

Field Labeled Labeling (as applied to evaluated products).

Equipment or materials to which has been attached a label, symbol, or other identifying mark of an field evaluation body (FEB)indicating the equipment or materials were evaluated and found to comply with requirements as described in an accompanyingfield evaluation report. [790, 2012]


Text changed to be the same as how it is referenced in the rest of the text of 691

Related Item

First Revision No. 7511-NFPA 70-2015 [New Section after 690.74(A)]


Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Sat Sep 12 17:43:29 EDT 2015


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Field Labeled (as applied to evaluated products).

Equipment or materials to which has been attached a label, symbol, or other identifying mark of an field evaluation body (FEB)indicating the equipment or materials were evaluated and found to comply with requirements as described in an accompanyingfield evaluation report. [ 790, 2012]


This section should be removed. Field evaluations (FE) are not defined in the NEC and are subject to interpretation by both NRTL’s and non-NRTL’s (private test labs). At what level of review is the FE process? Is testing required? Is document review only required? How or who qualifies the certification body performing the evaluation? What are the certification requirements of the test lab? Is the evaluator a licensed architect or civil engineer?

Related Item

Public Input No. 3289-NFPA 70-2014 [New Section after 690.91]


Submitter Full Name: Scott Humphrey

Organization: LA County DPW

Affilliation: Building and Safety

Street Address:

City:

State:

Zip:

Submittal Date: Thu Sep 17 19:38:33 EDT 2015


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Equipment or materials to which has been attached a label, symbol, or other identifying mark of an field evaluation body (FEB)indicating the equipment or materials were evaluated and found to comply with requirements as described in an accompanyingfield evaluation report. [790, 2012]


A reference to 790,2012 needs to be added. It is not clear what this refers to. Is it a NEC Code? ANSI standard? Other?

Related Item



Submitter Full Name: MARK BALDASSARI

Organization: ENPHASE ENERGY

Street Address:

City:

State:

Zip:

Submittal Date: Tue Sep 22 11:37:00 EDT 2015


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Public Comment No. 125-NFPA 70-2015 [ Article 225 ]

Article 225 Outside Branch Circuits and Feeders

225.1 Scope.

This article covers requirements for outside branch circuits and feeders run on or between buildings, structures, or poles on thepremises; and electrical equipment and wiring for the supply of utilization equipment that is located on or attached to the outsideof buildings, structures, or poles.

Informational Note: For additional information on wiring over 1000 volts, see ANSI see IEEE C2-2007 2012 , NationalElectrical Safety Code.

225.3 Other Articles.

Application of other articles, including additional requirements to specific cases of equipment and conductors, is shown in Table225.3.

Table 225.3 Other Articles

Equipment/Conductors Article

Branch circuits 210

Class 1, Class 2, and Class 3 remote-control, signaling, and power-limited circuits 725

Communications circuits 800

Community antenna television and radio distribution systems 820

Conductors for general wiring 310

Electrically driven or controlled irrigation machines 675

Electric signs and outline lighting 600

Feeders 215

Fire alarm systems 760

Fixed outdoor electric deicing and snow-melting equipment 426

Floating buildings 553

Grounding and bonding 250

Hazardous (classified) locations 500

Hazardous (classified) locations — specific 510

Marinas and boatyards 555

Messenger-supported wiring 396

Mobile homes, manufactured homes, and mobile home parks 550

Open wiring on insulators 398

Over 1000 volts, general 490

Overcurrent protection 240

Radio and television equipment 810

Services 230

Solar photovoltaic systems 690

Swimming pools, fountains, and similar installations 680

Use and identification of grounded conductors 200

Part I. General

225.4 Conductor Covering.

Where within 3.0 m (10 ft) of any building or structure other than supporting poles or towers, open individual (aerial) overheadconductors shall be insulated for the nominal voltage. The insulation of conductors in cables or raceways, except Type MI cable,shall be of thermoset or thermoplastic type and, in wet locations, shall comply with 310.10(C). The insulation of conductors forfestoon lighting shall be of the rubber-covered or thermoplastic type.

Exception: Equipment grounding conductors and grounded circuit conductors shall be permitted to be bare or covered asspecifically permitted elsewhere in this Code.

225.5 Size of Conductors 600 Volts, Nominal, or Less.

The ampacity of outdoor branch-circuit and feeder conductors shall be in accordance with 310.15 based on loads asdetermined under 220.10 and Part III of Article 220.

225.6 Conductor Size and Support.


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(A) Overhead Spans.

Open individual conductors shall not be smaller than the following:

(1) For 1000 volts, nominal, or less, 10 AWG copper or 8 AWG aluminum for spans up to 15 m (50 ft) in length, and 8 AWGcopper or 6 AWG aluminum for a longer span unless supported by a messenger wire

(2) For over 1000 volts, nominal, 6 AWG copper or 4 AWG aluminum where open individual conductors, and 8 AWG copperor 6 AWG aluminum where in cable

(B) Festoon Lighting.

Overhead conductors for festoon lighting shall not be smaller than 12 AWG unless the conductors are supported by messengerwires. In all spans exceeding 12 m (40 ft), the conductors shall be supported by messenger wire. The messenger wire shall besupported by strain insulators. Conductors or messenger wires shall not be attached to any fire escape, downspout, or plumbingequipment.

225.7 Lighting Equipment Installed Outdoors.

(A) General.

For the supply of lighting equipment installed outdoors, the branch circuits shall comply with Article 210 and 225.7(B) through(D).

(B) Common Neutral.

The ampacity of the neutral conductor shall not be less than the maximum net calculated load current between the neutralconductor and all ungrounded conductors connected to any one phase of the circuit.

(C) 277 Volts to Ground.

Circuits exceeding 120 volts, nominal, between conductors and not exceeding 277 volts, nominal, to ground shall be permittedto supply luminaires for illumination of outdoor areas of industrial establishments, office buildings, schools, stores, and othercommercial or public buildings.

(D) 1000Volts Between Conductors.

Circuits exceeding 277 volts, nominal, to ground and not exceeding 1000 volts, nominal, between conductors shall be permittedto supply the auxiliary equipment of electric-discharge lamps in accordance with 210.6(D) (1).

225.8 Calculation of Loads 1000 Volts, Nominal, or Less.

(A) Branch Circuits.

The load on outdoor branch circuits shall be as determined by 220.10.

(B) Feeders.

The load on outdoor feeders shall be as determined by Part III of Article 220.


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225.10 Wiring on Buildings (or Other Structures).

The installation of outside wiring on surfaces of buildings (or other structures) shall be permitted for circuits of not over 1000volts, nominal, as the following:

(1) Auxiliary gutters

(2) Busways

(3) Cable trays

(4) Cablebus

(5) Electrical metallic tubing (EMT)

(6) Flexible metal conduit (FMC)

(7) Intermediate metal conduit (IMC)

(8) Liquidtight flexible metal conduit (LFMC)

(9) Liquidtight flexible nonmetallic conduit (LFNC)

(10) Messenger-supported wiring

(11) Multiconductor cable

(12) Open wiring on insulators

(13) Reinforced thermosetting resin conduit (RTRC)

(14) Rigid metal conduit (RMC)

(15) Rigid polyvinyl chloride conduit (PVC)

(16) Type MC cable

(17) Type MI cable

(18) Type UF cable

(19) Wireways

Circuits of over 1000 volts, nominal, shall be installed as provided in 300.37.

225.11 Feeder and Branch-Circuit Conductors Entering, Exiting, or Attached to Buildings or Structures.

Feeder and branch-circuit conductors entering or exiting buildings or structures shall be in installed in accordance with therequirements of 230.52. Overhead branch circuits and feeders attached to buildings or structures shall be installed inaccordance with the requirements of 230.54.

225.12 Open-Conductor Supports.

Open conductors shall be supported on knobs, racks, brackets, or strain insulators, that are made of glass, porcelain, or otherapproved materials.

225.14 Open-Conductor Spacings.

(A) 1000 Volts, Nominal, or Less.

Conductors of 1000 volts, nominal, or less, shall comply with the spacings provided in Table 230.51(C).

(B) Over 1000 Volts, Nominal.

Conductors of over 1000 volts, nominal, shall comply with the spacings provided in 110.36 and 490.24.

(C) Separation from Other Circuits.

Open conductors shall be separated from open conductors of other circuits or systems by not less than 100 mm (4 in.).

(D) Conductors on Poles.

Conductors on poles shall have a separation of not less than 300 mm (1 ft) where not placed on racks or brackets. Conductorssupported on poles shall provide a horizontal climbing space not less than the following:

(1) Power conductors below communications conductors — 750 mm (30 in.)

(2) Power conductors alone or above communications conductors:

(3) 300 volts or less — 600 mm (24 in.)

(4) Over 300 volts — 750 mm (30 in.)

(5) Communications conductors below power conductors — same as power conductors

(6) Communications conductors alone — no requirement

225.15 Supports over Buildings.

Supports over a building shall be in accordance with 230.29.

225.16 Attachment to Buildings.


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(A) Point of Attachment.

The point of attachment to a building shall be in accordance with 230.26.

(B) Means of Attachment.

The means of attachment to a building shall be in accordance with 230.27.

225.17 Masts as Supports.

Only feeder or branch-circuit conductors specified within this section shall be permitted to be attached to the feeder and/orbranch-circuit mast. Masts used for the support of final spans of feeders or branch circuits shall be installed in accordance with225.17(A) and (B).

(A) Strength.

The mast shall have adequate strength or be supported by braces or guys to safely withstand the strain imposed by theoverhead feeder or branch-circuit conductors. Hubs intended for use with a conduit serving as a mast for support of feeder orbranch-circuit conductors shall be identified for use with a mast.

(B) Attachment.

Feeder and/or branch-circuit conductors shall not be attached to a mast where the connection is between a weatherhead or theend of the conduit and a coupling where the coupling is located above the last point of securement to the building or otherstructure, or where the coupling is located above the building or other structure.

225.18 Clearance for Overhead Conductors and Cables.

Overhead spans of open conductors and open multiconductor cables of not over 1000 volts, nominal, shall have a clearance ofnot less than the following:

(1) 3.0 m (10 ft) — above finished grade, sidewalks, or from any platform or projection from which they are reachable wherethe voltage does not exceed 150 volts to ground and accessible to pedestrians only

(2) 3.7 m (12 ft) — over residential property and driveways, and those commercial areas not subject to truck traffic where thevoltage does not exceed 300 volts to ground

(3) 4.5 m (15 ft) — for those areas listed in the 3.7 m (12 ft) classification where the voltage exceeds 300 volts to ground

(4) 5.5 m (18 ft) — over public streets, alleys, roads, parking areas subject to truck traffic, driveways on other than residentialproperty, and other land traversed by vehicles, such as cultivated, grazing, forest, and orchard

(5) 7.5 m (24 1⁄2 ft) — over track rails of railroads

225.19 Clearances from Buildings for Conductors of Not over 1000 Volts, Nominal.

(A) Above Roofs.

Overhead spans of open conductors and open multiconductor cables shall have a vertical clearance of not less than 2.7 m (8 ft6 in.) above the roof surface. The vertical clearance above the roof level shall be maintained for a distance not less than 900mm (3 ft) in all directions from the edge of the roof.

Exception No. 1: The area above a roof surface subject to pedestrian or vehicular traffic shall have a vertical clearance fromthe roof surface in accordance with the clearance requirements of 225.18.

Exception No. 2: Where the voltage between conductors does not exceed 300, and the roof has a slope of 100 mm in 300 mm(4 in. in 12 in.) or greater, a reduction in clearance to 900 mm (3 ft) shall be permitted.

Exception No. 3: Where the voltage between conductors does not exceed 300, a reduction in clearance above only theoverhanging portion of the roof to not less than 450 mm (18 in.) shall be permitted if (1) not more than 1.8 m (6 ft) of theconductors, 1.2 m (4 ft) horizontally, pass above the roof overhang, and (2) they are terminated at a through-the-roof racewayor approved support.

Exception No. 4: The requirement for maintaining the vertical clearance 900 mm (3 ft) from the edge of the roof shall not applyto the final conductor span where the conductors are attached to the side of a building.

(B) From Nonbuilding or Nonbridge Structures.

From signs, chimneys, radio and television antennas, tanks, and other nonbuilding or nonbridge structures, clearances —vertical, diagonal, and horizontal — shall not be less than 900 mm (3 ft).

(C) Horizontal Clearances.

Clearances shall not be less than 900 mm (3 ft).

(D) Final Spans.

Final spans of feeders or branch circuits shall comply with 225.19(D)(1) , (D)(2), and (D)(3).

(1) Clearance from Windows.

Final spans to the building they supply, or from which they are fed, shall be permitted to be attached to the building, but theyshall be kept not less than 900 mm (3 ft) from windows that are designed to be opened, and from doors, porches, balconies,ladders, stairs, fire escapes, or similar locations.

Exception: Conductors run above the top level of a window shall be permitted to be less than the 900 mm (3 ft) requirement.


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(2) Vertical Clearance.

The vertical clearance of final spans above or within 900 mm (3 ft) measured horizontally of platforms, projections, or surfacesfrom which they are reachable shall be maintained in accordance with 225.18.

(3) Building Openings.

The overhead branch-circuit and feeder conductors shall not be installed beneath openings through which materials may bemoved, such as openings in farm and commercial buildings, and shall not be installed where they obstruct entrance to theseopenings.

(E) Zone for Fire Ladders.

Where buildings exceed three stories or 15 m (50 ft) in height, overhead lines shall be arranged, where practicable, so that aclear space (or zone) at least 1.8 m (6 ft) wide will be left either adjacent to the buildings or beginning not over 2.5 m (8 ft) fromthem to facilitate the raising of ladders when necessary for fire fighting.

225.20 ProtectionAgainst Physical Damage.

Conductors installed on buildings, structures, or poles shall be protected against physical damage as provided for services in230.50.

225.21 Multiconductor Cables on Exterior Surfaces of Buildings (or Other Structures).

Supports for multiconductor cables on exterior surfaces of buildings (or other structures) shall be as provided in 230.51.

225.22 Raceways on Exterior Surfaces of Buildings or Other Structures.

Raceways on exteriors of buildings or other structures shall be arranged to drain and shall be listed or approved for use in wetlocations.

225.24 Outdoor Lampholders.

Where outdoor lampholders are attached as pendants, the connections to the circuit wires shall be staggered. Where suchlampholders have terminals of a type that puncture the insulation and make contact with the conductors, they shall be attachedonly to conductors of the stranded type.

225.25 Location of Outdoor Lamps.

Locations of lamps for outdoor lighting shall be below all energized conductors, transformers, or other electric utilizationequipment, unless either of the following apply:

(1) Clearances or other safeguards are provided for relamping operations.

(2) Equipment is controlled by a disconnecting means that is lockable in accordance with 110.25.

225.26 Vegetation as Support.

Vegetation such as trees shall not be used for support of overhead conductor spans.

225.27 Raceway Seal.

Where a raceway enters a building or structure from outside, it shall be sealed. Spare or unused raceways shall also be sealed.Sealants shall be identified for use with cable insulation, conductor insulation, bare conductor, shield, or other components.

Part II. Buildings or Other Structures Supplied by a Feeder(s) or Branch Circuit(s)

225.30 Number of Supplies.

A building or other structure that is served by a branch circuit or feeder on the load side of a service disconnecting means shallbe supplied by only one feeder or branch circuit unless permitted in 225.30(A) through (F). For the purpose of this section, amultiwire branch circuit shall be considered a single circuit.

Where a branch circuit or feeder originates in these additional buildings or other structures, only one feeder or branch circuitshall be permitted to supply power back to the original building or structure, unless permitted in 225.30(A) through (F).

(A) Special Conditions.

Additional feeders or branch circuits shall be permitted to supply the following:

(1) Fire pumps

(2) Emergency systems

(3) Legally required standby systems

(4) Optional standby systems

(5) Parallel power production systems

(6) Systems designed for connection to multiple sources of supply for the purpose of enhanced reliability

(7) Electric vehicle charging systems listed, labeled, and identified for more than a single branch circuit/feeder


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(B) Special Occupancies.

By special permission, additional feeders or branch circuits shall be permitted for either of the following:

(1) Multiple-occupancy buildings where there is no space available for supply equipment accessible to all occupants

(2) A single building or other structure sufficiently large to make two or more supplies necessary

(C) Capacity Requirements.

Additional feeders or branch circuits shall be permitted where the capacity requirements are in excess of 2000 amperes at asupply voltage of 1000 volts or less.

(D) Different Characteristics.

Additional feeders or branch circuits shall be permitted for different voltages, frequencies, or phases, or for different uses suchas control of outside lighting from multiple locations.

(E) Documented Switching Procedures.

Additional feeders or branch circuits shall be permitted to supply installations under single management where documentedsafe switching procedures are established and maintained for disconnection.

(F) One- or Two-Family Dwelling Unit(s).

For a one- or two-family dwelling unit(s) with multiple feeders, it shall be permissible to install not more than six disconnectsgrouped at one location where the feeders enter the building, provided the feeder conductors are sized 1/0 or larger andoriginate at the same location.

225.31 Disconnecting Means.

Means shall be provided for disconnecting all ungrounded conductors that supply or pass through the building or structure.

225.32 Location.

The disconnecting means shall be installed either inside or outside of the building or structure served or where the conductorspass through the building or structure. The disconnecting means shall be at a readily accessible location nearest the point ofentrance of the conductors. For the purposes of this section, the requirements in 230.6 shall be utilized.

Exception No. 1: For installations under single management, where documented safe switching procedures are establishedand maintained for disconnection, and where the installation is monitored by qualified individuals, the disconnecting meansshall be permitted to be located elsewhere on the premises.

Exception No. 2: For buildings or other structures qualifying under the provisions of Article 685, the disconnecting means shallbe permitted to be located elsewhere on the premises.

Exception No. 3: For towers or poles used as lighting standards, the disconnecting means shall be permitted to be locatedelsewhere on the premises.

Exception No. 4: For poles or similar structures used only for support of signs installed in accordance with Article 600, thedisconnecting means shall be permitted to be located elsewhere on the premises.

Exception No. 5: For electric vehicle charging systems, the disconnecting means shall be installed in accordance with 625.42.

225.33 Maximum Number of Disconnects.

(A) General.

The disconnecting means for each supply permitted by 225.30 shall consist of not more than six switches or six circuit breakersmounted in a single enclosure, in a group of separate enclosures, or in or on a switchboard or switchgear. There shall be nomore than six disconnects per supply grouped in any one location.

Exception: For the purposes of this section, disconnecting means used solely for the control circuit of the ground-faultprotection system, or the control circuit of the power-operated supply disconnecting means, installed as part of the listedequipment, shall not be considered a supply disconnecting means.

(B) Single-Pole Units.

Two or three single-pole switches or breakers capable of individual operation shall be permitted on multiwire circuits, one polefor each ungrounded conductor, as one multipole disconnect, provided they are equipped with identified handle ties or a masterhandle to disconnect all ungrounded conductors with no more than six operations of the hand.

225.34 Grouping of Disconnects.

(A) General.

The two to six disconnects as permitted in 225.33 shall be grouped. Each disconnect shall be marked to indicate the loadserved.

Exception: One of the two to six disconnecting means permitted in 225.33, where used only for a water pump also intended toprovide fire protection, shall be permitted to be located remote from the other disconnecting means.

(B) Additional Disconnecting Means.

The one or more additional disconnecting means for fire pumps or for emergency, legally required standby or optional standbysystem permitted by 225.30 shall be installed sufficiently remote from the one to six disconnecting means for normal supply tominimize the possibility of simultaneous interruption of supply.


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225.35 Access to Occupants.

In a multiple-occupancy building, each occupant shall have access to the occupant’s supply disconnecting means.

Exception: In a multiple-occupancy building where electric supply and electrical maintenance are provided by the buildingmanagement and where these are under continuous building management supervision, the supply disconnecting meanssupplying more than one occupancy shall be permitted to be accessible to authorized management personnel only.

225.36 Type of Disconnecting Means.

The disconnecting means specified in 225.31 shall be comprised of a circuit breaker, molded case switch, general-use switch,snap switch, or other approved means. Where applied in accordance with 250.32(B), Exception No. 1, the disconnecting meansshall be suitable for use as service equipment.

225.37 Identification.

Where a building or structure has any combination of feeders, branch circuits, or services passing through it or supplying it, apermanent plaque or directory shall be installed at each feeder and branch-circuit disconnect location denoting all otherservices, feeders, or branch circuits supplying that building or structure or passing through that building or structure and thearea served by each.

Exception No. 1: A plaque or directory shall not be required for large-capacity multibuilding industrial installations under singlemanagement, where it is ensured that disconnection can be accomplished by establishing and maintaining safe switchingprocedures.

Exception No. 2: This identification shall not be required for branch circuits installed from a dwelling unit to a second buildingor structure.

225.38 Disconnect Construction.

Disconnecting means shall meet the requirements of 225.38(A) through (D).

(A) Manually or Power Operable.

The disconnecting means shall consist of either (1) a manually operable switch or a circuit breaker equipped with a handle orother suitable operating means or (2) a power-operable switch or circuit breaker, provided the switch or circuit breaker can beopened by hand in the event of a power failure.

(B) Simultaneous Opening of Poles.

Each building or structure disconnecting means shall simultaneously disconnect all ungrounded supply conductors that itcontrols from the building or structure wiring system.

(C) Disconnection of Grounded Conductor.

Where the building or structure disconnecting means does not disconnect the grounded conductor from the groundedconductors in the building or structure wiring, other means shall be provided for this purpose at the location of the disconnectingmeans. A terminal or bus to which all grounded conductors can be attached by means of pressure connectors shall bepermitted for this purpose.

In a multisection switchboard or switchgear, disconnects for the grounded conductor shall be permitted to be in any section ofthe switchboard or switchgear, if the switchboard section or switchgear section is marked to indicate a grounded conductordisconnect is located within.

(D) Indicating.

The building or structure disconnecting means shall plainly indicate whether it is in the open or closed position.

225.39 Rating of Disconnect.

The feeder or branch-circuit disconnecting means shall have a rating of not less than the calculated load to be supplied,determined in accordance with Parts I and II of Article 220 for branch circuits, Part III or IV of Article 220 for feeders, or Part Vof Article 220 for farm loads. Where the branch circuit or feeder disconnecting means consists of more than one switch or circuitbreaker, as permitted by 225.33, combining the ratings of all the switches or circuit breakers for determining the rating of thedisconnecting means shall be permitted. In no case shall the rating be lower than specified in 225.39(A), (B), (C), or (D).

(A) One-Circuit Installation.

For installations to supply only limited loads of a single branch circuit, the branch circuit disconnecting means shall have a ratingof not less than 15 amperes.

(B) Two-Circuit Installations.

For installations consisting of not more than two 2-wire branch circuits, the feeder or branch-circuit disconnecting means shallhave a rating of not less than 30 amperes.

(C) One-Family Dwelling.

For a one-family dwelling, the feeder disconnecting means shall have a rating of not less than 100 amperes, 3-wire.

(D) All Others.

For all other installations, the feeder or branch-circuit disconnecting means shall have a rating of not less than 60 amperes.

225.40 Access to Overcurrent Protective Devices.

Where a feeder overcurrent device is not readily accessible, branch-circuit overcurrent devices shall be installed on the loadside, shall be mounted in a readily accessible location, and shall be of a lower ampere rating than the feeder overcurrent device.


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Part III. Over 1000 Volts.

225.50 Sizing of Conductors.

The sizing of conductors over 1000 volts shall be in accordance with 210.19(B) for branch circuits and 215.2(B) for feeders.

225.51 Isolating Switches.

Where oil switches or air, oil, vacuum, or sulfur hexafluoride circuit breakers constitute a building disconnecting means, anisolating switch with visible break contacts and meeting the requirements of 230.204(B), (C), and (D) shall be installed on thesupply side of the disconnecting means and all associated equipment.

Exception: The isolating switch shall not be required where the disconnecting means is mounted on removable truck panels orswitchgear units that cannot be opened unless the circuit is disconnected and that, when removed from the normal operatingposition, automatically disconnect the circuit breaker or switch from all energized parts.


(A) Location.

A building or structure disconnecting means shall be located in accordance with 225.32, or, if not readily accessible, it shall beoperable by mechanical linkage from a readily accessible point. For multibuilding industrial installations under singlemanagement, it shall be permitted to be electrically operated by a readily accessible, remote-control device in a separatebuilding or structure.

(B) Type.

Each building or structure disconnect shall simultaneously disconnect all ungrounded supply conductors it controls and shallhave a fault-closing rating not less than the maximum available short-circuit current available at its supply terminals.

Exception: Where the individual disconnecting means consists of fused cutouts, the simultaneous disconnection of allungrounded supply conductors shall not be required if there is a means to disconnect the load before opening the cutouts. Apermanent legible sign shall be installed adjacent to the fused cutouts and shall read DISCONNECT LOAD BEFOREOPENING CUTOUTS.

Where fused switches or separately mounted fuses are installed, the fuse characteristics shall be permitted to contribute to thefault closing rating of the disconnecting means.

(C) Locking.

Disconnecting means shall be lockable in accordance with 110.25.

Exception: Where an individual disconnecting means consists of fused cutouts, a suitable enclosure capable of being lockedand sized to contain all cutout fuse holders shall be installed at a convenient location to the fused cutouts.

(D) Indicating.

Disconnecting means shall clearly indicate whether they are in the open “off” or closed “on” position.

(E) Uniform Position.

Where disconnecting means handles are operated vertically, the “up” position of the handle shall be the “on” position.

Exception: A switching device having more than one “on” position, such as a double throw switch, shall not be required tocomply with this requirement.

(F) Identification.

Where a building or structure has any combination of feeders, branch circuits, or services passing through or supplying it, apermanent plaque or directory shall be installed at each feeder and branch-circuit disconnect location that denotes all otherservices, feeders, or branch circuits supplying that building or structure or passing through that building or structure and thearea served by each.

225.56 Inspections and Tests.

(A) Pre-Energization and Operating Tests.

The complete electrical system design, including settings for protective, switching, and control circuits, shall be prepared inadvance and made available on request to the authority having jurisdiction and shall be performance tested when first installedon-site. Each protective, switching, and control circuit shall be adjusted in accordance with the system design and tested byactual operation using current injection or equivalent methods as necessary to ensure that each and every such circuit operatescorrectly to the satisfaction of the authority having jurisdiction.

(1) Instrument Transformers.

All instrument transformers shall be tested to verify correct polarity and burden.

(2) Protective Relays.

Each protective relay shall be demonstrated to operate by injecting current or voltage, or both, at the associated instrumenttransformer output terminal and observing that the associated switching and signaling functions occur correctly and in propertime and sequence to accomplish the protective function intended.

(3) Switching Circuits.

Each switching circuit shall be observed to operate the associated equipment being switched.


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(4) Control and Signal Circuits.

Each control or signal circuit shall be observed to perform its proper control function or produce a correct signal output.

(5) Metering Circuits.

All metering circuits shall be verified to operate correctly from voltage and current sources in a similar manner to protective relaycircuits.

(6) Acceptance Tests.

Complete acceptance tests shall be performed, after the substation installation is completed, on all assemblies, equipment,conductors, and control and protective systems, as applicable, to verify the integrity of all the systems.

(7) Relays and Metering Utilizing Phase Differences.

All relays and metering that use phase differences for operation shall be verified by measuring phase angles at the relay underactual load conditions after operation commences.

(B) Test Report.

A test report covering the results of the tests required in 225.56(A) shall be delivered to the authority having jurisdiction prior toenergization.

Informational Note: For an example of acceptance specifications, see NETA ATS-2007 2013 , Acceptance TestingSpecifications for Electrical Power Distribution Equipment and Systems, published by the InterNational Electrical TestingAssociation.

225.60 Clearances over Roadways, Walkways, Rail, Water, and Open Land.

(A) 22 kV, Nominal, to Ground or Less.

The clearances over roadways, walkways, rail, water, and open land for conductors and live parts up to 22 kV, nominal, toground or less shall be not less than the values shown in Table 225.60.

(B) Over 22 kV Nominal to Ground.

Clearances for the categories shown in Table 225.60 shall be increased by 10 mm (0.4 in.) per kV above 22,000 volts.

(C) Special Cases.

For special cases, such as where crossings will be made over lakes, rivers, or areas using large vehicles such as miningoperations, specific designs shall be engineered considering the special circumstances and shall be approved by the authorityhaving jurisdiction.

Informational Note: For additional information, see ANSI see IEEE C2-2007 2012 , National Electrical Safety Code.

Table 225.60 Clearances over Roadways, Walkways, Rail, Water, and Open Land

Clearance

Location m ft

Open land subject to vehicles, cultivation, or grazing 5.6 18.5

Roadways, driveways, parking lots, and alleys 5.6 18.5

Walkways 4.1 13.5

Rails 8.1 26.5

Spaces and ways for pedestrians and restricted traffic 4.4 14.5

Water areas not suitable for boating 5.2 17.0

225.61 Clearances over Buildings and Other Structures.

(A) 22 kV Nominal to Ground or Less.

The clearances over buildings and other structures for conductors and live parts up to 22 kV, nominal, to ground or less shall benot less than the values shown in Table 225.61.


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(B) Over 22 kV Nominal to Ground.

Clearances for the categories shown in Table 225.61 shall be increased by 10 mm (0.4 in.) per kV above 22,000 volts.

Informational Note: For additional information, see ANSI see IEEE C2-2007 2012 , National Electrical Safety Code.

Table 225.61 Clearances over Buildings and Other Structures

Clearance from Conductors or Live Parts from:Horizontal Vertical

m ft m ft

Building walls, projections, and windows 2.3 7.5 — —

Balconies, catwalks, and similar areas accessible to people 2.3 7.5 4.1 13.5

Over or under roofs or projections not readily accessible to people — — 3.8 12.5

Over roofs accessible to vehicles but not trucks — — 4.1 13.5

Over roofs accessible to trucks — — 5.6 18.5

Other structures 2.3 7.5 — —


Updated ANSI C2-2007 to read IEEE C2-2012 throughout the chapter.Reference current edition of NETA ATS to 2013.

Related Item


Public Input No. 3826-NFPA 70-2014 [Article 225]


Submitter Full Name: Aaron Adamczyk

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Mon Jul 06 13:08:57 EDT 2015


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Public Comment No. 1754-NFPA 70-2015 [ Section No. 225.10 ]

225.10 Wiring on Buildings (or Other Structures).

The installation of outside wiring on surfaces of buildings (or other structures) shall be permitted for circuits of not over 1000volts, nominal, as the following:

(1) Auxiliary gutters

(2) Busways

(3) Cable trays

(4) Cablebus

(5) Electrical metallic tubing (EMT)

(6) Flexible metal conduit (FMC)

(7) Intermediate metal conduit (IMC)

(8) Liquidtight flexible metal conduit (LFMC)

(9) Liquidtight flexible nonmetallic conduit (LFNC)

(10) Messenger-supported wiring

(11) Multiconductor cable

(12) Open wiring on insulators

(13) Reinforced thermosetting resin conduit (RTRC)

(14) Rigid metal conduit (RMC)

(15) Rigid polyvinyl chloride conduit (PVC)

(16) Type MC cable

(17) Type MI cable

(18) Type UF cable

(19) Wireways

Circuits of over 1000 volts, nominal, shall be installed as provided in 300.37.


The Correlating Committee directs the panel to reconsider the action on FR 1023 relative to the use of the phrase “of over 1000 volts” and consider the use of the preferred phrase “exceeding 1000 volts” to comply with the NEC Style Manual.

Related Item

First Revision No. 1023-NFPA 70-2015 [Section No. 225.10]


Submitter Full Name: CC on NEC-AAC

Organization: NFPA

Street Address:

City:

State:

Zip:

Submittal Date: Mon Sep 28 15:02:40 EDT 2015


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225.18 Clearance for Overhead Conductors and Cables.

Overhead spans of open conductors and open multiconductor cables of not over 1000 volts, nominal, shall have a clearance ofnot less than the following:

(1) 3.0 m (10 ft) — above finished grade, sidewalks, or from any platform or projection from which they are reachableplatforms or projections where the voltage does not exceed 150 volts to ground and accessible to pedestrians only

(2) 3.7 m (12 ft) — over residential property and driveways, and those commercial areas not subject to truck traffic where thevoltage does not exceed 300 volts to ground

(3) 4.5 m (15 ft) — for those areas listed in the 3.7 m (12 ft) classification where the voltage exceeds 300 volts to ground

(4) 5.5 m (18 ft) — over public streets, alleys, roads, parking areas subject to truck traffic, driveways on other than residentialproperty, and other land traversed by vehicles, such as cultivated, grazing, forest, and orchard

(5) 7.5 m (24 1⁄2 ft) — over track rails of railroads


Proposed wording is awkward, at best. I believe the thought can be accurately conveyed using less words. And, I couldn't find 'reachable' in the dictionary.

Related Item



Submitter Full Name: J. Grant Hammett

Organization: Colorado State Electrical Board

Street Address:

City:

State:

Zip:



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Public Comment No. 527-NFPA 70-2015 [ Section No. 225.19(D)(2) ]

(2) Vertical Clearance.

The vertical clearance of final spans above finished grade or above and within 900 mm (3 ft) measured horizontally ofplatforms, projections, or surfaces from which they are reachable shall be maintained in accordance with 225.18.



Related Item

First Revision No. 909-NFPA 70-2015 [Section No. 225.19(D)(2)]




Street Address:

City:

State:

Zip:



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225.22 Raceways on Exterior Surfaces of Buildings or Other Structures.

Raceways on exteriors of buildings or other structures shall be arranged to drain and shall be listed or approved listed for usein wet locations.


All of the raceway article require the use of listed raceways. The of the words "or approved" add confusion as they suggest that the use of a raceway that is not listed would be permitted in a wet location.

Related Item



Submitter Full Name: DON GANIERE


Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 31 17:17:40 EDT 2015


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Where a raceway enters a building or structure from outside an underground distribution system , it shall be sealed inaccordance with 300 .5(G). Spare or unused raceways shall also be sealed. Sealants shall be identified for use with cableinsulation, conductor insulation, bare conductor, shield, or and other components.


Requiring that all conduits entering a building from outside will create corrosion issues for many metallic wiring methods entering a building from outside. Whereas most underground systems are nonmetallic wiring methods, or galvanized rigid, many times EMT is used to run conductors from inside a building to equipment outside the building. We have seen local instances where branch circuit conduit systems were sealed, trapping moisture that then corroded the conduit from the inside out. Requiring these conductors to be sealed can also conflict with the requirement that they be "arranged to drain" as required in 225.22.

Multiple example of this have been observed by local contractors in the Las Vegas area. One such installation problem discovered by a local contractor, Roberts Electric, is described below:

"During the summer of 2013, approximately June or July, our company received anemergency call regarding loss of power to three (3) roof mounted evaporative coolers. All three(3) of the existing coolers were fed from the same branch circuit with separate switching to eachcooler.The pictures illustrate the conduit that left the internal ceiling mounted junction box andtraveled approximately ten (10') feet across the warehouse ceiling to the point where itproceeded to pierce the roof membrane and terminate in the combination motor starter located onthe roof. The conduit in the pictures had a ninety degree bend where it traveled up through theroof and an additional ninety degree bend where it terminated in the aforementioned electricaljunction box. The conduit had been sealed at the electrical junction box and on the roof where itentered the combination motor starter.Because of the EMT and the temperature difference between the roof conduit and thewarehouse conduit, condensation had formed in the conduit. This condensation with nowhere toevaporate began corroding the interior of the conduit and the conductors were sitting in moisture.Eventually this caused the conductor insulation to degrade and this resulted in a fault.Our company has had several calls for this same commercial property with the exactsame scenario. The only difference seems to be the degree of the fault and the damage sustainedto the conduit and the conductors."

The photographs referenced above and further details are available if desired.

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Submitter Full Name: HOWARD HERNDON

Organization: SOUTHWEST ELECTRITECH SVCS LLC

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307 of 2079 10/1/2015 11:02 AM



Where a raceway enters a building or structure from outside an underground distribution system , it shall be sealed inaccordance with 300 .5(G). Spare or unused raceways shall also be sealed. Sealants shall be identified for use with cableinsulation, conductor insulation, bare conductor, shield, or other components.


No substantiation was made to make this change which fundamentally revises the requirement in 225.27. In addition, no parallel change was made to 230.8 which puts the two requirements for the same situation out of correlation between Article 225 Outside Branch Circuits and Feeders and Article 230 Services. The purpose of sealing the raceway is discussed in 300.5(G) and in the Informational Note of that same section. Not all raceways entering the building from outside would need to be sealed.

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Submitter Full Name: TIMOTHY CROUSHORE

Organization: FIRSTENERGY

Affilliation: FirstEnergy

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308 of 2079 10/1/2015 11:02 AM


225.30 Number of Supplies.

A building or other structure that is served by a branch circuit or feeder on the load side of a service disconnecting means shallbe supplied by only one feeder or branch circuit unless permitted in 225.30(A) through (F). For the purpose of this section, amultiwire branch circuit shall be considered a single circuit.

Where a branch circuit or feeder originates in these additional buildings or other structures, only one feeder or branch circuitshall be permitted to supply power back to the original building or structure, unless permitted in 225.30(A) through (F).

(A) Special Conditions.

Additional feeders or branch circuits shall be permitted to supply the following:

(1) Fire pumps

(2) Emergency systems

(3) Legally required standby systems

(4) Optional standby systems

(5) Parallel power production systems

(6) Systems designed for connection to multiple sources of supply for the purpose of enhanced reliability


(B) Special Occupancies.

By special permission, additional feeders or branch circuits shall be permitted for either of the following:

(1) Multiple-occupancy buildings where there is no space available for supply equipment accessible to all occupants

(2) A single building or other structure sufficiently large to make two or more supplies necessary

(C) Capacity Requirements.

Additional feeders or branch circuits shall be permitted where the capacity requirements are in excess of 2000 amperes at asupply voltage of 1000 volts or less.

(D) Different Characteristics.

Additional feeders or branch circuits shall be permitted for different voltages, frequencies, or phases, or for different uses suchas control of outside lighting from multiple locations.

(E) Documented Switching Procedures.

Additional feeders or branch circuits shall be permitted to supply installations under single management where documentedsafe switching procedures are established and maintained for disconnection.




The Correlating Committee directs that this First Revision be rewritten to comply with the NEC Style Manual and to clarify the phrase “for more than a single branch circuit/feeder.” Slash markings are not permitted by the NEC Style Manual. In addition, the panel is directed to clarify the phrase “and originate at the same location” in new (F) with the specifics of the feeder origin.

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309 of 2079 10/1/2015 11:02 AM



310 of 2079 10/1/2015 11:02 AM

Public Comment No. 37-NFPA 70-2015 [ Section No. 225.30(F) ]




This is an excellent change! We have for years wrestled with the code where the power company would only provide service from a meter pedestal with one or two 200 A. breakers. If the structure requirements exceeded 200 A. for a single feeder, we were forced to rely on the logic found in 230.2(C)(2), understanding we had feeder, not service conductors. This solves that problem! Good work!

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Submitter Full Name: J GRANT HAMMETT

Organization: COLORADO STATE ELECTRICAL BOARD

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Submittal Date: Wed Jun 24 15:08:59 EDT 2015


311 of 2079 10/1/2015 11:02 AM



For Multiple feeders shall be permitted for a one- or two-family dwelling unit(s) with multiple feeders, it shall be permissible toinstall not more than six disconnects grouped at one location where the feeders enter the building, provided the feederconductors are sized 1/0 or larger and originate at the same location .


IEC’s position is to delete wording and revise wording in 225.30(F) to improve clarity- (FR 921)

The grouping of disconnects is already required in 225.34 and the maximum number is stated in 225.33; adding this to 225.30(F) is redundant. The location of the disconnecting means is covered in 225.32.IEC respects the safety concern of the panel and recognizes that feeders are very different than service conductors in that feeders have overcurrent protection. Multiple feeders are installed in buildings in accordance with Article 215 and there is no requirement to have a disconnecting means at the termination point of the feeder. The words “where the feeders enter the building” could cause problems for the installer and additional expense for the home owner without enhancing safety. For instance, a service structure could be built 15 feet away from the house and all service equipment is installed on the structure. The main disconnect and the feeder disconnects are in a main distribution panel at the service structure. An AHJ could require additional disconnects at the house even though the required disconnects are readily accessible and grouped in the main distribution panel. Firefighters would be able to disconnect all power by turning off the main disconnect.IEC does not understand the minimum size of 1/0 or larger for a feeder. What Code provision is being violated with a #3 THWN conductor that is protected at its supply with a 100 amp overcurrent protective device, provided the conditions of use allow the #3 to be used at its 100 amp rating? The minimum size of feeders is addressed in 215.2.

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Submitter Full Name: JOHN MASARICK

Organization: Independent Electrical Contractors, Inc.

Affilliation: Independent Electrical Contractors, Inc.

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Submittal Date: Sun Sep 20 18:09:11 EDT 2015


312 of 2079 10/1/2015 11:02 AM


225.32 Location.

The disconnecting means shall be installed either inside or outside of the building or structure served or where the conductorspass through the building or structure. The disconnecting means shall be at a readily accessible location nearest the point ofentrance of the conductors. For the purposes of this section, the requirements in 230.6 shall be utilized.

Exception No. 1: For installations under single management, where documented safe switching procedures are establishedand maintained for disconnection, and where the installation is monitored by qualified individuals, the disconnecting meansshall be permitted to be located elsewhere on the premises.

Exception No. 2: For buildings or other structures qualifying under the provisions of Article 685, the disconnecting means shallbe permitted to be located elsewhere on the premises.

Exception No. 3: For towers or poles used as lighting standards, the disconnecting means shall be permitted to be locatedelsewhere on the premises.

Exception No. 4: For poles or similar structures used only for support of signs installed in accordance with Article 600, thedisconnecting means shall be permitted to be located elsewhere on the premises.

Exception No. 5: For electric vehicle charging systems, the disconnecting means shall be installed in accordance with625.42 .


Delete the proposed new exception.The action taken by CMP-1 on FR 13 to revise the defined term "structure" resolves the issue and concern raised by the submitters of PI's 3924 and 4610. The revised definition will be as follows:Structure.That which is built or constructed, other than equipment .The addition of the words "other than equipment" addresses the issue raised in the PI's. Additionally the proposed revision would allow unlimited lengths of conductors inside a building or structure. Vehicle charging equipment is not limited to outdoors only and 625.42 only requires the disconnecting means be "readily accessible". There is no requirement in Article 625 that addresses an outside branch circuit or feeder entering a building or structure. Article 625 relies on the general rule in 225.32 for the location of the disconnect.

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Public Input No. 3924-NFPA 70-2014 [Section No. 225.32]



Submitter Full Name: James Dollard

Organization: IBEW Local Union 98

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313 of 2079 10/1/2015 11:02 AM

Public Comment No. 1756-NFPA 70-2015 [ Section No. 225.38(C) ]

(C) Disconnection of Grounded Conductor.

Where the building or structure disconnecting means does not disconnect the grounded conductor from the groundedconductors in the building or structure wiring, other means shall be provided for this purpose at the location of thedisconnecting means. A terminal or bus to which all grounded conductors can be attached by means of pressure connectorsshall be permitted for this purpose.

In a multisection switchboard or switchgear, disconnects for the grounded conductor shall be permitted to be in any section ofthe switchboard or switchgear, if the switchboard section or switchgear section is marked to indicate a grounded conductordisconnect is located within.


The Correlating Committee directs that Code-Making Panel 4 clarify the use of the phrase “is located within.”

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First Revision No. 924-NFPA 70-2015 [Section No. 225.38(C)]



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314 of 2079 10/1/2015 11:02 AM

Public Comment No. 1091-NFPA 70-2015 [ New Section after 225.40 ]

TITLE OF NEW CONTENT

Type your content here ...

225.41 Surge Protection for Outside Feeders. All outside feeders supplying buildings or other structures shall include a listedType 1 or Type 2 surge protective device (SPD). The SPD shall be located in the disconnecting means, or immediately adjacentto the disconnecting means that is required by 225.31.

Exception: Surge protection is not required for non-habitable buildings or other structures supplied from outside feeders thatoriginate in one- and two-family dwellings.


The Committee Statement to resolve PI 2796 suggests that surge protection should be optional, at the discretion of the property owner. Surge protection is very similar to overcurrent protection in that it is needed to minimize equipment damage due to voltage surges. Since it is unreasonable to claim that surge voltages are not causing property damage, CMP 4 is encouraged to treat overvoltage protection in a manner similar to overcurrent protection.

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Submitter Full Name: Vincent Saporita

Organization: Eaton

Affilliation: Eaton

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315 of 2079 10/1/2015 11:02 AM


225.41 Electrical Service Areas .

At least one 125-volt, single-phase, 15- or 20-ampere-rated receptacle outlet shall be installed in an accessible location within7.5 m (25 ft) of the outdoor electrical service equipment.

Exception No. 1: The receptacle outlet shall not be required to be installed outside of one- and two-family dwellings.

Exception No. 2: Where the service voltage is greater than 120 volts to ground, a receptacle outlet shall not be required forservices dedicated to equipment covered in Articles 675 and 682.


In creating First Revision FR 323 to 210.64 to address cord sets running through open doors of electrical service areas, Code-Making Panel 2 explicitly rejected those portions of PI 1439 and 3344 that advocated for removal of these requirements for outdoor electrical service areas other than irrigation machines of Article 675 and artificial bodies of water of Article 682 due to remoteness. CMP-2 Statement for First Revision 323 reads:“PI 1439 and 3344: The panel did NOT AGREE that the receptacle required should ONLY BE REQUIRED FOR INDOOR SERVICES. A requirement that the receptacle be included in the service ROOM did not address similar needs for OUTSIDE SERVICES.”These requirements prior to FR 323 nonetheless encompass both indoor and outdoor electrical service areas. Outdoor electrical service areas however are addressed by Article 225 under the responsibility of CMP-4, not CMP-2. Accordingly, for correlation, the existing requirements for outdoor electrical service areas, except for the revisions for 25 ft distance and the exemptions for irrigation machines and artificial bodies of water, should be now maintained in Article 225.

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Submitter Full Name: VINCE BACLAWSKI

Organization: NEMA

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316 of 2079 10/1/2015 11:02 AM

Public Comment No. 304-NFPA 70-2015 [ New Section after 230.2(A) ]



Add a new item (7) to the list to coordinate with the new item (7) that was added in 225.30.

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317 of 2079 10/1/2015 11:02 AM


230.4 Services Seperate on Load-Side of Service Disconnect - PI 1187

Committee Comment – PI 1187, Additional Substantiation

The resolution statement doesn’t address the issue of two utility sources tied together through customer wiring as depicted onthe previously submitted PI files. In addition to the initial PI substantiation, the equipment grounding conductors between the twoservices creates a parallel path with the utility’s grounded system neutral. The utility’s fault or unbalanced current can flowthrough the customer’s wiring. Obviously, this creates the opportunity for stray voltage/current through customer wiring. This is asafety concern and can create a possible catastrophic event. From a NEC standpoint, this PI will help mitigate possible strayvoltage/current caused by customer wiring.


Committee Comment – PI 1187, Additional SubstantiationThe resolution statement doesn’t address the issue of two utility sources tied together through customer wiring as depicted on the previously submitted PI files. In addition to the initial PI substantiation, the equipment grounding conductors between the two services creates a parallel path with the utility’s grounded system neutral. The utility’s fault or unbalanced current can flow through the customer’s wiring. Obviously, this creates the opportunity for stray voltage/current through customer wiring. This is a safety concern and can create a possible catastrophic event. From a NEC standpoint, this PI will help mitigate possible stray voltage/current caused by customer wiring.

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Submitter Full Name: DARRELL SUMBERA

Organization: CENTERPOINT ENERGY

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Submittal Date: Mon Aug 03 11:03:46 EDT 2015


318 of 2079 10/1/2015 11:02 AM


230.7 Other Conductors in Raceway or Cable.

Conductors other than service conductors shall not be installed in the same service raceway or service cable.

Exception No. 1: Grounding electrode conductors or supply side bonding jumpers or conductors.

Exception No. 2: Load management control conductors having overcurrent protection.


The Correlating Committee directs that this FR 926 and Exception No. 2 be rewritten in complete sentences to comply with the NEC Style Manual, Section 3.1.4.1.

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319 of 2079 10/1/2015 11:02 AM

Public Comment No. 528-NFPA 70-2015 [ Section No. 230.9(B) ]

(B) Vertical Clearance.

The vertical clearance of final spans above finished grade , or above and within 900 mm (3 ft) measured horizontally of ,platforms, projections, or surfaces from which they are reachable shall be maintained in accordance with 230.24(B).



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First Revision No. 927-NFPA 70-2015 [Section No. 230.9(B)]




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320 of 2079 10/1/2015 11:02 AM



Service conductors passing over a roof shall be securely supported by substantial structures. For a grounded system, where thesubstantial structure is metal, it shall be bonded by means of a bonding jumper and listed connector to the grounded overheadservice conductor. The bonding jumper shall be of the same conductor size and material as the grounded overhead serviceconductor. Where practicable, such supports shall be independent of the building.For ungrounded system, where thesubstantial structure is metal, it shall be bonded by means of a bonding jumper and listed connector to the grounding electrodesystem. The bonding jumper shall be sized per 250.102C. Where practicable, such supports shall be independent of thebuilding.


Metal structures supporting ungrounded system still need to be bonded back to the grounding electrode system.

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Submitter Full Name: WENDELL WHISTLER

Organization: ALASKA JOINT ELECTRICAL APPREN

Affilliation: IBEW

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Submittal Date: Fri Sep 25 16:20:32 EDT 2015


321 of 2079 10/1/2015 11:02 AM



Service conductors passing over a roof shall be securely supported by substantial structures. For a grounded system, wherethe substantial structure is metal, it shall be bonded by means of a bonding jumper and listed connector to the groundedoverhead service conductor. The bonding jumper shall be of the same conductor size and material as the grounded overheadservice conductor. Where practicable, such supports shall be independent of the building.


I'm not trying to be rude, but this panel does not have the ability to write Grounding and Bonding rules. Either delete or have Panel 5 assist in the language. I don't want to go into the details on the many issues I have but let's just start with bonding jumper sizing?...

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Submitter Full Name: MIKE HOLT

Organization: MIKE HOLT ENTERPRISES INC

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Submittal Date: Tue Aug 04 14:56:34 EDT 2015


322 of 2079 10/1/2015 11:02 AM



Service conductors passing over a roof shall be securely supported by substantial structures. For a grounded system, where thesubstantial structure is metal, it shall be bonded by means of a bonding jumper and listed connector to the grounded overheadservice conductor. The bonding jumper shall be of the same conductor size and material as For an ungrounded system,where the substantial structure is metal, it shall be bonded by means of a bonding jumper and listed connector to the groundedoverhead service conductor. raceway. The bonding jumper shall be sized per 250.102(C)(1). Where practicable, such supportsshall be independent of the building.


There is a shock hazard with ungrounded systems as well as with grounded systems. Sizing the supply side bonding jumper can be determined by using Table 250.102(C)(1), the material installation requirements is covered by 250.102 (A), (B), and (C)

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Submitter Full Name: Christine Porter

Organization: Intertek Testing Services

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323 of 2079 10/1/2015 11:02 AM

Public Comment No. 1758-NFPA 70-2015 [ Section No. 230.30(A) ]

(A) Insulation.

Underground service conductors shall be insulated for the applied voltage.

Exception: A grounded conductor shall be permitted to be uninsulated as follows:

(1) Bare copper used in a raceway

(2) Bare copper for direct burial where bare copper is approved for the soil conditions

(3) Bare copper for direct burial without regard to soil conditions where part of a cable assembly identified for undergrounduse

(4) Aluminum or copper-clad aluminum without individual insulation or covering where part of a cable assembly identifiedfor underground use in a raceway or for direct burial


The Correlating Committee directs that Code-Making Panel 4 reconsider the use of the word “approved” in this context.

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First Revision No. 930-NFPA 70-2015 [Section No. 230.30(A)]



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324 of 2079 10/1/2015 11:02 AM


230.41 Insulation of Service-Entrance Conductors.

Service-entrance conductors entering or on the exterior of buildings or other structures shall be insulated.


(1) Bare copper used in a raceway or part of a service cable assembly

(2) Bare copper for direct burial where bare copper is approved for the soil conditions


(4) Aluminum or copper-clad aluminum without individual insulation or covering where part of a cable assembly or identifiedfor underground use in a raceway, or for direct burial

(5) Bare conductors used in an auxiliary gutter


The Correlating Committee directs that Code-Making Panel 4 reconsider the use of the word “approved” in this context.

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325 of 2079 10/1/2015 11:02 AM


230.41 Insulation of Service-Entrance Conductors.

Service-entrance conductors entering or on the exterior of buildings or other structures shall be insulated.


(1) Bare copper used in a raceway or part of a service cable assembly

(2) Bare copper for direct burial where bare copper is approved is identified for the soil conditions


(4) Aluminum or copper-clad aluminum without individual insulation or covering where part of a cable assembly or identifiedfor underground use in a raceway, or for direct burial

(5) Bare conductors used in an auxiliary gutter


This section has been proposed to be changed from "judged to be suitable" for the soil conditions to "approved" for the soil conditions. Perhaps a better choice of words here would be "identified" for the soil conditions. Who does approving? According to Article 100, the authority having jurisdiction (AHJ) does approving. The AHJ could "approve" any type of a conductor in this situation. As an AHJ, I greatly depended upon identified products by a third-party testing agency to base my approval. See the definition of "identified" in Article 100.

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Submitter Full Name: L. Keith Lofland

Organization: International Association of Electrical Inspectors (IAEI)

Affilliation: None

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326 of 2079 10/1/2015 11:02 AM


(A) General.

The ampacity of service-entrance conductors shall not be smaller than the largest required in230.42(A)(1), (A)(2), or (A)(3).Loads shall be determined in accordance with Part III, IV, or V of Article 220, as applicable. Ampacity shall be determined from310.15. The maximum allowable current of busways shall be that value for which the busway has been listed or and labeled.

(1) The sum of the noncontinuous loads plus 125 percent of continuous loads

Exception: Grounded conductors that are not connected to an overcurrent device shall be permitted to be sized at 100percent of the continuous and noncontinuous load.

(2) The sum of the noncontinuous load plus the continuous load after the application of any adjustment or correction factors

(3) The sum of the noncontinuous load plus the continuous load if the service-entrance conductors terminate in anovercurrent device where both the overcurrent device and its assembly are listed for operation at 100 percent of theirrating

Additional Proposed Changes

File Name Description Approved

Essential_Guide_to_Product_Testing_and_Certification_NOV_2014.pdf

ETL Essential Guide to Product Testing & Certification 2014/2015 North American Edition. Please review document page numbers 5, 8 and 10 to see that ETL has requirements similar to UL, that products that do not bear their certification (listed) mark are not considered by ETL as being listed.


UL recognizes the Correlating Committee created a global First Correlating Revision (FCR) which directed that in all locations where the term “and labeled” was added after “listed” during the First Revision Stage, the words “and labeled” after “listed” be deleted, returning to previous text. UL understands that the Correlating Committee appointed a task group to address several issues involving the use of the terms “listed” and “labeled,” most importantly, to clarify and establish a distinction between the terms “listed” and “labeled” which are often used interchangeably. UL supports the need for this task group. However, UL does not expect the work of this task group to affect the 2017 NEC regarding the issue of “listed and labeled.” As such, UL is submitting comments to request that the words “and labeled” be added in various locations throughout the Code for the reasons expressed in the public inputs UL submitted on this issue. UL believes that these revisions will address an ongoing problem that should not wait until the 2020 NEC for resolution.

Subsequent to the Public Input Code Panel Meetings, UL has discussed this issue with its Electrical Council whose membership includes many AHJs. The proposed revisions to the NEC received general support from the membership. This issue was also discussed at a NEMA – NRTLs Forum held on August 14, 2015 at NEMA Headquarters. UL reiterated its support for the proposed revisions. The NRTLs represented at the meeting voiced no objection to the proposals.

The rationale for the revision was simple, to provide information to the AHJ regarding the suitability of equipment they encounter. The mark on the product is the manufacturer’s attestation that the product is in compliance with the appropriate standard. NRTL’s conduct factory surveillance of products, surveillance is one method to validate the manufacturer’s attestation. Should a product be found not to be compliant the manufacturer has the option of removing the mark and shipping the product without the mark, or holding the shipment and bringing the product into compliance. In either case the “Listing” is not impacted, as the “listing” is created at the completion of the “original” certification of the product and indicates the authorization but not the mandate to label products. So the only true way an AHJ can determine whether the product he is seeing is compliant with the applicable standard is via a label on the product. Taking it one step further, listings change with time. It is quite possible that a “listing” has been withdrawn; however labeled product may still be available for sale. Should equipment that is labeled, but not listed, be deemed acceptable? Based on the NEC definitions, it is possible to have a product that meets the Article 100 definition of listed but the testing organization made the manufacture remove the label for a non-compliance issue.

As for the concerns of products that are too small to be labeled, the definition of labeled is not limited to an actual label, it also includes symbols, or other identifying marks. The Safety Standards which define the listing requirements do not address labeling of products as defined by Article 100. As a general rule, NRTL’s do not consider a product as being listed unless it is also labeled. The UL White Book states that “Only those products bearing the appropriate UL Mark and the company's name, trade name, trademark or other authorized identification should be considered as being covered by UL's Certification, Listing, Classification and Follow-Up Service. The UL Mark provides evidence of listing or labeling, which may be required by installation codes or standards.” Again the requirements for the UL Mark are not a Safety Standard requirement, they are a UL requirement and the only way to show that a product is UL Certified (Listed); other NRTL’s have similar requirements.


327 of 2079 10/1/2015 11:02 AM

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Public Input No. 882-NFPA 70-2014 [Section No. 230.42(A)]


Submitter Full Name: JEFFREY FECTEAU

Organization: UNDERWRITERS LABORATORIES LLC

Affilliation: UL

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328 of 2079 10/1/2015 11:02 AM


(A) General.

The ampacity of service Service -entrance conductors shall have an ampacity of not be smaller than the largest less then themaximum load to be served. Conductors shall be sized to carry not less then required in230.42(A)(1), (A)(2), or (A)(3). Loadsshall be determined in accordance with Part III, IV, or V of Article 220, as applicable. Ampacity shall be determined from310.15. The maximum allowable current of busways shall be that value for which the busway has been listed or labeled.

(1) The sum of the Where the service-entrance conductors carry continuous or any combination of noncontinuous andcontinuous loads, the minimum service-entrance conductor size shall have an allowable ampacity not less than the sum ofthe noncontinuous loads plus 125 percent of continuous loads.


(2) The sum minimum service-entrance conductor size shall have an ampacity not less than the sum of the noncontinuousload plus the continuous load after the application of any adjustment or correction factors.



Public Input 1270 was an attempt to provide consistency in the applications of 210.19(A)(1), 215.2(A)(1), and 230.42(A) and distinguish when allowable ampacity and ampacity should be used. As currently written, the ampacity of a service-entrance conductor is required to be not less then the noncontinuous load and 125% of the continuous load. Since ampacity is defined in Article 100 as being the maximum current the conductor can safely carry under conditions of use, 230.42(A)(2) is in conflict with 230.42(A)(1). As stated in 230.42(A)(2), is it not redundant to state after the application of adjustment and correction factors since the definition of ampacity already states conditions of use? If it is the panel's intent that 230.42(A)(1) would apply to a conductor's allowable ampacity, without adjustment and correction factors, then the text of the Code should clarify the rule by using the allowable ampacity and not ampacity. As stated in public comments 373 and 393, I would additionally ask the panel if there is a difference between allowable ampacity and ampacity? The allowable ampacity, which does not consider conditions of use, should be compared to the load as stated in 230.42(A)(1), and the ampacity, which considers conditions of use, should be compared to the load as stated in 230.42(A)(2).

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 393-NFPA 70-2015 [Section No. 215.2(A)(1)]

Public Comment No. 373-NFPA 70-2015 [Section No. 210.19]

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Submitter Full Name: Derrick Atkins

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329 of 2079 10/1/2015 11:02 AM


(A) General.

The ampacity of service-entrance conductors shall not be smaller than the largest required in230.42(A)(1), (A)(2), or (A)(3).Loads shall be determined in accordance with Part III, IV, or V of Article 220, as applicable. Ampacity shall be determined from310.15. The maximum allowable current of busways shall be that value for which the busway has been listed or labeled.

(1) The sum of the noncontinuous loads plus 125 percent of continuous loads


(2) The sum of the noncontinuous load plus the continuous load after the application of any adjustment or correction factors



The Correlating Committee directs that further consideration be given to FR 947 to correlate the language structure with 215.2 and 210.19. The difference in the positive language and exception structure can create confusion and in this case technical differences that may not have been intended.

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330 of 2079 10/1/2015 11:02 AM


230.44 Cable Trays.

Cable tray systems shall be permitted to support service-entrance conductors. Cable trays used to support service-entranceconductors shall contain only service-entrance conductors and shall be limited to the following methods:

(1) Type SE cable

(2) Type MC cable

(3) Type MI cable

(4) Type IGS cable

(5) Single conductors 1/0 and larger that are listed for use in cable tray or cable assemblies with Type TC rating

Such cable trays shall be identified with permanently affixed labels with the wording “Service-Entrance Conductors.” The labelsshall be located so as to be visible after installation with a spacing not to exceed 3 m (10 ft) so that the service-entranceconductors are able to be readily traced through the entire length of the cable tray.

Exception: Conductors, other than service-entrance conductors, shall be permitted to be installed in a cable tray with service-entrance conductors, provided a solid fixed barrier of a material compatible with the cable tray is installed to separate theservice-entrance conductors from other conductors installed in the cable tray.


The language "or Cable Assemblies with Type TC rating" is confusing since "cable assemblies" is not defined and "Type TC" is a cable wiring method that has not been evaluatedfor use as service conductors in cable tray.

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Submitter Full Name: Christel Hunter

Organization: General Cable

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331 of 2079 10/1/2015 11:02 AM


230.44 Cable Trays.


(1) Type SE cable

(2) Type MC cable

(3) Type MI cable

(4) Type IGS cable

(5) Single conductors 1/0 and larger that are listed for use in cable tray or cable assemblies with Type TC rating




The Correlating Committee directs the Panel to reconsider item (5) for correct terminology and consider the addition of “cable assemblies” as list item (6) with correct terminology is Power Tray Cable (Type TC)

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332 of 2079 10/1/2015 11:02 AM


Revise FR 933 as follows:

230.44 Cable Trays.


Type SE cable

Type MC cable

Type MI cable

Type IGS cable

Single conductors 1/0 and larger that are listed for use in cable tray or cable assemblies with Type TC rating




By limiting the service conductors permitted in cable trays systems to the five listed items many other methods permitted in 392.10(A) and 230.43 that provide safe physical protection of service conductors are prohibited without any substantiation. Cable tray systems are not a wiring method they are only a support system that may be used to support all types of wiring methods and single conductors under limited conditions. Please accept this change.

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Submitter Full Name: Richard Loyd

Organization: R & N Associates

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333 of 2079 10/1/2015 11:02 AM


230.53 Raceways to Drain.

Where exposed to the weather, raceways enclosing service-entrance conductors shall be listed or approved for listed andidentified for use in wet locations and arranged to drain. Where embedded in masonry, raceways shall be arranged to drain.


This section has been proposed to be changed from "suitable for use" in wet locations to "listed or approved" in wet locations. Perhaps a better choice of words here would be "listed and identified" in wet locations. Who does approving? According to Article 100, the authority having jurisdiction (AHJ) does approving. The way this section has been proposed, the AHJ could accept a listed raceway here (listed for what?), or the AHJ could accept ANY raceway he or she "approved" (and it would not have to be listed). Changing this proposed text to "listed AND identified" in a wet location takes the guess work out of the equation as AHJ could now depend upon identified products by a third-party testing agency to base an approval on. See the definition of "identified" in Article 100.

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Submitter Full Name: L. Keith Lofland

Organization: International Association of Electrical Inspectors (IAEI)

Affilliation: None

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334 of 2079 10/1/2015 11:02 AM


(C) Service Heads and Goosenecks Above Service-Drop or Overhead Service Attachment.

Service heads on raceways equipped with a service head or service-entrance cables and goosenecks in service-entrancecables shall be located above the point of attachment of the service-drop or overhead service conductors to the building or otherstructure.

Exception: Where it is impracticable to locate the service head or gooseneck above the point of attachment, the service heador gooseneck location shall be permitted not farther than 600 mm (24 in.) from the point of attachment.


The current wording requires that the raceway be installed above the point of the service drop or over head service conductor point of attachment. It is the service head and not the complete raceway that needs to be above the point of attachment.

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335 of 2079 10/1/2015 11:02 AM


230.66 Marking.

Service equipment rated at 1000 volts or less shall be marked to identify it as being suitable for use as service equipment. Allservice equipment shall be listed and labeled or field labeled. Individual meter socket enclosures shall not be consideredservice equipment but shall be listed, labeled and rated for the voltage and ampacity of the service.

Exception: Meter sockets purchased or under the exclusive control of an electric utility are not required to be listed andlabeled .










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337 of 2079 10/1/2015 11:02 AM


230.66 Marking.

Service equipment rated at 1000 volts or less shall be marked to identify it as being suitable for use as service equipment. Allservice equipment shall be listed or field labeled. Individual meter socket enclosures shall not be considered service equipmentbut shall be listed and rated for the voltage and , ampacity of the service, and maximum available fault current .

Exception: Meter sockets purchased or under the exclusive control of an electric utility are not required to be listed.


It is critical that this equipment be rated for the maximum available fault current, not just the voltage and ampere rating of the service.

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Organization: Eaton

Affilliation: Eaton

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339 of 2079 10/1/2015 11:02 AM


230.66 Marking.

Service equipment rated at 1000 volts or less shall be marked to identify it as being suitable for use as service equipment. Allservice equipment shall be listed or field labeled. Individual meter socket enclosures shall not be considered service equipmentbut shall be listed and rated for the voltage and ampacity of the service.

Exception: Meter sockets purchased or purchased and under the exclusive control of an electric utility are not required to belisted.


The original intent of the exception was to exempt only utility purchased meter sockets from being listed and labled. The word "or" would exempt all meter sockets regardless of who purchased them once the meter is installed and the utility seal is applied, thus making the meter socket under the exclusive control of the utility. Therefore, the word "or" should be changed to "and".

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Submitter Full Name: Roger McDaniel

Organization: Georgia Power Company

Affilliation: Edison Electric Institute

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340 of 2079 10/1/2015 11:02 AM


230.66 Marking.




The Correlating Committee directs the Panel to reconsider the addition of the exception based on correlation with 90.2(B)(5), since meter sockets under the exclusive control of an electric utility are outside the scope of the NEC®

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Organization: NFPA

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341 of 2079 10/1/2015 11:02 AM


230.66 Marking.

Service equipment rated at 1000 volts or less shall be marked to identify it as being suitable for use as service equipment. Allservice equipment shall be listed or field labeled . Individual meter socket enclosures shall not be considered service equipmentbut shall be listed and rated for the voltage and ampacity of the service.



Does the panel really mean 'field labeled' without telling me what that means? Can I use a Sharpie to 'field label' equipment to indicate that it's suitable as service equipment?

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342 of 2079 10/1/2015 11:02 AM


230.66 Marking.


Exception: Meter sockets purchased or socket enclosures under the exclusive control of an electric utility are not required tobe listed.


The exception is about 'enclosures' not 'sockets' also delete 'purchased' since all meter socket enclosure will have to be purchased, they are not free...

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343 of 2079 10/1/2015 11:02 AM


230.66 Marking.


Exception: Meter sockets purchased or purchased and under the exclusive control of an electric utility are not required to belisted.


By replacing "or" with "and" the text adds more clarity to reinforce the electric utility exclusion in 90.2 (B)(5).

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Submitter Full Name: ROLAND DEIKE

Organization: Edison Electric Institute

Affilliation: The Electric Light and Power National Electrical Code Task Force

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Submittal Date: Thu Aug 13 13:37:03 EDT 2015


344 of 2079 10/1/2015 11:02 AM


230.66 Marking.




IEC's position is to delete the exception for 230.66

The exception to allow meter sockets to be unlisted is unclear. By the literal reading of the text anytime a meter socket is purchased, whether the socket is under the exclusive control of the utility or not, it would not be required to be listed. We don’t think that was the intent. If a person were to go to the supply house to buy a meter socket that is approved by the local utility is the meter required to be listed? Or does this mean the meter sockets purchased from a utility are not required to be listed? All meter sockets need to be rated for load and short circuit current and allowing non-listed products appears to reduce safety. There will always be controversy over whether meter sockets are covered by the NEC as stated in 90.2(3) or if they fall under 90.2(B)(5)a. The meter socket should be covered by the NEC and the meter or metering equipment should not be covered.

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Submitter Full Name: JOHN MASARICK

Organization: Independent Electrical Contractors, Inc.

Affilliation: Independent Electrical Contractors, Inc.

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345 of 2079 10/1/2015 11:02 AM

Public Comment No. 979-NFPA 70-2015 [ New Section after 230.70(A)(1) ]

(A) Dwellings

Where installed on one-family and two-family dwellings, the service disconnecting means shall be installed outside thestructure at the nearest point of entrance of the service conductors.


This public comment is submitted on behalf of the IAFF in response to the resolution of PI 4224, wherein the Panel Statement reads: "This requirement is overly onerous and not necessary. Why is the hazard greater in a one or two family dwelling than it is in a multi-family dwelling or commercial building? Larger services for these types of buildings actually pose more of a hazard." The PI was written to address the challenges on one-family and two-family dwellings. It does not take a position of comparable hazards levels of multi-family or high-rise occupancies. The key to this public comment request, is the lack of an external service disconnect for safe fire fighter operations within a residential structure. From the mid 1970's forward, it has been acknowledged that using a meter as a service disconnect is a dangerous practice for fire fighters to secure utilities, yet the code has not been modified to provide a safer NFPA70E-compliant alternative. Many emergencies may make the need to cut electrical power such as fires, gas leaks, structural damage, & flooding. To require that personnel enter a potentially hazardous environment to perform this task, when a well-established method is available, is thebasis of this reasonable safety code modification. The comments on environmental effects on enclosures is a UL standards compliance issue, and should be addressed under use of the appropriate listed enclosure. This is not an overly onerous requirement as proven by the many utilities in many states that require an external method to disconnect power in an emergency without requiring responders to enter the structure to secure power.

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Public Input No. 4224-NFPA 70-2014 [Section No. 230.70(A)(1)]


Submitter Full Name: Matthew Paiss

Organization: International Association of Fire Fighters

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346 of 2079 10/1/2015 11:02 AM

Public Comment No. 1082-NFPA 70-2015 [ Section No. 230.70(A)(1) ]

(1) Readily Accessible Location.

The service disconnecting means shall be installed at a readily accessible location either outside of a building or structure orinside nearest the point of entrance of the service conductors.

Exception: A service disconnecting means for residential occupancies shall be installed outside the structure nearest the pointof entrance of the service entrance conductors.


Fire fighters should not be required to pull a meter in order to disconnect a residential service, unless of course, the meter and meter socket are tested and listed as a disconnecting means. In addition the the increased safety for firefighters trying to disconnect the service, acceptance of this Public Comment would provide an additional degree of safety by allowing for the incoming lugs of an indoor residential panelboard to be de-energized while work is being performed in the panelboard. Finally, if the service disconnecting means also includes the service overcurrent protective device, additional protection is provided for the service entrance conductors, conductors that are not now protected from short-circuits between the meter and the service entrance overcurrent protective device.

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Organization: Eaton

Affilliation: Eaton

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347 of 2079 10/1/2015 11:02 AM



The service disconnecting means shall be installed at a readily accessible location either outside of a building or structure orinside nearest the point of entrance of the service conductors. In new buildings, excluding one- and two-family dwellings, adisconnect to the building shall be provided as follows:

(a) In the Fire Command Center, where a Fire Command Center is provided in the building.

(b) At the fire alarm annunciator, where there is no Fire Command Center.

(c) In an appropriately sized and weatherproofed fire department access box on the address side of the building, where there isno fire alarm annunciator or Fire Command Center.

In existing buildings, excluding one- and two-family dwellings, where there are significant upgrades to the building electricalservice, such as modifying or replacing the switchgear, a disconnecting means shall be provided as for new buildings.


This is a firefighter safety issue. It is intended to allow a firefighter to disconnect the power to a building without the need to go searching for the disconnect in an involved building. down to the third floor or a parking garage below the building to kill the electricity to the entire building.

It is correct in assuming it will not de-energize ALL circuits. However whether you wait for the firefighter to locate the disconnecting means (losing valuable time) or if you shunt trip the main the result will be the same. The emergency circuits will still be energized. Throughout the NEC greater protection for emergency circuits and especially emergency feeders is required thus reducing the accidental physical damage by firefighter and or fire. By de-energizing the main you will reduce the number of energized circuits by 75% or greater. This will provide greater protection for our first responders. By shunt tripping the main at the fire command center it will save time and possibly reduce the threat of injury or death to our first responders. There are jurisdictions that will not allow firefighters into a building until the utility company arrives and de-energizes the building due to risking their responders lives while searching through the building for the disconnect. It does require control wires but a shunt trip module (coil unit) must be factory installed on a new installation or field installable on existing breakers for substantial renovations. The cost varies. But in talking with various manufacturers, most of their main breakers (originating back to the 1950's) can be field installed with shunt trip devices at a cost of $1000 or less for the module. If the main disconnecting means uses fused disconnects, it might be more to meet the requirement on a remodel if this is the case. This can be easily achieved at a cost much less than what we are currently requiring for rapid shutdown of photovoltaic systems. That requirement was adopted to protect our first responders, and so should this.

If the CMP wants to consider not applying this to existing buildings, then the last paragraph could be deleted. Consideration could also be made to applying this only to new buildings with Fire Command Centers.

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Submitter Full Name: Jim Muir

Organization: Building Safety Division, Clark County, WA

Affilliation: NFPAs Building Code Development Committee (BCDC)

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348 of 2079 10/1/2015 11:02 AM



The service disconnecting means shall be installed at a readily accessible location either outside of a building or structure orinside nearest the point of entrance of the service conductors.

(A) Dwellings

Where installed on one family and two family dwellings, the service disconnecting means shall be installed outside the structureat the nearest point of entrance of the service

conductors or provide a shunt trip breaker with actuation located on the outside of the structure near the service entrance .


This requirement would further enhance the safety of the emergency responders. Manyemergencies may require disconnection of electrical power such as fires, gas leaks, structuraldamage, & flooding. Requiring that personnel enter a potentially hazardous environment to perform this task, when a well establishedmethod is available that would comply with the requirements of NFPA 70 E, is the basis of this reasonable safety code modification.

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Affilliation: IBEW

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349 of 2079 10/1/2015 11:02 AM


(A) General.

The service disconnecting means for each service permitted by 230.2, or for each set of service-entrance conductorspermitted by 230.40, Exception No. 1, 3, 4, or 5, shall consist of not more than six switches or sets of circuit breakers, or acombination of not more than six switches and sets of circuit breakers, mounted in a single enclosure, in a group of separateenclosures, or in or on a switchboard or in switchgear. There shall be not more than six sets of disconnects per servicegrouped in any one location.

For the purpose of this section, disconnecting means installed as part of listed equipment and used solely for the following shallnot be considered a service disconnecting means:

(1) Power monitoring equipment

(2) Surge-protective device(s) that are installed in accordance with 285.23

(3) Control circuit of the ground-fault protection system

(4) Power-operable service disconnecting means


The Correlating Committee directs that Code-Making Panel 4 reconsider the added requirement to be installed in accordance with 285.3 since 90.3 already requires compliance with 285.23

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Organization: NFPA

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350 of 2079 10/1/2015 11:02 AM


(C) Performance Testing.

The ground-fault protection system shall be performance tested when first installed on site. This testing shall be conducted by aqualified person(s) using a test process of primary or secondary current injection, in accordance with instructions that shall beprovided with the equipment. A written record of this testing shall be made and shall be available to the authority havingjurisdiction.

Informational Note No. 1: Ground-fault protection that functions to open the service disconnect affords no protection fromfaults on the line side of the protective element. It serves only to limit damage to conductors and equipment on the loadside in the event of an arcing ground fault on the load side of the protective element.

Informational Note No. 2: This added protective equipment at the service equipment may make it necessary to review theoverall wiring system for proper selective overcurrent protection coordination. Additional installations of ground-faultprotective equipment may be needed on feeders and branch circuits where maximum continuity of electric service isnecessary.

Informational Note No. 3: Where ground-fault protection is provided for the service disconnect and interconnection ismade with another supply system by a transfer device, means or devices may be needed to ensure proper ground-faultsensing by the ground-fault protection equipment.

Informational Note No. 4: See 517.17(A) for information on where an additional step of ground-fault protection is requiredfor hospitals and other buildings with critical areas or life support equipment.


The following is from an article written by Howard Herndon and was published in the Nov/Dec 2010 edition of the IAEI magazine.

"Use of a secondary injection test set will test the electronics of the relay or trip unit, but does not insure the CT installation and wiring are correct. Use of the test-trip button will test the circuit within the relay or trip unit, but again does not insure the CT installation and wiring are correct. This does not meet the intent of performance testing as outlined in NEC 230.95(C). Use of the secondary test set or push-to-test button is like performance testing the safety features of a car while it is up on blocks — it may look good, but is not very effective."

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351 of 2079 10/1/2015 11:02 AM


230.200 General.

Service conductors and equipment used on circuits exceeding 1000 volts, nominal, shall comply with all the applicableprovisions of the preceding sections of this article and with the following sections that supplement or modify the precedingsections. In no case shall the provisions of Part VIII apply to equipment on the supply side of the service point.

Informational Note: For clearances of conductors of over 1000 volts, nominal, see ANSI see IEEE C2-2007 2012 ,National Electrical Safety Code.


Referenced correct SDO in the informational note.

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352 of 2079 10/1/2015 11:02 AM

Public Comment No. 643-NFPA 70-2015 [ Part VIII. ]

Part VIII. Energy Storage Systems


Part VIII was supposed to be deleted according to the resolution logs. This section was erroneously retained. All energy storage language from Article 690 has been utilized in the new Article 706 - Energy Storage Systems. This deletion also includes all of 690.71, 690.72, and 690.74.

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First Revision No. 1012-NFPA 70-2015 [Sections Part VIII., 690.71]


Submitter Full Name: Ward Bower

Organization: Solar Energy Industries Associ

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2074 of 2079 10/1/2015 11:02 AM

The graphics currently included in the first revision of 2017 NEC do not cover all options and system configurations available in the market today. We suggest to include additional graphics showing

- an ac coupled multimode system, and - an ac coupled stand-alone system.

Please add the following graphics to Figures 690.1(b):

kshea

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690.1_Proposal_NEC2017a.pdfThis document contains graphics that need to be included in Figure 690.1(b) to represent typical system configurations available in the market today.


The graphics shown in the first revision of 2017 NEC Figure 690.1(b) only shows one possible configuration of an ac coupled multimode system. A second configuration using a common ac bus for both inverters is already available in the market today. The first of the two graphics in the uploaded file represents such a configuration.


1342 of 2079 10/1/2015 11:02 AM

kshea

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The graphics shown in the first revision of 2017 NEC Figure 690.1(b) only shows an dc coupled stand-alone system. A second configuration using a common ac bus for both inverters is already available in the market today. We suggest calling this configuration ac coupled stand-alone system. The second of the two graphics in the uploaded file represents such a configuration.

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Submitter Full Name: Michael Mendik

Organization: SMA America

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1343 of 2079 10/1/2015 11:02 AM

This article applies to solar PV systems, other than those covered by Article 691, including the array circuit(s), inverter(s), andcontroller(s) for such systems. [See Figure 690.1(a) and Figure 690.1(b) .]The systems covered by this article may beinteractive with other electrical power production sources or stand-alone or both, and may or may not be connected to energystorage systems such as batteries. These PV systems may have ac or dc output for utilization.

Informational Note: Article 691 covers the installation of large-scale PV electric supply stations.

Figure 690.1(a) Identification of PV Power Source Components With or Without DC-to-DC Converters.

Figure 690.1(b) Identification of PV System Components in Common Configurations.


1351 of 2079 10/1/2015 11:02 AM

kshea

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Note 4 in Figure 1(a) States there are possible custom designs but the figure showing dc-dc converters in series with the PV string or modules will lead AHJs to insist on that location. The Note should read "Custom PV power source designs occur and the use and location of some components are design options.

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1352 of 2079 10/1/2015 11:02 AM

This article applies to solar PV systems, other than those covered by Article 691, including the array circuit(s), inverter(s), andcontroller(s) for such systems. [See Figure 690.1(a) and Figure 690.1(b) .]The systems covered by this article may beinteractive with other electrical power production sources or stand-alone or both, and may or may not be connected to energystorage systems such as batteries. These PV systems may have ac or dc output for utilization.

Informational Note: Article 691 covers the installation of large-scale PV electric supply stations.

Figure 690.1(a) Identification of PV Power Source Components With or Without DC-to-DC Converters.

Figure 690.1(b) Identification of PV System Components in Common Configurations.


1346 of 2079 10/1/2015 11:02 AM

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Public Comment No. 1845-NFPA 70-2015 [ Section No. 690.1


The Correlating Committee directs the panel to consider the use of consistent terminology

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Organization: NFPA


1347 of 2079 10/1/2015 11:02 AM

Public Comment No. 1360-NFPA 70-2015 [ Definition: Engineering Supervision. ]

Engineering Supervision.

Designed and approved (or certified) Supervised by a licensed professional engineer competent in the specific area undersupervision.


The correlating committee has concerns about this definition. The rewording is intended to limit the definition to defining what the term means and letting the text of the requirements determine how it is used.

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Submitter Full Name: Bill Brooks

Organization: Brooks Engineering

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1561 of 2079 10/1/2015 11:02 AM



Designed and approved (or certified) by a licensed Licensed professional engineer competent engaged primarily in thespecific area under supervision. design and maintenance of electrical installations under their supervision. The documentsshall be wet stamped by the professional engineer. This documentation shall be made available to those authorized to design,install, inspect, maintain and operatethe system.


Clarify and further refine who is can provide electrical design and engineering for these large PV systems

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Affilliation: IBEW

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1562 of 2079 10/1/2015 11:02 AM



Designed and approved (or certified) by a licensed professional engineer competent in the specific area under supervision.


There is a subtle difference between the definitions of Engineering Supervision within Article 690 and 691 that we don't believe was intentional but could cause confusion if left in the current state. We suggest to make both definitions the same to avoid interpretation that Engineering Supervision within Article 690 is different than that of 691.

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First Revision No. 1002-NFPA 70-2015 [New Definition after Definition: Electrical Production and ...]


Submitter Full Name: JASON SPOKES

Organization: SUNPOWER CORP

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1355 of 2079 10/1/2015 11:02 AM



Designed and approved by a licensed professional engineer competent engaged primarily in the specific area undersupervision design of PV systems .


TerraView is incorrectly highlighting the entire definition as new. The proposed revision is to replace "competent in the specific area under supervision" with "engaged primarily in the design of PV systems".

SunPower believe that it will be very difficult for an AHJ to objectively determine whether an engineer is "competent in the specific area under supervision". Therefore, we propose using language that was modeled after the engineering supervision requirement specified in NEC 240.86(A). We also believe that it is critical that the engineer be experienced with designing PV systems. In our experience, many licensed electrical engineers lack the experience required to correctly design PV systems because of it unique characteristics. Namely, it is a current and voltage limited generator. Many licensed engineers are very experienced with designing electrical systems that deliver electricity to loads connected the grid, which is a source with "infinite" current. Since the purpose of this definition is to define the credentials of the supervising engineer that will be permitted to use alternative methods to meet the requirements in article 690, it is imperative that this person have direct experience designing PV systems. Otherwise, the engineer might make mistakes that could have dangerous consequences. We believe the requested revision to this definition will reduce the chances that this could happen.

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Submitter Full Name: MARK ALBERS

Organization: SUNPOWER

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1356 of 2079 10/1/2015 11:02 AM



Designed and approved by a licensed professional engineer competent in the specific area under supervision.


The Correlating Committee directs that this First Revision be reviewed and the panel take action on the use of the word “approved” as it is a defined term and does not fit the definition. The panel is also directed to review the definitions for compliance with the NEC Style Manual.

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Organization: NFPA

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1357 of 2079 10/1/2015 11:02 AM

Public Comment No. 648-NFPA 70-2015 [ Definition: Generating Capacity. ]

Generating Capacity.

The sum of parallel -connected inverter maximum continuous output power at 40°C in kilowatts.


The use of the term parallel-connected clarifies the definition and removes any chance of ambiguity

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1359 of 2079 10/1/2015 11:02 AM

Public Comment No. 1847-NFPA 70-2015 [ Definition: Photovoltaic System Voltage. ]

Photovoltaic System Voltage.

The direct current (dc) voltage of any PV source or PV output circuit. For multiwire installations, the PV system voltage is thehighest voltage between any two dc conductors.


The Correlating Committee directs the Panel to clarify the definition and the informational note.

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First Revision No. 954-NFPA 70-2015 [New Definition after Definition: Photovoltaic System Voltag...]



Organization: NFPA

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1360 of 2079 10/1/2015 11:02 AM

Public Comment No. 1018-NFPA 70-2015 [ Definition: Reference Grounded PV System. ]

Reference Grounded PV System.

A PV system that has an electrical reference to ground that is not solidly grounded.

Informational Note: The reference to ground is often a fuse, circuit breaker, resistance device, non-isolated grounded accircuit, or electronic means that is part of a listed ground-fault protection system. Conductors in these systems that arenormally at ground potential may have voltage to ground during fault conditions.


This public comment deletes this new definition to address concerns expressed by the correlating committee. Rather than defining a new term, typical PV system configurations are still described in 690.41(A). The informational note used in the definition is revised and used to inform 690.41(A).

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First Revision No. 954-NFPA 70-2015 [New Definition after Definition: Photovoltaic System Voltag...]




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1361 of 2079 10/1/2015 11:02 AM


(B) Equipment.

Inverters, motor generators, PV modules, PV panels, ac PV modules, dc combiners, dc-to-dc converters, and charge controllersintended for use in PV systems shall be listed and labeled or field labeled for the PV application.










Related Item

Public Input No. 941-NFPA 70-2014 [Section No. 690.35(G)]



Public Input No. 1903-NFPA 70-2014 [Section No. 690.4(B)]



First Revision No. 1010-NFPA 70-2015 [Sections Part IX., 690.80, 690.81, 690.85]


1362 of 2079 10/1/2015 11:02 AM


(B) Equipment.

Inverters, motor generators, PV modules, PV panels, ac PV modules, dc combiners, dc-to-dc converters, and chargecontrollers intended for use in PV systems shall be listed or field labeled for the PV application.


Change "ac PV module" to "ac module." The term "ac PV module" is not defined in 690.2. Section 690.8 used the term "ac module."



Public Comment No. 889-NFPA 70-2015 [Section No. 690.4(D)]

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1364 of 2079 10/1/2015 11:02 AM

Public Comment No. 649-NFPA 70-2015 [ Section No. 690.4(D) ]

(D) Multiple PV Systems.

Multiple PV systems shall be permitted to be installed in or on a single building or structure. Where the PV systems are remotelylocated from each other, a directory in accordance with 705.10 shall be provided at each dc PV each PV system disconnectingmeans.


Disconnecting means for PV systems may be either ac or dc per the new set of drawings showing identification of PV system components. Deleting the term "dc" provides for complying with the requirements

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First Revision No. 963-NFPA 70-2015 [Section No. 690.4(D)]




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1365 of 2079 10/1/2015 11:02 AM


(D) Multiple PV Systems.

Multiple PV systems shall be permitted to be installed in or on a single building or structure. Where the PV systems are remotelylocated from each other, a directory in accordance with 705.10 shall be provided at indicate each dc PV system disconnectingmeans.


The language is misleading. I believe the intent is for the directory to define the location for each "PV system" disconnecting means. For instance, with microinverters, the current language will require a sign at each dc disconnect which is located at each microinverter. It is only necessary to have disconnecting means at the output of a "PV system." The proposed language clarifies this objective.



Public Comment No. 586-NFPA 70-2015 [Section No. 690.4(B)]

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1366 of 2079 10/1/2015 11:02 AM


690.7 Maximum Voltage.

PV system dc conductors on or in one- and two family dwellings shall be permitted to have a maximum voltage of 600 volts orless. PV system dc conductors on or in other types of buildings shall be permitted to have a maximum voltage of 1000 volts orless.

(A) Photovoltaic Source and Output Circuits.

In a dc PV source circuit or output circuit, the maximum PV system voltage for that circuit shall be calculated in accordance withone of the following methods:

(1) The sum of the PV module rated open-circuit voltage of the series connected modules corrected for the lowest expectedambient temperature using the open-circuit voltage temperature coefficients in accordance with the instructions included inthe listing or labeling of the module

(2) For crystalline and multicrystalline silicon modules, the sum of the PV module rated open-circuit voltage of the seriesconnected modules corrected for the lowest expected ambient temperature using the correction factor provided in Table690.7(A)

Informational Note: One source for statistically valid, lowest-expected, ambient temperature design data for variouslocations is the chapter titled Extreme Annual Mean Minimum Design Dry Bulb Temperature found in the ASHRAEHandbook — Fundamentals, 2009 2013 . These temperature data can be used to calculate maximum voltageusing the manufacturer’s temperature coefficients relative to the rating temperature of 25°C.

(3) For PV systems with a generating capacity of 100 kilowatts or greater, an industry standard method shall be permitted tobe used under engineering supervision.

Informational Note: One industry standard method for calculating maximum voltage of a PV system is published bySandia National Laboratories, reference SAND 2004-3535, Photovoltaic Array Performance Model.

Maximum voltage shall be corrected using one of the three following methods to calculate the module voltage:

(1) The open-circuit voltage temperature coefficients module voltage in accordance with the instructions included in the listingof the module.

(2) For crystalline and multicrystalline silicon modules, the correction factors provided in Table 690.7(A) shall be permitted tobe used.

(3) For PV systems with a generating capacity of 100 kilowatts or greater, alternate methods shall be permitted to be usedunder engineering supervision.

Informational Note: A method is published by Sandia National Laboratories, reference SAND 2004-3535, PhotovoltaicArray Performance Model.

The maximum voltage shall be used to determine the voltage rating of conductors, cables, disconnects, overcurrent devices,and other equipment.

Table 690.7(A) Voltage Correction Factors for Crystalline and Multicrystalline Silicon Modules

Correction Factors for Ambient Temperatures Below 25°C (77°F). (Multiply the rated open circuit voltage by theappropriate correction factor shown below.)

Ambient Temperature (°C) Factor Ambient Temperature (°F)

24 to 20 1.02 76 to 68

19 to 15 1.04 67 to 59

14 to 10 1.06 58 to 50

9 to 5 1.08 49 to 41

4 to 0 1.10 40 to 32

–1 to –5 1.12 31 to 23

–6 to –10 1.14 22 to 14

–11 to –15 1.16 13 to 5

–16 to –20 1.18 4 to –4

–21 to –25 1.20 –5 to –13

–26 to –30 1.21 –14 to –22

–31 to –35 1.23 –23 to –31

–36 to –40 1.25 –32 to –40


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(B) DC-to-DC Converter Source and Output Circuits.

In a dc-to-dc converter source and output circuit, the maximum voltage shall be calculated in accordance with 690.7(B) (1) or(2).

(1) For circuits connected to the output of a single dc-to-dc converter, the maximum voltage shall be the maximum ratedvoltage output of the dc-to-dc converter.

(2) For circuits connected to the output of two or more series-connected dc-to-dc converters, the maximum voltage shall bedetermined in accordance with the instructions included in the listing or labeling of the dc-to-dc converter.

(C) Bipolar Source and Output Circuits.

For 2-wire circuits connected to bipolar systems, the maximum voltage shall be the highest voltage between the conductors ofthe 2-wire circuit if all of the following conditions apply:

(1) One conductor of each circuit of a bipolar subarray is referenced to ground to prevent overvoltage of the circuit. Theoperation of ground-fault or arc-fault devices (abnormal operation) shall be permitted to interrupt the ground referencewhen the entire bipolar array becomes two distinct arrays isolated from each other and the utilization equipment.

(2) Each circuit is connected to a separate subarray.


Referenced current edition of ASHRAE Handbook-Fundamentals.



Public Comment No. 39-NFPA 70-2015 [Section No. 110.31]Referenced correct SDO name, standard name,number, and edition.



Public Comment No. 42-NFPA 70-2015 [Section No. Table]Referenced correct SDO name, standard name,number, and edition.

Public Comment No. 43-NFPA 70-2015 [Section No. B.310.15(B)(2)]Referenced correct SDO name, standard name,number, and edition.

Public Comment No. 47-NFPA 70-2015 [Section No. 770.44(B)]Referenced correct SDO name, standard name,number, and edition.


Public Comment No. 50-NFPA 70-2015 [Section No. 800.90(A)]Referenced correct SDO name, standard name,number, and edition.


Public Comment No. 52-NFPA 70-2015 [Section No. 830.44(C)]Referenced correct SDO name, standard name,number, and edition.





Public Comment No. 69-NFPA 70-2015 [Section No. 620.91 [Excludingany Sub-Sections]]

Referenced correct SDO name, standard name,number, and edition.

Public Comment No. 70-NFPA 70-2015 [Section No. 645.5(E)(2)]Referenced correct SDO name, standard name,number, and edition.





1368 of 2079 10/1/2015 11:02 AM





Public Comment No. 96-NFPA 70-2015 [Definition: Equipment Rack.]

Public Comment No. 110-NFPA 70-2015 [Section No. 500.6(A)(4)]



Public Comment No. 114-NFPA 70-2015 [Section No. 505.6 [Excludingany Sub-Sections]]

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Public Comment No. 477-NFPA 70-2015 [ Section No. 690.7 [Excluding any Sub-Sections] ]

PV system dc conductors on or in one- and two family dwellings shall be permitted to have a maximum system voltage of 600volts or less. PV system dc conductors on or in other types of buildings shall be permitted to have a maximum system voltage of1000 volts or less.


It's the system voltage that we are discussing, not the conductor insulation voltage.

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Submittal Date: Sun Aug 30 16:33:26 EDT 2015


1373 of 2079 10/1/2015 11:02 AM


690.7 Maximum Voltage.

PV system dc conductors on or in one- and two- family dwellings shall be permitted to have a maximum voltage of 600 volts orless. PV system dc conductors on or in other types of buildings shall be permitted to have a maximum voltage of 1000 volts orless.





Informational Note: One source for statistically valid, lowest-expected, ambient temperature design data for variouslocations is the chapter titled Extreme Annual Mean Minimum Design Dry Bulb Temperature found in the ASHRAEHandbook — Fundamentals, 2009. These temperature data can be used to calculate maximum voltage using themanufacturer’s temperature coefficients relative to the rating temperature of 25°C.

(3) For PV systems with a generating capacity of 100 kilowatts kW or greater, an industry standard method shall bepermitted to be used under engineering supervision.





(3) For PV systems with a generating capacity of 100 kilowatts kW or greater, alternate methods shall be permitted to beused under engineering supervision.






24 to 20 1.02 76 to 68

19 to 15 1.04 67 to 59

14 to 10 1.06 58 to 50

9 to 5 1.08 49 to 41

4 to 0 1.10 40 to 32

–1 to –5 1.12 31 to 23

–6 to –10 1.14 22 to 14

–11 to –15 1.16 13 to 5

–16 to –20 1.18 4 to –4

–21 to –25 1.20 –5 to –13

–26 to –30 1.21 –14 to –22

–31 to –35 1.23 –23 to –31

–36 to –40 1.25 –32 to –40


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(1) For circuits connected to the output of a single dc-to-dc converter, the maximum voltage shall be the maximum ratedvoltage output of the dc-to-dc converter.

(2) For circuits connected to the output of two or more series-connected dc-to-dc converters, the maximum voltage shall bedetermined in accordance with the instructions included in the listing or labeling of the dc-to-dc converter.


For 2-wire circuits connected to bipolar systems, the maximum voltage shall be the highest voltage between the conductors ofthe 2-wire circuit if all of the following conditions apply:

(1) One conductor of each circuit of a bipolar subarray is referenced to ground to prevent overvoltage of the circuit. Theoperation of ground-fault or arc-fault devices (abnormal operation) shall be permitted to interrupt the ground referencewhen the entire bipolar array becomes two distinct arrays isolated from each other and the utilization equipment.

(2) Each circuit is connected to a separate subarray.


Corrections are made to comply with the NEC style manual and to use consitent language for PV source circuits.

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1371 of 2079 10/1/2015 11:02 AM


PV system dc conductors on or in one- and two family dwellings shall be permitted to have a maximum voltage of 600 volts orless. PV system dc conductors on or in other types of buildings shall be permitted to have a maximum voltage of 1000 volts orless. PV system dc conductors and equipment not on or in a building with a maximum voltage of 1500V or less do not needto comply with Article 490.


In PI#3181 it was proposed to raise the voltage limit in the scope of Art. 490 from 1000V to 2000V. The substantiation for PI#3181 pointed out that product standards for HV equipment begin at 2000V and that recent changes to product standards for low voltage equipment have raised requirements suitable for higher voltages up to 1500V or 2000V in some cases.

In particular, for the PV industry there has been a lot of work done to revise product standards for switches, circuit breakers, fuses, modules, power conversion, etc. to cover PV system voltages up to at least 1500V. Such systems should not have to use the approaches in Art. 490, which are intended to address medium voltage installations at 2.4kV and higher using HV equipment. The burden such requirements place on PV systems are not justified at system voltages of 1500V or less using appropriately rated and approved equipment.

PI#3181 was resolved, but in their Resolution statement the CMP wrote "Increasling the upper limit may be practical in microenvironments such as those covered in Articles 690 or 694...:" which indicates that it would be appropriate to narrow the scope of PI#3181 to just PV, and move it to Art. 690 and 691, which we are now doing with this Public Comment and a related one for a revision to 691.8.

Note that we would like to get both revisions accepted: this one to 690.7 and the related one for 691.8. However if the CMP feels that they cannot accept this 690.7 proposal, please consider the 691.8 proposal separately and on its own merit.




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Submitter Full Name: JIM EICHNER

Organization: SCHNEIDER ELECTRIC

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1372 of 2079 10/1/2015 11:02 AM

10/5/2015 National Fire Protection Association Report

http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/Content/702014.ditamap/2/C1443801183685.xml&viewmode=nfpa/xslt/nfpaviewmode.xsl 1/5



Public Comment No. 1883NFPA 702015 [ Section No. 690.7(A) ]



In a dc PV source circuit or output circuit, the maximum PV system voltage for that circuitshall be calculated in accordance with one of the following methods:

(1) The sum of the PV module rated opencircuit voltage of the series connected modulescorrected for the lowest expected ambient temperature using the opencircuit voltagetemperature coefficients in accordance with the instructions included in the listing orlabeling of the module

(2) For crystalline and multicrystalline silicon modules, the sum of the PV module ratedopencircuit voltage of the series connected modules corrected for the lowest expectedambient temperature using the correction factor provided in Table 690.7(A)

Informational Note: One source for statistically valid, lowestexpected, ambienttemperature design data for various locations is the chapter titled Extreme AnnualMean Minimum Design Dry Bulb Temperature found in the ASHRAE Handbook— Fundamentals, 2009. These temperature data can be used to calculatemaximum voltage using the manufacturer’s temperature coefficients relative tothe rating temperature of 25°C.

(3) For PV systems with a generating capacity of 100 kilowatts or greater, an industrystandard method shall be permitted to be used under engineering supervision.

Informational Note: One industry standard method for calculating maximumvoltage of a PV system is published by Sandia National Laboratories, referenceSAND 20043535, Photovoltaic Array Performance Model.

Maximum voltage shall be corrected using one of the three following methods to calculate themodule voltage:

(1) The opencircuit voltage temperature coefficients module voltage in accordance withthe instructions included in the listing of the module.

(2) For crystalline and multicrystalline silicon modules, the correction factors provided inTable 690.7(A) shall be permitted to be used.

(3) For PV systems with a generating capacity of 100 kilowatts or greater, alternatemethods shall be permitted to be used under engineering supervision.

Informational Note: A method is published by Sandia National Laboratories, referenceSAND 20043535, Photovoltaic Array Performance Model.

The maximum voltage shall be used to determine the voltage rating of conductors, cables,disconnects, overcurrent devices, and other equipment.


Correction Factors for Ambient Temperatures Below 25°C (77°F). (Multiply the ratedopen circuit voltage by the appropriate correction factor shown below.)

Ambient Temperature (°C) Factor Ambient Temperature (°F)24 to 20 1.02 76 to 6819 to 15 1.04 67 to 5914 to 10 1.06 58 to 509 to 5 1.08 49 to 414 to 0 1.10 40 to 32–1 to –5 1.12 31 to 23–6 to –10 1.14 22 to 14–11 to –15 1.16 13 to 5



–16 to –20 1.18 4 to –4–21 to –25 1.20 –5 to –13–26 to –30 1.21 –14 to –22–31 to –35 1.23 –23 to –31–36 to –40 1.25 –32 to –40


SunPower would like to thank the CMP for adopting a version of our proposal to add provisions for using the Sandia Model to calculate the Maximum PV System Voltage It appears that two versions of 690.7(A) were included in the First Draft version of 690.7. SunPower supports using the first version and removing the second version as it more clearly states the requirements.

Related ItemFirst Revision No. 1020NFPA 702015 [Section No. 690.7]


Submitter Full Name:MARK ALBERSOrganization: SUNPOWERStreet Address:City:State:Zip:Submittal Date: Fri Oct 02 11:53:03 EDT 2015

Copyright Assignment

I, MARK ALBERS, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and fullrights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem andSubstantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication ofthe NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I amthe author of this Public Comment and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am MARK ALBERS, and I agree to be legally bound by the above CopyrightAssignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I amcreating an electronic signature that will, upon my submission of this form, have the same legal force and effect as ahandwritten signature


PV system dc conductors on or in one- and two- family dwellings shall be permitted to have a maximum voltage of 600 volts orless. PV system dc conductors on or in other types of buildings shall be permitted to have a maximum voltage of 1000 volts orless.


Editorial note: A "dash" should be added between the words "two" and "family."

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Maximum voltage shall be corrected using one of the three following methods to calculate the module voltage: The open-circuitvoltage temperature coefficients module voltage in accordance with the instructions included in the listing of the module.

For crystalline and multicrystalline silicon modules, the correction factors provided in Table 690.7(A) shall be permitted to beused.

For PV systems with a generating capacity of 100 kilowatts or greater, alternate methods shall be permitted to be used underengineering supervision.

Informational Note: A method is published by Sandia National Laboratories, reference SAND 2004-3535, PhotovoltaicArray Performance Model .





24 to 20 1.02 76 to 68

19 to 15 1.04 67 to 59

14 to 10 1.06 58 to 50

9 to 5 1.08 49 to 41

4 to 0 1.10 40 to 32

–1 to –5 1.12 31 to 23

–6 to –10 1.14 22 to 14

–11 to –15 1.16 13 to 5

–16 to –20 1.18 4 to –4

–21 to –25 1.20 –5 to –13

–26 to –30 1.21 –14 to –22

–31 to –35 1.23 –23 to –31

–36 to –40 1.25 –32 to –40


This text repeats what is already said more succinctly in 1-3 above.

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1375 of 2079 10/1/2015 11:02 AM


Submitter Full Name: BRIAN LYDIC

Organization: FRONIUS USA

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1376 of 2079 10/1/2015 11:02 AM









Maximum voltage shall be corrected using one of the three following methods to calculate the module voltage: The open-circuitvoltage temperature coefficients module voltage in accordance with the instructions included in the listing of the module.

For crystalline and multicrystalline silicon modules, the correction factors provided in Table 690.7(A) shall be permitted to beused.

For PV systems with a generating capacity of 100 kilowatts or greater, alternate methods shall be permitted to be used underengineering supervision.

Informational Note: A method is published by Sandia National Laboratories, reference SAND 2004-3535, PhotovoltaicArray Performance Model .





24 to 20 1.02 76 to 68

19 to 15 1.04 67 to 59

14 to 10 1.06 58 to 50

9 to 5 1.08 49 to 41

4 to 0 1.10 40 to 32

–1 to –5 1.12 31 to 23

–6 to –10 1.14 22 to 14

–11 to –15 1.16 13 to 5

–16 to –20 1.18 4 to –4

–21 to –25 1.20 –5 to –13

–26 to –30 1.21 –14 to –22

–31 to –35 1.23 –23 to –31

–36 to –40 1.25 –32 to –40


This appears to be an editing error in the draft. The deleted text duplicates the other text in the section.

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1377 of 2079 10/1/2015 11:02 AM




Informational Note: One source for statistically valid, lowest-expected, ambient temperature design data for various locationsis the chapter titled Extreme Annual Mean Minimum Design Dry Bulb Temperature found in the ASHRAE Handbook —Fundamentals , 2009. These temperature data can be used to calculate maximum voltage using the manufacturer’stemperature coefficients relative to the rating temperature of 25°C.



Informational Note: One source for statistically valid, lowest-expected, ambient temperature design data for variouslocations is the chapter titled Extreme Annual Mean Minimum Design Dry Bulb Temperature found in the ASHRAEHandbook — Fundamentals , 2009. These temperature data can be used to calculate maximum voltage using themanufacturer’s temperature coefficients relative to the rating temperature of 25°C.












24 to 20 1.02 76 to 68

19 to 15 1.04 67 to 59

14 to 10 1.06 58 to 50

9 to 5 1.08 49 to 41

4 to 0 1.10 40 to 32

–1 to –5 1.12 31 to 23

–6 to –10 1.14 22 to 14

–11 to –15 1.16 13 to 5

–16 to –20 1.18 4 to –4

–21 to –25 1.20 –5 to –13

–26 to –30 1.21 –14 to –22

–31 to –35 1.23 –23 to –31

–36 to –40 1.25 –32 to –40


1379 of 2079 10/1/2015 11:02 AM


The "informational Note" should be moved to the beginning of the section. Currently the draft has located this note under list item (2). This location suggests to the reader that it only applies to list item (2). This information equally applies to list item (1) and (3). A better location would be at the top of the list items as then it would be clear the "Informational Note" applies to all list items (1) through (3).

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1380 of 2079 10/1/2015 11:02 AM







(3) For PV systems with a generating capacity of 100 kilowatts or greater, an approved industry standard method shall bepermitted to be used under engineering supervision.











24 to 20 1.02 76 to 68

19 to 15 1.04 67 to 59

14 to 10 1.06 58 to 50

9 to 5 1.08 49 to 41

4 to 0 1.10 40 to 32

–1 to –5 1.12 31 to 23

–6 to –10 1.14 22 to 14

–11 to –15 1.16 13 to 5

–16 to –20 1.18 4 to –4

–21 to –25 1.20 –5 to –13

–26 to –30 1.21 –14 to –22

–31 to –35 1.23 –23 to –31

–36 to –40 1.25 –32 to –40


The correlating committee requested to rephrase this provision and the definition of engineering supervision. This comment allows the AHJ to decide what is an approved method. In reality, many AHJs require this type of calculation to be done by a design professional who is often an engineer.


1381 of 2079 10/1/2015 11:02 AM

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1382 of 2079 10/1/2015 11:02 AM




(1) Single dc-to-dc Converter. For circuits connected to the output of a single dc-to-dc converter, the maximum voltageshall be the maximum rated voltage output of the dc-to-dc converter.

(2) Two or More Series-connected dc-to-dc Converters. For circuits connected to the output of two or more series-connected dc-to-dc converters, the maximum voltage shall be determined in accordance with either of the followingmethods.

(a) The instructions included in the listing or labeling of the dc-to-dc converter.

(b) If instructions are not included in the listing or labeling of the dc-to-dc converter the maximum voltage shall be thesum of the maximum rated voltage output of the dc-to-dc converters in series.


DC-DC Converter instructions are not required to provide a method to calculate the maximum voltage when connecting them in series. In my experience most do not provide this information. Therefore a second method must be given in the code in the instance where the manufacturer does not provide the required method to calculate the maximum voltage. That is simply to sum up the maximum voltages of the individual devices.

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1383 of 2079 10/1/2015 11:02 AM



For 2-wire circuits connected to bipolar systems, the maximum voltage shall be the highest voltage between the conductors ofthe 2-wire circuit if all of the following conditions apply: One conductor of each circuit of a bipolar subarray is referencedconnnected to ground to prevent overvoltage of the circuit. The operation of ground-fault or arc-fault devices (abnormaloperation) shall be permitted to interrupt the ground reference when the entire bipolar array becomes a ground detector. At thedetection of a ground-fault, the entire bipolar array shall become two distinct arrays isolated from each other and the utilizationequipment. Each circuit is connected to a separate subarray to prevent overvoltage of either circuit .


This comment is to address the correlating committees concerns about use of terms related to reference grounding of PV systems. This revised language is consistent with the revised version of 690.41(A) and 250.21. Simply stated, the voltage of a bipolar array can be considered the highest voltage between the two conductors in a bipolar subarray provided that, in the event of a ground-fault, the two subarrays are isolated from one another so that their voltages cannot be additive. It is also not needed to state that the Bipolar PV system is isolated from utilization equipment since that is already a requirement in 690.41(B).

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1384 of 2079 10/1/2015 11:02 AM


(1) Photovoltaic Source Circuit Currents.

The maximum current shall be calculated by one of the following methods:

(1) The sum of parallel PV module rated short-circuit currents multiplied by 125 percent

(2) For PV systems with a generating capacity of 100 kilowatts or greater, an industry standard method, performed underengineering supervision, that accounts for the maximum current variables of elevation, array orientation, and irradiance.The calculated maximum current value used by this method shall not be less than 70 percent of the value calculated using690.8(A)(1) (a). The wire size shall not be smaller than the minimum wire size for the wiring terminal of theequipment, and the minimum wire size based on the product ratings and installation instructions.

Informational Note: One industry standard method for calculating maximum current of a PV system is available fromSandia National Laboratories, reference SAND 2004-3535, Photovoltaic Array Performance Model. This model is usedby the System Advisor Model simulation program provided by the National Renewable Energy Laboratory.


As written the calculations could result in use of a smaller wire size than is appropriate for the equipment.

We suggest appending the following text to the end of item (2): "The wire size shall not be smaller than the minimum wire size for the wiring terminal of the equipment, and the minimum wire size based on the product ratings and installation instructions."

Related Item

First Revision No. 966-NFPA 70-2015 [Section No. 690.8(A)(1)]


Submitter Full Name: Timothy Zgonena

Organization: UL LLC

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1385 of 2079 10/1/2015 11:02 AM


690.10 Stand-Alone Systems.

The premises wiring system shall be adequate to meet the requirements of this Code for a similar installation connected to aservice. The wiring on the supply side of the building or structure disconnecting means shall comply with the requirements of thisCode , except as modified by 690.10(A) through (D).

(A) Inverter Output.

The ac output from a stand-alone inverter(s) shall be permitted to supply ac power to the building or structure disconnectingmeans at current levels less than the calculated load connected to that disconnect. The inverter output rating or the rating of analternate energy source shall be equal to or greater than the load posed by the largest single utilization equipment connected tothe system. Calculated general lighting loads shall not be considered as a single load.

(B) Sizing and Protection.

The circuit conductors between the inverter output and the building or structure disconnecting means shall be sized based onthe output rating of the inverter. These conductors shall be protected from overcurrents in accordance with Article 240 . Theovercurrent protection shall be located at the output of the inverter.

(C) Single 120-Volt Supply.

The inverter output of a stand-alone solar PV system shall be permitted to supply 120 volts to single-phase, 3-wire,120/240-volt service equipment or distribution panels where there are no 240-volt outlets and where there are no multiwirebranch circuits. In all installations, the rating of the overcurrent device connected to the output of the inverter shall be less thanthe rating of the neutral bus in the service equipment. This equipment shall be marked with the following words or equivalent:

WARNING

SINGLE 120-VOLT SUPPLY. DO NOT CONNECT MULTIWIRE BRANCH CIRCUITS!

The warning sign(s) or label(s) shall comply with 110.21(B) .

(D) Back-Fed Circuit Breakers.

Plug-in type back-fed circuit breakers connected to the stand-alone output of a stand-alone inverter or multimode inverter shallbe secured in accordance with 408.36(D) . Circuit breakers marked “line” and “load” shall not be back-fed. PV system shall beinstalled in accordance with 705.175.


This comment removes the content of 690.10 and replaces it with a reference to the new 705,175 where the content of 690.10 was moved.

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First Revision No. 1045-NFPA 70-2015 [New Part after III.]




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1398 of 2079 10/1/2015 11:02 AM


690.10 Stand-Alone Systems.

The premises wiring system shall be adequate to meet the requirements of this Code for a similar installation connected to aservice. The wiring on the supply side of the building or structure disconnecting means shall comply with the requirements ofthis Code, except as modified by 690.10(A) through (D).

(A) Inverter Output.

The ac output from a stand-alone inverter(s) shall be permitted to supply ac power to the building or structure disconnectingmeans at current levels less than the calculated load connected to that disconnect. The inverter output rating or the rating of analternate energy source shall be equal to or greater than the load posed by the largest single utilization equipment connected tothe system. Calculated general lighting loads shall not be considered as a single load.


The circuit conductors between the inverter output and the building or structure disconnecting means shall be sized based onthe output rating of the inverter. These conductors shall be protected from overcurrents in accordance with Article 240. Theovercurrent protection shall be located at the output of the inverter.


The inverter output of a stand-alone solar PV system shall be permitted to supply 120 volts to single-phase, 3-wire, 120/240-voltservice equipment or distribution panels where there are no 240-volt outlets and where there are no multiwire branch circuits. Inall installations, the rating of the overcurrent device connected to the output of the inverter shall be less than the rating of theneutral bus in the service equipment. This equipment shall be marked with the following words or equivalent:

WARNING


The warning sign(s) or label(s) shall comply with 110.21(B).

(D) Energy Storage or Backup Power System Requirements.

Energy storage or backup power supplies are not required.

(E) Back-Fed Circuit Breakers.

Plug-in type back-fed circuit breakers connected to the stand-alone output of a stand-alone inverter or multimode inverter shallbe secured in accordance with 408.36(D). Circuit breakers marked “line” and “load” shall not be back-fed.


The public input states that (D) was deleted becasue the content was moved to the definition of a stand-alone system but the change to the definition was rejected by the CMP. (D) should therefore be left in.

The reason (D) was in 690.10 was because some AHJs were requiring storage to be installed on stand-alone systems that did not incorporate storage. Removing this could cause AHJs to start requiring storage on all stand-alone systems again.

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Public Input No. 3899-NFPA 70-2014 [Section No. 690.10(D)]




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1399 of 2079 10/1/2015 11:02 AM


690.11 Arc-Fault Circuit Protection (Direct Current).

Photovoltaic systems operating at 80 volts or greater shall be protected by a listed, labeled and identified PV arc-fault circuitinterrupteror other system components listed and labeled to provide equivalent protection. The system shall detect and interruptarcing faults resulting from a failure in the intended continuity of a conductor, connection, module, or other system component inthe PV system dc circuits.

Informational Note: Annex A includes the reference for the Photovoltaic DC Arc-Fault Circuit Protection product standard.

Exception: For PV systems not installed on or in buildings, PV output circuits and dc-to-dc converter output circuits that aredirect buried, installed in metallic raceways, or installed in enclosed metallic cable trays are permitted without arc-fault circuitprotection. Buildings whose sole purpose is to house PV system equipment shall not be considered buildings according to thisexception.










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Affilliation: UL

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Photovoltaic systems operating at 80 volts or greater shall be protected by a listed PV arc-fault circuit interrupteror other systemcomponents listed to provide equivalent protection. The system shall detect and interrupt arcing faults resulting from a failure inthe intended continuity of a conductor, connection, module, or other system component in the PV system dc circuits.


Exception: For PV systems not installed on or in buildings, PV output circuits and dc-to-dc converter output circuits that aredirect buried, installed in metallic raceways, or installed in enclosed metallic cable trays are permitted without arc-fault circuitprotection as long as ground fault protection is provided . Buildings whose sole purpose is to house PV system equipmentshall not be considered buildings according to this exception.


Removal of Arc-fault protection is removing a level of safety with the installed system. Ground fault protection will provide both series and parallel fault protection for workers should the conductor become damaged.

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1402 of 2079 10/1/2015 11:02 AM



Photovoltaic systems operating at 80 volts or greater shall be protected by a listed PV arc-fault circuit interrupteror othersystem components listed to provide equivalent protection. The system shall detect and interrupt arcing faults resulting from afailure in the intended continuity of a conductor, connection, module, or other system component in the PV system dc circuits.

Informational Note: Annex A includes the reference for the Photovoltaic DC Arc-Fault Circuit Protection productstandard.

Exception: For PV systems not installed on or in buildings, PV output circuits and dc-to-dc converter output circuits that aredirect buried, installed in metallic raceways, or installed in enclosed metallic cable trays are permitted without arc-fault circuitprotection. Buildings whose sole purpose is to house PV system equipment shall not be considered buildings according tothis exception.


The Correlating Committee directs that further consideration be given to the comments expressed in voting on FR 971.

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1403 of 2079 10/1/2015 11:02 AM



Photovoltaic systems operating at 80 volts or greater shall be protected by a listed PV arc-fault circuit interrupteror other systemcomponents listed to provide equivalent protection. The system shall detect and interrupt arcing faults resulting from a failure inthe intended continuity of a conductor, connection, module, or other system component in the PV system dc circuits.


Exception: For PV systems not installed on or in buildings, or for PV systems installed on or in buildings whose sole purposeis to house PV system equipment, PV output circuits and dc-to-dc converter output circuits that are direct buried, installed inmetallic raceways, or installed in enclosed metallic cable trays are permitted without arc-fault circuit protection. Buildingswhose sole purpose is to house PV system equipment shall not be considered buildings according to this exception. notrequired to comply with 690.11.


The wording saying basically that "some buildings shall not be considered buildings" does not sound very logical to me. My revised wording conveys the same meaning without creating a logical contradiction. Changed the wording to make it more clear that the exception allows noncompliance with 690.11.

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Photovoltaic systems operating at 80 volts or greater shall be protected by a listed PV arc-fault circuit interrupteror othersystem components listed to provide equivalent protection. The system shall detect and interrupt arcing faults resulting from afailure in the intended continuity of a conductor, connection, module, or other system component in the PV system dc circuits.

Informational Note: Annex A includes the reference for the Photovoltaic DC Arc-Fault Circuit Protection productstandard.

Exception: For PV systems not installed on or in buildings, PV output circuits and dc-to-dc converter output circuits that aredirect buried, installed in metallic raceways, or installed in enclosed metallic cable trays are permitted without arc-fault circuitprotection. Buildings whose sole purpose is to house PV system equipment shall not be considered buildings according tothis exception.


Enphase Energy supports the language proposed by CMP-4 especially at it applies to PV systems operating at 8- ovlts or less. This limit is important because without it, intra-module disconnecting means would be required. This technology is not available today.

The removal of the previous list items is important as it described the behavior of the Arc-Fault Circuit Protection device. Description of behavior belongs in the safety standards where they can be adequately described and tested.

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1405 of 2079 10/1/2015 11:02 AM


690.12 Rapid Shutdown of PV Systems on Buildings.

PV system circuits installed on or in buildings shall include a rapid shutdown in accordance with 690.12(A) through (E).

(A) Controlled Conductors.

Requirements for controlled conductors shall apply to PV system dc circuits and inverter output circuits supplied by the PVsystem. PV system dc circuits shall be controlled from all sources of supply, including energy storage or other dc powersources, as applicable. PV inverter output circuits shall only be required to be controlled from the PV source.

(B) Controlled Limits.

The use of the term, array boundary, in this section is defined as 30 cm (1 ft) from the array in all directions. Controlledconductors shall apply to 690.12(B) (1) and (2)

(1) Controlled conductors located outside the boundary or more than 1 m (3 ft) from the point of entry inside a building shallbe limited to not more than 30 volts within 10 seconds of rapid shutdown initiation. Voltage shall be measured betweenany two conductors and between any conductor and ground.

(2) Controlled conductors located inside the boundary or less than 1 m (3 ft) from the point of entry inside a building shall belimited to not more than 80 volts within 10 seconds of rapid shutdown initiation. Voltage shall be measured between anytwo conductors and between any conductor and ground. This requirement shall become effective January 1, 2018,

Informational Note: Inverter input circuit conductors can remain energized for up to 5 minutes with inverters not listed forrapid shutdown.

(C) Initiation Device.

Where multiple PV systems are installed on a single service, a single device shall initiate the rapid shutdown of all PV systemson that service. Additional auxiliary initiation devices operating in accordance with rapid shutdown equipment listings shall bepermitted. The rapid shutdown initiation device shall comply with one of the following:

(1) Where the PV system is connected in accordance with 705.12(D) and rapid shutdown initiates upon loss of voltage fromthe utility, the service disconnecting means shall be the initiation device.

(2) Where the PV system is connected in accordance with 705.12(A) and rapid shutdown initiates upon loss of voltage fromthe utility, the PV system disconnecting means shall be the initiation device.

(3) Where rapid shutdown does not initiate upon loss of voltage from the utility, the initiation device shall be readily accessibleand clearly indicate whether the PV system is “off” or “on.” The initiation device shall be lockable in the “off” position.

Informational Note: 690.12(C)(3) would apply to, for example, a PV system with standby operation where conductorsare not controlled upon loss of voltage from the utility.

(D) Manually Reset.

When the rapid shutdown system is manually initiated the PV system shall not reset without manual intervention.

(E) Equipment.

Equipment that performs the rapid shutdown functions, other than initiation devices such as listed disconnect switches, circuitbreakers, or control switches, shall be listed, labeled, and identified for providing rapid shutdown protection.

(F) Marking.

(1)

The rapid shutdown initiation device shall have a sign complying with 690.56 located on or no more than 1 meter (3 ft) from thedevice that includes the following wording:

RAPID SHUTDOWN PV SYSTEM DISCONNECT

(2)

If a rapid shutdown initiation device is not located near the service disconnecting means, a sign shall be installed at the servicedisconnecting means location, identifying the location of the initiation device.

Exception: Ground mounted PV system circuits that enter buildings or structures, of which the sole purpose is to house PVpower generating equipment, are not required to comply with 690.12.


I support FR 1008 to reduce the voltage within a rooftop PV array. This will ensure that fire service personnel do not become injured by accidentally coming into contact with a damaged PV array.


1406 of 2079 10/1/2015 11:02 AM

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Organization: Los Angeles County FD

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(D) Manually Reset.


(E) Equipment.


(F) Marking.

(1)



(2)




I support the proposed first revision language. Manual fire fighting efforts are necessary to control roof level fires for roof mounted PV arrays. PV arrays are expected to last over 20 years, with exposure to weather and natural hazards, and potentially minimal maintenance.The level of voltage output from PV assemblies must be reduced to allow safe and effective emergency response.

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Submitter Full Name: Richard Davis

Organization: FM Global

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PV system circuits installed on or in buildings shall include a rapid shutdown function to reduce shock hazard for emergencyresponders in accordance with 690.12 (A) through (E D ).


Requirements for controlled conductors shall apply only to PV system dc circuits and inverter output circuits supplied by thePV system. PV system dc circuits shall be controlled from all sources of supply, including energy storage or other dc powersources, as applicable. PV inverter output circuits shall only be required to be controlled from the PV source.


The use of the term, array boundary, in this section is defined as 30 cm (1 ft) from the array in all directions. Controlledconductors shall apply to outside the array boundary shall comply with 690.12(B) (1) and inside the array boundary shallcomply with 690.12 ( B) ( 2)

(1) Controlled conductors located outside the boundary or more than 1 m (3 ft) from the point of entry inside a building shallbe limited to not more than 30 volts

within 10

(1) within 30 seconds of rapid shutdown initiation. Voltage shall be measured between any two conductors and between anyconductor and ground.

Controlled

(1) Rapid shutdown equipment shall be installed to limit firefighter exposure to electrical hazards from the controlledconductors located inside the

boundary or less than 1 m (3 ft) from the point of entry inside a building shall be limited to not more than 80 volts within 10seconds of rapid shutdown initiation. Voltage shall be measured between any two conductors and between any conductor andground. This requirement

(1) array boundary and shall be listed and labeled as PV Equipment Safe for Proximity Fire Fighting.This requirement of 690.12(B)(2) shall become effective January 1,

2018,

(1)2020.

Informational Note:

Inverter input circuit conductors can remain energized for up to 5 minutes with inverters not listed for rapid shutdown

(1) The designation PV Equipment Safe for Proximity Fire Fighting identifies equipment and components that limit firefighterexposure to an electrical hazard within the array boundary after the Rapid Shutdown initiator has been activated. Thisdesignation addresses single point failures that might occur when the PV system is inadvertently damaged by firefightingoperations or other mechanical damage or during a building fire. Control of electric shock hazard may be achieved bymethods such as limiting access to exposed components that might become energized, reducing the potential differencebetween energized components, limiting the electric current that might flow in an electrical circuit involving personnel withincreased resistance of the conductive circuit, or by a combination of such methods .


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(E

Where multiple PV systems are installed on a single service, a single deviceThe initiation device(s) shall initiate the rapid shutdown function of

all PV systems on that service. Additional auxiliary initiation devices operating in accordance with rapid shutdown equipmentlistings shall be permitted.the PV system. The device "off" position shall indicate that the rapid shutdown function has been initiated. For one-family andtwo-family dwellings an initiation device(s) shall be located at a readily accessible location outside the building.

The rapid shutdown initiation device shall comply with devices shall consist of at least one of the following:

(1) Where the PV system is connected in accordance with 705.12(D) and rapid shutdown initiates upon loss of voltagefrom the utility, the service disconnecting means shall be the initiation device.


Where rapid shutdown does not initiate upon loss of voltage from the utility, the initiation device shall be readily accessibleand clearly indicate whether the PV system is “off” or “on.” The initiation device shall be lockable in the “off”

(3) Service disconnecting means.

(4) PV system disconnecting means.

(5) Readily accessible switch that plainly indicates whether the device is in the “off” or “on” position.

Informational Note: 690.12(C)(3) would apply to, for example, a PV system with standby operation where conductorsare not controlled that remains energized upon loss of utility voltage from the utility .

(D) Manually Reset.


Where multiple PV systems are installed with rapid shutdown functions on a single service, the initiation device(s) shallconsist of not more than six switches or six sets of circuit breakers, or a combination of not more than six switches andsets of circuit breakers, mounted in a single enclosure, or in a group of separate enclosures. These initiation device(s)shall initiate the rapid shutdown of all PV systems with rapid shutdown functions on that service. Additional auxiliaryinitiation devices, installed in accordance with rapid shutdown equipment listings, shall be permitted.

(D ) Equipment.

(2)

Equipment that performs the rapid shutdown functions, other than initiation devices such as listed disconnect switches, circuitbreakers, or control switches, shall be listed , and labeled , and identified for providing rapid shutdown protection.

(F) Marking.

(1)

The rapid shutdown initiation device shall have a sign complying with 690.56 located on or no more than 1 meter (3 ft) fromthe device that includes the following wording:


If a rapid shutdown initiation device is not located near the service disconnecting means, a sign shall be installed at the servicedisconnecting means location, identifying the location of the initiation deviceRapid shutdown equipment not meeting the requirements of 690.12(B)(2) shall be labeled Rapid Shutdown Equipment for PV.

Informational Note: Inverter input circuit conductors can remain energized for up to 15 minutes with inverters not listed for rapidshutdown .

Exception: Ground mounted PV system circuits that enter buildings or structures, of which the sole purpose is to house PVpower generating equipment, are not required to comply with 690.12 .



Proposal_690.12_NEC2017_FINAL.pdf The uploaded file contains a legible version of all proposed changes to 690.12.


These proposed revisions to 690.12, and 690.12(B)(2) in particular, are intended to enhance electrical protection within the array and significantly increase the safety of fire fighters working on roofs with PV equipment.

In order to measure an increase in safety, there should be a baseline for comparison. The number of PV-related fatalities of first responders is zero. According to the National Institute for Occupational Safety and Health database, between 1984 and 2013, there have been seven first responder deaths due to electrocution, and all were related to AC medium-voltage overhead or downed power lines. Not a single one was related to DC voltage from a PV array.


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As is often the case with the evolution of PV, we can look to European markets to offer some level of experience and guidance. A German study conducted by the Federal Ministry for Economic Affairs & Energy, TÜV Rheinland, and Fraunhofer was completed in March 2015 and titled “Assessment of the Fire Risk in Photovoltaic Systems and Elaboration of Safety Concepts for Minimization of Risks.” The study concluded that PV systems do not pose any particular threat to fire department personnel, provided they comply with safety clearances just as with any other live electrical equipment. Moreover, the vast majority of European PV systems do not utilize module-level electronics and there has never been a governing body that has enforced a code mandating module-level shutdown.

An additional report issued by Fraunhofer, Europe’s largest application-oriented research organization, was completed in May 2015 and titled “Recent Facts about Photovoltaics in Germany.” The report offered updated statistics regarding first responder safety and revealed a considerably successful record. With more than 1.4 million PV plants installed in Germany, to date no firefighter has been injured by PV power while putting out a fire. This significant fact becomes even more telling when you consider it was achieved in a market that does not mandate rapid shutdown at all, let alone module-level shutdown. The report goes on to state, “Comprehensive training courses for the fire brigade could eliminate any uncertainties firefighters may have. As with every electrical installation, it is possible to extinguish a fire using water from a distance of one to five meters. Based on investigations to date, all of the claims stating that the fire brigade could not extinguish a house fire due to the PV system have been found to be false.”

One must also look at the experience in the Australian market with very stringent requirements on generator shutdown put into force in 2012. Australia has today not only a leading role in the sheer numbers of PV installations but also in PV related fires. According to a report on metrosolar.com.au, as of November 2014, there have been more than 167 fires in Queensland alone, all related to the mandatory rooftop DC isolator.

Looking at the full picture, it turns out that there is no imminent need for a change of existing codes and procedures. It even shows, that adding an extra layer of complexity such as the mandatory DC isolators in Australia, might even increase the number of incidents and thus reduce the level of safety significantly, adding additional risk to every PV installation. One must conclude that every piece of equipment in a PV installation – especially if intended for an additional layer of safety – will have to be thoroughly specified and tested according to established standards.

As of today, there is no existing universal standard qualifying PV Equipment Safe for Proximity Fire Fighting. This standard still needs to be defined. It should account for the existing international experiences, defining a general safety objective, and shall not mandate the usage of a specific PV technology with a questionable effect on safety.

Looking at the details of the first draft of 2017 NEC, it is not clear that the suggested 80V limit will result in an increase in first responder safety. The 80V limit is somewhat arbitrary and was chosen primarily because it is greater than most modules’ maximum voltage rather than corresponding to a recognized safety limit. It is also, coincidentally, the threshold at which module level electronics manufacturers can comply using currently available solutions. According to UL 1310, the safe voltage in dry conditions is 60V and 30V in wet conditions (also 2014 NEC Chapter 9, Table 11(B)). Additionally, UL 62109-1 and 2014 NEC outline 240VA as the safe limit (energy hazard), which is a lower power level than many modules in the market today. The first draft of 2017 NEC removes the 240VA reference, while introducing an 80V limit. If first responders need to cut a hole in a roof and come into contact with a module, then they would potentially be exposing themselves to a higher voltage than prescribed by UL or current NEC. Even though the wiring between modules may not be live, the modules will remain energized. To cut through a roof in an area where PV exists would mean chopping through a module, potentially giving module power a path to ground and exposing firefighters to more than 300VA.

Furthermore, trusting rapid shutdown to reliably work without taking other personal safety measures could lead to perceived safety and a false sense of security. Therefore, there still needs to be a keep out zone for first responder guidance. If there is reason to get on the roof at all, it is also best to stay in the walkways and keep a safe clearance from the array. Thus, the proposed change in the first draft of 2017 NEC, 690.12 will not improve the safety of rooftop PV systems, but will only achieve an increase in system complexity, cost, maintenance, and add new risks.

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(D) Manually Reset.


(E) Equipment.


(F) Marking.

(1)



(2)




I support this effort to reduce the voltage within the array in an emergency. The lower voltage will greatly reduce possibility of personnel injury in an emergency.

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Submitter Full Name: Robert Hoover

Organization: Hagerstown Fire Department

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The use of the term, array boundary, in this section is defined as 30 cm (1 ft) from the array in all directions. Controlledconductors outside the array boundary shall apply to 690.12(B) (1) and inside the array boundary shall comply with690.12 (B)( 2).

(1) Outside the array boundary. Controlled conductors located outside the boundary or more than 1 m (3 ft) from the pointof entry inside a building shall be limited to not more than 30 volts within 10 30 seconds of rapid shutdown initiation.Voltage shall be measured between any two conductors and between any conductor and ground.

(2) Inside the array boundary. The PV system shall comply with (a) or (b):

(a) The PV array is listed and labeled or field labeled as a rapid shutdown PV array. Such a PV array is installed and usedin accordance with the instructions included with the rapid shutdown PV array listing and labeling or field labeling.

Informational Note: A listed or labeled or field labeled rapid shutdown PV array is evaluated to provide an equivalent or

lower shock hazard exposure as that provided by 690.12(B)(2)(b).


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(b) Controlled conductors located inside the boundary or

less

not more than 1 m (3 ft) from the point of

entry inside a

penetration of the surface of the building shall be limited to not more than 80 volts within

10

30 seconds of rapid shutdown initiation. Voltage shall be measured between any two conductors and between any conductorand ground.

This requirement

The requirement of 690.12(B)(2)(b) shall become effective January 1, 2018,



Where multiple PV systems are installed on a single service, a single device

The initiation device(s) shall initiate the rapid shutdown function of the PV system. The device “off” position shallindicate that the rapid shutdown function has been initiated for all PV systems

on

connected to that

service. Additional auxiliary initiation devices operating in accordance with rapid shutdown equipment listings shall bepermitted.

device. For one-family and two-family dwellings, an initiation device(s) shall be located at a readily accessible locationoutside the building.

The rapid shutdown initiation device shall comply with (s) shall consist of at least one of the following:



Where rapid shutdown does not initiate upon loss of voltage from the utility, the initiation device shall be readily accessibleand clearly indicate whether the PV system is “off” or “on.”



(5) Readily accessible switch that plainly indicates whether it is in the “off” or “on” position. The initiation device shall belockable in the “off” position.

Informational Note: One example of why an initiation device that complies with 690.12(C)(3) would apply to, forexample, be used is where a PV system with standby operation where conductors are not controlled is connected to anoptional standby system that remains energized upon loss of utility voltage from the utility .

(D) Manually Reset.


(E Where multiple PV systems are installed with rapid shutdown functions on a single service, the initiation device(s) shallconsist of not more than six switches or six sets of circuit breakers, or a combination of not more than six switches and sets ofcircuit breakers, mounted in a single enclosure, or in a group of separate enclosures. These initiation device(s) shall initiate therapid shutdown of all PV systems with rapid shutdown functions on that service. Where auxiliary initiation devices are installed,these auxiliary devices shall control all PV systems with rapid shutdown functions on that service.

(D ) Equipment.

Equipment that performs the rapid shutdown functions, other than initiation devices such as listed disconnect switches, circuitbreakers, or control switches, shall be listed

,

and labeled

, and identified

for providing rapid shutdown protection.

(F) Marking.


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(1)



(2)



Informational Note: Inverter input circuit conductors often remain energized for up to 5 minutes with inverters not listed for

rapid shutdown.



690-12_task_group_comment_version_9-24-15.docx

Word document in track changes mode to more easily read the final version and better understand the actual changes to the document since TerraView does not fully accurately represent the changes.


This comment on the first revision is a product of the NFPA Fire Fighter Safety and PV Systems Task Group that has been involved in an ongoing dialogue since December 2014 that includes this recommended language for the 2017 version of 690.12. This Task Group is made up of over 20 participants from Code Making Panel 4, the solar industry, the fire service, the insurance industry, test laboratories, and other relevant stakeholders.

A section-by-section summary of the recommended changes are described below.

Main paragraph:Renumbered list since two of the sections were removed. Also, the prime reason for rapid shutdown is clearly stated in the main paragraph as relating to the reduced shock hazard for emergency responders. The benefit of this reduced shock hazard to other personnel is not the purpose of this requirement or the standards that will support this requirement. This is an important distinction since some may try to use this equipment for purposes other than what they were intended for. For instance, 690.12 is not intended to provide electrical isolation for electrical worker safety. That electrical isolation is covered by the disconnecting means requirements in Part III, Disconnecting Means, of Article 690.

Section (A):This section was greatly simplified since the definition of a PV system has also been greatly simplified in the 2017 NEC cycle. The PV system can only control the ac output of PV inverters on the PV supply side of the circuit. If that circuit is connected to a utility-connected circuit breaker, only the PV end of the circuit can be deenergized since the circuit breaker is connected to a utility source that may need to be separately turned off.

Section (B): This section saw the most significant debate as it is the key difference between the 2014 NEC and the first draft of the 2017 NEC. The heading was changed to further clarify which section refers to outside versus inside the array boundary. Each subsection was given a heading for even further clarification.

The subsection related to within the array boundary [690.12(B)(2)] now provides for two methods of compliance. The first method is a performance requirement that requires the PV array be evaluated as a rapid shutdown PV array. Currently, there is no standard for this option, but it is key that this option be made available so that the standards process will see the need to develop a standard to which this equipment will be evaluated. It is expected that, once a standard is developed, many PV arrays will be listed and labeled for this function. However, some configurations may require field labeling which is why this option is also provided.

The fire service has expressed concern that the lack of a rapid shutdown PV array standard may result in lesser safety than the 80Volts required in 690.12(B)(2)(b). To further clarify that the intent of this listing process is for fire fighter safety, the informational note clarifies the intent that a listed product will equivalent or lesser hazard than a system built in accordance with 690.12(B)(2)(b). This clearly signals to the relevant standards committees, what the code intent is for this new standard.

The informational note about capacitors in inverters was moved to the equipment section where it more relevant. Lastly, the wording of the start date of the requirements inside the array boundary were clarified to specifically only apply to the area inside the array boundary. All other requirements in 690.12 are intended to be enforced when this version is enforce by a jurisdiction.

Section (C):The initiation device section was reorganized, simplified, and clarified for better enforcement. The list of devices is the same, but all the additional language about initiation on loss of utility voltage is removed since it is not relevant. The standard, which is already under


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development, addresses these different scenarios. The NEC only needs a simple list.

The main paragraph has been added to clarify that the function of the initiation device is to initiate rapid shutdown. It further clarifies that an initiation device in the “off” position puts the PV system in the rapid shutdown mode. Lastly, the first paragraph requires that the rapid shutdown initiator be located on the outside of the building for one- and two-family dwellings. This was requested by the fire service as many service disconnects may be internal to a building and difficult for fire fighters to access.

Section (D):This section was removed since the three initiator options are all switches that have an “on” or “off” position. The new clarified wording requires that an initiator in the “off” position requires that the PV system be in the rapid shutdown mode. If not initiators are turned “off” and the rapid shutdown system initiates on a loss of utility voltage, the fire fighter must know that they are unprotected until the initiator is moved to the “off” position since the power could be restored, which would reenergize the PV system (and potentially other ac wiring in the building).

Section (E):The word identified was changed to “labeled” since that is consistent with numerous changes in the first draft. The informational note was moved to this section as it is more relevant to equipment since inverters are one prominent piece of equipment.

Section (F):The marking section has been completely moved to the marking section of 690.56(C) and the intent of 690.12(F) has been captured in that new, much longer and detailed section.

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(D) Manually Reset.


(E) Equipment.


(F) Marking.

(1)



(2)




Representing fire fighters, I support the effort to shut down PV systems to the module level during emergencies. The recent proliferation of solar systems in our jurisdiction is having an impact on fire fighter's ability to respond to fire emergencies. Access and egress and egress during roof top operations and the inability to control utilities for the entire structure are concerns. It is vital that the code development process recognizes the need to protect fire fighter safety. This proposal utilizes existing technology to do just that.


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Submitter Full Name: RICHARD DOANE

Organization: CHICO FIRE-RESCUE

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(D) Manually Reset.


(E) Equipment.


(F) Marking.

(1)



(2)




Fire Marshals Association of Colorado supports the language in the First Revision as well as the work from the Firefighter Safety and PV System Task Group. PV system on rooftops can present a several hazards to firefighters, the most serious is electric shock in an emergency situation. This section and the proposed change is a significant step forward in improving firefighter safety.

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Submitter Full Name: DAVID LOWREY

Organization: BOULDER CITY OF

Affilliation: Fire Marshals Association of Colorado (FMAC)

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PV system circuits installed on or in buildings shall include a rapid shutdown function to reduce shock hazard for emergencyresponders in accordance with 690.12 (A) through ( E D ).


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The use of the term, array boundary, in this section is defined as 30 cm (1 ft) from the array in all directions. Controlledconductors outside the array boundary shall apply to comply with 690.12(B) (1) and inside the array boundary shall complywith ( B) ( 2) .

(1) Controlled conductors located outside the boundary or more than 1 m (3 ft) from the point of entry inside a building shall belimited to not more than 30 volts within 10 30 seconds of rapid shutdown initiation. Voltage shall be measured betweenany two conductors and between any conductor and ground.

(2) Rapid shutdown equipment shall be installed to limit firefighter exposure to electrical hazards from the controlledconductors located inside the array boundary and shall be listed and labeled as PV Equipment Safe for Proximity FireFighting. Controlled conductors located inside the boundary or less than 1 m (3 ft) from the point of entry inside a buildingshall be limited to not more than 80 volts within 10 seconds of rapid shutdown initiation. Voltage shall be measuredbetween any two conductors and between any conductor and ground.

Informational Note: The designation PV Equipment Safe for Proximity Fire Fighting identifies equipment and componentsthat limit firefighter exposure to an electrical hazard within the array boundary after the Rapid Shutdown initiator has beenactivated. This designation addresses single point failures that might occur when the PV system is inadvertently damagedby firefighting operations or other mechanical damage or during a building fire. Control of electric shock hazard may beachieved by methods such as limiting access to exposed components that might become energized, reducing the potentialdifference between energized components, limiting the electric current that might flow in an electrical circuit involvingpersonnel with increased resistance of the conductive circuit, or by a combination of such methods.

This requirement of 690.12(B)(2) shall become effective January 1, 2020. . 2018,

Informational Note:

Inverter Inverter input circuit conductors can remain energized for up to 5 minutes with inverters not listed for rapid shutdown.


The initiation device(s) shall initiate the rapid shutdown function of the PV system. The device “off” position shall indicate thatthe rapid shutdown function has been initiated. For one-family and two-family dwellings an initiation device(s) shall be located ata readily accessible location outside the building. Where multiple PV systems are installed on a single service, a single deviceshall initiate the rapid shutdown of all PV systems on that service. Additional auxiliary initiation devices operating in accordancewith rapid shutdown equipment listings shall be permitted. The rapid shutdown initiation device (s) shall consist of at leastcomply with one of the following:

(1) Where the PV system is connected in accordance with 705.12(D) and rapid shutdown initiates upon loss of voltage fromthe utility, the

service

(1) s Service disconnecting means shall be the initiation device .

(2) Where the PV system is connected in accordance with 705.12(A) and rapid shutdown initiates upon loss of voltage fromthe utility, the PV system disconnecting means shall be the initiation device .

(3) Where rapid shutdown does not initiate upon loss of voltage from the utility, the initiation device shall be

readily

(1) Readily- accessible switch that plainly and clearly indicate s whether the device PV system is in the “off” or “on . ”position. The initiation device shall be lockable in the “off” position.

Informational Note: 690.12(C)(3) would apply to, for example, a PV system with standby operation that remains energized where conductors are not controlled upon loss of utility voltage from the utility .

Where multiple PV systems are installed with rapid shutdown functions on a single service, the initiation device ( s) shall consistof not more than six switches or six sets of circuit breakers, or a combination of not more than six switches and sets of circuitbreakers, mounted in a single enclosure, or in a group of separate enclosures. These initiation device(s) shall initiate the rapidshutdown of all PV systems with rapid shutdown functions on that service. Additional auxiliary initiation devices, installed inaccordance with rapid shutdown equipment listings, shall be permitted.

( D) Manually Reset.


( E D ) Equipment.


Rapid shutdown equipment not meeting the requirements of 690.12 ( B)(2) shall be labeled Rapid Shutdown Equipment for PV.

Informational Note: Inverter input circuit conductors can remain energized for up to 15 minutes with inverters not listed for rapidshutdown.


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( F) Marking.

(1)



(2)


Exception:

Ground Ground mounted PV system circuits that enter buildings or structures, of which the sole purpose is to house PV powergenerating equipment, are not required to comply with 690.12 .



Attachment_for_SEIA_Public_Comment_No_1408_Art_690.12.docxFull Word version of comment to clarify formatting and complex text issues with the electronic submission.


These proposed revisions to 690.12, and 690.12(B)(2) in particular, are intended to enhance electrical protection within the array and significantly reduce the risk of accidental shock to fire fighters. Importantly, SEIA understands and largely agrees with the Fire Service’s intent to further enhance rapid shutdown requirements in the 2017 NEC. SEIA disagrees, however, with the specific requirement limits that have been aggressively promoted during this revision cycle and adopted by the NFPA’s Fire Fighter Safety Task Group (Task Group). The incorporation of these limits into the NEC would effectively mandate module level electronics, resulting in a variety of negative consequences. SEIA is also opposed to the creation of two options for compliance, as this will likely create two distinct and different levels of safety and performance based on which compliance method the installing contractor selects. In SEIA’s view, the 2017 NEC requirement for improving PV electrical safety for fire fighters should focus solely on the development of a new PV Equipment Safe for Proximity Fire Fighting standard and related equipment labeling.

SEIA’s proposal is intended to address fire service safety concerns without the negative effects of prescribing a specific product technology. Reliance on a specific technology would, in SEIA’s view, increase safety risks to service personnel, stifle innovation of potentially more effective rapid shutdown technologies, and decrease the value of solar PV to the consumer. Importantly, although SEIA strongly disagrees with the Task Group’s proposal for a module level electronics mandate, SEIA accepts nearly all of the other proposed changes agreed upon by the Task Group. SEIA’s proposed language, therefore, largely tracks the Task Group’s most recent language, with one obvious exception.

SEIA’s strong contention is that, given the absence of any independent technical justification for the proposed module level electronics mandate, it is inappropriate for the NFPA to set voltage requirements within the array equipment. Indeed, the NFPA would be setting an arbitrary level of safety based solely on statements from a few existing product manufacturers and not fact-based testing involving a wide selection of performance criteria. Indeed, it would be unprecedented for the NFPA to adopt a code change of this magnitude without any independent technical justification. SEIA believes that the product safety standard development process is the only appropriate path for limits, such as acceptable voltage, to be explored and documented.

Using existing live electrical fire fighting methods and well-documented techniques, fire fighters are able to safely perform fire-fighting operations involving PV arrays. But as with nearly any product involving electricity, there are always opportunities to make safety improvements, particularly when new safety-related technologies become available. Indeed, the three-year code development cycle speaks to the need to continuously update and improve the NEC. The NFPA has also consistently recognized that improvements to the code must be adopted on an incremental basis.

In contrast, if the proposed language from the Task Group is accepted by the CMP without revision, the NFPA would be codifying the wholesale adoption of module level electronic technology over a single code cycle, and would be doing this in advance of any product safety standard or long-term product field testing for this new requirement. In its haste to address the legitimate concerns of several important stakeholders, the NFPA risks a variety of unintended, and significantly adverse, consequences.

There are multiple approaches to significantly reduce the risk of shock hazard to fire fighters operating within the PV array boundary. In contrast, a module level electronics mandate would favor certain technologies over others. This is an overly prescriptive approach which will create a disincentive to develop competing technologies and stifle innovation. It should also be recognized that nearly all module level electronic devices being sold today are principally designed for power conversion and monitoring—not rapid shutdown.

The long-term reliability of module level electronics is also relatively unproven. Indeed, few devices currently being sold for module level rapid shutdown have undergone long-term reliability testing in the field. In addition, rapid shutdown devices used within the array boundary must endure harsh environments, e.g., operating temperatures up to 190 degrees °F, humidity, and corrosion. These devices are also subject to large daily temperature cycles, which, pursuant to Sandia National Laboratories, result in increased stress on componentry and more difficult thermal management. Module level electronics also incorporate a variety of sophisticated semiconductor-based components and printed circuit board assemblies, which are particularly susceptible to high temperatures. Given


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these risks, the better approach is to subject all rapid shutdown solutions to the rigors of long-term reliability testing before the wholesale adoption of any one technology.

Reliability is not only a concern for fire fighters but also for PV service personnel exposed to the inherent hazards of roof work. The concern here is that unreliable rapid shutdown devices will significantly, and unnecessarily, increase the amount of time PV installers and electricians spend on rooftops to replace or repair failed devices. And while PV installers and electricians recognize and accept the inherent risks of rooftop environments, no one should have to accept unnecessary exposure to such hazards.

Based on the foregoing, further improvements to 690.12 through the adoption of a PV Equipment Safe for Proximity Fire Fighting standard is the prudent approach. To allow adequate time for the development of this standard, it is essential that the effective date of subsection 690.12(B)(2) be deferred until January 1, 2020. Delayed enforcement is supported by a realistic assessment of the standards development process, recent experience with the 2014 NEC, and NFPA precedent on AC arc fault circuit interrupters (AFCI).

With respect to the 2014 NEC, while rapid shutdown requirements are starting to be implemented at the state-level, a rapid shutdown standard has not yet been adopted. SEIA recognizes that the necessary revisions are being made to UL 1741 to include a rapid shutdown standard consistent with the 2014 NEC but this new language will not be released until mid-2016, and this release date assumes the current standards development process remains on track. As a result, it will be the end of 2016 before products are listed to this standard and installed in the field, a full three years after the 2014 NEC was first published.

Delayed enforcement is also supported by NFPA precedent. For example, AFCI requirements were first published in the 1999 version of the NEC with a delayed enforcement date of Jan 1, 2002. Deferment will also allow for additional field testing of rapid shutdown equipment before final adoption of the 2020 NEC.

Related Item



Submitter Full Name: JOHN SMIRNOW

Organization: Smirnow Law

Affilliation: Solar Energy Industries Association

Street Address:

City:

State:

Zip:



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(D) Manually Reset.


(E) Equipment.


(F) Marking.

(1)



(2)




I support this first revision language for multiple reasons. 1) Dietz and Watson fire - this is a very strong example of a catastrophe created whereby the fire fighters could not pro-actively interact with a solar array to engage a rooftop fire using standard fire fighting practices. A very large and un-necessary property loss was the result. 2) There is no other appliance allowed to be used in and around populated areas, where there is not a clearly designated switch, plug or other de-energizing method for fully de-activing the system - why should solar be any different? This industry inconsistency results in an even greater hazard to those untrained in solar, as the


1427 of 2079 10/1/2015 11:02 AM

default expectation is that such that all electrical systems can be turned off and are fundamentally safe. 3) There is an increasing focus on reducing the cost of distributed energy by increasing the power and energy density of arrays. As part of increasing the rooftop power density, there is a critical need to be able to confidently and fully de-energize a solar array such that first responders can pro-actively engage directly with the PV array and roof areas as needed (such as quickly breaking out modules to increase access, roof venting, etc., and unless the array is de-energized to a safe level this is not possible).

The only remaining concern about the first revision as written, would be to dis-allow "radio frequency" or "power-line carrier" based devices or other remote based devices as an initiation device, given the inherent and un-reliable nature of these devices and the inability to confirm they operated successfully during a fire event (and were not damaged by the fire prior to being activated). There is only one thing worse than a known exposed electrical hazard to a fire fighter -and that is one where the fire fighter believes the hazard has been deactivated - when in fact they have not.

Related Item

Public Input No. 1008-NFPA 70-2014 [Section No. 700.12(F)(2)]


Submitter Full Name: TIM JOHNSON

Organization: TENKSOLAR

Street Address:

City:

State:

Zip:



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PV system circuits installed on or in buildings shall include a rapid shutdown in accordance with 690.12 (A) through (E).





(1) Controlled conductors located outside the boundary or more than 1 m (3 ft) from the point of entry inside a building shallbe limited to not more than 30 volts within 10 seconds of rapid shutdown initiation. Voltage shall be measured between anytwo conductors and between any conductor and ground.









(D) Manually Reset.


(E) Equipment.


(F) Marking.

(1)



(2)



I support reducing the voltage within the array during an emergency


i support the effort to reduce the voltage in the array in the event of an emergency

Related Item


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Submitter Full Name: jeb eckstine


Street Address:

City:

State:

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Requirements for controlled conductors shall apply only to PV system dc circuits and inverter output circuits supplied by the PVsystem. PV system dc circuits shall be controlled from all sources of supply, including energy storage or other dc powersources, as applicable. PV inverter output circuits shall only be required to be controlled from the PV source.


The use of the term, array boundary, in this section is defined as 30 cm (1 ft) from the array in all directions. Controlledconductors shall apply to outside the array boundary shall comply with 690.12(B) (1) and inside the array boundary shallcomply with (B)( 2).

(1) Controlled conductors located outside the boundary or more than 1 m (3 ft) from the point of entry inside a building shallbe limited to not more than 30 volts within 10 30 seconds of rapid shutdown initiation. Voltage shall be measured betweenany two conductors and between any conductor and ground.

(2) Controlled Rapid shutdown equipment shall be installed to limit firefighter exposure to electrical hazards from thecontrolled conductors located inside the boundary or less than 1 m (3 ft) from the point of entry inside a building shall belimited to not more than 80 volts within 10 seconds of rapid shutdown initiation. Voltage shall be measured between anytwo conductors and between any conductor and ground. This requirement shall become effective January 1, 2018,

Informational Note: Inverter input circuit conductors can remain energized for up to 5 minutes with inverters not listed for rapidshutdown

(1) array boundary and shall be listed and labeled as PV Equipment Safe for Proximity Fire Fighting.

Informational Note: The designation PV Equipment Safe for Proximity Fire Fighting identifies equipment andcomponents that limit firefighter exposure to an electrical hazard within the array boundary after the Rapid Shutdowninitiator has been activated. This designation addresses single point failures that might occur when the PV system isinadvertently damaged by firefighting operations or other mechanical damage or during a building fire. Control ofelectric shock hazard may be achieved by methods such as limiting access to exposed components that mightbecome energized, reducing the potential difference between energized components, limiting the electric current thatmight flow in an electrical circuit involving personnel with increased resistance of the conductive circuit, or by acombination of such methods.

This requirement of 690.12(B)(2) shall become effective January 1, 2020 .


Where multiple PV systems are installed on a single service, a single device The initiation device(s) shall initiate the rapidshutdown function of all PV systems on that service. Additional auxiliary initiation devices operating in accordance with rapidshutdown equipment listings shall be permitted the PV system. The device “off” position shall indicate that the rapid shutdownfunction has been initiated. For one-family and two-family dwellings an initiation device(s) shall be located at a readilyaccessible location outside the building . The rapid shutdown initiation device shall comply with (s) shall consist of at least oneof the following:



Where rapid shutdown does not initiate upon loss of voltage from the utility, the initiation device shall be readily accessibleand clearly indicate whether the PV system is “off” or “on.” The initiation device shall be lockable in the “off”



(5) Readily accessible switch that plainly indicates whether the device is in th e “off” or “on" position.

Informational Note: 690.12(C)(3) would apply to, for example, a PV system with standby operation where conductorsare not controlled that remains energized upon loss of utility voltage from the utility .


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(D)

Manually Reset.


(E) Equipment.


(F) Marking.

(1)



(2)

If a rapid shutdown initiation device is not located near the service disconnecting means, a sign shall be installed at the servicedisconnecting means location, identifying the location of the initiation device. Exception: Ground mounted PV system circuitsthat enter buildings or structures, of which the sole purpose is to house PV power generating equipment, are not required tocomply with 690.12 .

Rapid shutdown equipment not meeting the requirements of 690.12(B)(2) shall be labeled Rapid Shutdown Equipment for PV.

Informational Note: Inverter input circuit conductors can remain energized for up to 15 minutes with inverters not listed for rapidshutdown.


Sunrun supports the proposed alternative code language offered by the Solar Energy Industries Association (SEIA), which takes a balanced and reasonable approach to accessing actual safety risks and developing a variety of technical solutions to improve fire fighter safety. Sunrun supports these proposed revisions to 690.12 that will allow for continued electrical protection within the array and reduce risk for fire fighters, while providing needed flexibility for a variety of technical solutions to develop. We support the Fire Service in their intent to further enhance fire safety requirements in the 2017 NEC, however we disagree with the specific proposed requirement to limit voltage to 80 volts within an array after rapid shutdown initiation. This will effectively requires module level power electronics at significant upfront cost as well as unknown long term costs associated with reliability. There are currently too few proven module level products to choose from in the market.

SEIA’s proposal addresses fire service safety concerns without the negative effects of prescribing a specific product technology which has limited selection. Reliance on a specific technology would stifle innovation of potentially more effective rapid shutdown technologies, increase cost, and decrease the value of solar PV to the consumer.

Additionally, new technologies should only be incorporated into the NEC on an incremental basis, and should allow time to test new technologies in the field to ensure reliability and safety. To allow adequate time for the development of this standard, it is essential that the effective date of subsection 690.12(B)(2) be deferred until January 1, 2020. Deferment will also allow for additional field testing of rapid shutdown equipment before final adoption of the article.

Related Item



Submitter Full Name: Amy Heart

Organization: Sunrun, Inc

Street Address:

City:

State:

Zip:



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PV system circuits installed on or in buildings shall include a rapid shutdown in accordance with 690.12 (A) through (E).






(2) Controlled Rapid shutdown equipment shall be installed to limit firefighter exposure to electrical hazards from thecontrolled conductors located inside the boundary or less than 1 m (3 ft) from the point of entry inside a building shall belimited to not more than 80 volts within 10 seconds of rapid shutdown initiation. Voltage shall be measured between anytwo conductors and between any conductor and ground. array boundary and shall be listed and labeled as PV EquipmentSafe for Proximity Fire Fighting. This requirement shall become effective January 1, 2018 2020 ,

Informational Note 1 : The designation PV Equipment Safe for Proximity Fire Fighting identifies equipment andcomponents that limit firefighter exposure to an electrical hazard within the array boundary after the Rapid Shutdowninitiator has been activated. This designation addresses single point failures that might occur when the PV system isinadvertently damaged by firefighting operations or other mechanical damage or during a building fire. Control of electricshock hazard may be achieved by methods such as limiting access to exposed components that might becomeenergized, reducing the potential difference between energized components, limiting the electric current that might flowin an electrical circuit involving personnel with increased resistance of the conductive circuit, or by a combination of suchmethods.








(D) Manually Reset.


(E) Equipment.

Equipment that performs the rapid shutdown functions, other than initiation devices such as listed disconnect switches, circuitbreakers, or control switches, shall be listed , and labeled , and identified for providing rapid shutdown protection. Rapidshutdown equipment not meeting the requirements of 690.12(B)(2) shall be labeled Rapid Shutdown Equipment for PV.

(F) Marking.

(1)




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(2)




SunPower actively supports improving the safety of PV Systems. We have aggressively attacked the primary cause of fires in PV systems, undetected ground faults, by offering more sensitive ground fault protection (GFP) upgrades to our customers with systems that use legacy ground fault protection technology. All of our new systems employ more sensitive GFP equipment before it has been required by the inverter standards, in line with the revisions to 690.5 in the 2014 NEC. As a result of this work, we have reduced the occurrence of fires in SunPower PV systems from being rare to being almost extinct.

In addition to improved GFP, we also support the need to add control systems to new PV systems that limit the exposure of emergency response personnel, such as firefighters, to electrical hazards. With this goal in mind, we request that the CMP 4 alter the 2017 NEC requirements for Rapid Shutdown inside the array boundary to require that all new PV systems use equipment or components that will limit the electrical hazard for firefighters and that these devices be required to be certified to provide this functionality. This certification will ensure that all the devices used for Rapid Shutdown within the array boundary reliably provide the required level of safety before they are sold to the public. Furthermore, compliance with the standard will ensure that a product does not create a liability for the NFPA, the product manufacturer, the system owner, nor system integrator because the product fails to protect a firefighter from injury, a real possibility with the first draft requirement for 690.12(B)(2).

The current language only requires that the devices controlling conductors inside the array boundary limit the voltage to 80V. There is no mention of what conditions under which this device must function, no mention of whether the device needs to periodically self-test, no mention of whether it needs to be fail-safe, no mention of immunity to heat, electrical noise, or moisture. To be clear, we don’t think that these requirements should be spelled out in the NEC, but they are essential to the safe and reliable operation of these devices. Hence, we request that the 80V requirement be replaced with a new certification requirement. It is critical that this certification requirement be distinct from the other rapid shutdown requirement because it will need to provide functionality that is distinct from the other devices. The rapid shutdown devices outside of the array boundary only need to isolate certain conductors. The devices inside the array boundary need to limit the electrical hazards on the components directly connected to the PV modules, which are always energized. The present language is also silent about the amperage requirement, which is the physical quantity that actually causes harm to humans. With 80V and no limit on current, it is still possible to electrocute a human. As a result, the 80V limit does not truly address the electrical hazard; it just sounds impressive and can be realized by the product manufacturers sponsoring this requirement. Whereas, the PV Equipment Safe for Proximity Fire Fighting standard can define in painful detail the current limits that are required for limiting the electrical hazard to the standards development. This will ensure that all Rapid Shutdown products installed in the field provided the required level of protection.

While we need to move as fast as reasonably possible to deploy these new devices, we also need to ensure that the devices have undergone sufficient product testing before they are deployed. Otherwise, the public (PV system owners) will bear the responsibility of performing the product testing, which is an inappropriate transfer of this responsibility from the product manufacturers to the public. SunPower continues to replace and upgrade faulty AFCI equipment in our customer’s PV systems because the products were rushed to the market before they were ready for primetime. We have replaced AFCI equipment for over 4,000 customers, many of whom are very upset that the products were not adequately tested before they were required to be installed. The certification requirement and the delayed enforcement date of January 1, 2020 will ensure that the rapid shutdown devices will be sufficiently validated for functionality and reliability before being installed in real customers systems.

Lastly, if the Rapid Shutdown products are not adequately certified, who will be liable for the consequences when a poorly designed product injures a firefighter? The 80V requirement could be met by products that have been carefully designed and validated or by ones that were developed by an opportunistic company that does not plan to be in business when the products start failing. The certification requirement will prevent inadequately designed products from being used in PV systems. If this certification requirement is not developed and imposed, who will be liable when a firefighter is injured because the 80V limit does not provide the level of protection that has been claimed by its proponents (electric current is actually what hurts humans)? If the 80V requirement remains, the liability for these injuries could fall on the NFPA for creating a requirement that does provide the level of safety it suggests is being provided.

SunPower agrees that there is a need to improve safety of PV Systems for firefighters. However, the 80V requirement proposed for the 2017 NEC does NOT address this need. The certification requirement proposed by SunPower and others will allow for the development of the many functional requirements and test requirements that cannot be defined in the NEC. This process will take some time as evidenced by the revisions to UL 1741 for the 2014 Rapid Shutdown requirements and the development of UL 1699B for PV AFCI requirements. As a result, we request that the enforcement of this requirement be scheduled for January 1st, 2020 to provide the time required to develop the necessary standards and to validate that products meet this standard. Additionally, the labeling associated with this certification (PV Equipment Safe for Proximity Fire Fighting) will make it easy for inspectors to verify that the equipment deliveries the expected level of safety for firefighters.



Public Comment No. 1658-NFPA 70-2015 [Section No. 690.56(C)]

Related Item


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Street Address:

City:

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(D) Manually Reset.


(E) Equipment.


(F) Marking.

(1)



(2)




The Correlating Committee directs the Panel to revise the text including the informational note to comply with the NEC Style manual.

Related Item



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Organization: NFPA

Street Address:

City:

State:

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(D) Manually Reset.


(E) Equipment.


(F) Marking.

(1)



(2)




I support the effort to reduce the voltage in a PV array under emergency conditions.

Related Item



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Submitter Full Name: Corey Condren

Organization: San Jose Fire Department

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 31 17:14:33 EDT 2015


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(D) Manually Reset.


(E) Equipment.


(F) Marking.

(1)



(2)




Enphase Energy supports the language proposed by CMP-4 especially the reduced voltage level within an array when initiated by emergency personnel. Rooftop PV arrays should reduce be able to shut down to safe voltage levels in the event of emergency conditions. This is particularly important when considering the life span of a system as older systems may present electrical hazards to emergency personnel.


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Related Item





Street Address:

City:

State:

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(D) Manually Reset.


(E) Equipment.


(F) Marking.

(1)



(2)




I am in favor of this first revision to reduce the voltage within an array during emergency operations.

Related Item



1442 of 2079 10/1/2015 11:02 AM


Submitter Full Name: JOHN JUSTICE

Organization: SANTA CLARA CNTY FIRE DEPT

Street Address:

City:

State:

Zip:



1443 of 2079 10/1/2015 11:02 AM





The second sentence "PV inverter output circuits shall only be required to be controlled from the PV source" is unclear as to its intent. If intended for module integrated inverters, it is implying that a disconnect device is required on the dc side of the inverter (so that the ac inverter output is de-energized). I think it is meant to apply to roof-mounted string inverters that are more than 3 ft from the array.

Related Item

First Revision No. 3659-NFPA 70-2015 [Section No. 708.10(C)(1)]


Submitter Full Name: Robert Wills

Organization: Intergrid, LLC

Street Address:

City:

State:

Zip:



1444 of 2079 10/1/2015 11:02 AM





This section was greatly simplified since the definition of a PV system has also been greatly simplified in the 2017 NEC cycle. The PV system can only control the ac output of PV inverters on the PV supply side of the circuit. If that circuit is connected to a utility-connected circuit breaker, only the PV end of the circuit can be deenergized since the circuit breaker is connected to a utility source that may need to be separately turned off.

Related Item



Submitter Full Name: PHIL UNDERCUFFLER

Organization: OUTBACK POWER TECHNOLOGIES

Street Address:

City:

State:

Zip:



1445 of 2079 10/1/2015 11:02 AM





(2) Controlled conductors located inside the boundary or less than 1 m (3 ft) from the point of entry inside a building shall belimited to not more than 80 220 volts within 10 seconds of rapid shutdown initiation. Voltage shall be measured betweenany two conductors and between any conductor and ground. This requirement shall become effective January 1, 2018,



80 V seems an arbitrary limit, not determined by the shock hazard. Household voltage exceeds 220 Vac; the electrocution hazard is considered acceptable for residents, etc.. The hazardous voltage threshold for DC is higher than for AC and firefighters wear gloves that offer at least some additional protection.

Raising the voltage to 220-240 V, or similar, would bring the code more in line with existing standards.

The problem with this requirement from the firefighter's perspective is it creates a false sense of security. The module-level electronics required to achieve the 80-V limit are certain to fail over time, in ways that may not be predictable. Hidden behind the solar modules on a roof, they will be difficult to check. If the electronics doesn't "fail safe", firefighters that trust the rapid shutdown system may not take adequate precautions. In this case, it would be better, for example, to throw fire blankets over the array to assure low voltage within the array boundary. Dry leather gloves might also be better protection than electronics that may or may not be working as promised.

Related Item



Submitter Full Name: Geoffrey Kinsey

Organization: Mantech International

Street Address:

City:

State:

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SMA-NEC2017_WhitePaper_FINAL.pdfWhite Paper on the value of module-level rapid shutdown from SMA (largest PV inverter manufacturer in the world)

Fronius_Reliability.pdf Fronius paper on inverter reliability


A Risk Analysis related to the PV Rapid Shutdown Proposal, 690.12(B)(2).

690.12(B)(2) essentially mandates module-level electronics in every PV module for rooftop solar. While perhaps a well-intentioned proposal to improve safety for fire fighters, it in fact is likely to both increase the number of accidents on rooftops (especially amongst electrical workers), and also increase the likelihood of rooftop fires.This proposed requirement will put thousands of IBEW and independent electrical contractors at risk, every year.The 2014 NEC required in 690.4(C) "The installation of equipment and all associated wiring and interconnections shall be performed only by qualified persons." – this means, in most cases, electrical contractors.

The submitters did not provide technical justification for this new requirement. In fact, PV systems have been installed on roofs now for more than 35 years. In this time, I understand that there has not been a single reported incidence of electric shock to fire fighters. This view is supported by the attached white paper from SMA, the world's largest PV inverter manufacturer.

This proposal was promoted by manufacturers such as Enphase and Solar-edge who claim that their reliability numbers make maintenance a non-issue, and stand to profit enormously from this requirement. Enphase, for example claims a Mean Time Between Failure (MTBF) of > 300 years. This is a theoretical number, and it does not take into account beginning and end of life effects. It is also about 10 x higher than the MTBF numbers quoted by string inverter manufacturers (i.e., 30 years) which operate typically in a far less demanding thermal regime. The literature (e.g., the paper by Fronius, attached, suggests that a 100 year MTBF is more likely. I use 200 years in the analysis below).

Estimate of residential roof fires where a PV array is present (2022):- NFPA reported 368,000 residential structure fires in 2014- Assume roughly half of these resulted in a need for firefighter roof access (200,000)- There will be about 1 million PV systems on residential roofs by 2022. That’s 0.75% of the total US housing stock of 133 million.- Estimate of residential roof fires with PV on the roof (2022): 1500 per year.

Estimating rooftop inverter or converter failures (2022) :- Estimated new PV systems installed 2017 – 2022: 500,000 (source – SEIA – similar to current installation rate)- Average system size: 10 kW- Module/inverter rating: 250 W- Module-inverters per system: 40- Total inverters installed over 5 years: 20 million- Estimated MTBF: 200 years (0.5% failures per year)- Annual failures: 100,000 – which need to be repaired

In summary, a well-intentioned effort to protect firefighters from 1500 fire instances per year could put 100,000 electricians working on roofs every year. This is clearly an unreasonable risk and burden to the electrical worker community.

Further, as inverter failures per year would continue to grow as more systems are installed, and as inverter components age, things would get worse in later years.


1448 of 2079 10/1/2015 11:02 AM

The additional fire risk related to installing 20 million power electronics devices on rooftops is hard to quantify – but it probably more than 1500 per year. In other words, a measure designed to protect fire fighters could subject them to maybe twice as many fires with PV on the roof than without module-level rapid shutdown.

690.12(B)(2) mandates an UNPRECEDENTED installation of electrical apparatus on residential rooftops without full analysis of its personnel and fire-safety impact.

It is important to point out that replacing a micro-inverter or junction box converter in the middle of a PV array may involve disassembly of a significant portion of the array – it’s a complicated process that exposes the installer to fall hazards, and often several hours of rooftop work to replace a $200 component.

Finally, the proposal related to 690.12(B)(2) has not been developed in accordance with NFPA and ANSI regulations. The NFPA’s Guide For The Conduct of Participants in the NFPA Standards Development Process states :… all participants in the NFPA Standards Development Process should adhere tothe following general principles:…(b) To maintain a process that is open, honest, and fair to all participants(c) To promote the development of codes and standards that are scientificallyand technically sound, that promote creativity and innovation in the developmentof new methods and technologies, and that set reasonable standards intendedto minimize the possibility and effects of fire and related hazards(d) To promote the development of consensus through the broad and balancedparticipation of a variety of interests and through the full airing and discussionof all points of view

690.12(B)(2), as proposed, fails to meet (b), (c), or (d). Rather than “minimizing the possibility and effects of fire and related hazards”, it increases them.

The representative for the solar industry on CMP4 (SEIA) voted negative (as did I – a former SEIA alternate) on the first draft of 690.12 revisions). The present 690.12 working group has little representation from the PV industry in general (i.e. module manufacturers, inverter manufacturers and installers). It appears to be a partisan group.

I urge CMP4 to remove 690.12(B)(2) as proposed, and give this topic to a balanced working group who can develop a consensus, technically sound proposal on this topic for the 2020 NEC.

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(1) Controlled conductors located outside the boundary or more than 1 m (3 ft) from the point of entry inside a building shall belimited to not more than 30 volts within 10 seconds of rapid shutdown initiation. Voltage shall be measured between anytwo conductors and between any conductor and ground.

Controlled conductors located inside the boundary or less than 1 m (3 ft) from the point of entry inside a building shall belimited to not more than 80 volts within 10

(2) DC or 15 volts ac within 30 seconds of rapid shutdown initiation. Voltage shall be measured between any two conductorsand between any conductor and ground.

(3) This requirement shall become effective January 1, 2018,



Including conductors under the PV array as controlled conductors will mandate PV Module level electronics. This will result in significantly increased maintenance activities and reduced system reliability. The increase in risk of injury to service personnel will be an unacceptable unintended consequence.

The national fire code already includes requirements for roof access areas for firefighters. These access areas allow firefighters to perform their job in a reasonable manner with no risk of electrical injury. It would be reasonable to reduce the 1 Foot requirement to zero feet. This would allow firefighters to quickly and easily determine those areas that contain controlled conductors.

It is clear that those within the PV industry who are supporting the Module Level requirement stand to benefit from implementation as written. If we took this same approach to transportation vehicles, we would require that all petroleum products in the vehicle become non-flammable in the event of an accident.

If implemented as currently written, this will be a train wreck.

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Submitter Full Name: Marv Dargatz

Organization: Kaylaco Enterprises, LLC

Affilliation: PV industry consultant

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(2) Controlled conductors located insideInside the array boundary

or less than 1 m (3 ft) from the point of entry inside a building shall be limited to not more than 80 volts within 10 secondsof rapid shutdown initiation. Voltage shall be measured between any two conductors and between any conductor andground. This requirement, the PV system shall comply with either (a) or (b):

(a) Building-integrated PV power sources listed as a complete assembly, having no grounded components, andhaving ungrounded PV power source circuits shall be listed and labeled or field labeled as a building-integratedrapid shutdown PV array.

(b) PV system DC circuit components shall be listed and labeled as rapid shutdown PV equipment.

The requirement of 690.12(B)(2) shall become effective January 1, 2018

,.



Dow Chemical is a manufacturer of BIPV shingles that do not have accessible wiring. Field inspection to the 690.12(B)(2) requirement is impossible without damaging the product. Dow Chemical strongly supports the development of a test standard so that compliance can be verified through listing/labeling. It is Dow’s preference that compliance to a listing/labeling requirement be mandated in the code for all industry participants, but as a minimum it should be allowed as a method of compliance. Options (a) and (b) are added to address this.

Option (a) is for products expected to function as part of the building envelope long after the power production lifetime has expired. These products can remain installed for 50 years or more, far longer than the life of the electronics inside of them. When listed as a PV array rather than as a sum of listed components, manufacturers can eliminate shock hazards without the use of electronics. The Dow Chemical BIPV shingle achieves this objective by eliminating conduction paths, even when wet and damaged. It does not use a metal frame or racking system. The product listing restricts applications to pitched, wooden roof decks. There is no grounded metal on the roof, and when used in combination with an ungrounded inverter, there is no possible conduction path to ground even if the PV circuit is exposed. These types of inherent safety improvements for BIPV products should not be discouraged through prescriptive code language. BIPV products should instead be subject to a different listing requirement that enables an equivalent or greater level of shock hazard protection using methods that consider the longevity of the products.

Option (b) is for non-BIPV component manufacturers that want to comply through listing/labeling much like they do today for other code requirements.

30V (725.41) and 50V (200.7) are industry-standard voltage cutoffs already defined within the Code. The arbitrary 80V language in 690.12(B)(2) is uniquely tailored to allow microinverter companies a method of compliance without meeting a listing/labeling requirement. This favors a particular industry technology designed for traditional PV modules. No equivalent technology exists for many types of building integrated PV. Dow has reached out to over 30 electronics firms that serve the PV market. None of those firms have or will have technology by 2018 that would enable BIPV firms to comply with the 690.12(B)(2) requirement. Even with an option for compliance through listing/labeling, if a test standard is not finalized by January 2018, Dow and other BIPV manufacturers will be unable to meet the code requirement. If this happens, the listing exemption will give microinverters an unfair market advantage. There is no technical reason to treat microinverters differently in the code.




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Submitter Full Name: Stephen Pisklak

Organization: Dow Chemical

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(2) Controlled conductors located inside the boundary or less than 1 m (3 ft) from the point of entry inside a building shall belimited to not more than 80 volts within 10 seconds of rapid shutdown initiation. Voltage shall be measured between anytwo conductors and between any conductor and ground. This requirement shall become effective January 1, 2018, .Exception: Building-integrated photovoltaics with no grounded components except as required by 690.31(G).



30V (725.41) and 50V (200.7) are industry-standard voltage cutoffs already defined within the Code. The 80V value is not derived from any safety testing; it is designed to allow compliance through the use of microinverters and traditional panels. No equivalent technology exists for many types of building integrated PV (BIPV). The 80V requirement therefore favors a particular industry technology, and non-traditional PV products should be allowed time to develop similar solutions. Industry experts, including those representing microinverter companies, have publically estimated this development cycle to be about 5 years. An exception for one code cycle is therefore warranted for what is a relatively small segment of the overall rooftop PV market.



Public Comment No. 1386-NFPA 70-2015 [Section No. 690.12(B)] Alternate acceptable revision.

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Submitter Full Name: Stephen Pisklak

Organization: Dow Chemical

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Worker safety exposure due to the PV Rapid Shutdown Proposal 690.12(B)(2)

690.12(B)(2), as proposed, is not the most effective path to increase firefighter safety, but increases risk and hazard exposure to electricians, thereby leading to an overall increase in risk for injury and fatality and an overall reduction in safety.

SEIA estimates that over 645,000 homes and businesses have installed solar power systems as of 2014. The only fatalities related to PV have involved falls from rooftops, falls through skylights or workers accidentally contacting overhead service lines while preparing scaffolding to work on roofs (http://www.cdph.ca.gov/programs/ohb-face/Pages/Solar.aspx). According to OSHA, in 2013 falls were the leading cause of worker deaths on construction sites, accounting for 36.5% of deaths in construction-related injuries and fatalities (https://www.osha.gov/oshstats/commonstats.html). There are no recorded instances of firefighters being killed or injured due to hazards from PV systems.

All power electronics fail and will require service and troubleshooting. 690.12(B)(2) effectively mandates module-level power electronics at every module for rooftop solar. The greatest threat to worker safety is having to work on the roof, and every piece of power electronics placed on the roof is another exposure to worker risk. We must make sure that the risks we ask electrical workers to take on are balanced and fair, and present a reasonable risk in minimizing the possibility and effects of fire and related hazards.

Representatives of the fire service tell us that they need to quickly ventilate a structure that is on fire, and as a ten year veteran of the fire service and Chief of a rural fire department, I can tell you that they are right. However, the position that vertical ventilation is the best and only way to ventilate, and that the fire service therefore needs full and unlimited access to the roof, does not align with modern fire science. Some firefighters joke that the fire service has a hundred years of tradition unimpeded by progress, but there is new information available that many fire services are embracing as it offers a safer, more effective way of ventilation than rooftop operations.

The majority of homes and structures built today are dramatically different than those of our grandparents. Construction is lightweight trusses and engineered lumber, not beams and timbers. According to a study by UL comparing the effects of fire on modern versus legacy homes, today's larger homes, open layout, increased fuel loads and lightweight construction materials result in faster fire propagation, shorter time to flashover, shorter escape times and shorter time to structural collapse (UL, Analysis of Changing Residential Fire Dynamics and Its Implications on Firefighter Operational Timeframes, p3, http://newscience.ul.com/wp-content/uploads/2014/04/Analysis_of_Changing_Residential_Fire_Dynamics_and_Its_Implications_on_Firefighter_Operational_Timeframes.pdf). Under these conditions, fast and effective ventilation becomes increasingly important. However, studies performed by NIST and others have shown that Positive Pressure Ventilation (PPV) is a more effective method than traditional vertical ventilation. In tests representative of a residential fire, PPV "lowered the temperatures in the room, forced all of the combustion products to flow out of the room without affecting the corridor and improved the visibility leading up to and in the room itself. In this experimental configuration a fire fighting team would likely have been able to attack the PPV ventilated fire more easily than the naturally ventilated fire" (NISTIR 7213, Effect of Positive Pressure Ventilation on a Room Fire p16, http://www.nist.gov/customcf/get_pdf.cfm?pub_id=861347).

In a similar test evaluating the effectiveness of PPV in large structures, "the pressure was increased sufficiently to: reduce temperatures, giving potential occupants a more survivable environment and increase fire fighter safety, limit smoke spread, keeping additional parts of the structure safe for occupants and undamaged and reducing the scale of the emergency for the fire fighters, and increase visibility, allowing occupants a better chance to self evacuate and providing fire fighters with an easier atmosphere to operate in. Positive pressure ventilation is a tool the fire service can utilize to make their job safer and more efficient" (NIST Technical Note 1498, Evaluating Positive Pressure Ventilation In Large Structures: School Pressure and Fire Experiments, p187, http://www.nist.gov/customcf/get_pdf.cfm?pub_id=861537).

According to this research, vertical rooftop ventilation can no longer be considered the golden standard for effective fireground operations.

690.12 should ensure that a local source of electricity (i.e. the PV array) can be easily disconnected from a building electrical system in


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the event of a fire, and 690.12(B)(1) achieves that goal. Requiring conductors within the array zone to be controlled to 80 volts does not provide a touch-safe environment, and there are thousands of legacy PV installations currently installed which are not controlled within the array zone; therefore, 690.12(B)(2) creates a false sense of security for the fire service. Fire operations should not be in the array zone when there are better options.

The current proposal for 690.12(B)(1) ensures the control of conductors leaving the array field, and significantly limits the zone around a PV array where conductors are not controlled. This is a reasonable and workable level of safety, as it will allow a significant reduction in rooftop power electronics devices versus the module-level required by 690.12(B)(2). In addition, those components on the roof will be located at or under the edge of the array, leading to corresponding reductions in time-on-roof for service and maintenance versus having to pull every module, which directly relates to risk of fall hazard exposure to electrical workers.

The safety of PV systems has increased substantially in the past few code cycles, based on reasoned analysis of incidents in the field, lab tests, and a consensus process involving broad stakeholder participation. This led to the implementation of improvements such as arc fault protection and improvements in ground fault detection and protection. Recent studies indicate additional improvements can be made in terms of arc fault detection, and that process is underway. These improvements have significantly increased the safety of a PV system through the broad and balanced participation of a variety of interests promoting the development of codes and standards. That can not be said for 690.12(B)(2).

Mandating new requirements in the NEC for the power electronics required to achieve 80v module-level of control is premature, not scientifically or technically sound, and will only expose electrical workers to higher levels of risk, to the benefit of a few companies. I urge CMP4 to remove 690.12(B)(2).

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690.12.B.2 as written would in effect mandate the installation of electronics on every single PV module installed. Although this change may have been advanced in the interest of life safety, we believe it is unnecessary and will in fact have the opposite effect.

While PV modules themselves are extremely reliable (warranted to last 25 years in most cases), module electronics is a very new industry - the leading providers of this equipment were founded less than 10 years ago, and early models suffered from significant reliability issues. If module electronics are mandated by NEC and even a few widely-deployed makes or models of module electronics are found to be unreliable in the field, it will result in hundreds of thousands of otherwise un-necessary roof accesses, each one of which carries risk of accident to electrical personnel. Because of the nature of module electronics, in many cases a large number of modules may need to be removed to access the faulty module electronics component - this is awkward work that multiplies the level of risk.

It is also not at all clear that module-level electronics reduces the risk of fire, because by its nature it increases the number of electronic components on the roof by 1-2 orders of magnitude, and while the available commercial units are in theory designed for a 25 year life, virtually none of the models being deployed today have been in service for even 5 years.

Besides the significant safety issues, failures related to newly-mandated module-level rapid shutdown equipment could have a catastrophic effect on the solar industry. Even in the absence of widespread failures, module-level electronics significantly increases the cost and complexity of solar installations.

Module electronics also adds significant cost and complexity for a questionable (and quite possibly negative) safety benefit. Array- and subarray-level solutions are available that provide ample safety as demonstrated by millions of installations in the US and Europe. We propose that 690.12.B.2 be struck from the 2017 code, and module-level electronics technology be allowed to mature further, and an open, honest, fair, and scientifically sound process be employed before such an unprecedented mandate is imposed.

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Submitter Full Name: Ben Polito

Organization: Pika Energy Inc

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Controlled conductors

located insidelocated within the boundary

or less thanor not more than 1 m (3 ft) from the point of entry inside a building shall be limited to not more than 80 volts within 10seconds of rapid shutdown initiation. Voltage shall be measured between any two conductors and between anyconductor and ground. This requirement shall become effective January 1, 2018,

Informational Note: Inverter input circuit conductors can remain energized for up to 5 minutes with inverters not listedfor rapid shutdown.


Deleted information note on 690.12 B.2 shouldn't define any option for non listed rapid shutdown components/systems to activate rapid shutdown.

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Public Input No. 1003-NFPA 70-2014 [Definition: Electrical Circuit Protective System]


Submitter Full Name: BIJAY SHRESTHA

Organization: TIGO ENERGY INC.

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It appears technical innovations to reduce I^2R losses could be inhibited by this rule. This rule could impede module efficiency improvements and hence slow cost reductions for clean energy.

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First Revision No. 18-NFPA 70-2015 [Global Input]


Submitter Full Name: Gene Choi

Organization: Solexel

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(3)



Bosch is concerned with the safety of everyone working with or around PV systems, and especially with the safety of those working on rooftops such as firefighters and personnel installing or maintaining the PV systems. Modern PV systems have achieved a level of elegant simplicity in terms of the amount of required rooftop equipment, resulting in very high reliability systems that may be installed on rooftops quickly and efficiently with little or no maintenance required over the lifetime, reducing the amount of time installers, electricians, and other service personnel need to spend on the rooftop. The rapid-shutdown requirements added in NEC 2014 also help to assure firefighters that any voltages generated by the PV array exist only near the array itself after a rapid shutdown is initiated, allowing the firefighters to work confidently on other areas of the rooftop or in other areas of the building nearby the PV array if needed during an emergency.Bosch is very experienced in producing high reliability electronics for harsh environments through our automotive, industrial, and other activities. The 80V requirement essentially requires sophisticated electronics to be installed on the rooftop at or near every PV module, drastically increasing the complexity of the PV array, especially in large commercial rooftop installations which may contain thousands of PV modules. Even with the most reliable electronics, this increase in complexity will result in increased installation time and especially increased maintenance over the lifetime, resulting in more personnel working on rooftops with the associated risks involved.Bosch believes the rapid shutdown requirement introduced with NEC 2014 already provides a high level of protection to firefighters, in the rare case they need to work nearby PV arrays on rooftops or in buildings due to an emergency situation. The added complexity of adding potentially thousands of disconnection circuits between the PV modules within a single PV array itself as proposed for NEC 2017 would add an unnecessary level of complexity, decreasing reliability and increasing the occurrence of rooftop maintenance work. Maintaining a potentially large number of electronic components distributed within a PV array as would be required by this 2017 NEC rapid shutdown proposal is also a much more complex and time-consuming task as compared to maintaining a much smaller amount of electronic components around the periphery of a PV array, as required by the NEC 2014 rapid shutdown requirement. Therefore, the time workers will need to spend on the rooftop is increased both by the quantity of additional electronics needed and by the relatively inaccessible location of the electronics within the array, especially for large commercial arrays.Although the proposal is well intentioned, Bosch does not believe the 80V requirement would result in a safer system overall when considering all potential for accidents to personnel working on the rooftop over the lifetime of the system.

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Submitter Full Name: John Saussele

Organization: Robert Bosch LLC

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The use of the term, array boundary, in this section is defined as 30 cm (1 ft) from the array in all directions. Controlledconductors shall apply to outside the array boundary shall comply with 690.12(B) (1) and inside the array boundary shallcomply with (B)( 2).

(1) Controlled conductors located outside the boundary or more than 1 m (3 ft) from the point of entry inside a building shallbe limited to not more than 30 volts within 10 seconds 30 seconds of rapid shutdown initiation. Voltage shall be measuredbetween any two conductors and between any conductor and ground.

(2) Controlled Rapid shutdown equipment shall be installed to limit firefighter exposure to electrical hazards from thecontrolled conductors located inside the boundary or less than 1 m (3 ft) from the point of entry inside a building shall belimited to not more than 80 volts within 10 seconds of rapid shutdown initiation. Voltage shall be measured between anytwo conductors and between any conductor and ground. array boundary and shall be listed and labeled as PV EquipmentSafe for Proximity Fire Fighting.

Informational Note: The designation PV Equipment Safe for Proximity Fire Fighting identifies equipment and componentsthat limit firefighter exposure to an electrical hazard within the array boundary after the Rapid Shutdown initiator has beenactivated. This designation addresses single point failures that might occur when the PV system is inadvertentlydamaged by firefighting operations or other mechanical damage or during a building fire. Control of electric shock hazardmay be achieved by methods such as limiting access to exposed components that might become energized, reducing thepotential difference between energized components, limiting the electric current that might flow in an electrical circuitinvolving personnel with increased resistance of the conductive circuit, or by a combination of such methods.

This requirement shall become effective January 1, 2018,


(1) 2020


The proposed revisions to 690.12(B)(2) are intended to increase electrical safety to unqualified personnel, including firefighters, working on damaged equipment within the array boundary.

While SolarCity supports the fire service in their intent to increase safety within the boundary of the array, the First Draft of Article 690.12(B)(2) has been written in such a way that effectively prescribes a specific type of electronic solution currently available in the marketplace. These devices are typically referred to as Module Level Power Electronics (MLPE) and include products like microinverters and optimizers. They are complicated devices, with a wide array of functions, but they were never designed for the sole purpose of “turning off” solar modules. The use of these complex devices as the means to accomplish rapid shutdown is a concern for several reasons.

HOW RELIABLE ARE MODULE LEVEL POWER ELECTRONICS (MLPE)?• Prominent manufacturers of MLPEs often point to their “Mean-Time-Between-Failure” models (MTBF) to support their claims of reliability. According to Lusser’s Law, the chance that a system will fail is calculated by multiplying the Mean-Time-Between-Failures (MTBF) for each part by the number of parts. So if a MLPE has 500 parts in series, and each part is 99.9% reliable, the reliability of the entire MLPE device drops to 60%. Translation: the many features and functions of MLPEs = more failure points. • Modeling the lifetime of these complex devices is hard. Models that translate to real-life field performance don’t exist yet. This was painfully exposed when an industry-leading maker of Module Level Power Electronics had to admit that their MTBF models, which had been advertised as sophisticated and reliable, had significantly underestimated true failure rates in the field. This manufacturer had to correct their financial statements about warranty claims on their failed devices to the tune of tens of millions of dollars. [1] • Nonetheless, MLPE manufacturers claim that devices should last up to 25 years even though conventional inverters, with comparable parts and functions, are rated to last only 12-15 years. But their models do not realistically predict the reliability of the individual parts inside them. Even for the most trusted and experienced manufacturers, bad batches make it through to final production. MTBF calculations do not consider the impact of manufacturing quality issues. • Dr. Jack Flicker of Sandia National Laboratories says the failures are caused, in part, by “more extreme diurnal temperature cycling [with] increased stress on componentry [resulting in] more difficult thermal management.” With “one MLPE unit for every module [equal to] 5,000 units per megaWatt of PV [it is] difficult-to-impossible to track and repair/replace units as they fail.” [2] • Bottomline: These devices have not been built for the sole purpose of “turning off” solar modules. Because of their complexity, these devices cannot last as long as solar panels and even the best manufacturers, with established track records, have had to back track on their reliability claims. If the existing manufacturers are having a hard time, what will that mean when new companies rush to market with new rapid shutdown devices that are supposed to protect firefighters?


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SAFETY FOR FIRST RESPONDERS & SOLAR WORKERS• While the effort to enhance safety for first responders is laudable, it is important to remember that not a single firefighter has been killed while on a building with solar, suggesting that existing safety provisions for PV have been largely effective. • While the solar industry aggressively promotes worker safety, falls remain the number one cause of death among all construction workers. [3]. If MLPEs are mandated as rapid shutdown devices, solar construction workers will be the ones replacing them during the life of the system. Mandating one device beneath every solar module will directly increase the time solar construction workers will have to spend on the roof to replace them. More time on roof = higher risk of falling.• The best way to mitigate this increased danger to American solar workers, is to place rapid shutdown devices in accessible locations that can be reached quickly and safely for testing and service, not beneath each solar module. • There is another danger to using MLPEs to accomplish rapid shutdown. Even when these devices work "as advertised," the system is never truly “shutdown.” A solar module producing 80V is not the same as "Off." UL confirmed as recently as June, in their evaluation of firefighter PPE, that voltages *below* 80V still pose a risk. This was disclosed at the NFPA conference, which several members of this panel attended. A reduction in voltage does not eliminate the hazard, giving unsuspecting firefighters a false sense of security that only puts them at risk. • Captain John Green, of the Los Angeles Fire Department (2nd largest in the US) echoed this when he said, “We don’t want our firefighters messing with the array, no matter what. Our protocol is a proven operating process, and adding layers of guess work complicates the job. Some systems might have panel level shutdown, some will not. Some of those that do will be operative, some will not. So we do not want that option to even exist; in a situation, there is no time to try to figure out what might work or not on a solar system. There is enough uncertainty in what we do. For us, the rule is ‘Do not engage’, period.” [4] • Bottomline: Requiring the Module Level Power Electronics to accomplish rapid shutdown poses hazards to firefighters and solar construction workers alike. Even prominent members of the fire service do not support, and will not rely on, Module Level Power Electronics to protect them.

The First Draft of Article 690.12 effectively prescribes an immature technology, not expressly designed to accomplish rapid shutdown. It has the unintended effect of putting firefighters and solar workers in harm’s way. We urge this panel to vote against it and instead support the proposal put forth by SEIA's representatives as the best path to develop safety solutions that achieve the intent of 690.12 without prescribing a single technology that closes the door on innovation.

References:[1]: http://www.nasdaq.com/article/enphase-anemic-revenue-growth-with-alarming-warranty-obligation-growth-cm310291#ixzz3dvaYDJ1C[2] http://www.nrel.gov/pv/pdfs/2014_pvmrw_35_flicker.pdf[3] https://www.osha.gov/oshstats/commonstats.html[4] http://blog.renewableenergyworld.com/ugc/blogs/2015/09/solar_rapid_shutdown.html

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Submitter Full Name: Duncan Cleminshaw

Organization: SolarCity

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(2) Controlled conductors located inside the boundary or less than 1 m (3 ft) from the point of entry inside a building shall belimited to not more than 80 volts within 10 30 seconds of rapid shutdown initiation. Voltage shall be measured betweenany two conductors and between any conductor and ground. This requirement shall become effective January 1, 2018,



It's become clear through discussions while incorporating RSS into the UL Standard that provision for low voltage ride through that is being required of new smart inverter technology is at odds with the RSS requirements when the initiation is by loss of utility power. To reduce the possibility of interference between RSS and low voltage ride though it is recommended that the shed down time be extended to 30 seconds.

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There are devices available today that can implement the RSS functionality so there is no need to delay the requirement farther out than the adoption date of the 2017 NEC. Considering that other provisions are put in the NEC that have no effective way to implement them at the time of code adoption it seems to be unusual that this particular provision would be delayed. Even if no means is available when the 2017 NEC is adopted 90.4 can be used to waive the requirement as it is done in many other cases.

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The use of the term, array boundary, in this section is defined as 30 cm (1 ft) from the array in all directions. Controlledconductors shall apply to outside the array boundary shall comply with 690.12(B) (1) and inside the array boundary shallcomply (B) ( 2)

(1) Controlled conductors located outside the boundary or more than 1 m (3 ft) from the point of entry inside a building shallbe limited to not more than 30 volts within 10 seconds 30 seconds of rapid shutdown initiation. Voltage shall be measuredbetween any two conductors and between any conductor and ground.

(2) Controlled Rapid shutdown equipment shall be installed to limit firefighter exposure to electrical hazards from thecontrolled conductors located inside the boundary or less than 1 m (3 ft) from the point of entry inside a building shall belimited to not more than 80 volts within 10 seconds of rapid shutdown initiation. Voltage shall be measured between anytwo conductors and between any conductor and ground. array boundary and shall be listed and labeled as PV EquipmentSafe for Proximity Fire Fighting.

Informational Note: The designation PV Equipment Safe for Proximity Fire Fighting identifies equipment andcomponents that limit firefighter exposure to an electrical hazard within the array boundary after the Rapid Shutdowninitiator has been activated. This designation addresses single point failures that might occur when the PV system isinadvertently damaged by firefighting operations or other mechanical damage or during a building fire. Control ofelectric shock hazard may be achieved by methods such as limiting access to exposed components that might becomeenergized, reducing the potential difference between energized components, limiting the electric current that might flowin an electrical circuit involving personnel with increased resistance of the conductive circuit, or by a combination ofsuch methods.

This requirement shall become effective January 1,

2018,


2020


The proposed language of 690.12(B)(2), which effectively mandates the use of module-level electronics to comply, cannot be practically enforced and field verified by the authority having jurisdiction(AHJ). This is a concern for several reasons:1. Volume - This places the burden of verifying the presence and effectiveness of over 10 million devices projected to be installed on buildings annually by the year 2018, squarely on the shoulders of local AHJs. (Source: Citi Research)2. Liability - The associated liability from the failure of these electronics to perform as anticipated could fall with the AHJ. This liability concern is best avoided by the application of the provisions found in Article 90.7 of the NEC, Examination of Equipment for Safety, which places the task of verifying suitability of specific electrical components in the hands of a nationally recognized testing laboratory. 3. Physical location – Arrays installed on pitched roofs may be inaccessible to AHJs tasked with verifying compliance.4. Verification - The lack of adequate test points in a typical photovoltaic array would make the 80V and 10 second limitations impossible to verify without the dis-assembly of a completed installation. The proper training, tools, and personal protective equipment needed for such field testing is not widely available to all AHJs.

Given these concerns, it is unlikely the provisions of the proposal will be adequately enforced.

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Submitter Full Name: CHARLES PICARD

Organization: SolarCity

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Public Comment No. 1693-NFPA 70-2015 [ Section No. 690.12(E) ]

(E) Equipment.

Equipment that performs the rapid shutdown functions, other than initiation devices such as listed disconnect switches, circuitbreakers, or control switches , shall be listed, labeled, and identified are identified for providing rapid shutdown protection.


Listing and verification requirement shouldn't be defines as part of NEC guideline

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Public Input No. 1003-NFPA 70-2014 [Definition: Electrical Circuit Protective System]


Submitter Full Name: BIJAY SHRESTHA

Organization: TIGO ENERGY INC.

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1464 of 2079 10/1/2015 11:02 AM

Public Comment No. 891-NFPA 70-2015 [ New Section after 690.12(F)(2) ]

TITLE OF NEW CONTENT

Type your content here ...

"Both significant weather-related, and seismic events can leave a PV system in an electrically hazardous condition, affecting fireservice response. I am in full support of the IAFF First Revision #1008 to shutdown a rooftop PV array to the lowest degreepossible utilizing current available products."


Statement of ProblemThis submission reflects the incremental code change to lower the available PV system voltage after the initiation of a Rapid Shutdown.Eliminating areas of hazardous voltage within the array after shutdown, has been identified by both the fire service and insuranceindustry as a key gap and concern.This was the original recommendation of the NFPA Fire Task Group from the 2014 cycle with the 690.12 proposal for modulelevelcontrol. The UL 1741 standards body is expected to have an updated standard addressing modulelevelcontrol devices in place prior toimplementation of the 2017 code.There is no requirement in the NEC that there be a way to deenergizethe electrical circuits connected to PV modules mounted onbuildings. These circuits remain energized anytime the modules are illuminated and up to the maximum system voltage which can beup to 1,000Vdc. This results in increased level of danger to first responders when the structure has been damaged.Historically this has been accepted since there was no practical way to isolate a PV module from the PV source circuit that wouldoperate remotely and on all PV modules in an array simultaneously. Module level systems were not developed to the point whereproducts were readily available on the market to provide this functionality. Today this is no longer true, many reliable products areavailable that can be either incorporated into a PV module or added to a PV module in the field to provide PV module isolation byremote control. The reliability concerns from 2014 are no longer relevant today, and market data estimates that up to 10 million unitscapable of module level isolation are now in service.Under normal fault response conditions, the inverter is taken offlinedue to the first fault. A risk of re-ignitionremains with string andcentral inverters due to the discontinuation of fault detection, interruption, and annunciation when inverters are offlinedue to a fault, ormaintenance. Module level electronics provide for continued array monitoring in the event one fault occurs within the system due to theseries nature of the devices monitoring each module.

There is no longer any reasonable justification to not address the additional hazard that having energized conductors represents in astructure mounted PV array. Reducing the voltage only in conductors outside the array, leaves very large areas of a structure withhazardous voltages, and should be considered “offlimits”to firefighters. Additionally this leaves no options for first or secondresponders to safely deenergizein the event of an emergency.

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Submitter Full Name: James Penn

Organization: Compton Fire Department

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1465 of 2079 10/1/2015 11:02 AM

Public Comment No. 502-NFPA 70-2015 [ Section No. 690.12(F)(2) ]

(2)


Exception: Ground mounted PV system circuits that enter buildings or structures, of which the sole purpose is to house PVpower generating system equipment, are not required to comply with 690.12.


Harmonizes wording with exception in 690.11. Consistency counts.

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1466 of 2079 10/1/2015 11:02 AM


690.13 Photovoltaic System Disconnecting Means.

Means shall be provided to disconnect the PV system from all wiring systems including power systems, energy storagesystems, and utilization equipment and its associated premises wiring.

(A) Location.

The PV system disconnecting means shall be installed at a readily accessible location.

Informational Note: PV systems installed in accordance with 690.12 address the concerns related to live conductorsentering a building.

(B) Marking.

Each PV system disconnecting means shall be permanently marked to identify it as a PV system disconnect and shall indicatewhether in the open or closed position. For PV system disconnecting means where the line and load terminals may beenergized in the open position, the device shall be marked with the following words or equivalent:

WARNING

ELECTRIC SHOCK HAZARD

TERMINALS ON THE LINE AND LOAD SIDES MAY BE

ENERGIZED IN THE OPEN POSITION


(C) Suitable for Use.

If the PV system is connected to the supply side of the service disconnecting means as permitted in 230.82(6), the PV systemdisconnecting means shall be listed as suitable for use as service equipment.

(D) Maximum Number of Disconnects.

Each PV system disconnecting means shall consist of not more than six switches or six sets of circuit breakers, or acombination of not more than six switches and sets of circuit breakers, mounted in a single enclosure, or in a group of separateenclosures. A single PV system disconnecting means shall be permitted for the combined ac output of one or more inverters orac modules in an interactive system.

Informational Note: This requirement does not limit the number of PV systems connected to a service as permitted in690.4(D). This requirement allows up to six disconnecting means to disconnect a single PV system. For PV systemswhere all power is converted through interactive inverters, a dedicated circuit breaker, in 705.12(D) (1), is an example ofa single PV system disconnecting means.

(E) Interrupting Rating.

The PV system disconnecting means shall have an interrupting rating sufficient for the maximum available short circuit currentand voltage that is available at the terminals of the PV system disconnect.

(F) Type of Disconnect.

The PV system disconnecting means shall simultaneously disconnect the PV system conductors of the circuit from allconductors of other wiring systems. The PV system disconnecting means shall be an externally operable general-use switch orcircuit breaker, or other approved means. A dc PV system disconnecting means shall be marked for use in PV systems or besuitable for backfeed operation.



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1467 of 2079 10/1/2015 11:02 AM


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(A) Location.

The PV system disconnecting means shall be installed at a readily accessible location.

Informational Note: PV systems installed in accordance with 690.12 address the concerns related to live energizedconductors entering a building.


This simply changes "live" to "energized" as directed by the correlating committee comments.

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1469 of 2079 10/1/2015 11:02 AM


(B) Marking.

Each PV system disconnecting means shall be permanently marked to identify it as a PV system disconnect and shall indicatewhether in the open or closed position. The marking should indicate that it is a PV system disconnect or equivalent, but mayprovide additional information as warranted by the system configuration. The marking minimum shall be:

PV SYSTEM DISCONNECT

For PV system disconnecting means where the line and load terminals may be energized in the open position, the device shallbe marked with the following words or equivalent:

WARNING


TERMINALS ON THE LINE AND LOAD SIDES MAY BE

ENERGIZED IN THE OPEN POSITION



According to the current language, "Eacy PV System disconnecting means shall be permanently marked to identify it as aPV System disconnect" Some guidance should be provided in 690.13 for the marking. A suggestion is simply "PV System Disconnect" but it should be permiitted to provide additional information depending on the system topology.

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Submitter Full Name: Todd Fries

Organization: HellermannTyton

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1470 of 2079 10/1/2015 11:02 AM


(C) Suitable for Use.

If the PV system is connected to the supply side of the service disconnecting means as permitted in 230.82(6), the PV systemdisconnecting means shall be listed as suitable for use as service equipment.

Informational Note: DC-rated enclosed switches, open-type switches and low-voltage power circuit breakers are suitable foruse.


The informational note appears to have been deleted in the first revision. Retaining the informaational note adds clarity to the purpose of the section.

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1471 of 2079 10/1/2015 11:02 AM


(E) Interrupting Rating.

The PV system disconnecting means shall comply with one of the following interrupt rating requirements.

(1) A PV system disconnecting means that uses a circuit breaker shall have an interrupting rating sufficient for the maximumavailable short circuit current and voltage that is available at the terminals of the PV system disconnect.

(2) A PV system disconnecting means that does NOT provide overcurrent protection shall have an interrupting rating sufficientfor the maximum operating current and voltage that is available at the terminals of the PV system disconnect. Thedisconnecting means shall have the bracing required to conduct the maximum available short circuit current.


SunPower would like to thank CMP 4 for making these much needed revisions to 690.13. Unfortunately, the interrupt rating requirement for the PV System Disconnect (PSD) was revised in such a way that a listed switch that does not provide overcurrent protection could not be used as a PSD. Switches without overcurrent protection would not be designed to be opened under fault conditions, only under normal operating loads. Thus, their design and their listing would only allow them to conduct the short circuit current during a fault condition, but not interrupt the fault. The overcurrent protection device would be designed to provide the fault interruption capability. It would be undesirable to prevent the use of standard switches as the PSD when upstream devices provide the required overcurrent protection.

In some system designs, a circuit breaker would be used for the PSD and it would provide both the disconnecting means and the overcurrent protection required to protect the circuit. For these systems, the interrupting rating of the PSD should include the maximum available short circuit current from the service/utility. These disconnects would need to comply with the requirement in 690.13(E)(1) that we have proposed here.

In other system designs, a separate fuse or circuit breaker would provide the overcurrent protection for the circuit. In this case, the PSD would not be used to interrupt the fault, only to disconnect the equipment under normal operating conditions. Thus, the interrupt rating of these switches would only need to deal with the maximum operating current available at the terminals of the switch. The switch does need to be capable of having fault current pass through it though should the fault be on the PV system side of the PSD, hence the bracing requirement. The PSD used for these system designs would need to comply with the requirement in 690.13(E)(2) that we have proposed here.

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1472 of 2079 10/1/2015 11:02 AM


(F) Type of Disconnect.

The PV system disconnecting means shall simultaneously disconnect the PV system conductors of the circuit from allconductors of other wiring systems. The PV system disconnecting means shall be an externally operable general-use switch orcircuit breaker, or other approved means. A dc PV system disconnecting means shall be marked for use in PV systems or besuitable for backfeed operation.

Informational Note: Dc-rated enclosed switches, open-type switches, and low-voltage power circuit breakers are suitable forbackfeed operation.


The first draft mistakenly omitted the informational note that was in the FR.

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1473 of 2079 10/1/2015 11:02 AM


(C) Isolating Device.

An isolating device shall not be required to simultaneously disconnect all current carrying conductors of a circuit. The isolatingdevice shall be one of the following:

(1) A connector meeting the requirements of 690.33 and listed and identified for use with specific equipment

(2) A finger safe fuse holder

(3) An isolating switch that requires a tool to open

(4) An isolating device listed for the intended application

An isolating device shall be marked “Do Not Disconnect Under Load” or “Not for Current Interrupting”.


This statement implies that connectors should be listed for use with the equipment that they are intended to isolate. This would be true if connectors are listed as part of the equipment being used under the "within the equipment" clause. However, if the isolating device is "within sight and within 10 feet of" they would not need to be listed to work specifically with that equipment - they would just be listed connectors. It is a general requirement that listed equipment be used in accordance with its listing, so this statement is unnecessary and misleading as written.

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1478 of 2079 10/1/2015 11:02 AM


(B) Interrupting Rating.

An equipment disconnecting means shall have an interrupting rating sufficient for the maximum voltage and, dc short-circuit orac load current and voltage that is available at the terminals of the equipment. An isolating device shall not be required to havean interrupting rating.


The dc PV circuits are current limited and therefore define the disrupting current. For ac circuits, such as inverter output circuits, the conductors and disconnect switch are protected by an ODCP that carries proper interrupt current ratings for the fault current of the source. It is not necessary for the disconnect device to interrupt the full fault current, only the load current.

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1477 of 2079 10/1/2015 11:02 AM


Isolating devices shall be provided to isolate PV modules, ac PV modules, fuses, dc-to-dc converters inverters, and chargecontrollers from all conductors that are not solidly grounded. An equipment disconnecting means or a PV system disconnectingmeans shall be permitted in place of an isolating device. Where the maximum circuit current is greater than 30 amperes for theoutput circuit of a dc combiner or the input circuit of a charge controller or inverter, an equipment disconnecting meanscomplying with 690.13(B) shall be provided for isolation. Where a charge controller or inverter has multiple input circuits, asingle equipment disconnecting means shall be permitted to isolate the equipment from the input circuits.

Informational Note: The purpose of these isolating devices are for the safe and convenient replacement or service ofspecific PV system equipment without exposure to energized conductors.


This is simply providing the requirements of disconnect device vs. isolation device but with teh word complying with 690.13(B) clarifies the marking confusion.

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1476 of 2079 10/1/2015 11:02 AM


Isolating devices shall be provided to isolate PV modules, ac PV modules, fuses, dc-to-dc converters inverters, and chargecontrollers from all conductors that are not solidly grounded. An equipment disconnecting means or a PV system disconnectingmeans shall be permitted in place of an isolating device. Where the maximum circuit current is greater than 30 than 35amperes for the output circuit of a dc combiner or the input circuit of a charge controller or inverter, an equipment disconnectingmeans shall be provided for isolation. Where a charge controller or inverter has multiple input circuits, a single equipmentdisconnecting means shall be permitted to isolate the equipment from the input circuits.



Problem: The proposed 30 Amperes limit is arbitrarily chosen. Typically available state of the art PV connectors are listed for arated current of up to 35 Amperes (see UL file QIJQ2.E343590 - Amphenol, QIJQ2.E339277 - Huber+Suhner). Today’s typicalsystem designs rely on the availability of these connectors as isolating device (according (C )(1)) up to this maximum limit.

Solution: We suggest to set the limit to 35 Amperes because there is a large number of listed standard PV connectors with a ratedcurrent of up to 35 Amperes. From a safety point of view there is no difference between a listed connector being used as isolatingdevice in a circuit with a maximum current of 30 Amperes compared to a circuit with a maximum current of 35 Amperes. In eithercase the connector will be considered an isolating device according to (C )(1) not to be disconnected under load and labeledaccordingly.

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1474 of 2079 10/1/2015 11:02 AM


Isolating devices shall be provided to isolate PV modules, ac PV modules, fuses, dc-to-dc converters inverters, and chargecontrollers from all conductors that are not solidly grounded. An equipment disconnecting means or a PV system disconnectingmeans shall be permitted in place of an isolating device. Where the maximum circuit current is greater than 30 amperes for theoutput circuit of a dc combiner or the input circuit of a charge controller or inverter, an equipment disconnecting means shall beprovided for isolation. Where a charge controller or inverter has multiple input circuits, a single equipment disconnecting meansshall be permitted to isolate the equipment from the input circuits.



The Correlating Committee directs that further consideration be given to the comments expressed in voting on FR 1013. . The Correlating Committee directs that the panel rewrite the Exception to comply with the NEC Style Manual.

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1475 of 2079 10/1/2015 11:02 AM








An isolating device shall be marked “Do Not Disconnect Under Load” or “Not for Current Interrupting”.


This statement implies that connectors should be listed for use with the equipment that they are intended to isolate. This would be true if connectors are listed as part of the equipment being used under the "within the equipment" clause. However, if the isolating device is "within sight and within 10 feet of" they would not need to be listed to work specifically with that equipment - they would just be listed connectors. It is a general requirement that listed equipment be used in accordance with its listing, so this statement is unnecessary and misleading as written.

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1478 of 2079 10/1/2015 11:02 AM








An If an isolating device does not have an interrupting rating, it shall be marked “Do Not Disconnect Under Load” or “Not forCurrent Interrupting”.


690.15 states an Isolation device shall be permitted to have an interrupting rating. If so, then it is not necessary to mark it as "do not disconnect under load."

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1479 of 2079 10/1/2015 11:02 AM


(D) Equipment Disconnecting Means.

An equipment disconnecting means shall simultaneously disconnect all current carrying conductors that are not solidlygrounded of the circuit to which it is connected. An equipment disconnecting means shall be externally operable withoutexposing the operator to contact with live parts and shall indicate whether in the open or closed position. An equipmentdisconnecting means shall be one of the following devices:

(1) A manually operable switch or circuit breaker

(2) A connector meeting the requirements of 690.33(E) (1)

(3) A load break fused pull out switch

(4) A remote controlled circuit breaker, contactor, or relay that is operable locally and opens automatically when control poweris interrupted

Informational Note: Devices marked with “line” and “load” are not suitable for backfeed or reverse current. Dc-ratedenclosed switches, open-type switches, and low-voltage power circuit breakers are suitable for backfeed operation.

For equipment disconnecting means where the line and load terminals may be energized in the open position, the device shallbe marked with the following words or equivalent:

WARNING


TERMINALS ON THE LINE AND LOAD SIDES MAY BE ENERGIZED IN THE OPEN POSITION


Exception: Connectors that meet 690.33 are shall be exempt from this marking requirement.


At the direction of the correlating committee, this comment changes "are" to "shall be".

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1480 of 2079 10/1/2015 11:02 AM







(4) A remote controlled circuit breaker , contactor, or relay that or other Listed isolating means that is operable locally andopens automatically when control power is interrupted



WARNING




Exception: Connectors that meet 690.33 are exempt from this marking requirement.


The requirements as written require either an isolating means or a disconnecting means, and allow a contactor or relay to act as a disconnecting means. It must be noted that contactors and relays may provide a disconnecting function, but generally do not provide adequate air gaps to be considered an isolating means. Additionally the contacts of contactors and relays are allowed to weld during short circuit testing, whereas Listed isolating devices are not allowed to weld. As the FR is presently written, there is an implication that relays and contactors can be used in place of an isolating means, which could result in a possible shock hazard. Since the purpose of allowing a remote disconnecting means is to provide the isolation needed to work safely on the equipment, the use of contactors or relays should not be allowed.

Suggest revising item (4) to read as follows: A remote controlled circuit breaker or other Listed isolating means, that is operable locally and opens automatically when control power is interrupted.

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1481 of 2079 10/1/2015 11:02 AM







(4) A remote controlled circuit breaker , contactor, or relay or contactor that is operable locally and opens automatically whencontrol power is interrupted



WARNING






The use of a relay for a disconnection means appears too lenient. Relays are know to stick or mis-operate.

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1482 of 2079 10/1/2015 11:02 AM







(4) A remote controlled circuit breaker, contactor, or relay that is operable locally and opens automatically when control poweris interrupted



WARNING






This is redundant to 690.13. All marking requirements should be in 690.13.

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1483 of 2079 10/1/2015 11:02 AM


(A) Wiring Systems.

All raceway and cable wiring methods included in this Code, other wiring systems and fittings specifically listed for use on PVarrays, and wiring as part of a listed system shall be permitted. Where wiring devices with integral enclosures are used,sufficient length of cable shall be provided to facilitate replacement.

Where PV source and output circuits operating at voltages greater than 30 volts are installed in readily accessible locations,circuit conductors shall be guarded or installed in Type MC cable or in a raceway.


Just a style change. "a raceway" is a particular singular raceway where "raceway" indicates a type of enclosure.

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1484 of 2079 10/1/2015 11:02 AM

Public Comment No. 511-NFPA 70-2015 [ Section No. 690.31(B)(1) ]

(1) Identification.

PV system circuit conductors shall be identified at all accessible points of termination, connection, and splices.

The means of identification shall be permitted by separate color coding, marking tape, tagging, or other approved means. Onlysolidly grounded PV system circuit conductors shall be marked in accordance with 200.6. PV system circuit conductors thatare not solidly grounded shall not be marked white unless part of a multiconductor cable assembly.

Exception: Where the identification of the conductors is evident by spacing or arrangement, further identification shall not berequired.


The sentence removed is redundant and not completely accurate. The revised and accepted text states that only solidly grounded conductors shall be marked as indicated in 200.6. Based on this not solidly grounded conductors can't be marked as white. The deleted sentence only references white as a marking for solidly grounded conductors, ignoring all the other types of marking called out in 200.6.

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1485 of 2079 10/1/2015 11:02 AM


(C) Single-Conductor Cable.

(1) General. Single-conductor cable listed and labeled as photovoltaic (PV) wire shall be permitted in exposed outdoorlocations in PV source circuits.PV wire shall be installed in accordance with 338.10(B)(4) (b) and 334.30.

Exception: Single-conductor cable Type USE-2 shall be permitted in solidly grounded PV systems.

(2) Cable Tray. PV source circuits and PV output circuits using single-conductor cable listed and labeled as photovoltaic (PV)wire of all sizes, with or without a cable tray marking/rating, shall be permitted in cable trays installed in outdoor locations,provided that the cables are supported at intervals not to exceed 300 mm (12 in.) and secured at intervals not to exceed1.4 m (4 1⁄2 ft).

Informational Note: Photovoltaic wire and PV cable have a nonstandard outer diameter. See Table 1 of Chapter 9 forconduit fill calculations. The warning sign(s) or label(s) shall comply with 110.21(B) . contains the allowable percent ofcross section of conduit and tubing for conductors and cables.


This comment fixes a mistaken reference to 110.21(B) and addresses a comment by the correlating committee to properly reference Table 1 in Chapter 9.

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1486 of 2079 10/1/2015 11:02 AM





(2) Cable Tray. PV source circuits and PV output circuits using single-conductor cable listed and labeled as photovoltaic (PV)wire of all sizes, with or without a cable tray marking/rating, shall be permitted in cable trays installed in outdoor locationswhere the cable tray and/or conductors are not in contact

with a building , provided that the cables are supported at intervals not to exceed 300 mm (12 in.) and secured at intervalsnot to exceed 1.4 m (4 1 ⁄2 ft). Where cable trays are in contact with a building, a cable tray marking/rating shall berequired for single conductor PV wire contained in the cable tray.

Informational Note: Photovoltaic wire and PV cable have a nonstandard outer diameter. See Table 1 of Chapter 9 forconduit fill calculations. The warning sign(s) or label(s) shall comply with 110.21(B).


The committee statement in the Public Input phase expressed concern that the original proposed changes "... would remove the use of cable tray on buildings which was one of the intentions for the addition of 690.31(C)(2) in the 2014 Code. Cable tray must be installed in accordance with the manufacturer’sinstructions, so unless there is a clearer way of distinguishing the concern of the submitter, the paneldoes not recommend the addition." The revised language submitted in this Comment addresses that concern by clearly allowing the use of cable tray in contact with a building when the PV wire inside the cable tray is listed for use in cable tray.The cable tray rating on single conductors means that they must pass a vertical-tray flame test that will ensure the conductors will not propagate flame. This is an important safety consideration for any conductors installed in cable tray where in or on a building to prevent the rapid transmission of flame along the wire.

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Public Input No. 4771-NFPA 70-2014 [Section No. 690.31(C)]


Submitter Full Name: Christel Hunter

Organization: General Cable

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1487 of 2079 10/1/2015 11:02 AM



(1) General. Single-conductor cable listed, labeled and labeled identified as photovoltaic (PV) wire shall be permitted inexposed outdoor locations in PV source circuits.PV wire shall be installed in accordance with 338.10(B)(4) (b) and 334.30.


(2) Cable Tray. PV source circuits and PV output circuits using single-conductor cable listed, labeled and labeled identifiedas photovoltaic (PV) wire of all sizes, with or without a cable tray marking/rating, shall be permitted in cable trays installedin outdoor locations, provided that the cables are supported at intervals not to exceed 300 mm (12 in.) and secured atintervals not to exceed 1.4 m (4 1⁄2 ft).







The term identified was added as UL 4703 require PV wire to be marked with the words "Photovoltaic Wire", or "PV Wire" at intervals not exceeding 40 inches (1 meter).




As for the concerns of products that are too small to be labeled, the definition of labeled is not limited to an actual label, it also includes symbols, or other identifying marks. The Safety Standards which define the listing requirements do not address labeling of products as defined by Article 100. As a general rule, NRTL’s do not consider a product as being listed unless it is also labeled. The UL White Book states that “Only those products bearing the appropriate UL Mark and the company's name, trade name, trademark or other authorized identification should be considered as being covered by UL's Certification, Listing, Classification and Follow-Up Service. The UL Mark provides evidence of listing or labeling, which may be required by installation codes or standards.” Again the requirements for the UL Mark are not a Safety Standard requirement, they are a UL requirement and the only way to show that a product is UL Certified (Listed);


1488 of 2079 10/1/2015 11:02 AM

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1489 of 2079 10/1/2015 11:02 AM



(1) General. Single-conductor cable listed and labeled as photovoltaic (PV) wire shall be permitted in exposed outdoorlocations in PV source circuits.PV wire shall be installed in accordance with 338.10(B)(4)(b) and 334.30.


(2) Cable Tray. PV source circuits and PV output circuits using single-conductor cable listed and labeled as photovoltaic (PV)wire of all sizes, with or without a cable tray marking/rating, shall be permitted in cable trays installed in outdoor locations,provided that the cables are supported at intervals not to exceed 300 mm (12 in.) and secured at intervals not to exceed1.4 m (41⁄2 ft).



The Correlating Committee directs the panel to consider rewrite the Informational Note so that it does not contain a requirement, to comply with 3.1.3 of the NEC Style Manual. The Correlating Committee also directs the panel to clarify the measurement at the end of (C)(2).

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1490 of 2079 10/1/2015 11:02 AM



(1) General. Single-conductor cable listed and labeled as photovoltaic (PV) wire shall be permitted in exposed outdoorlocations in PV within the array locations for PV source circuits.PV wire shall be installed in accordance with 338.10(B)(4)(b) and 334.30.





My revision is to continue to limit exposed conductors within the array footprint per the 2014 NEC.

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1491 of 2079 10/1/2015 11:02 AM




Exception: Single-conductor cable Type USE-2 shall be permitted

in solidly

in reference grounded PV systems.




The panel needs to do a search and replace for 'solidly grounded' and replace with 'reference grounded' where applicable.

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1492 of 2079 10/1/2015 11:02 AM


(D) Multiconductor Cable.

Jacketed multiconductor cable assemblies listed, labeled and identified for the application shall be permitted in outdoorlocations. The cable shall be secured at intervals not exceeding 1.8 m (6 ft).










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1494 of 2079 10/1/2015 11:02 AM


(E) Flexible Cords and Cables Connected to Tracking PV Arrays.

Flexible cords and flexible cables, where connected to moving parts of tracking PV arrays, shall comply with Article 400 andshall be of a type identified as a hard service cord or portable power cable; they shall be suitable for extra-hard usage, listed foroutdoor use, water resistant, and sunlight resistant. Flexible PV wireFor ambient temperatures exceeding 30°C (86°F), the ampacities shall be derated by the appropriate factors given in

Table 690.31(E). Stranded copper PV Wire shall also be permitted to be connected to moving parts of tracking PVarrays provided it has the minimum number of strands specified in table 690 . 31 (X) .

New Table 690.31(X).

PV wire AWG Min PV wire Strands

18 17

16-10 19

8 - 4 49

2 130

1 AWG - 1000MCM 259

Table 690.31(E) Correction Factors

Ambient Temperature (°C)Temperature Rating of Conductor

Ambient Temperature (°F)60°C (140°F) 75°C (167°F) 90°C (194°F) 105°C (221°F)

30 1.00 1.00 1.00 1.00 86

31–35 0.91 0.94 0.96 0.97 87–95

36–40 0.82 0.88 0.91 0.93 96–104

41–45 0.71 0.82 0.87 0.89 105–113

46–50 0.58 0.75 0.82 0.86 114–122

51–55 0.41 0.67 0.76 0.82 123–131

56–60 — 0.58 0.71 0.77 132–140

61–70 — 0.33 0.58 0.68 141–158

71–80 — — 0.41 0.58 159–176


Not all PV wire is suitable for connection to moving parts since the number of strands can vary from PV wire to PV wire. The proposed table below matches the minimum number of strands required for other wires allowed in the NEC for connection to moving parts. The following revised text is intended to replace the FR998. PV wire may include aluminum conductors which are not suitable for flexing as work hardening of aluminum causes strand breakage. Additionally the reference to the derating table 690.31(E) and the Table 690.31(E) should be maintained.

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First Revision No. 998-NFPA 70-2015 [Section No. 690.31(E)]




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1495 of 2079 10/1/2015 11:02 AM



Flexible cords and flexible cables, where connected to moving parts of tracking PV arrays, shall comply with Article 400 andshall be of a type identified as a hard service cord or portable power cable; they shall be suitable for extra-hard usage, listed foroutdoor use, water resistant, and sunlight resistant. Flexible PV wire shall also be permitted to be connected to moving parts oftracking PV arrays..




30 1.00 1.00 1.00 1.00 86

31–35 0.91 0.94 0.96 0.97 87–95

36–40 0.82 0.88 0.91 0.93 96–104

41–45 0.71 0.82 0.87 0.89 105–113

46–50 0.58 0.75 0.82 0.86 114–122

51–55 0.41 0.67 0.76 0.82 123–131

56–60 — 0.58 0.71 0.77 132–140

61–70 — 0.33 0.58 0.68 141–158

71–80 — — 0.41 0.58 159–176



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1497 of 2079 10/1/2015 11:02 AM



Flexible cords and flexible cables, where connected to moving parts of tracking PV arrays, shall comply with Article 400 andshall be of a type identified as a hard service cord or portable power cable; they shall be suitable for extra-hard usage, listed foroutdoor use, water resistant, and sunlight resistant. Flexible PV wire shall also be permitted to be connected to moving parts oftracking PV arrays. For ambient temperatures exceeding 30°C (86°F), the

ampacities shall be derated by the appropriate factors given in Table 690 . 31 (E)




30 1.00 1.00 1.00 1.00 86

31–35 0.91 0.94 0.96 0.97 87–95

36–40 0.82 0.88 0.91 0.93 96–104

41–45 0.71 0.82 0.87 0.89 105–113

46–50 0.58 0.75 0.82 0.86 114–122

51–55 0.41 0.67 0.76 0.82 123–131

56–60 — 0.58 0.71 0.77 132–140

61–70 — 0.33 0.58 0.68 141–158

71–80 — — 0.41 0.58 159–176


The sentence "For ambient temperatures exceeding 30°C (86°F), the ampacities shall be derated by the appropriate factors given in Table 690.31(E)." was deleted from the PI transfer to the FR. Section 31(E) now has a table with nothing referreing to it

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1498 of 2079 10/1/2015 11:02 AM

Public Comment No. 1004-NFPA 70-2015 [ Section No. 690.31(G) ]

(G) Direct-Current Photovoltaic Source and System Direct-Current Output Circuits on or Inside a Building.

Where dc PV source or system dc PV output circuits are run inside a building or structure , they shall be contained in metalraceways, Type MC metal-clad cable that complies with 250.118(10), or metal enclosures from the point of penetration of thesurface of the building or structure to the first readily accessible disconnecting means. The disconnecting means shall complywith 690.13(B) and (C) and 690.15(A) and (B). The wiring methods shall comply with the additional installation requirements in690.31(G)(1) through (4).

(1) Embedded in Building Surfaces.

Where circuits are embedded in built-up, laminate, or membrane roofing materials in roof areas not covered by PV modules andassociated equipment, the location of circuits shall be clearly marked using a marking protocol that is approved as beingsuitable for continuous exposure to sunlight and weather.

(2) Flexible Wiring Methods.

Where flexible metal conduit (FMC) smaller than metric designator 21 (trade size 3⁄4 ) or Type MC cable smaller than 25 mm (1in.) in diameter containing PV power circuit conductors is installed across ceilings or floor joists, the raceway or cable shall beprotected by substantial guard strips that are at least as high as the raceway or cable. Where run exposed, other than within 1.8m (6 ft) of their connection to equipment, these wiring methods shall closely follow the building surface or be protected fromphysical damage by an approved means.

(3) Marking and Labeling Required.

The following wiring methods and enclosures that contain PV power source conductors shall be marked with the wordingWARNING: PHOTOVOLTAIC POWER SOURCE by means of permanently affixed labels or other approved permanent marking:

(1) Exposed raceways, cable trays, and other wiring methods

(2) Covers or enclosures of pull boxes and junction boxes

(3) Conduit bodies in which any of the available conduit openings are unused

(4) Marking and Labeling Methods and Locations.

The labels or markings shall be visible after installation. The labels shall be reflective, and all letters shall be capitalized andshall be a minimum height of 9.5 mm ( 3⁄8 in.) in white on a red background. PV power circuit labels shall appear on everysection of the wiring system that is separated by enclosures, walls, partitions, ceilings, or floors. Spacing between labels ormarkings, or between a label and a marking, shall not be more than 3 m (10 ft). Labels required by this section shall be suitablefor the environment where they are installed.


The advent of the new definition for PV system dc circuit requires the editing of this section title and first sentence for clarity and consistency.

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First Revision No. 990-NFPA 70-2015 [Section No. 690.31(G) [Excluding any Sub-Sections]]




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1499 of 2079 10/1/2015 11:02 AM

Public Comment No. 897-NFPA 70-2015 [ Section No. 690.31(G)(3) ]

(3) Marking and Labeling Required.

The following wiring methods and enclosures that contain PV power source System DC Circuit conductors shall be markedwith the wording WARNING: PHOTOVOLTAIC POWER SOURCE by means of permanently affixed labels or other approvedpermanent marking:

(1) Exposed raceways, cable trays, and other wiring methods

(2) Covers or enclosures of pull boxes and junction boxes

(3) Conduit bodies in which any of the available conduit openings are unused


"PV power source" is an undifined term and should be replaced with Photovoltaic System DC Circuit which is defined.

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1500 of 2079 10/1/2015 11:02 AM

Public Comment No. 898-NFPA 70-2015 [ Section No. 690.31(G)(4) ]

(4) Marking and Labeling Methods and Locations.

The labels or markings shall be visible after installation. The labels shall be reflective, and all letters shall be capitalized andshall be a minimum height of 9.5 mm ( 3⁄8 in.) in white on a red background. PV power System DC circuit labels shall appear onevery section of the wiring system that is separated by enclosures, walls, partitions, ceilings, or floors. Spacing between labelsor markings, or between a label and a marking, shall not be more than 3 m (10 ft). Labels required by this section shall besuitable for the environment where they are installed.


PV System DC Circuit is a defined term and should be used in place of "PV power circuit."

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1501 of 2079 10/1/2015 11:02 AM

Public Comment No. 519-NFPA 70-2015 [ Section No. 690.31(J) ]

(J) Module Connection Arrangement.

For solidly grounded PV systems, the The connection to a module or panel shall be arranged so that removal of a module orpanel from a PV source circuit does not interrupt a grounded conductor connection to other PV source circuits.


The PI this change is based on incorrectly concludes that this section would only apply to solidly grounded PV systems. Even in systems that are reference grounded removal of a PV module should not isolate the grounded conductor of any other PV module in the system from the reference ground.

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Public Input No. 3813-NFPA 70-2014 [Section No. 690.31(J)]




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1502 of 2079 10/1/2015 11:02 AM


Connectors other than those allowed by 690.32 shall comply with 690.33(A) through (E).


The Correlating Committee directs that FR 980 be rewritten to clarify which connectors are required to comply with 690.33 and revise to comply with the NEC Style Manual.

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First Revision No. 980-NFPA 70-2015 [Section No. 690.33 [Excluding any Sub-Sections]]



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1503 of 2079 10/1/2015 11:02 AM


(C) Type.

The connectors shall be of the latching or locking type. Connectors that are readily accessible and that are used in circuitsoperating at over 30 volts dc or 15 volts ac shall require a tool for opening.


The proposed text conflicts with the existing wet location shock hazard voltage limits within the NEC and most safety standards which are different between AC and DC circuits.

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1504 of 2079 10/1/2015 11:02 AM


690.34 Access to Boxes.

Junction, pull, and outlet boxes located behind modules or panels shall be so installed that the wiring contained in them can berendered accessible directly or by displacement of a module(s) or panel(s) secured by removable fasteners and connected by aflexible wiring system.

Exception: Where devices are used to provide grounding of the module frames as permitted in 690.43(D), and identified as asingle-use bonding/grounding device, displacement of a module(s) or panel(s) shall not be permitted for junction, pull or outletbox access.Informational Note: ANSI/UL 2703-2015, UL Standard for Mounting Systems, Mounting Devices, Clamping/Retention Devices,and Ground Lugs for Use with Flat-Plate Photovoltaic Modules and Panels requires the installation instructions for single-usebonding/grounding devices to include the statement "For single-use only", or the equivalent.



Weeb_9.5NL_Single_Use_Only.pdfSunPower Installation instructions in part that identify "Single Use Only" PV grounding clip.

Weeb_PMC_Single_Use_Only.pdfSnapRack Installation instructions in part that identify "Single Use Only" PV grounding clamp.


Devices used to ground module frames as permitted in section 690.43(D) are tested in combination with specific PV modules, specific PV module frames, or specific mounting-system rails as identified in the individual certifications. When these devices are Certified (Listed) as a single-use bonding/grounding device, UL 2703 requires that the installation instructions shall include the statement "For single-use only" or the equivalent.

Therefore, if a module is displaced for access to a junction box, this would require the grounding device to be replaced, 110.3(B). Since these devices are specific to PV modules and mounting systems, it is highly unlikely that the person removing the module would have the correct replacement device to maintain the tested ground path of the Certified (Listed) system. Also, the way these devices are installed, typically a single device will ground multiple PV modules to the mounting-system. The removal of a single module will have a domino effect on other modules, thereby causing the replacement of numerous devices.

If these devices are not replaced, the grounding of the modules as required by 690.43(A) will be compromised and create a potentially hazardous installation. The following are typical notes found within the installation instructions for these types of devices;

Intended for SINGLE USE ONLY! Functionality will not be guaranteed if reused.

SINGLE USE ONLY! Do not torque fasteners down if position of solar modules is not finalized. Only slightly tighten fasteners to keep modules in place.

When replacing a single faulty module, also remove the adjacent module that connects to the same grounding device as the faulty module. This will ensure that there are never ungrounded modules in the array.

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1505 of 2079 10/1/2015 11:02 AM





(2) For PV systems with a generating capacity of 100 kilowatts or greater, an industry standard method, performed underengineering supervision, that accounts for the maximum current variables of elevation, array orientation, and irradiance.The calculated maximum current value used by this method shall not be less than 70 percent of the value calculated using690.8(A)(1) (a). The wire size shall not be smaller than the minimum wire size for the wiring terminal of theequipment, and the minimum wire size based on the product ratings and installation instructions.



As written the calculations could result in use of a smaller wire size than is appropriate for the equipment.

We suggest appending the following text to the end of item (2): "The wire size shall not be smaller than the minimum wire size for the wiring terminal of the equipment, and the minimum wire size based on the product ratings and installation instructions."

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1385 of 2079 10/1/2015 11:02 AM





(2) For PV systems not mounted on building and with a generating capacity of 100 kilowatts or greater, an industry standardmethod, performed under engineering supervision, that accounts for the maximum current variables of elevation, arrayorientation, and irradiance. The calculated maximum current value used by this method shall not be less than 70 percent ofthe value calculated using 690.8(A)(1) (a)



SunPower views the addition of 690.8(A)(1)(b) has serious risk for the PV industry. If this adjustment is not calculated correctly, conductors and equipment will overheat because they are carrying more current then they are capable of carrying, which could cause a fire. The situations where this provision is needed are limited. Additionally, there are not well established public resources for the environmental data that would need to be used for this adjustment. Whereas, the ASHRAE handbook provides an established resource for the temperature data needed to apply the Sandia Model to the maximum PV System voltage calculation, the same is not true for maximum irradiance data. As a result the risks associated with this proposal out weigh the advantages. For this reason, SunPower and other members of SEIA opposed introducing this concept into the 2017 NEC and it was not submitted as a SEIA proposal for the First Draft hearing. Since this concept has been introduced and adopted by CMP 4, we recommend that the risk associated with this proposal be limited by not allowing it to be used for PV systems on buildings. This will limit the consequences if this provision is incorrectly used and the mistake causes a fire.

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1386 of 2079 10/1/2015 11:02 AM



The maximum current shall be calculated by one of the following methods:(a) The sum of parallel PV module rated short-circuit currents multiplied by 125 percent

(b) For PV systems with a generating capacity of 100 kilowatts or greater, an industry standard method, performedunder engineering supervision, that accounts for the maximum current variables of elevation, array orientation, andirradiance. The calculated maximum current value used by this method shall not be less than 70 percent of the valuecalculated using 690.8(A)(1) (a)



Incorrect level 3 identifier according to the style manual.

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1387 of 2079 10/1/2015 11:02 AM





(2) For PV systems with a generating capacity of 100 kilowatts or greater, an approved industry standard method, performedunder engineering supervision, that accounts for calculates the maximum current variables of elevation, array orientation,and irradiance 3-hour current based on the simulated irradiance on the PV array . The calculated maximum current valueused by this method shall not be less than 70 percent of the value calculated using 690.8(A)(1) (a)



This comment clarifies that the maximum current is a 3-hour value that is based on simulated irradiance on the PV array. The variables of elevation and orientation are relevant to current as they adjust the irradiance on the PV array so ultimately irradiance is the only true factor that determines current. Mentioning the other two factors of elevation and orientation may be confusing to AHJs.

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1388 of 2079 10/1/2015 11:02 AM


(B) Conductor Ampacity.

PV system currents shall be considered to be continuous. Circuit conductors shall be sized to carry not less than the larger of690.8(B)(1) or (2) or where protected by adjustable electronic overcurrent protection as per 690 .9(B) Exception 2, not lessthan the current in 690.8(B)(3).

(1)

One hundred and twenty-five percent of the maximum currents calculated in 690.8(A) before the application of adjustment andcorrection factors

Exception: Circuits containing an assembly, together with its overcurrent device(s), that is listed for continuous operation at100 percent of its rating shall be permitted to be used at 100 percent of its rating.

(2)

The maximum currents calculated in 690.8(A) after the application of adjustment and correction factors

(3)

The rating or setting of the adjustable electronic overcurrent protection in accordance with Art. 240.4


Our PI#4744 and PI #4749 were intended to revise the rules for sizing of overcurrent protective devices in PV source and output circuits so that adjustable electronic trip devices could be sized more traditionally (per Art. 240) rather than having to be sized for 125% of the PV short circuit current in the existing 690.9 approach, ensuring they can never trip in the forward direction. While thermal devices such as fuses can be damaged or fail to clear properly when faced with low fault currents, the same is not true of adjustable electronic overcurrent devices. By allowing the rating or setting of such devices in accordance with Art. 240, the devices can provide protection in the forward direction, without risk of being damaged or failing to clear properly, and the devices and the conductors they protect may be made smaller in some situations.

Those PI's were resolved, so we are submitting two related Public Comments: this one on 690.8(B) and a related one on 690.9(B). We feel the intent of the original PI's may not have been clear by the way they were structured, and so these Public Comments attempt to achieve the same objectives in a different way.




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1389 of 2079 10/1/2015 11:02 AM


690.9 Overcurrent Protection.

(A) Circuits and Equipment.

PV system dc circuitand inverter output conductors and equipment shall be protected against overcurrent. Overcurrentprotection devices are not required for circuits with sufficient ampacity for the highest available current. Circuits connected tocurrent limited supplies (e.g., PV modules, dc-to-dc converters, output circuits) and also connected to sources having highercurrent availability (e.g., parallel strings of modules, utility power) shall be protected at the higher current source connection.

Exception: An overcurrent device shall not be required for PV modules or PV source circuit or dc-to-dc converters sourcecircuit conductors sized in accordance with 690.8(B) where one of the following applies:

(1) There are no external sources such as parallel-connected source circuits, batteries, or backfeed from inverters.

(2) The short-circuit currents from all sources do not exceed the ampacity of the conductors and the maximum overcurrentprotective device size rating specified for the PV module or dc-to-dc converter.

Informational Note: Photovoltaic system dc circuits are current limited circuits that only need overcurrent protectionwhen connected in parallel to higher current sources. Where necessary, the overcurrent device is installed at the highercurrent source end of the circuit.

(B) Overcurrent Device Ratings.

Overcurrent devices used in any dc portion of a PV system shall be listed for use in PV systems. Overcurrent device ratingsshall be not less than 125 percent of the maximum currents calculated in 690.8(A).


(C) Photovoltaic Source and Output Circuits.

A single overcurrent protection device, where required, shall be permitted to protect the PV modules and conductors of eachsource circuit or the conductors of each output circuit. Where single overcurrent protection devices are used to protect PVsource or output circuits, all overcurrent devices shall be placed in the same polarity for all circuits within a PV system. Theovercurrent devices shall be accessible but shall not be required to be readily accessible.

Informational Note: Due to improved ground-fault protection required in PV systems by 690.41(B), a single overcurrentprotection device in either the positive or negative conductors of a PV system in combination with this ground-faultprotection provides adequate overcurrent protection.

(D) Power Transformers.

Overcurrent protection for a transformer with a source(s) on each side shall be provided in accordance with 450.3 byconsidering first one side of the transformer, then the other side of the transformer, as the primary.

Exception: A power transformer with a current rating on the side connected toward the -interactive inverter output, not lessthan the rated continuous output current of the inverter, shall be permitted without overcurrent protection from the inverter.


The Correlating Committee directs that FR 972 be rewritten to comply with the NEC Style Manual. Wherever the phrase “overcurrent protection device” is used in this subsection rewrite, replace with the phrase “overcurrent protective device.”

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1390 of 2079 10/1/2015 11:02 AM



PV system dc circuitand inverter output conductors and equipment shall be protected against overcurrent. Overcurrentprotection protective devices are not required for circuits with sufficient ampacity for the highest available current. Circuitsconnected to current limited supplies (e.g., PV modules, dc-to-dc converters, interactive inverter output circuits) and alsoconnected to sources having higher current availability (e.g., parallel strings of modules, utility power) shall be protected at thehigher current source connection.

Exception: An overcurrent device shall not be required for PV modules or PV source circuit or dc-to-dc converters sourcecircuit conductors sized in accordance with 690.8(B) where one of the following applies:


(2) The short-circuit currents from all sources do not exceed the ampacity of the conductors and the maximum overcurrentprotective device size rating specified for the PV module or dc-to-dc converter.

Informational Note: Photovoltaic system dc circuits are current limited circuits that only need overcurrent protection whenconnected in parallel to higher current sources. Where necessary, the overcurrent device is installed at the higher currentsource end of the circuit.


This comment addresses two issues raised by the correlating committee. The term "protective" device is used instead of protection device. Also, the addition of the words "interactive inverter" to output circuits was part of the FR but inadvertently dropped from the draft. This comment reinstates those words.

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1391 of 2079 10/1/2015 11:02 AM



Overcurrent devices used in any dc portion of a PV system shall be listed for use in PV systems. Overcurrent device ratingsshall be not less than 125 percent of the maximum currents calculated in 690.8(A).

Exception (1) : Circuits containing an assembly, together with its overcurrent device(s), that is listed for continuous operationat 100 percent of its rating shall be permitted to be used at 100 percent of its rating.

Exception (2): Adjustable electronic overcurrent protection devices may be rated or set in accordance with Art. 240.4


Our PI#4744 and PI #4749 were intended to revise the rules for sizing of overcurrent protective devices in PV source and output circuits so that adjustable electronic trip devices could be sized more traditionally (per Art. 240) rather than having to be sized for 125% of the PV short circuit current in the existing 690.9 approach, ensuring they can never trip in the forward direction. While thermal devices such as fuses can be damaged or fail to clear properly when faced with low fault currents, the same is not true of adjustable electronic overcurrent devices. By allowing the rating or setting of such devices in accordance with Art. 240, the devices can provide protection in the forward direction, without risk of being damaged or failing to clear properly, and the devices and the conductors they protect may be made smaller in some situations.Those PI's were resolved, so we are submitting two related Public Comments: this one on 690.9(B) and a related one on 690.8(B). We feel the intent of the original PI's may not have been clear by the way they were structured, and so these Public Comments attempt to achieve the same objectives in a different way.




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1392 of 2079 10/1/2015 11:02 AM



Overcurrent devices used in any dc portion of a PV system shall be listed, labeled and identified for use in PV systems.Overcurrent device ratings shall be not less than 125 percent of the maximum currents calculated in 690.8(A) .

Exception: Circuits containing an assembly, together with its overcurrent device(s), that is listed and labeled for continuousoperation at 100 percent of its rating shall be permitted to be used at 100 percent of its rating.










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1394 of 2079 10/1/2015 11:02 AM



Overcurrent devices used in any dc portion of a PV system source circuits shall be listed for use in PV systems. Overcurrentdevice ratings shall be not less than 125 percent of the maximum currents calculated in 690.8(A).



Not all dc portions of a renewable energy system is exposed to the special considerations specific to PV source circuits, and listed dc components appropriate for those applications are readily available and have been used successfully and safely for years. The proposed revision acknowledges this, and uses PV source circuits as defined in 690 to clarify that it is the nature of PV source circuits, not merely dc, that triggers the higher requirement to be listed for PV systems.

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1395 of 2079 10/1/2015 11:02 AM



A single overcurrent protection device, where required, shall be permitted to protect the PV modules and conductors of eachsource circuit or the conductors of each output circuit. Where single overcurrent protection devices are used to protect PVsource or output circuits, all overcurrent devices shall be placed in the same polarity for all circuits within a PV system. Theovercurrent devices shall be accessible but shall not be required to be readily accessible. For PV systems designed underengineering supervision and not on or in one or two family dwellings, blocking diodes rated for the maximum PV system voltageand for the current required by 690.9(B) shall be permitted as overcurrent protection devices for PV source and output circuits.

Informational Note: Due to improved ground-fault protection required in PV systems by 690.41(B), a single overcurrentprotection device in either the positive or negative conductors of a PV system in combination with this ground-faultprotection provides adequate overcurrent protection.


The OCPD used in PV source and PV output circuits only serve one purpose, to interrupt backfeed current when a fault occurs somewhere between the PV modules and the OCPD. However, the OCPD also needs to be sized to allow the normal operating current to pass through it without activating the OCPD. For a typical PV source circuit, the various derating factors would require that I use a 12A fuse when I have a PV module Isc of 6A. The 12A fuse will not blow until have more than 16 to 20A of fault current flowing through it. As a result, I could feed a fault on a PV source circuit with 6A from the PV modules connected to that string and another 20A from the parallel connected strings forever. This amount of current is more than sufficient to cause a fire. This is not a theoretical concept as there are cases where this situation has already occurred.

A preferred OCPD would allow the device to carry the required current during normal operation conditions and NOT allow any backfeed current to flow through the device during a fault condition. A blocking diode would provide this capability. However, the NEC as written does not allow for blocking diodes to be used as OCPDs. Thus, we propose that 690.9(C) be revised to allow for this superior solution to be implemented. This approach is not new; it has been used in PV systems in Japan for many years. However, we recognize that it would be new in the United States. Thus, we propose that in this code cycle it only be permitted to be used in systems designed under engineering supervision and not in residential systems. This will allow for this solution be used on a limited basis to demonstrate that it will also work well here in the US. In future code cycles, this restriction could be removed.

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1396 of 2079 10/1/2015 11:02 AM



A single overcurrent protection protective device, where required, shall be permitted to protect the PV modules and conductorsof each source circuit or the conductors of each output circuit. Where single overcurrent protection devices are used to protectPV source or output circuits, all overcurrent devices shall be placed in the same polarity for all circuits within a PV system. Theovercurrent devices shall be accessible but shall not be required to be readily accessible.

Informational Note: Due to improved ground-fault protection required in PV systems by 690.41(B), a single overcurrentprotection protective device in either the positive or negative conductors of a PV system in combination with thisground-fault protection provides adequate overcurrent protection.


Changes protection to "protective" as directed by the correlating committee.

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1397 of 2079 10/1/2015 11:02 AM


690.41 System Grounding.

(A) PV System Grounding Configurations.

One or more of the following system grounding configurations shall be employed:

Reference grounded 2-wire

(1) Ungrounded PV systems with

one conductor referenced to ground

(2) Reference grounded bipolar PV systems with the reference (center tap) conductor referenced to ground and meets therequirements of 690.7(C)

(3) PV systems not isolated from the inverter output circuit

(4) Ungrounded PV systems

(5) a ground detector in accordance with 690.41(B)

(6) Solidly grounded PV systems as permitted in 690.41(B) Exception

(7) PV systems that use other methods that accomplish equivalent system protection in accordance with 250.4(A) withequipment listed and identified for the use .

Informational Note: The ground detector in ungrounded PV systems may include a ground-sensing circuit using a fuse, circuitbreaker, resistance device, non-isolated grounded ac circuit, or electronic means that is part of a listed ground-fault protectionsystem. Some conductors in these systems may normally be at ground potential but have voltage to ground during faultconditions.

(B) Ground -Fault Protection Detector .

DC Dc PV arrays shall be provided with dc ground -fault protection detector meeting the requirements of 690.41(B)(1) and(2) to reduce fire hazards.

Exception: Ground-mounted or pole-mounted PV arrays with not more than two paralleled source circuits and with all dcsource and dc output circuits isolated from buildings shall be permitted without ground-fault protection. PV systems with noground-fault protection shall be solidly grounded.

(1) Ground-Fault Detection and Interruption .

The ground fault protection device or system detector shall detect ground fault(s) in the PV array dc current–carryingconductors and components, including any reference intentionally grounded conductors, and be listed for providing PVground-fault protection.

(2) Isolating Faulted Circuits.

The faulted circuits shall be isolated by one of the following two methods:

(1) The current-carrying conductors of the faulted circuit shall be automatically disconnected.

(2) The inverter or charge controller fed by the faulted circuit shall automatically cease to supply power to output circuits.



690-41.docx Readable version to show what it looks like without TerraView mixing up the numbering.


The correlating committee had serious concerns about the terminology recommended in FR 991. This language was drafted to address the correlating committee concerns and to be more consistent with Article 250.21 provisions for ungrounded ac systems. The new definition for reference grounded PV systems was also removed to further address the correlating committee's concerns with the language and all references to reference grounded systems revised it 690.7 and 690.41.

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1507 of 2079 10/1/2015 11:02 AM


(1) Ground-Fault Detection and Interruption.

The ground fault protection device or system shall

detectbe listed for providing PV ground - fault

(s)protection in the PV array dc current–carrying conductors and components, including any reference grounded conductors

, and be listed for providing PV ground-fault protection.. Indication of the fault shall be provided.

Automatically isolating from the ground reference for measurement purposes shall be permitted.


SunPower would like to thank the Panel 4 for making these very important changes to the ground fault protection (GFP) requirements for PV systems. There are a couple edits that were introduced in the new version that will produce some unintended consequences. Hence, SunPower requests that you make a few small revisions to the requirement in 690.41(B)(1). As it is written right now, it only requires that the GFP device detect the ground fault, not interrupt the fault. The interruption requirement previously existed in the 2014 version of 690.5. The indication requirement was also likely inadvertently lost in the new version of the language. Thus, SunPower requests that the panel revise the language to read "... shall be listed for providing PV ground-fault protection ...". The requirement to provide "protection" will include both the need to detect the fault and interrupt it. We also included the requirement for providing an indication of the fault. As a coordinator of the UL Task Group revising the ground fault protection requirements in the US PV standards, it is critical that the STP be given clear direction on these requirements so that they can be included in the standard.

Another provision that was lost in the migration of the requirements from 690.5 was the allowance for automatically opening the ground reference for measurement purposes. The UL 62109-2 working group will require the use of insulation resistance measurement in grounded systems before the system starts to produce power. This measurement has the required sensitivity to detect low level ground faults that when left undetected have caused fires in PV systems. To implement this measurement, the system must temporally disconnect from ground while it is performing the measurement. Prior to including the automatically opening provision in the 2014 version of 690.5, this approach was unnecessarily interpreted as a code violation. It is critical that the provision for opening the ground reference for automatic measurement purposes be retained to allow for implementation of this essential improvement in GFP.

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The faulted circuits shall be isolated by one of the following two methods:(a) The current-carrying conductors of the faulted circuit shall be automatically disconnected.

(b) The inverter or charge controller fed by the faulted circuit shall automatically cease to supply power to output circuits andisolate the system from the ground reference if it is a reference grounded system .


For some reason, TerraView is highlighting all of 690.41(B)(2) as a revision. I am only proposing to add "and isolate the system from the ground reference if it is a reference grounded system" to the end of 690.41(B)(2)(b).

As I mentioned in my comment on 690.41(B)(1), SunPower is grateful to CMP 4 for making these very important changes to the ground fault protection (GFP) requirements for PV systems. The addition of the isolation requirement for grounded systems is critical for effective implementation of GFP in grounded systems. Turning off the inverter in these systems does not provide the isolation required to stop the fault current. The connection to ground must also be opened. The inclusion of the requested revision will address this gap.

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(1) The current-carrying conductors of the faulted circuit shall be automatically disconnected.



The word two is not necessary. This is an editoral comment

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(1) The current-carrying conductors of the faulted circuit shall be automatically disconnected. , or



The requirement refers to optional list items. The word ",or" should be added to clarify that requirements can be met with item 1 or 2.

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690.42 Point of System Grounding Connection.

Systems with a ground-fault protection devicein accordance with 690.41(B) shall have any required grounded conductor-to-ground bond made by the ground-fault protection device. This bond, where internal to the ground-fault equipment, shall notbe duplicated with an external connection. For solidly grounded PV systems, the dc circuit grounding connection shall be madeat any single point on the PV output circuit.


The addition of "PV" clarifies that this relates to PV systems and not other systems.

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690.45 Size of Equipment Grounding Conductors.

Equipment grounding conductors for PV source and PV output circuits shall be sized in accordance with 250.122. Where noovercurrent protective device is used in the circuit, an assumed overcurrent device in rating sized in accordance with 690.9(B)shall be used when applying Table 250.122. Increases in equipment grounding conductor size to address voltage dropconsiderations shall not be required. An equipment grounding conductor shall not be smaller than 14 AWG.


simply adds the word "sized" to correctly apply to 690.9 as directed by the correlating committee comment.

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Equipment grounding conductors for PV source and PV output circuits shall be sized in accordance with 250.122. Where noovercurrent protective device is used in the circuit, an assumed overcurrent device device rated in rating in accordance with690.9(B) shall be used when applying Table 250.122. Increases in equipment grounding conductor size to address voltagedrop considerations shall not be required. An equipment grounding conductor shall not be smaller than 14 AWG.


Editorial Revision

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Equipment grounding conductors for PV source and PV output circuits shall be sized in accordance with 250.122. Where noovercurrent protective device is used in the circuit, an assumed overcurrent device in rating in accordance with 690.9(B) shallbe used when applying Table 250.122. Increases in equipment grounding conductor size to address voltage dropconsiderations shall not be required. An equipment grounding conductor shall not be smaller than 14 AWG.



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Equipment grounding conductors for PV source and PV output circuits shall be sized in accordance with 250.122. Where noovercurrent protective device is used in the circuit, an assumed overcurrent device rated in rating in accordance with 690.9(B)shall be used when applying Table 250.122. Increases in equipment grounding conductor size to address voltage dropconsiderations shall not be required. An equipment grounding conductor shall not be smaller than 14 AWG.


Just a change in the wording to make the sentence flow better.

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Equipment grounding conductors for PV source and PV output circuits shall be sized in accordance with 250.122. Where noovercurrent protective device is used in the circuit, an assumed overcurrent device device rated in rating in accordance with690.9(B) shall be used when applying Table 250.122. Increases in equipment grounding conductor size to address voltagedrop considerations shall not be required. An equipment grounding conductor shall not be smaller than 14 AWG.


The first revision grammer and sentence organization was confusing if not incorrect. This is an editoral comment

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(A) Buildings or Structures Supporting a PV System.

A building or structure supporting a PV system shall have a grounding electrode system installed in accordance with Part III ofArticle 250.

The PV system equipment grounding conductors shall be connected to the grounding electrode system of the building orstructure supporting the PV system by means of the grounding electrode conductor, or the grounding bus of associatedequipment connected to the grounding electrode conductor. This connection shall be in addition to any other equipmentgrounding conductor requirements in 690.43(C). The PV system equipment grounding conductors shall be sized in accordancewith 690.45.

For solidly grounded PV systems, as permitted in 690.41(A)(5 2 ) , the grounded conductor shall be connected to a groundingelectrode system with a grounding electrode conductor sized in accordance with 250.166.

Informational Note: Previous versions of this Code treated all grounded PV systems as solidly grounded systems andtherefore required Most PV systems installed in the past decade are ungrounded systems with a ground detector. Manyof these PV systems have been mistakenly referred to as grounded systems because fuses have often been connectedto one of the dc conductors as part of some ground detectors. This has often led to treating these as solidly groundedsystems requiring a dc grounding electrode conductor to be connected to grounded PV system dc circuits. Since mostPV systems installed in the past decade are not solidly grounded, this Code narrows the requirement for a dc groundingelectrode to only those that are actually solidly grounded in accordance with 690.41(A)(5) . All other PV systemgrounding configurations listed in 690.41(A) do not require a dc grounding electrode conductor conductors are notconnected to the grounding electrode conductor. An ungrounded PV system with an interactive inverter output typicallyhas a connection to the grounding electrode conductor at associated equipment, such as ac distribution equipment in abuildng, at which point the equipment grounding conductor and ground detector circuit has a solid connection to ground .


The language in the first draft caused some objections in the correlating committee. Much of the concern comes from wording in the informational note about grounded PV systems. With the rewriting of 690.41(A), it is more appropriate to explain that most PV systems are actually ungrounded systems with ground detectors. These systems must still have a connection to the grounding electrode conductor, but this connection typically occurs at the PV system disconnecting means on the output of the interactive inverter. That disconnecting means is often in service or distribution equipment that already has an established connection to the grounding electrode conductor. This provides the appropriate point to connect the equipment grounding conductor and ground detector to ground.

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(A) Buildings or Structures Supporting a PV System.

A building or structure supporting a PV system shall have a grounding electrode system installed in accordance with Part III ofArticle 250.

The PV system equipment grounding conductors shall be connected to; the grounding electrode system of the building orstructure supporting the PV system by means of , the grounding electrode conductor, or the grounding bus of associatedequipment connected to the grounding electrode conductor. This connection shall be in addition to any other equipmentgrounding conductor requirements in 690.43(C). The PV system equipment grounding conductors shall be sized in accordancewith 690.45.

For solidly grounded PV systems, as permitted in 690.41(A)(5) , the grounded conductor shall be connected to a groundingelectrode system with a grounding electrode conductor sized in accordance with 250.166.

Informational Note: Previous versions of this Code treated all grounded PV systems as solidly grounded systems andtherefore required a dc grounding electrode conductor to be connected to grounded PV system dc circuits. Since mostPV systems installed in the past decade are not solidly grounded, this Code narrows the requirement for a dc groundingelectrode to only those that are actually solidly grounded in accordance with 690.41(A)(5) . All other PV system groundingconfigurations listed in 690.41(A) do not require a dc grounding electrode conductor.


The changes proposed clarify that the array equipment (module frames, racking, etc.) can be connected to the grounding system through an equipment ground. The current wording seems to imply the equipment is connected through a GEC, when only an EGC is required.

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(B) Additional Auxiliary Electrodes for Array Grounding.

Grounding electrodes

A grounding electrode shall be

permitted to be

installed in accordance with 250.52 and 250.54 at the location of all ground- and pole-mounted PV arrays and asclose as practicable to the location of roof-mounted PV arrays. The electrodes shall be

permitted to be

connected directly to the array frame(s) or structure. The dc grounding electrode conductor shall be sized accordingto 250.

66.

166 . Additional electrodes are not permitted to be used as a substitute for equipment bonding or equipmentgrounding conductor requirements. The structure of a ground- or pole- mounted PV array shall be permitted to beconsidered a grounding electrode if it meets the requirements of 250.52 . Roof - mounted PV arrays shall bepermitted to use the metal frame of a building or structure if the requirements of 250.52(A) (2) are met.

Exception No. 1: An array grounding electrode(s) shall not be required where the load served by the array is integral with thearray.

Exception No. 2: An additional array grounding electrode(s) shall not be required if located within 1.8 m (6 ft) of the premiseswiring electrode.


This change would restore the language that is currently located in the 2014 NEC. This change was made with no technical substantiation being made one PI stated that the existing requirement was confusing, one PI attempted to relate this requirement to NFPA 780, this requirement is not intended to supersede or contradict the requirements that are used when installing a lightning protection system as covered in NFPA 780 but rather to provide some level of protection when a 780 system is not installed.

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Submitter Full Name: DAVID CLEMENTS

Organization: INTL ASSOC ELEC INSP

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690.53 Direct-Current Photovoltaic Power Source.

A permanent label for the PV power source indicating the information specified in (1) through (3) shall be provided by theinstaller at dc PV system disconnecting means and at each dc equipment disconnecting means required by 690.15. Where adisconnecting means has more than one dc PV power source, the values in 690.53(1) through (3) shall be specified for eachsource.

(1) Maximum voltage

Informational Note to (1): See 690.7 for voltage.

(2) Maximum circuit current

Informational Note to (2): See 690.8(A) for calculation of maximum circuit current.

(3) Maximum rated output current of the charge controller or dc-to-dc converter (if installed)


The Correlating Committee directs that FR 996 be revised to comply with the NEC Style Manual, Section 2.1.5, Subdividing Sections.

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690.53 Direct-Current Photovoltaic Power Source.

A permanent label for the dc PV power source indicating the information specified in (1) through (3) shall be provided by theinstaller at dc PV system disconnecting means and at each dc equipment disconnecting means required by 690.15. Where adisconnecting means has more than one dc PV power source, the values in 690.53(1) through (3) shall be specified for eachsource.

(1) Maximum voltage

Informational Note to (1): See 690.7 for voltage.

(2) Maximum circuit current

Informational Note to (2): See 690.8(A) for calculation of maximum circuit current.

(3) Maximum rated output current of the charge controller or dc-to-dc converter (if installed)


Add the word "dc" in front of the first instance of "PV power source". The term "PV power source" is undefined, while "dc PV power source" is being described in the requirement.

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690.55 Photovoltaic Systems Connected to Energy Storage Systems.

Energy storage systems shall be marked with the maximum operating voltage, including any equalization voltage. If solidlygrounded, the grounded circuit conductor The PV system output circuit conductors shall be marked to indicate the polaritywhere connected to energy storage systems .


The first draft language applied to requirements in the new Article 706. Article 690 should not be making requirements for Article 706. This marking requirement is focused on polarity and is only relevant to the polarity of a dc PV system that is connected to an dc energy storage system.

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690.56 Identification of Power Sources.

(A) Facilities with Stand-Alone Systems.

Any structure or building with a PV power system that is not connected to a utility service source and is a stand-alone systemshall have a permanent plaque or directory installed on the exterior of the building or structure at a readily visible location. Theplaque or directory shall indicate the location of system disconnecting means and that the structure contains a stand-aloneelectrical power system. —

(B) Facilities with Utility Services and Photovoltaic Systems.

Plaques or directories shall be installed in accordance with 705.10.

(C) Facilities with Rapid Shutdown.

Buildings or structures with both utility service and a PV system complying with 690.12 shall have a permanent plaque ordirectory that includes the following wording:

PHOTOVOLTAIC SYSTEM EQUIPPED WITH RAPID SHUTDOWN ARRAY PARTITIONING

The plaque or directory shall be reflective, with all letters capitalized and having a minimum height of 9.5 mm ( 3⁄8 in.), in whiteon red background. The plaque or directory shall be located on, or no more than 1 m (3 ft) from, the service disconnectingmeans to which the PV systems are connected, or in accordance with 690.56(A) or (B), as applicable, and shall indicate thelocation of the rapid shutdown initiator if not at the same location.


The First Revision for this article was totally inadequate to provide signage that insures first responder safety. The concern for the new language is that it does not provide methods to distinguish between legacy systems with no rapid shutdown, systems installed according to the 2014 NEC with array level disconnects, and systems that may installed according to a revised NEC. I chose the word partitioning since nothing in the array is shutdown.

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(B) Facilities with Utility Services and Photovoltaic Systems.

Plaques or directories shall be installed in accordance with 705.10.


The Correlating Committee directs that further consideration be given to the comments expressed in voting on FR 989. The Correlating Committee directs the panel to clarify “rapid shutdowninitiator” and correlate with FR 1008 for use of terms.

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Buildings

or structures with both utility service and a PV system complying with 690.12 shall have a permanent plaque or directory thatincludes the following wording:

PHOTOVOLTAIC SYSTEM EQUIPPED WITH RAPID SHUTDOWN

The plaque or directory shall be reflective, with all letters capitalized and havingwith PV systems, shall have a permanent labels as described in (1) through (3)

(1) Rapid Shutdown Type. The type of PV system rapid shutdown shall be labeled as described in a) or b):

a) For PV systems that shutdown the array and conductors leaving the array:

SOLAR PV SYSTEM IS EQUIPPED WITH RAPID SHUTDOWN.

TURN RAPID SHUTDOWN SWITCH TO THE “OFF” POSITION

TO SHUTDOWN PV SYSTEM AND REDUCE SHOCK HAZARD IN ARRAY

The first two lines of the label shall be capitalized characters with a minimum height of 9.5 mm (

3 ⁄ 83⁄8 in.) in white on green background and the remaining characters shall be capitalized with a minimum height of 4.8 mm (3/16in.)

,in black on white background.

Figure 56(C)(1)(a)

b) For PV systems that only shutdown conductors leaving the array:

EMERGENCY RESPONDER:


TURN RAPID SHUTDOWN SWITCH TO THE “OFF” POSITION.

TO SHUTDOWN CONDUCTORS OUTSIDE THE ARRAY. CONDUCTORS IN ARRAY REMAIN ENERGIZED IN SUNLIGHT.

The first two lines of the label shall be capitalized characters with a minimum height of 9.5 mm (3⁄8 in.) in white on redbackground and the remaining characters shall be capitalized with a minimum height of 4 .

The plaque or directory shall be located on,8 mm (3/16 in.) in black on white background.

Figure 56(C)(1)(b)


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kshea

Text Box


The labels in 690.56(C)(1)(a) and (b) shall include a simple diagram of a building with a roof. Diagram sections in red signifysections of the PV system that are not shutdown when the rapid shutdown switch is operated. Sections of the diagram in greensignify sections of the PV system that are shutdown when the rapid shutdown switch is operated.

The rapid shutdown label in 690.56(C)(1) shall be located on or no more than 1

mmeter (3 ft) from

,the service disconnecting means to which the PV systems are connected,

or in accordance with 690.56(A) or (B), as applicable,and shall indicate the location of

theall identified rapid shutdown

initiatorswitches if not at the same location.

(2) Buildings with More Than One Rapid Shutdown Type. For buildings that have PV systems with both rapid shutdowntypes or a PV system with a rapid shutdown type and a PV system with no rapid shutdown, a detailed plan view diagram of theroof shall be provided showing each different PV system and a dotted line around areas that remain energized after the rapidshutdown switch is operated.

(3) Rapid Shutdown Switch. A rapid shutdown switch shall have a label located on or no more than 1 meter (3 ft) from theswitch that includes the following wording:

RAPID SHUTDOWN SWITCH FOR SOLAR PV SYSTEM

The label shall be reflective, with all letters capitalized and having a minimum height of 9.5 mm (3⁄8 in.), in white on redbackground.



690-56_task_group_comment_version_9-24-15.docxReadable Word document in track changes mode to clearly see the graphics and changes related to 690.56(C).


These new marking requirements for Rapid Shutdown PV systems are part of a series of proposals developed by the NFPA Fire Fighter Safety and PV Systems Task Group that was reorganized in December of 2014. This collaborative Task Group is working on proposals for NFPA1, NFPA70, and other related documents. This Task Group is made up of over 20 participants from Code Making Panel 4, the solar industry, the fire service, the insurance industry, test laboratories, and other relevant stakeholders. The Rapid Shutdown marking requirements proposed in this second draft input includes the language for these signs and greyscale figures of the color signs to print in the Code. Actual examples of these signs will exist in the handbook of the 2017 NEC Handbook for section 690.56(C) and the Annex of NFPA1, 2018 edition. The signs are provided here so that reviewers can visualize what the signs are intended to look like.

Two different signs are required on buildings depending on what type of rapid shutdown system is on the building. Systems with multiple rapid shutdown types will be required to have a detailed directory since a simple sign will not be sufficient to clarify the levels of hazard on the roof.Lastly, all switches that are intended to be used as rapid shutdown switches shall be labeled with the words, “RAPID SHUTDOWN SWITCH FOR SOLAR PV SYSTEM.”


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Sign for 690.56(C)(1)(a):

Sign for 690.56(C)(1)(b):

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Section PI PAGE DISPOSITION

690.56(C) Comment on First Revision

Text (C) FacilitiesBuildings with Rapid Shutdown. Buildings with a PV

system complying with 690.12, shall have a permanent plaque or

directory including the following wording:


The plaque or directory shall be reflective, with all letters capitalized

and having a minimum height of 9.5 mm (3⁄8 in.), in white on red

background. The plaque or directory shall be located on or no more

than 1 meter (3 ft) from the service disconnecting means to which the

PV systems are connected, or in accordance with 690.56 (A) or (B), as

applicable, and shall indicate the location of the rapid shutdown

initiator if not at the same location.

Buildings with PV systems, shall have a permanent labels as

described in (1) through (3)

(1) Rapid Shutdown Type. The type of PV system rapid shutdown

shall be labeled as described in a) or b):

a) For PV systems that shutdown the array and conductors leaving the

array:


TURN RAPID SHUTDOWN SWITCH TO THE “OFF” POSITION TO SHUTDOWN PV SYSTEM AND REDUCE SHOCK HAZARD IN

ARRAY

The first two lines of the label shall be capitalized characters with a

minimum height of 9.5 mm (3⁄8 in.) in white on green background and

the remaining characters shall be capitalized with a minimum height of

4.8 mm (3/16 in.) in black on white background.

Figure 56(C)(1)(a)

b) For PV systems that only shutdown conductors leaving the array:

EMERGENCY RESPONDER: SOLAR PV SYSTEM IS EQUIPPED WITH RAPID SHUTDOWN.

TURN RAPID SHUTDOWN SWITCH TO THE “OFF” POSITION.

TO SHUTDOWN CONDUCTORS OUTSIDE THE ARRAY. CONDUCTORS IN ARRAY REMAIN ENERGIZED IN SUNLIGHT.

The first two lines of the label shall be capitalized characters with a

minimum height of 9.5 mm (3⁄8 in.) in white on red background and the remaining characters shall be capitalized with a minimum height of 4.8

mm (3/16 in.) in black on white background.

Figure 56(C)(1)(b)

The labels in 690.56(C)(1)(a) and (b) shall include a simple diagram of

a building with a roof. Diagram sections in red signify sections of the

PV system that are not shutdown when the rapid shutdown switch is

operated. Sections of the diagram in green signify sections of the PV

system that are shutdown when the rapid shutdown switch is operated.

The rapid shutdown label in 690.56(C)(1) shall be located on or no

more than 1 meter (3 ft) from the service disconnecting means to

which the PV systems are connected, and shall indicate the location of

all identified rapid shutdown switches if not at the same location.

(2) Buildings with More Than One Rapid Shutdown Type. For

buildings that have PV systems with both rapid shutdown types or a

PV system with a rapid shutdown type and a PV system with no rapid

shutdown, a detailed plan view diagram of the roof shall be provided

showing each different PV system and a dotted line around areas that

remain energized after the rapid shutdown switch is operated.

(3) Rapid Shutdown Switch. A rapid shutdown switch shall have a

label located on or no more than 1 meter (3 ft) from the switch that

includes the following wording:

RAPID SHUTDOWN SWITCH FOR SOLAR PV SYSTEM

The label shall be reflective, with all letters capitalized and having a

minimum height of 9.5 mm (3⁄8 in.), in white on red background.

Statement These new marking requirements for Rapid Shutdown PV systems are

part of a series of proposals developed by the NFPA Fire Fighter

Safety and PV Systems Task Group that was reorganized in

December of 2014. This collaborative Task Group is working on

proposals for NFPA1, NFPA70, and other related documents. This

Task Group is made up of members of the fire service, PV industry,

insurance industry, certification organizations, and other relevant

stakeholders.

The Rapid Shutdown marking requirements proposed in this second

draft input includes the language for these signs and greyscale figures

of the color signs to print in the Code. Actual examples of these signs

will exist in the handbook of the 2017 NEC Handbook for section

690.56(C) and the Annex of NFPA1, 2018 edition. The signs are

provided here so that reviewers can visualize what the signs are

intended to look like.

Three different signs are required on buildings depending on what type

of rapid shutdown system is on the building. Systems with multiple

rapid shutdown types will be required to have a detailed directory since

a simple sign will not be sufficient to clarify the levels of hazard on the

roof.

Lastly, all switches that are intended to be used as rapid shutdown

switches shall be labeled with the words, “RAPID SHUTDOWN

SWITCH FOR SOLAR PV SYSTEM.”

Sign for 690.56(C)(1)(a):

Sign for 690.56(C)(1)(b):


(C) Facilities Buildings with Rapid Shutdown.



located within 1 meter (3 ft) of the service disconnecting means to which the PV systems are connected. In one and two familydwellings where the service disconnecting means is located inside of the building, the plaque shall be located on the exterior ofthe building near the entrance of the main service conductors. In buildings other than one and two family dwellings that areequipped with a fire alarm system, an additional plaque shall be located within 1 meter (3ft) of the main fire alarm panel or theprimary access point to the building for the fire service. The plaque(s) shall include the following wording, symbols, anddiagrams:(1) The following symbol shall be placed in the upper left corner of the plaque:

See the attached image file for PV System Symbol.

(2) The following wording shall be to the right of the above symbol:

BUILDING EQUIPPED WITH SOLAR PANELS

(3) The following wording shall be printed below (C)(1) and (C)(2):

TURN THE RAPID SHUTDOWN SWITCH TO "OFF" POSITION TO SHUT DOWN THE SOLAR SYSTEM

(4) Where the rapid shutdown initiator is located more than 1 meter (3ft) from the plaque, a directory shall be provided below(C)(3) that illustrates the location of the rapid shutdown initiator.

(5) A directory showing the PV equipment on the roof of the building shall be provided. All areas containing components orequipment that is not touch safe shall be highlighted in red on the directory.

(6) Below the rooftop directory, the warning symbol shall be printed followed by the wording:

WARNING - CONDUCTORS AND EQUIPMENT IN RED AREAS WILL REMAIN ENERGIZED

The plaque or directory shall be reflective, with all letters capitalized and having a minimum height of 9.5 mm ( 3⁄8 in.), in whiteon red background. The plaque or directory shall be located on, or no more than 1 m (3 ft) from, the service disconnectingmeans to which the PV systems are connected, or in accordance with . The text from 690.56(C)(2) shall be printed in black ona white background. The text from 690.56( A C ) or (B 6 ) , as applicable, and shall indicate the location of the rapid shutdowninitiator if not at the same location shall be printed in white on red background .



PV_System_Present_Symbol.tif PV System Symbol

Example_Rapid_Shutdown_Plaque.pdf Example of a Rapid Shutdown Plaque that would result from this requirement


A recent PV system safety survey, conducted by an independent consultant with a group of 10 firefighters (3 of whom had direct experience with fires in PV Systems on commercial buildings), revealed that more firefighters want clear instructions about what equipment is energized than any other safety improvement in PV systems. This result has motivated SunPower to resubmit its request that clear and simple signage requirements be added to the 2017 NEC for systems mounted on buildings. We are delighted that CMP 4 saw value in our original proposal and requested that the Firefighter Safety Task Group (FSTG) review our proposal. While the task group did consider our proposal and incorporated elements of our proposal in their recommendation, we believe there are some very dangerous concepts also included in their proposal that should NOT be adopted. As a result, we have updated our proposal and are resubmitting it for further consideration.

The intent of this proposal is to:• Provide a clear and standard message to a firefighter that there is a PV system installed on the building because it may not be visible to them from the ground level.• Avoid the use of technical terms like PV and Rapid Shutdown that would only be familiar to a firefighter trained on PV systems. We need to provide instructions that an untrained firefighter can use as well.• Clearly communicate what is safe to touch and what is not safe to touch. Anything that is not touch safe should be labeled as energized.

The proposal from the FSTG had two major flaws. First, it still uses technical terms. Second, it requires highlighting equipment that lowers the voltage to 80V in green, which would communicate to a firefighter that there is no hazard associated with this equipment and that they could do anything to it without risk of injury. This is false and will lead to firefighters getting killed. At 80V, a wet person could be exposed to 160mA, which is double the 80mA need to electrocute a person. Thus, this green labeling is more dangerous to a firefighter than a system that does NOT have rapid shutdown because it could cause him/her to unknowingly electrocute


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You Are Here Rapid Shutdown Switch

himself/herself. Therefore, SunPower vehemently opposes the signage proposal from FSTG.

Instead, we recommend that CMP 4 adopt the requirements in this proposal which will require the use of a sign like the example attached to this proposal. This sign only uses terms that a non-expert on PV would use, it directs the firefighter to the location of the Rapid Shutdown Initiator (switch) if they are not next to it already, and it clearly identifies what equipment is still live after the system has been shut down. This will allow a firefighter to take the proper precautions when working with the PV system.




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1533 of 2079 10/1/2015 11:02 AM




PHOTOVOLTAIC SYSTEM EQUIPPED WITH RAPID SHUTDOWN SHUTDOWN SYSTEM AS REQUIRED BY THE 2017 NEC



The evolution of RSS system requirements between the 2014 and 2017 NEC require first responders to treat them differently or to assume all RSS systems only comply with the limited provisions of the 2014 NEC. Adding text to the marking indicating that the RSS system was designed to comply with the 2017 NEC will allow first responders to appropriately assess the operation of the system.

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1534 of 2079 10/1/2015 11:02 AM







Not all buildings have utility service, but every building that has a rapid shutdown PV system should be marked. We should not to create an inadvertent loophole where the RSD function on stand-alone homes does not need to be marked.

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1535 of 2079 10/1/2015 11:02 AM


690.60 Identified Interactive Equipment.

Only inverters and ac modules listed, labeled and identified or field labeled and identified as interactive shall be permitted ininteractive systems.










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Affilliation: UL


1536 of 2079 10/1/2015 11:02 AM


690.61 Loss of Interactive System Power.

An inverter or an ac module in an interactive A normally interactive solar PV system shall automatically de-energize its outputto the connected electrical production and distribution network upon loss of voltage in that system and shall remain in that stateuntil the be permitted to operate as a stand-alone system to supply loads that have been disconnected from electricalproduction and distribution network voltage has been restored. sources


The wrong portion of the 2014 language was deleted. Inverters will be increasingly required to provide grid supporting functions even when the grid (EPS) falters, and this functionality is better described in the listing certification instead of an installation standard. Conversely, the clarification that an inverter may be permitted to continue operation in stand-alone mode after disconnecting from the grid upon loss of interactive systems power is still useful and serves a valid purpose.

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1539 of 2079 10/1/2015 11:02 AM


690.63 Unbalanced Interconnections.

Unbalanced connections shall be in accordance with 705.100 .


Remove this section as it is covered under 705.100.

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1540 of 2079 10/1/2015 11:02 AM


690.64 Point of Connection.

Point of connection shall be in accordance with 705.12 .


This requirement is covered under 705.12 and should be removed from Article 690

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1541 of 2079 10/1/2015 11:02 AM


690.71 General.

An energy storage system connected to a PV system shall be installed in accordance with Article 706 .


Part VIII was supposed to be deleted according to the resolution logs. This section was erroneously retained. All energy storage language from Article 690 has been utilized in the new Article 706 - Energy Storage Systems. This deletion also includes all of 690.71, 690.72, and 690.74. Note there is an inconsistency in the on line TerraView FR and the NFPA published FR.

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1542 of 2079 10/1/2015 11:02 AM


690.72 Charge Control.

(A) General.

Equipment shall be provided to control the charging process of the battery. Charge control shall not be required where thedesign of the photovoltaic source circuit is matched to the voltage rating and charge current requirements of the interconnectedbattery cells and the maximum charging current multiplied by 1 hour is less than 3 percent of the rated battery capacityexpressed in ampere-hours or as recommended by the battery manufacturer.

All adjusting means for control of the charging process shall be accessible only to qualified persons.

Informational Note: Certain battery types such as valve-regulated lead acid or nickel cadmium can experience thermalfailure when overcharged.

(B) Diversion Charge Controller.

(1) Sole Means of Regulating Charging.

A photovoltaic power system employing a diversion charge controller as the sole means of regulating the charging of a batteryshall be equipped with a second independent means to prevent overcharging of the battery.

(2) Circuits with Direct-Current Diversion Charge Controller and Diversion Load.

Circuits containing a dc diversion charge controller and a dc diversion load shall comply with the following:

(1) The current rating of the diversion load shall be less than or equal to the current rating of the diversion load chargecontroller. The voltage rating of the diversion load shall be greater than the maximum battery voltage. The power rating ofthe diversion load shall be at least 150 percent of the power rating of the photovoltaic array.

(2) The conductor ampacity and the rating of the overcurrent device for this circuit shall be at least 150 percent of themaximum current rating of the diversion charge controller.

(3) PV Systems Using Utility-Interactive Inverters.

Photovoltaic power systems using utility-interactive inverters to control battery state-of-charge by diverting excess power intothe utility system shall comply with (1) and (2):

(1) These systems shall not be required to comply with 690.72(B)(2) . The charge regulation circuits used shall comply withthe requirements of 690.8 .

(2) These systems shall have a second, independent means of controlling the battery charging process for use when theutility is not present or when the primary charge controller fails or is disabled.

(C) Buck/Boost Direct-Current Converters.

When buck/boost charge controllers and other dc power converters that increase or decrease the output current or outputvoltage with respect to the input current or input voltage are installed, the requirements shall comply with 690.72(C)(1) and(C)(2).

(1) The ampacity of the conductors in output circuits shall be based on the maximum rated continuous output current of thecharge controller or converter for the selected output voltage range.

(2) The voltage rating of the output circuits shall be based on the maximum voltage output of the charge controller orconverter for the selected output voltage range.


The first draft erroneously kept this section that was deleted by the related FR.

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690.72 Charge Control.

(A) General.

Equipment shall be provided to control the charging process of the battery. Charge control shall not be required where thedesign of the photovoltaic source circuit is matched to the voltage rating and charge current requirements of the interconnectedbattery cells and the maximum charging current multiplied by 1 hour is less than 3 percent of the rated battery capacityexpressed in ampere-hours or as recommended by the battery manufacturer.

All adjusting means for control of the charging process shall be accessible only to qualified persons.

Informational Note: Certain battery types such as valve-regulated lead acid or nickel cadmium can experience thermalfailure when overcharged.


















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1546 of 2079 10/1/2015 11:02 AM

Public Comment No. 1146-NFPA 70-2015 [ Sections 690.72(B), 690.72(C) ]

Sections 690.72(B), 690.72(C)

















This comment is coordinated with the proposed new Article 706 Energy Storage Systems (FR 3662). Currently batteries are addressed in numerous places in the NEC such as Articles 480 and 690, which has been appropriate over time with the former article historically covering lead-acid batteries and the latter recently added to address the application of batteries in general, not just lead acid, to PV systems. The current state of energy storage technology, which includes batteries, and anticipated evolution of energy storage supports the need for a singular set of requirements in the NEC covering such systems. If this is not accomplished in the 2017 NEC and available to serve as a singular foundation for needed changes in the future, the provisions covering such systems will continue to reside in different places within the NEC and likely evolve to attach themselves as parts to existing criteria throughout the NEC. To foster the safe application of energy storage systems and facilitate the application and use of the NEC by technology proponents as well as those who install and inspect such systems there should be a singular article in the NEC on energy storage systems. This specific clause is replaced by 706.33.

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First Revision No. 3662-NFPA 70-2015 [New Section after 705.143]




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1547 of 2079 10/1/2015 11:02 AM


(3) PV Systems Using Utility- Interactive Inverters.

Photovoltaic power systems using utility- interactive inverters to control battery state-of-charge by diverting excess power intothe utility system shall comply with (1) and (2):

(1) These systems shall not be required to comply with 690.72(B)(2). The charge regulation circuits used shall comply withthe requirements of 690.8.



The term "utility-interactive inverter" has been replaced with "interactive inverter" as defined in section 690.2.

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Public Input No. 1083-NFPA 70-2014 [Section No. 690.72(B)(3)]




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1549 of 2079 10/1/2015 11:02 AM


690.74 Battery Interconnections.

(A) Flexible Cables.

Flexible cables, as identified in Article 400 , in sizes 2/0 AWG and larger shall be permitted within the battery enclosure frombattery terminals to a nearby junction box where they shall be connected to an approved wiring method. Flexible battery cablesshall also be permitted between batteries and cells within the battery enclosure. Such cables shall be listed for hard-service useand identified as moisture resistant.

Flexible, fine-stranded cables shall be terminated only with terminals, lugs, devices, or connectors in accordance with 110.14 .


The first draft erroneously retained the language that was eliminated in the related FR.

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Flexible cables, as identified in Article 400, in sizes 2/0 AWG and larger shall be permitted within the battery enclosure frombattery terminals to a nearby junction box where they shall be connected to an approved wiring method. Flexible battery cablesshall also be permitted between batteries and cells within the battery enclosure. Such cables shall be listed for hard-service useand identified as moisture resistant.



This comment is coordinated with the proposed new Article 706 Energy Storage Systems (FR 3662). Currently batteries are addressed in numerous places in the NEC such as Articles 480 and 690, which has been appropriate over time with the former article historically covering lead-acid batteries and the latter recently added to address the application of batteries in general, not just lead acid, to PV systems. The current state of energy storage technology, which includes batteries, and anticipated evolution of energy storage supports the need for a singular set of requirements in the NEC covering such systems. If this is not accomplished in the 2017 NEC and available to serve as a singular foundation for needed changes in the future, the provisions covering such systems will continue to reside in different places within the NEC and likely evolve to attach themselves as parts to existing criteria throughout the NEC. To foster the safe application of energy storage systems and facilitate the application and use of the NEC by technology proponents as well as those who install and inspect such systems there should be a singular article in the NEC on energy storage systems. This specific requirement is replaced by 706.32.

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1551 of 2079 10/1/2015 11:02 AM




Flexible cables, as identified in Article 400 , in sizes 2/0 AWG and larger shall be permitted within the battery enclosure frombattery terminals to a nearby junction box where they shall be connected to an approved wiring method. Flexible battery cablesshall also be permitted between batteries and cells within the battery enclosure. Such cables shall be listed for hard-service useand identified as moisture resistant.




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1552 of 2079 10/1/2015 11:02 AM



Flexible cables, as identified in Article 400, in sizes 2/0 AWG and larger shall be permitted within the battery enclosure frombattery terminals to a nearby junction box where they shall be connected to an approved wiring method. Flexible battery cablesshall also be permitted between batteries and cells within the battery enclosure. Such cables shall be listed for hard-serviceuse and identified as moisture resistant.

Flexible, fine-stranded cables shall be terminated only with terminals, lugs, devices, or connectors in accordance with 110.14.


The Correlating Committee advises that article titles and scope statements are the responsibility of the Correlating Committee. The Correlating Committee accepts the article scope. The Correlating Committee directs that further consideration be given to the comments expressed in voting on FR 7511 with regard to the Article title and text

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1553 of 2079 10/1/2015 11:02 AM

Public Comment No. 1711-NFPA 70-2015 [ Article 691 ]

Article 691 Large-Scale Photovoltaic (PV) Electric Supply Stations Power Production Facility

691.1 Scope.

This article covers the installation of large-scale PV electric supply stations power production facilities operated for the solepurpose of providing electric supply to the utility transmission or distribution system with a generating capacity of no less than5 2 ,000 kW. Electric supply stations power production facilities are locations containing the generating stations solarphotovoltaic power production facility and substations, including their associated generator, storage battery, transformer, andswitchgear areas. Facilities covered by this article have specific design and safety features unique to large-scale PV facilities.

Informational Note: 90.2(B)(5) includes information about utility-owned properties not covered under this Code. Foradditional information on electric supply stations power production facilities , see ANSI/IEEE C2-2012, National ElectricalSafety Code.

691.2 Definitions.




Equipment or materials to which has been attached a label, symbol, or other identifying mark of an field evaluation body (FEB)indicating the equipment or materials were evaluated and found to comply with requirements as described in an accompanyingfield evaluation report. [ 790, 2012]


The sum of the parallel inverter rated maximum continuous output power at 40°C in kilowatts (kW).

Generating Station Solar Photovoltaic Power Production Facility .

A plant wherein electric energy is produced by conversion from some other form of energy (e.g., chemical, nuclear, solar,wind, mechanical, or hydraulic) by means of suitable apparatus.

Utility Distribution System.

An electrical system operated by a regulated utility company operating at an ac voltage greater than 1000 volts and less than100,000 volts.

Utility Transmission System.

An electrical system operated by a regulated utility company operating at a voltage equal to or greater than 100,000 volts.

691.4 Special Requirements for Large-Scale PV Electric Supply Stations Power Production Facilities .

Large-scale PV electric supply stations power production facilities shall comply with the following:

(1) Electrical circuits and equipment for large-scale PV electric supply stations power production facilities areaccessible only to qualified personnel needed for the maintenance and operation of the PV electric supplystation power production facility .

Informational Note: Refer to NFPA 70E-2015, Standard for Electrical Safety in the Workplace , for electricalsafety requirements.

(2) Access to PV electric supply stations is power production facilitiesis restricted by fencing or other adequatemeans in accordance with 110.31 . Field applied hazard markings shall be applied in accordance with 110.21(B) .

(3) The connection between the PV electric supply station power production facility and the utility transmission ordistribution system is through medium- or high-voltage switch gear, substation, switch yard, or similar methodswhose sole purpose is to safely and effectively interconnect the two systems.

(4) The electrical loads within the supply station power production facility are only used to power auxiliaryequipment for the generation of the PV power.

(5) PV electric supply stations power production facilities shall not be installed on buildings.

691.5 Equipment Approval.

All Equipment used for interconnection with an electric utility shall be approved by the electric utility, and allelectrical equipment shall be approved for installation by one of the following:

(1) Listing and labeling

(2) Field labeling

(3) Where products complying with 691.5(1) or (2) are not available, by engineering review validating that the electricalequipment is tested to relevant standards or industry practice


1554 of 2079 10/1/2015 11:02 AM

691.6 Design Under Engineering Supervision.

Documentation of the engineered design of the electric supply station power production facility shall be providedupon request of the AHJ. An additional independent engineering report detailing compliance of the design withapplicable standards and industry practice shall be provided upon request of the AHJ. This documentation shallinclude details of conformance of the design with Article 690 , and any alternative methods to Article 690 , or otherarticles of this Code .

691.7 Installation Under Engineering Supervision.

Documentation of the electric supply station power production facility installation shall be provided upon request ofthe AHJ. An additional independent engineering report detailing compliance with applicable standards and industrypractice shall be provided upon request of the AHJ. This documentation shall include details of conformance of theinstallation with this Code , applicable standards, and industry practice. This documentation, where requested, shallbe available prior to the commercial operation of the station facility .

691.8 Direct Current Operating Voltage.

For large-scale PV electric supply stations power production facilities operating at a dc voltage above 1000 volts,calculations shall be performed under engineering supervision.

691.9 Disconnection of Photovoltaic Equipment.

Isolating devices shall be permitted to be more than 1.8 m (6 ft) from the equipment where written safety procedures andconditions of maintenance and supervision ensure that only qualified persons service the equipment.

Informational Note: For information on lockout/tagout procedures, see NFPA 70E-2015, Standard for ElectricalSafety in the Workplace .

Buildings whose sole purpose is to house and protect supply station power production facility equipment shall not berequired to comply with 690.12 . Written standard operating procedures shall be available at the site detailingnecessary shutdown procedures in the event of an emergency.

691.10 Arc-Fault Mitigation.

PV systems that do not comply with the requirements of 690.11 shall be designed under engineering supervision thatincludes fire mitigation plans to address dc arc-faults.

691.11 Fence Grounding.

Fence grounding requirements and details shall be provided under engineering supervision.


1.) There are several terms used in the article taken from the National Electrical Safety Code (NESC) which provides requirements for generationg, transmission, distribution and metering assets of electric utilities. One such term is "Supply Station" and for this article is best replaced with "Power Production Facility" to be consistent with terminology found in the National Electrical Code (NEC) associated with premises wiring in Article 705.2.) It is common for 2000kW large Solar PV systems to be interconnected to primary voltage utility systems.3.) "Solar Photovoltaic Power Production Facility" is more appropriately defined and used in this article for premises wiring systems than "Generating Station" which is a utility term.4.) The definition and use of "Utility Distribution System" and "Utility Transmission System" is not necessary for premises wiring as these systems are specific to utilities. It would be more appropriate to make references to Article 225- Outside Branch Circuits and Feeders and Article 230- Services from the NEC. 5.) Equipment used for interconnection with an electric utility shall also be approved by the electric utility.

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Submitter Full Name: Roger McDaniel

Organization: Georgia Power Company

Affilliation: Edison Electric Institute

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1555 of 2079 10/1/2015 11:02 AM


691.1 Scope.

This article covers the installation of large-scale PV electric supply stations operated for the sole purpose of providing electricsupply to the utility transmission or distribution system with a generating capacity of no less than 5,000 kW. Electric supplystations are locations containing the generating stations and substations, including their associated generator, storage battery,transformer, and switchgear areas. Facilities covered by this article have specific design and safety features unique tolarge-scale PV facilities.

Informational Note: 90.2(B)(5) includes information about utility-owned properties not covered under this Code. Foradditional information on electric supply stations, see ANSI/ IEEE C2-2012, National Electrical Safety Code.


Referenced correct SDO in the informational note.

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Submittal Date: Wed Jul 01 23:44:55 EDT 2015


1556 of 2079 10/1/2015 11:02 AM


691.1 Scope.

This article covers the installation of large-scale PV electric supply stations operated for the sole purpose of providing electricsupply to the utility transmission or distribution system with a generating capacity of no less than 5,000 kW. Electric supplystations are locations containing the generating stations and substations, including their associated generator, storage battery,transformer, and switchgear areas. Facilities covered by this article have specific design and safety features unique tolarge-scale PV facilities. This statement should be removed, unless the design and safety features are specifically definedwhich there not and if they were would be extremely limiting as all site locations are unique in nature regarding location andqualified personnel cannot be measured in a document but requires actual hands on training.

Informational Note: 90.2(B)(5) includes information about utility-owned properties not covered under this Code . For additionalinformation on electric supply stations, see ANSI/IEEE C2-2012, National Electrical Safety Code . This IN should be removed as

all these systems are privately owned property and exchange hands, sold, to different par es


Facilities covered by this article have specific design and safety features unique to large-scale PV facilities. This statement should be removed, unless the design and safety features are specifically defined which there not and if they were would be extremely limiting as all site locations are unique in nature regarding location and qualified personnel cannot be measured in a document but requires actual hands on training. Informational Note: 90.2(B)(5) includes information about utility-owned properties not covered under this Code. For additional information on electric supply stations, see ANSI/IEEE C2-2012, National Electrical Safety Code. This IN should be removed as all these systems are privately owned property and exchange hands, sold, to different parties.

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1560 of 2079 10/1/2015 11:02 AM


691.1 Scope.

This article covers the installation of large-scale PV electric supply stations operated for by independent power producers forthe sole purpose of providing electric supply to the utility transmission or distribution system with a generating capacity of noless than 5 1 ,000 kW. Electric supply stations are locations containing the generating stations and substations, including theirassociated generator, storage battery, transformer, and switchgear areas. Facilities covered by this article have specific designand safety features unique to large-scale PV facilities.

Informational Note: 90.2(B)(5) includes information about utility-owned properties not covered under this Code. Foradditional information on electric supply stations, see ANSI/IEEE C2-2012, National Electrical Safety Code.


Clarify that unless the owner is a regulated public utility they are not exempt from the requirements of this articleReduction of the 5000 KWh to 1000 KWh to allow for smaller ground mounted systems to make use of the reduced requirements of this article

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1557 of 2079 10/1/2015 11:02 AM


691.1 Scope.

This article covers the installation of large-scale PV electric supply stations operated for the sole purpose of providing electricsupply to the utility transmission or distribution system with a generating capacity of no less than 5,000 1000 kW. Electricsupply stations are locations containing the generating stations and substations, including their associated generator, storagebattery, transformer, and switchgear areas. Facilities covered by this article have specific design and safety features unique tolarge-scale PV facilities.



The First Draft sets the entry level for the new Article 691 at 5000 kW, which is a very large system. Furthermore, the attributes of a PV plant that really matter for application of Art. 691 are interconnection at MV or HV, restricted access, and being ground mounted, not simply power. We feel that smaller systems that satisfy these other attributes should be allowed to use the approaches in Art. 691, and frequently already do (design and installation under engineering supervision for example).

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1558 of 2079 10/1/2015 11:02 AM


691.1 Scope.

This article covers the installation of large-scale PV electric supply stations operated for the sole purpose of providing electricsupply to the utility transmission or distribution system at a voltage greater than 1000V with a generating capacity of no lessthan 5,000 kW. Electric supply stations are locations containing the generating stations and substations, including theirassociated generator, storage battery, transformer, and switchgear areas. Facilities covered by this article have specific designand safety features unique to large-scale PV facilities.



The reference to transmission and distribution levels is vague in the definitions and really says that the interconnection to the utility is to be at 1000V or greater. Text is updated to state this and remove the reference to transmission and distribution. See comment on the definitions for Utility Transmission System and Utility Distribution System.



Public Comment No. 620-NFPA 70-2015 [Definition: Engineering Supervision.]

Public Comment No. 621-NFPA 70-2015 [Definition: Generating Capacity.]

Public Comment No. 622-NFPA 70-2015 [Definitions (691.2): Utility Dis... to Utility Tra...]


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1559 of 2079 10/1/2015 11:02 AM


691.1 Scope.

This article covers the installation of large-scale PV electric supply stations operated for by independent power producers forthe sole purpose of providing electric supply to the utility transmission or distribution system with a generating capacity of noless than 5 1 ,000 kW. Electric supply stations are locations containing the generating stations and substations, including theirassociated generator, storage battery, transformer, and switchgear areas. Facilities covered by this article have specific designand safety features unique to large-scale PV facilities.



Clarify that unless the owner is a regulated public utility they are not exempt from the requirements of this articleReduction of the 5000 KWh to 1000 KWh to allow for smaller ground mounted systems to make use of the reduced requirements of this article

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1557 of 2079 10/1/2015 11:02 AM


691.1 Scope.

This article covers the installation of large-scale PV electric supply stations operated for the sole purpose of providing electricsupply to the utility transmission or distribution system with a generating capacity of no less than 5,000 1000 kW. Electricsupply stations are locations containing the generating stations and substations, including their associated generator, storagebattery, transformer, and switchgear areas. Facilities covered by this article have specific design and safety features unique tolarge-scale PV facilities.



The First Draft sets the entry level for the new Article 691 at 5000 kW, which is a very large system. Furthermore, the attributes of a PV plant that really matter for application of Art. 691 are interconnection at MV or HV, restricted access, and being ground mounted, not simply power. We feel that smaller systems that satisfy these other attributes should be allowed to use the approaches in Art. 691, and frequently already do (design and installation under engineering supervision for example).

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This definition should be removed; as stated in Article 90.1 Purpose "This code is not intended as a design specification or an instruction manual for untrained persons." The code doesn't define designed, certified and competent engineer, one could argue that a civil engineer is competent in the specific area of fault current studies or relay settings for a substation. Additionally, The term approved is already defined in Article 100

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Designed and approved by a licensed professional engineer competent in the specific area under supervision.


This definition should be removed; as stated in Article 90.1 Purpose "This code is not intended as a design specification or an instruction manual for untrained persons." The code doesn't define designed and competent engineer, one could argue that a civil engineer is competent in the specific area of fault current studies or relay settings for a substation.

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1358 of 2079 10/1/2015 11:02 AM


Engineering Supervision. Designed and approved

Supervised by a licensed professional engineer competent in the specific area under supervision.


The correlating committee is concerned about the use of the term Engineering Supervision. The edits in this comment remove the problematic language about engineers approving anything.

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1354 of 2079 10/1/2015 11:02 AM



Designed and approved (or certified) sealed by a licensed professional engineer competent in the specific area undersupervision.


A licensed engineer seals documents that they have produced, or were produced under their supervision, with their state P.E. seal and signature. This is the only legal way of indicating approval or certification by a licensed engineer.




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1563 of 2079 10/1/2015 11:02 AM

Public Comment No. 621-NFPA 70-2015 [ Definition: Generating Capacity. ]


The sum of the parallel inverter rated maximum continuous output power at 40°C in kilowatts (kW).


The term Generating Capacity is not reference in the article and therefore does not require a definition.




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1568 of 2079 10/1/2015 11:02 AM

Public Comment No. 628-NFPA 70-2015 [ Definition: Generating Station. ]

Generating Station.

A plant wherein electric energy is produced by conversion from some other form of energy (e.g., chemical, nuclear, solar, wind,mechanical, or hydraulic) by means of suitable apparatus.


Generating Station is not referenced in the article and therefore does not nee dot be defined.

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1569 of 2079 10/1/2015 11:02 AM

Public Comment No. 716-NFPA 70-2015 [ Definition: Utility Distribution System. ]




This section should be removed. Article 90.2 Scope (B)(5) identifies installations not covered by the NEC to include installation under the exclusive control of an electric utility.

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Organization: LA County


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1570 of 2079 10/1/2015 11:02 AM

Public Comment No. 622-NFPA 70-2015 [ Definitions (691.2): Utility Dis... to Utility Tra... ]

Definitions (691.2): Utility Dis... to Utility Tra...






Unfortunately there is no standard in the industry that supports these voltage levels to identify distribution verses transmission systems. I have seen the break between distribution and transmission set at a number of voltages between 30kV and 120kV. Distribution covers everything down to the 240/120V conductors on the pole outside a residence.

The definition is also not needed since all PV systems interconnected to a utility interconnect at some point in the utility transmission or distribution system. Perhaps a better way of defining the interconnection would be to interconnect at voltages greater than 1000V?






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1572 of 2079 10/1/2015 11:02 AM

Public Comment No. 717-NFPA 70-2015 [ Definition: Utility Transmission System. ]




This section should be removed. Article 90.2 Scope (B)(5) identifies installations not covered by the NEC to include installation under the exclusive control of an electric utility.

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1571 of 2079 10/1/2015 11:02 AM


691.4 Special Requirements for Large-Scale PV Electric Supply Stations.

Large-scale PV electric supply stations shall comply with the following:

(1) Electrical circuits and equipment for large-scale PV electric supply stations are accessible only to qualified personnelneeded for the maintenance and operation of the PV electric supply station.

Informational Note: Refer to NFPA 70E-2015, Standard for Electrical Safety in the Workplace, for electrical safetyrequirements.

(2) Access to PV electric supply stations is restricted by fencing or other adequate means in accordance with 110.31. Fieldapplied hazard markings shall be applied in accordance with 110.21(B).

(3) The connection between the PV electric supply station and the utility transmission or distribution system is throughmedium- or high-voltage switch gear, substation, switch yard, or similar methods whose sole purpose is to safely andeffectively interconnect the two systems.

(4) The electrical loads within the supply station are only used to power auxiliary equipment for the generation of the PVpower.

(5) PV electric supply stations shall not be installed on buildings.


The reference to transmission and distribution removed from text. See comment on the definitions for Utility Transmission System and Utility Distribution System an comment on Scope.






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1573 of 2079 10/1/2015 11:02 AM




(1) Electrical circuits and equipment for large-scale PV electric supply stations are accessible only to qualified personnelneeded for the maintenance and operation of the PV electric supply station .


(2) Access to PV electric supply stations is restricted by fencing or other adequate means in accordance with 110.31. Fieldapplied hazard markings shall be applied in accordance with 110.21(B).



(5) PV electric supply stations shall not be installed on buildings.


I don't see any safety advantage to limiting access to something greater than qualified personnel only.

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1574 of 2079 10/1/2015 11:02 AM




(1) Electrical circuits and equipment for large-scale PV electric supply stations are accessible only to qualified personnelneeded for the maintenance and operation of the PV electric supply station.


(2) Access to PV electric supply stations is restricted by fencing or other adequate means in accordance with 110.31. Fieldapplied hazard markings shall be applied in accordance with 110.21(B). Add language to increase the height of the fencesurrounding a substa on on privately owned land to 8 . to be in line (consistent) with OSHA requirements



(5) PV electric supply stations shall not be installed on buildings. I’m not sure why were referencing this as other por ons of the

code would limit the installa on; however if a company like BOEING wanted to install several 1MW arrays on let’s say 6 buildings why

would we limit this installa on (6MW)?


OSHA 1926.403(J)(1) & (2) says for equipment operating at over 600V "a wall screen or fence less than 8 feet in height is not considered adequate to prevent access."

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1575 of 2079 10/1/2015 11:02 AM



All electrical equipment shall be approved for installation by one of the following:

(1) Listing and labeling

(2) Field labeling

(3) Where products complying with 691.5(1) or (2) are not available, by engineering review validating that the electricalequipment is tested to relevant standards or industry practice . This section should be removed. The ability to have properly

listed equipment is available even for all the 230kV components and below through the use of IEEE Standards. STP’s need to be

developed.


Field evaluations and engineering review are not defined in Article 100 NFPA 70. Part 2 and 3 should be removed.

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1576 of 2079 10/1/2015 11:02 AM


692.6 Listing Requirement.

The fuel cell system shall be listed and labeled or field labeled for its intended application.










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Affilliation: UL

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1590 of 2079 10/1/2015 11:02 AM



Documentation of the engineered design of the electric supply station shall be provided upon request of the AHJ. An additionalindependent engineering report detailing compliance of the design with applicable standards and industry practice shall beprovided upon request of the AHJ. The independent engineer shall be a licensed professional engineer competent in thespecific area under review and selected in mutual agreement between the AHJ and engineer of record. This documentationshall include details of conformance of the design with Article 690, and any alternative methods to Article 690, or other articlesof this Code.


This proposed change helps to ensure that the independent engineer has experience with large scale PV and that both parties are fairly represented. We would like to avoid scenarios in which the AHJ has complete control over the selection of the independent engineer as this would not seem to meet the intent of the independent engineering report referenced within 691.6.

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1577 of 2079 10/1/2015 11:02 AM



Documentation of the engineered design of the electric supply station shall be provided upon request of the AHJ. An additionalindependent engineering report detailing compliance of the design with applicable standards and industry practice shall beprovided upon request of the AHJ. This documentation shall include details of conformance of the design with Article 690, andany alternative methods to Article 690, or other articles of this Code . " Any alterna ves” should be removed from this ar cle as this

is already defined in Ar cle 90.2 (C)


"Any alternatives” should be removed from this article as this is already defined in Article 90.2(C)

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1578 of 2079 10/1/2015 11:02 AM



Documentation of the electric supply station installation shall be provided upon request of the AHJ. An additional independentengineering report detailing compliance with applicable standards and industry practice shall be provided upon request of theAHJ. The independent engineer shall be a licensed professional engineer competent in the specific area under review andselected in mutual agreement between the AHJ and engineer of record. This documentation shall include details ofconformance of the installation with this Code, applicable standards, and industry practice. This documentation, whererequested, shall be available prior to the commercial operation of the station.


This proposed change helps to ensure that the independent engineer has experience with large scale PV and that both parties are fairly represented. We would like to avoid scenarios in which the AHJ has complete control over the selection of the independent engineer as this would not seem to meet the intent of the independent engineering report referenced within 691.7.

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1579 of 2079 10/1/2015 11:02 AM



Documentation of the electric supply station installation shall be provided upon request of the AHJ. An additional independentengineering report detailing compliance with applicable standards and industry practice shall be provided upon request of theAHJ. This documentation shall include details of conformance of the installation with this Code , applicable standards, andindustry practice. This documentation, where requested, shall be available prior to the commercial operation of the station.


This requirement for engineering supervision of installation will create a need for a service that a reasonable engineering company or engineer will not want to provide.

Engineers traditionally do not supervise construction projects or contractors and nowhere else in the NEC is it called out that an engineer will supervise a construction project. Engineers do provide construction observation which is performing site visits at appropriate intervals to inspect the work for general conformance with the design, but that is not an inspection or supervision.

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1580 of 2079 10/1/2015 11:02 AM



Documentation of the electric supply station installation shall be provided upon request of the AHJ. An additional independentengineering report detailing compliance with applicable standards and industry practice shall be provided upon request of theAHJ. This documentation shall include details of conformance of the installation with this Code , applicable standards, andindustry practice. This documentation, where requested, shall be available prior to the commercial operation of the station. Thisshould be removed (en re sec on) as all systems should be subject to plan check approval. This document would be more in line with

something for the owner as part of the condi ons of acceptability


This should be removed as all systems should be subject to plan check approval. This document would be more in line with something for the owner as part of the conditions of acceptability but not an NFPA 70 requirement.

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1581 of 2079 10/1/2015 11:02 AM



For large-scale PV electric supply stations operating at a dc voltage above 1000 volts, calculations shall be performed underengineering supervision. PV system dc conductors and equipment with a maximum voltage of 1500V or less do not need tocomply with Article 490.


In PI#3181 it was proposed to raise the voltage limit in the scope of Art. 490 from 1000V to 2000V. The substantiation for PI#3181 pointed out that product standards for HV equipment begin at 2000V and that recent changes to product standards for low voltage equipment have raised requirements suitable for higher voltages up to 1500V or 2000V in some cases. In particular, for the PV industry there has been a lot of work done to revise product standards for switches, circuit breakers, fuses, modules, power conversion, etc. to cover PV system voltages up to at least 1500V. Such systems should not have to use the approaches in Art. 490, which are intended to address medium voltage installations at 2.4kV and higher using HV equipment. The burden such requirements place on PV systems are not justified at system voltages of 1500V or less using appropriately rated and approved equipment. PI#3181 was resolved, but in their Resolution statement the CMP wrote "Increasling the upper limit may be practical in microenvironments such as those covered in Articles 690 or 694...:" which indicates that it would be appropriate to narrow the scope of PI#3181 to just PV, and move it to Art. 690 and 691, which we are now doing with this Public Comment and a related one for a revision to 690.7.Note that we would like to get both revisions accepted: this one to 691.8 and the related one for 690.7. However if the CMP feels that they cannot accept this 691.8 proposal, please consider the 690.7 proposal separately and on its own merit.



Public Comment No. 1074-NFPA 70-2015 [Section No. 690.7 [Excluding any Sub-Sections]]

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1582 of 2079 10/1/2015 11:02 AM



For large-scale PV electric supply stations operating at a dc voltage above 1000 volts, calculations shall be performed underengineering supervision.


We support this language in principle but propose to strike/delete it because we do not believe it adds substance and may actually cause confusion for the following reasons:

1) 691.6 already allows design of large scale PV systems to be performed under engineering supervision and requires documentation to be provided to the AHJ to demonstrate compliance with Article 690 or any alternative methods to Article 690. Calling out a small subset of a large scale PV system design (i.e. max dc operating voltage calculation) and requiring that to be calculated under engineering supervision appears to be redundant.

2) Stating that DC system voltages >1kV shall be calculated under engineering supervision creates a distinction between systems <=1kV and systems >1kV and implies these two scenarios might be treated differently. We believe the intent of Article 691 is to allow maximum DC operating voltages (less than or greater than 1kV) for large scale PV systems to be calculated under engineering supervision. Therefore the distinction between <=1kV and >1kV systems should be removed.

3) 690.7 allows DC operating voltages to exceed 1kV under certain conditions, yet does not require calculation under engineering supervision for those systems that exceed 1kV.

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1583 of 2079 10/1/2015 11:02 AM



For large-scale PV electric supply stations operating at a dc voltage above 1000 volts, calculations shall be performed underengineering supervision. This should be removed as the calcula ons for all aspects of the system are no different from any electrical

system to include the medium voltage (just larger numbers)


This should be removed as the calculations for all aspects of the system are no different from any electrical system to include the medium voltage (just larger numbers). Seems obvious that an engineer would be involved with the design lets keep the book (NEC) to one volume and save a tree.

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1584 of 2079 10/1/2015 11:02 AM


691.9 Disconnection of Photovoltaic Equipment.

Isolating devices shall be permitted to be more than 1.8 m (6 ft) from the equipment where written safety procedures andconditions of maintenance and supervision ensure that only qualified persons service the equipment.

Informational Note: For information on lockout/tagout procedures, see NFPA 70E-2015, Standard for Electrical Safety in theWorkplace .

Buildings whose sole purpose is to house and protect supply station equipment shall not be required to comply with 690.12 .Written standard operating procedures shall be available at the site detailing necessary shutdown procedures in the event of anemergency.

Written safety procedures should be replaced with a sign/plaque/directory; personal experience, no one reads the writtenprocedures. With that said again this is more in line with a document used by O & M and presented to the owner. (Are isolatingdevices defined in the NEC? Are they to be listed? If so, to what standard?)


Written safety procedures should be replaced with a sign/plaque/directory; personal experience, no one reads the written procedures. With that said again this is more in line with a document used by O & M and presented to the owner. (Are isolating devices defined in the NEC? Are they to be listed? If so, to what standard?) It seems were adding language with no direction and/or definition of the components were referring to. Suggest this section be removed, very vague as to component requirements and safe operating procedures for the disconnecting means and its design and certification requirements.

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1585 of 2079 10/1/2015 11:02 AM


691.10 Arc-Fault Mitigation.

PV systems that do not comply with the requirements of 690.11 shall be designed under engineering supervision that includesfire mitigation plans to address dc arc-faults.

Remove in its en rety as most large solar installa ons have an O & M Building which may or may not have PV on the roof and would be

required to meet this requirement; these buildings are occupied structures covered under the Building Code and contain sleeping quarters.


Remove in its entirety as most large solar installations have an O & M Building which may or may not have PV on the roof and would be required to meet this requirement; these buildings are occupied structures covered under the Building Code and contain sleeping quarters.

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1586 of 2079 10/1/2015 11:02 AM





We support this language in principle but propose to strike/delete it because we do not believe it adds substance and may actually cause confusion for the following reasons:

1) 691.6 already allows design of large scale PV systems to be performed under engineering supervision and requires documentation to be provided to the AHJ to demonstrate compliance with Article 690 or any alternative methods to Article 690. Calling out a small subset of a large scale PV system design (i.e. fence grounding) and requiring the details to be provided under engineering supervision appears to be redundant.

2) Stating that fence grounding details must be provided under engineering supervision creates a distinction between fence grounding and other system grounding and implies these two aspects of large scale PV system grounding might be treated differently. We believe the intent of Article 691 is to allow large scale PV system grounding to be designed under engineering supervision. Therefore the distinction between fence grounding and all other large scale PV system grounding should be removed.

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1587 of 2079 10/1/2015 11:02 AM




Limit fence grounding to only areas where conductors travel over or under a fence and use approved isolators to limit migra on of fault

current in the construc on of the build of the fence


Limit fence grounding to only areas where conductors travel over or under a fence and use approved isolators to limit migration of fault current in the construction of the build of the fence.The danger is where the feeder conductors operating at over 600v to ground travel over or under fenced in areas. These areas should also be designed with isolators within a specified distance of the conductors. lets not require the entire fence to be grounded which could be several square miles of fencing.

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1588 of 2079 10/1/2015 11:02 AM


692.1 Scope.

This article applies to fuel cell systems. These systems may be interactive with other electrical power production sources orstand-alone or both, and may or may not be connected to electric energy storage systems such as batteries. These systemsmay have ac and or dc output(s) for utilization.


The Correlating Committee directs that the last sentence of 692.1 be rewritten to comply with the NEC Style Manual that discourages the use of “and/or.”

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1589 of 2079 10/1/2015 11:02 AM

Public Comment No. 1708-NFPA 70-2015 [ New Part after I. ]

694 - Wind Turbines Systems - Working Clearances

Working space shall be provided for electrical cabinets and other electrical equipment in accordance with 110.26(A).

For large wind turbines permitting entry of service personell, where space constraints exist and there is a necessity forperforming daignostic work on energized equipment (for example in the Nacelle), working clearances shall comply with followingtable up to 1,000:

Working Spaces

Nominal voltage to ground Condition 1 Condition 2 Condition 3

0-150 900 mm (3 ft) 900 mm(3 ft) 900 mm (3 ft)

151-1,000 900 (3 ft) 1.0 m (3 ft 6 in) 1.2 m (4 ft)

Note: Conditions are defined in accordance with section 110.26, extending the values from 600V to 1,000V

Conditions of maintenance and supervision shall ensure that only qualified persons examine, adjust, service, and maintain theequipment.


Working spaces in large wind turbines in the nacelle and hub where space is limited, and considering UL 6141 with consideration to extended voltage range to 1000V

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Public Input No. 1-NFPA 70-2013 [Section No. 310.15(B)(3)]


Submitter Full Name: Amir Zohar

Organization: Suzlon Wind Energy Corporation

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2054 of 2079 10/1/2015 11:02 AM


694.1 Scope.

This article applies to wind (turbine) electric systems that consist of one or more wind electric generatorsand generators andtheir related alternators, inverters, controllers, and associated equipment.

Informational Note: Some wind electric systems are interactive with other electric power sources and some arestandalone systems. Some systems have ac output and some have dc output. Some systems contain electrical energystorage, such as batteries.

Figure 694.1(a) Identification of Wind Electric System Components — Interactive System.

Figure 694.1(b) Identification of Wind Electric System Components — Stand-Alone System.


The general term "generator" encompasses both the DC generator and the AC alternator. Either of these can be used in a wind system. The way the text is written it limits wind generators to AC alternators.

Figure 694.1(a) uses "Outlet" for the output of the inverter and they could be misinterpreted to mean that an electrical outlet is used. Art. 690 uses "Electric Power Production and Distribution Network" for this call out. The figure is too specific by showing only an alternator based system and there are other types of systems.

Figure 694.1(b) is to specific, it shows an AC coupled alternator based system and there are DC generator based systems and AC coupled systems.

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1592 of 2079 10/1/2015 11:02 AM


694.1 Scope.

This article applies to wind (turbine) electric systems that consist of one or more wind electric generatorsand their relatedalternators, inverters, controllers, and associated equipment.





The Correlating Committee advises that article scope statements are the responsibility of the Correlating Committee and the Correlating Committee accepts the panel action. The Correlating Committee directs that further consideration be given to the comment expressed in voting on FR 943 in regards to Figure 694.1(A).

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1593 of 2079 10/1/2015 11:02 AM


694.1 Scope.

This article applies to wind (turbine) electric systems that consist of one or more wind electric generatorsand their relatedalternators, inverters, controllers, and associated equipment.



[Replace Figure 694.1(a) with similar but change word "outlet" to "Electric production and distribution network".]




fig_1a.jpg Revised Figure 694.1(a)


Figure shows output of interactive inverter feeding an outlet. This is incorrect. An interactive inverter feeds the utility grid, aka Electric Power Production and Distribution Network.

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1594 of 2079 10/1/2015 11:02 AM

Public Comment No. 808-NFPA 70-2015 [ Definition: Guy. ]

Guy (as related to wind electrical systems) .

A cable that mechanically supports a wind turbine tower.


All NFPA definitions are incorporated without change or comment into the NFPA Glossary of terms which simply indicates the code or standard where the definition originates. The definition of guy in the NEC can refer to multiple occupations or products and is not unique to article 694. If the panel wants to identify it in a different way, that would still comply with the concept that "guy" is too generic a term to stay as a definition that applies solely to a wind turbine cable. I can imagine multiple other concepts to which the term "guy" applies.

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Public Input No. 2467-NFPA 70-2014 [Definition: Guy.]


Submitter Full Name: Marcelo Hirschler

Organization: GBH International

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1595 of 2079 10/1/2015 11:02 AM

Public Comment No. 809-NFPA 70-2015 [ Definition: Tower. ]

Tower (as applied to wind electric systems) .

A pole or other structure that supports a wind turbine.


All NFPA definitions are incorporated without change or comment into the NFPA Glossary of terms which simply indicates the code or standard where the definition originates. The definition of tower in the NEC can refer to multiple structures and is not unique to article 694. If the panel wants to identify it in a different way, that would still comply with the concept that "tower" is too generic a term to stay as a definition that applies solely to a structure that supports a wind turbine.

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Public Input No. 2468-NFPA 70-2014 [Definition: Tower.]


Submitter Full Name: Marcelo Hirschler

Organization: GBH International

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1596 of 2079 10/1/2015 11:02 AM


(B) Equipment.

Wind electric systems shall be listed and or field labeled for the application. Wind electric systems under development or undergoing evalua on and tes ng for type cer fica on and/or lis ng shall be permi ed to be operated under condi ons of engineering

supervision in a controlled loca on with access limited to qualified personnel.


Field labeling is a common activity for large wind turbines, as they are often build as a batch using common components, but with some variation from batch to batch. It is impractical to type test or fully fix the design of large-scale wind turbines (this applies to listing of the overall assembly. In general, components are certified for the application). Field-labeling is sometimes also used for intermediate and small wind turbines, but they are more generally type-tested and listed. Questions regarding appropriate wording for listing and labeling were raised across the board for all articles in this code cycle. Wind turbines are a special case where either listing OR field labeling is appropriate.

The additional sentence regarding turbines under development is also important as a wind turbine cannot be listed or certified without several months of operating at a wide range of wind speeds. This certification testing is performed under engineering supervision in an access-limited environment (for example at the National Wind Test Center in Boulder, CO).Provision for such testing is necessary as the turbines still need to feed the power grid during this time, and so are subject to inspection and the NEC. Utility Interactive inverters are still required to be NRTL listed to applicable ANSI standards and interconnection must comply with Article 705.

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1597 of 2079 10/1/2015 11:02 AM


(F) Poles or Towers Supporting Wind Turbines Used as a Raceway.

A pole or tower shall be permitted to be used as a raceway if evaluated as part of the listing for the wind turbine or otherwiseshall be listed and labeled or field labeled for the purpose.










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Public Input No. 947-NFPA 70-2014 [Section No. 694.7(F)]





Affilliation: UL


1598 of 2079 10/1/2015 11:02 AM


See Correlating Note below


The Correlating Committee directs the panel to reconsider and correlate the deletion of 694.18, as Code-Making Panel 13 did not approve the proposed new Article 710 (Microgrids and Stand-AloneSystems).

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1600 of 2079 10/1/2015 11:02 AM


(C) Direct-Current Rating.

Overcurrent devices, either fuses or circuit breakers, used in any dc portion of a wind electric system shall be listed andlableled for use in dc circuits and shall have appropriate voltage, current, and interrupting ratings.










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Affilliation: UL


1601 of 2079 10/1/2015 11:02 AM

Public Comment No. 1521-NFPA 70-2015 [ Part IV. ]

Part IV. Microgrid ( Intentionally Islanded and Stand-Alone ) Systems


This heading should be modified as:1/ part of this section should move to Art 710 [proposed] Standalone Systems, as recommended by TCC, and thus "Standalone" is removed from heading/Standalone systems DOES NOT belong in Interconnected Systems ! They are fundamental opposites.Creation of Article 710 standalone systems [new] should be referred to a task group prior to the SD meeting.

2/ The common and now widely used term for intentional island systems is now "microgrids". The former term (used in IEEE1547.4 is now superseded. See for example IEEE P2030.7 and 2030.8.

3/ intentional island systems should be changed to microgrid (intentional island) systems throughout this section (i.e. all sub-paragraphs below this heading.A task group should be assigned to this part of Article 705.

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2063 of 2079 10/1/2015 11:02 AM


705.1 Scope.

This article covers installation of one or more electric power production sources operating either in parallel with a primarysource(s) of electricity, as intentionally islanded, as stand-alone, or in any combination thereof .

Informational Note: Examples of the types of primary sources include a utility supply or an on-site electric powersource(s).


A gap exists in the current code for both stand-alone and intentionally islanded systems, both of which typically involve the interconnection of multiple power sources but which were not directly addressed under 705. By revising the scope of 705 to clarify it applies to systems operating in parallel, as stand-alone, intentionally islanded or any combination, this article can clearly address these systems. Additional requirements for stand-alone and intentionally islanded systems are currently under consideration through other actions in this code cycle, this proposal is intended to coordinate with them.

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1655 of 2079 10/1/2015 11:02 AM


705.1 Scope.

This article covers installation of one or more electric power production sources operating in parallel with a primary source(s) ofelectricity or operating as an intentionally islanded system or operating as a stand-alone system .

Informational Note: Examples of the types of primary sources include a utility supply or an on-site electric powersource(s).


Revision to the Scope as recommended by Mr. Roger McDaniel in his affirmative comment on FR 1045.

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1656 of 2079 10/1/2015 11:02 AM

Public Comment No. 1638-NFPA 70-2015 [ Definition: Intentionally Islanded System. ]

Intentionally Islanded System.

A

premises wiring

system that has generation and/or energy storage and load (s) ,

has

that includes the ability to

disconnect from and

be operated in parallel with , or intentionally disconnected from the primary source

, and is intentionally planned

.

Informational Note: An electrical system that separates from the primary source and can operate individually orinterconnected is sometimes referred to as a microgrid.


The grammar in the definition is incorrect and confusing.

Suggest changing it to read: "A system that has generation and/or energy storage and load(s), that includes the ability to be operated in parallel with, or intentionally disconnected from the primary source."

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First Revision No. 1046-NFPA 70-2015 [New Definition after Definition: Multimode Inverter.]




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1658 of 2079 10/1/2015 11:02 AM



A premises wiring system that has generation and/or energy storage and load, has the ability to disconnect from and parallelwith the primary source, and is intentionally planned.



The Correlating Committee directs that further consideration be given to the comment expressed in voting on FR 1046. The Correlating Committee directs that “and/or” be replaced to comply with the NEC Style Manual.

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1659 of 2079 10/1/2015 11:02 AM

Public Comment No. 1457-NFPA 70-2015 [ Definition: Island Interconnection Device (IID). ]

Island Interconnection Device (IID).

A device that allows an intentionally islanded system to separate from and reconnect to a primary power source.


The interconnection function is already addressed in existing requirements and standards, and should not be duplicated in this manner. UL standards for interactive product address the specific considerations that must be addressed for this application and listed Interactive inverters which manage the interconnection to the area EPS are available from numerous manufacturers, yet these devices are not marked as being "Island Interconnection Devices" and so would not appear to comply with this requirement. In addition, there is no functional requirement for an intentionally islanded system to perform a seamless transfer, other than customer convenience; a listed manual double throw safety switch would provide the same level of safety, albeit at a lower level of convenience, but is not marked as an Island Interconnection Device. Overcurrent protection, disconnecting means, synchronizing means and the protection from multiple sources are addressed elsewhere in this article, so there is no benefit from adding this new requirement, only added complexity and potential confusion to AHJs and installers.




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1660 of 2079 10/1/2015 11:02 AM

Public Comment No. 1484-NFPA 70-2015 [ Definition: Island Interconnection Device (IID). ]

Island Interconnection Microgrid Interconnect Device (IID).

A device that allows an a microgrid ( intentionally islanded) system to separate from and reconnect to a primary power source.


The term "intentionally islanded system" has been superseded in common usage and IEEE and IEC standards with the word "microgrid".IEEE in its new standard 2030.7 (Microgrid Controllers) has adopted the term Microgrid Interconnect Device, rather than Island Interconnect Device, as the former is self explanatory, while the latter is ambiguous. By 2017, the term "intentional island" will probably have disappeared entirely, as its source (IEEE 1547.4) is likely to be superseded.

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1661 of 2079 10/1/2015 11:02 AM

Public Comment No. 919-NFPA 70-2015 [ Definition: Multimode Inverter. ]

Multimode Inverter.

Equipment having the capabilities of both the utility- interactive inverter and the stand-alone inverter.


The term "utility-interactive inverter" has been replaced with "interactive inverter."

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1662 of 2079 10/1/2015 11:02 AM



A premises wiring system that has generation and/or energy storage and load, and has the ability to disconnect from andoperate either in parallel with or intentionally disconnected from the primary source, and is intentionally planned .



The grammar in the original proposal was unclear

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1657 of 2079 10/1/2015 11:02 AM

Public Comment No. 1506-NFPA 70-2015 [ Definition: Stand-Alone System. ]

Stand-Alone System.

A system that supplies power independently independent of an electrical production and distribution network.


Correct grammar (no -ly). Also this definition should move to Art 710 [proposed] Standalone Systems, as recommended by TCC.Standalone systems DOES NOT belong in Interconnected Systems ! they are fundamental opposites.Creation of Article 710 standalone systems [new] should be referred to a task group prior to the SD meeting.

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1663 of 2079 10/1/2015 11:02 AM



Interconnected electric power production sources shall comply with this article and also with the applicable requirements of thearticles in Table 705.3.


Equipment/System Article

Generators 445


Fuel cell systems 692

Wind electric systems 694

Emergency systems 700

Legally required standby systems 701

Optional standby systems 702

Energy storage systems

Standalone Systems

706

710


Add 710 Standalone Systems, if it is created as stand-alone systems, if multi-mode and capable of interconnection, must also comply with 705.

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Affilliation: NEC DC Task Force / Microgrid WG

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1664 of 2079 10/1/2015 11:02 AM



Interconnected electric power production sources shall comply with this article and also with the applicable requirements of thearticles in Table 705.3.


Equipment/System Article

Generators 445


Fuel cell systems 692

Wind electric systems 694

Emergency systems 700

Legally required standby systems 701

Optional standby systems 702

Energy storage systems 706


The Correlating Committee directs the panel consider adding Article 712 (DC Microgrids) to the list of Articles for improved correlation

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1665 of 2079 10/1/2015 11:02 AM



All equipment shall be approved for the intended use. Utility-interactive inverters for interconnection systems interactiveInteractive equipment intended to operate in parallel with the electric power system including, but not limited to, interactiveinverters, engine generators, energy storage equipment, and wind turbines shall be listed and or field labeled, and identified forthe intended use of interconnection service .


This input is intended to clean up fragmented language and eliminate repetition, while maintaining the intent of the PI. Identification and options for field labeling is addressed in 110.3, and do not need to be repeated here. Inverters, wind turbines, energy storage systems and other equipment intended to operate in parallel with other sources are listed and marked as interactive, not as interconnection service. The incorrect language could lead to confusion with AHJs and installers.

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1666 of 2079 10/1/2015 11:02 AM



All equipment shall be approved for the intended use. Utility-interactive inverters for interconnection systems interactiveequipment intended to operate in parallel with the electric power system including, but not limited to, interactive inverters,engine generators, energy storage equipment, and wind turbines shall be listed, labeled and identified or field labeled , andidentified for the intended use of interconnection service.










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1667 of 2079 10/1/2015 11:02 AM

Affilliation: UL

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1668 of 2079 10/1/2015 11:02 AM



All equipment shall be approved for the intended use. Utility-interactive inverters for interconnection systems interactiveequipment intended to operate in parallel with the electric power system including, but not limited to, interactive inverters,engine generators, energy storage equipment, and wind turbines shall be listed and or field labeled, and identified for theintended use of interconnection service.


The Correlating Committee directs that further consideration be given to the comments expressed in voting on FR 1039. The Correlating Committee directs the panel to consider removing “Utility” from “Utility-interactive” as the first word of the second sentence to correlate with FR 955.

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First Revision No. 955-NFPA 70-2015 [Definition: Utility-Interactive Inverter.]



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1669 of 2079 10/1/2015 11:02 AM



All equipment shall be approved for the intended use. Utility-interactive Interactive inverters for interconnection systemsinteractive equipment intended to operate in parallel with the electric power system including, but not limited to, interactiveinverters, engine generators, energy storage equipment, and wind turbines shall be listed and or field labeled, and identified forthe intended use of interconnection service.


Edit

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1670 of 2079 10/1/2015 11:02 AM



All equipment shall be approved for the intended use. Utility-interactive Interactive inverters for interconnection to systemsinteractive equipment intended to operate in parallel with the electric power system including, but not limited to, interactiveinverters, engine generators, energy storage equipment, and wind turbines shall be listed and or field labeled, and identified forthe intended use of interconnection service.


The first revision sentence was incomplete and very confusing. This is an editoral change not intended to change the meaning.

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1671 of 2079 10/1/2015 11:02 AM



All equipment shall be approved for the intended use. Utility-interactive Interactive inverters for interconnection systemsinteractive equipment intended to operate in parallel with the electric power system including, but not limited to, interactiveinverters, engine generators, energy storage equipment, and wind turbines shall be listed and or field labeled, and identified forthe intended use of interconnection service.


The term "Utility-Interactive inverter" has been replaced with "Interactive inverter."

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First Revision No. 1036-NFPA 70-2015 [Sections 705.40, 705.42]




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1672 of 2079 10/1/2015 11:02 AM


705.8 System Installation.

Installation of one or more electrical power production sources operating in parallel with a primary source(s) of electricity shallbe installed be performed only by qualified persons.

Informational Note: See Article 100 for the definition of Qualified Person.


The present text includes incorrect grammar.

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1673 of 2079 10/1/2015 11:02 AM


705.12 Point of Connection.

The output of an interconnected electric power source shall be connected as specified in 705.12(A) , or (B), (C), or (D) .

(A) Supply Side.

An electric power production source shall be permitted to be connected to the supply side of the service disconnecting meansas permitted in 230.82(6) . The sum of the ratings of all overcurrent devices connected to power production sources shall notexceed the rating of the service.

(

( B) Integrated Electrical Systems.

The outputs shall be permitted to be interconnected at a point or points elsewhere on the premises where the system qualifiesas an integrated electrical system and incorporates protective equipment in accordance with all applicable sections of Article685.

The outputs shall be permitted to be interconnected at a point or points elsewhere on the premises where all of the followingconditions are met:

(1) The aggregate of non-utility sources of electricity has a capacity in excess of 100 kW, or the service is above 1000 volts.

(2) The conditions of maintenance and supervision ensure that qualified persons service and operate the system.

(3) Safeguards, documented procedures, and protective equipment are established and maintained.

(4) If the interconnection occurs in a switchboard or a panelboard that is fed simultaneously by a primary source(s) ofelectricity, and where this distribution equipment is capable of supplying multiple branch circuits or feeders or both, theinterconnecting provisions for the interconnected electric power production source shall comply with 705.12(D)(1)through (D)(5).

(D)

C)

Greater Than 100 kW.

Load Side.

The output of an electric power production source shall be permitted to be connected to the load side of the servicedisconnecting means of the other source(s) at any distribution equipment on the premises. Where distribution equipment,including switchgear, switchboards, or panelboards, is fed simultaneously by a primary source(s) of electricity and one or moreother power source(s), and where this distribution equipment is capable of supplying multiple branch circuits or feeders, or both,the interconnecting provisions for other power sources shall comply with 705.12(D)(1) through (D)(5).

(1) Dedicated Overcurrent and Disconnect.

Each source interconnection of one or more power sources installed in one system shall be made at a dedicated circuit breakeror fusible disconnecting means.


1674 of 2079 10/1/2015 11:02 AM

(2) Bus or Conductor Ampere Rating.

One hundred twenty-five percent of the power source output circuit current shall be used in ampacity calculations for thefollowing:

(1) Feeders. Where the power source output connection is made to a feeder at a location other than the opposite end of thefeeder from the primary source overcurrent device, that portion of the feeder on the load side of the power source outputconnection shall be protected by one of the following:

(2) The feeder ampacity shall be not less than the sum of the primary source overcurrent device and 125 percent ofthe power source output circuit current.

(3) An overcurrent device on the load side of the power source connection shall be rated not greater than the ampacityof the feeder.

(4) Taps. In systems where power source output connections are made at feeders, any taps shall be sized based on the sumof 125 percent of the power source(s) output circuit current and the rating of the overcurrent device protecting the feederconductors as calculated in 240.21(B). Power source output circuit conductors, where smaller than the feeder conductors,shall be sized to carry not less than the larger of 705.60 or 240.21(B).

(5) Busbars. One of the methods that follows shall be used to determine the ratings of busbars in panelboards.

(a) The sum of 125 percent of the power source(s) output circuit current and the rating of the overcurrent deviceprotecting the busbar shall not exceed the ampacity of the busbar.

Informational Note: This general rule assumes no limitation in the number of the loads or sources applied tobusbars or their locations.

(b) Where two sources, one a primary power source and the other another power source, are located at opposite ends ofa busbar that contains loads, the sum of 125 percent of the power source(s) output circuit current and the rating of theovercurrent device protecting the busbar shall not exceed 120 percent of the ampacity of the busbar. The busbar shall be sizedfor the loads connected in accordance with Article 220. A permanent warning label shall be applied to the distribution equipmentadjacent to the back-fed breaker from the power source that displays the following or equivalent wording:

WARNING:

POWER SOURCE OUTPUT CONNECTION —

DO NOT RELOCATE THIS OVERCURRENT DEVICE.

The warning sign(s) or label (s) shall comply with 110.21(B).

(c) The sum of the ampere ratings of all overcurrent devices on panelboards, both load and supply devices, excluding therating of the overcurrent device protecting the busbar, shall not exceed the ampacity of the busbar. The rating of the overcurrentdevice protecting the busbar shall not exceed the rating of the busbar. Permanent warning labels shall be applied to distributionequipment displaying the following or equivalent wording:

WARNING:

THIS EQUIPMENT FED BY MULTIPLE SOURCES.

TOTAL RATING OF ALL OVERCURRENT DEVICES

EXCLUDING MAIN SUPPLY OVERCURRENT DEVICE

SHALL NOT EXCEED AMPACITY OF BUSBAR.


(d) Connections shall be permitted on multiple-ampacity busbars or center-fed panelboards where designed underengineering supervision that includes fault studies and busbar load calculations.

(3) Marking.

Equipment containing overcurrent devices in circuits supplying power to a busbar or conductor supplied from multiple sourcesshall be marked to indicate the presence of all sources.

(4) Suitable for Backfeed.

Circuit breakers, if backfed, shall be suitable for such operation.

Informational Note: Fused disconnects, unless otherwise marked, are suitable for backfeeding.


1675 of 2079 10/1/2015 11:02 AM

(5) Fastening.

Listed plug-in-type circuit breakers backfed from interactive inverters or other electric power sources that are listed andidentified as interactive shall be permitted to omit the additional fastener normally required by 408.36(D) for such applications.


With the change of title of 705.12(D) to "Load Side" and the text change from "inverter" to "power source" 705.12(D) now applies to all types of energy source interconnections. Since 705.12(D) allows interconnection "at any distribution equipment on the premises" it negates the need for B or C which made special allowances for systems that could be interconnected at other points on the premises. Sections B and C now serve no purpose and can be removed. All systems simply are load side or supply side interconnected, significant simplifying 705.12.

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1676 of 2079 10/1/2015 11:02 AM

Public Comment No. 1076-NFPA 70-2015 [ Section No. 705.12(D) [Excluding any Sub-Sections] ]

The output of an interconnected electric power production source shall be permitted to be connected to the load side of theservice disconnecting means of the other source(s) at any distribution equipment on the premises. Where distributionequipment, including switchgear, switchboards, or panelboards, is fed simultaneously by a primary source(s) of electricity andone or more other power source(s), and where this distribution equipment is capable of supplying multiple branch circuits orfeeders, or both, the interconnecting provisions for other power sources shall comply with 705.12(D)(1) through (D)(5).


Text changed to match the text under 705.12.

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1677 of 2079 10/1/2015 11:02 AM









(a) The sum of 125 percent of the power source(s) output circuit current and the rating of the overcurrent deviceprotecting the busbar shall not exceed

the ampacity of the busbar.

Informational Note: This general rule assumes no limitation in the number of the loads or sources applied to busbarsor their locations.

(b) Where two sources, one a primary power source and the other another power source, are located at opposite ends ofa busbar that contains loads, the sum of 125 percent of the power source(s) output circuit current and the rating of theovercurrent device protecting the busbar shall not exceed 120 percent of the ampacity of the busbar. The busbar shall be sizedfor the loads connected in accordance with Article 220. A permanent warning label shall be applied to the distributionequipment adjacent to the back-fed breaker from the power source that displays the following or equivalent wording:

WARNING:



(c) The warning sign(s) or label (s) shall comply with 110.21(B) .

(d) The sum of the ampere ratings of all overcurrent devices on panelboards, both load and supply devices, excluding therating of the overcurrent device protecting the busbar, shall not exceed the ampacity of the busbar. The rating of the overcurrentdevice protecting the busbar shall not exceed the rating of the busbar. Permanent warning labels shall be applied to distributionequipment displaying the following or equivalent wording:

WARNING:






(e) Connections shall be permitted on multiple-ampacity busbars or center-fed panelboards where designed underengineering supervision that includes available fault studies current and busbar load calculations.


The following is an email from Fred Hartwell of CMP9 and who was involved with the original 2008 NEC approval of the 120% rule


1678 of 2079 10/1/2015 11:02 AM

related to panelboards.

****Hartwell email dated 3/29

I think there is a fundamental misunderstanding of the 100% rule versus the 120% rule that pervades some current NEC requirements in 705.12(D) as well as the Wiles articles, which I have now reread more carefully than I should have when they first came out.

First, the 120% rule has nothing to do with busbar overloading. I can take a panelboard bus and protect opposite ends at 100% of rating (thus, connect it to sources at 200% of tis rating), and never subject it to more amperes than its ampacity would allow. For example, consider a 200A bus with 200A supply circuit breakers arranged at opposite ends. No segment of the intervening busbars will see over 200A of current. If we had 250A of load connected to this busbar, there are two possibilities: Either one end receives over 200A, or not. If over 200A comes in from one side, then that side trips and regular conditions apply from the other end. If less than 200A comes in from one side, then the remaining current comes in from the other side which subtracts from the current needed from the first side. The 200A number cannot be exceeded in practice.

Second, even though the busbars could not be overloaded in terms of ampacity, the panelboard as an entity can be overloaded in terms of power delivered with any multiple sources of supply totaling above 100% of the rating for which it was tested. In the above example, the 200A bus assembly delivers 400A times voltage times applicable power factor in the form of power. My understanding, and this goes back to that cell phone conversation with the former CMP 9 NEMA rep I elaborated on at length in one of our previous conversations, is that this power density provides an overall heating effect that the panelboard manufacturers have not designed for.

The 120% rule should be understood, therefore, as an allowable fudge factor that can be applied due to concerns about practicalities and the knowledge that there doesn’t seem to be any loss experience to challenge it. I am looking at language that allows the 120% rule to be extended to a center-fed panelboard even though the 100% protection rule has an academic potential of being violated in some minor way unlikely to be experienced in the real world.

******End of email.

This email explains that the removal of the requirement of the opposite end of the busbar will not have a significant impact on the thermal loading of a panelboard. To simplify the process for enforcement and construction, removal of the opposite end of the busbar will be simpler and essentially no different than applying the current rule for the opposite end of the busbar.

The last comment edits the wording of the last section about multi-ampacity buswork by removing the reference to center-fed panels, since it is now longer relevant. Also, it clarifies the original wording to specifically address the relevant concern of available fault current rather than the less defined term of fault studies.



Public Comment No. 1356-NFPA 70-2015 [Section No. 705.12(D)(2)]

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1680 of 2079 10/1/2015 11:02 AM






(4) Taps. In systems where power source output connections are made at feeders, any taps the output conductors shall besized based on the sum of 125 percent of the power source(s) output circuit current and the permitted to be sized as tapconductors according to 240.21(B) under the following conditions:

a. For calculation purposes, the assumed rating of the overcurrent device protecting the feeder conductors as calculatedin 240.21(B) . Power source output circuit conductors, where smaller than the feeder conductors, shall be sized to carrynot less than the larger of 705.60 or 240.21(B) . shall be the sum of the primary source overcurrent device rating and125% of the output circuit current of all other sources that can supply additional current to the feeder

b. The power source output conductors and overcurrent device shall not be smaller than required by 705.60




(b) Where two sources, one a primary power source and the other another power source, are located at opposite ends ofa busbar that contains loads, the sum of 125 percent of the power source(s) output circuit current and the rating of theovercurrent device protecting the busbar shall not exceed 120 percent of the ampacity of the busbar. The busbar shall be sizedfor the loads connected in accordance with Article 220. A permanent warning label shall be applied to the distribution equipmentadjacent to the back-fed breaker from the power source that displays the following or equivalent wording:

WARNING:





WARNING:






(d) Connections shall be permitted on multiple-ampacity busbars or center-fed panelboards where designed underengineering supervision that includes fault studies and busbar load calculations.


This comment is mainly editorial, with the goal of having the code better communicate the requirements in section 705.12(D)(2)(2).


1681 of 2079 10/1/2015 11:02 AM

However it also contains a technical change which allows the requirements to comprehensively cover types of installations that are neglected by the current language.

The original language of 705.12(2)(2)language from the 2014 code, as well as the First Draft language, can be easily misinterpreted as requiring the ampacity of a tap conductor to be the sum of the minimum requirements of 705.60 and 240.21(B), which is much larger than necessary. While the phrase "as calcuated in 240.21(B)" seems intended to apply to the entire sum, it is not properly placed grammatically so as to make this clear and certain. This leaves many readers trying to interpret the meaning of phrase "the rating of the overcurrent device protecting the feeders as calculated in 240.21(B)". It is not entirely insensible to interpret that phrase as meaning the minimum requirements of 240.21(B). Thus some readers add the minimum requirements of the two sections together.

The new language proposed in this comment clears up any potential confusion about how 240.21(B) is to be followed. It uses the term 'tap conductors' properly as defined in 240.21(B). And by referring to an 'assumed rating', which is a sum more clearly defined in this section, it clears up which number is supposed to be used for 240.21(B) calculations, and in what manner.

In addition, the proposed language covers installations that have multiple sources connected to the same feeder, whether by taps or in panelboards fed by the feeder, or both. The rules in 240.21(B) are designed to account for the amount of available fault current, and the intention of 705.12(2)(2) is to have the fault current from all sources considered. However, the current First Draft language (like the 2014 code) assumes that the tap is the only non-primary source connection to the feeder. And yet a system could have one or more sources connected by taps, plus one or more sources connected with circuit breakers in downstream panelboards. There is no prohibition on such setups, nor should there be, but the First Draft language offers no guidance on such cases. By changing the relevant sum to include "all other sources that can supply additional fault current to the feeder", the new language concisely covers even the most complicated of real-world possibilities. All sources of fault current will be considered when sizing tap conductors.

Finally, in case the miminum size requirements of 240.21(B) are not clear because they refer to a 'load', the language proposed in this comment retains the minimum size requirements of 705.60.

In summary, I believe the language I've proposed here better communicates the intentions of CMP4 with respect to 705.12(D)(2)(2), while extending those intentions as much as possible to all conceivable installations.

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Submitter Full Name: JOEL FRANGQUIST]

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1682 of 2079 10/1/2015 11:02 AM











(b) Where two sources, one a primary power source and the other another power source, are located at opposite ends ofa busbar that contains loads, the sum of 125 percent of the power source(s) output circuit current and the rating of theovercurrent device protecting the busbar shall not exceed 120 percent of the ampacity current rating of the busbar. The busbarshall be sized for the loads connected in accordance with Article 220. A permanent warning label shall be applied to thedistribution equipment adjacent to the back-fed breaker from the power source that displays the following or equivalent wording:

WARNING:





WARNING:






(d) A connection at either end, but not both ends, of a center-fed panelboard shall be permitted where the rating of theovercurrent device does not exceed 120 percent of the current rating of the busbar. Connections shall be permitted on multiple-ampacity busbars or center-fed panelboards where designed under engineering supervision that includes available faultstudies current and busbar load calculations.



1683 of 2079 10/1/2015 11:02 AM

This is another option for the wording related to busbars in 705.12(D). This wording was recommended by Fred Hartwell as a way to simply allow center-fed panels to have a source connection. His explanation follows in a quote from an email he composed:

I think there is a fundamental misunderstanding of the 100% rule versus the 120% rule that pervades some current NEC requirements in 705.12(D) as well as the Wiles articles, which I have now reread more carefully than I should have when they first came out.

First, the 120% rule has nothing to do with busbar overloading. I can take a panelboard bus and protect opposite ends at 100% of rating (thus, connect it to sources at 200% of tis rating), and never subject it to more amperes than its ampacity would allow. For example, consider a 200A bus with 200A supply circuit breakers arranged at opposite ends. No segment of the intervening busbars will see over 200A of current. If we had 250A of load connected to this busbar, there are two possibilities: Either one end receives over 200A, or not. If over 200A comes in from one side, then that side trips and regular conditions apply from the other end. If less than 200A comes in from one side, then the remaining current comes in from the other side which subtracts from the current needed from the first side. The 200A number cannot be exceeded in practice.

Second, even though the busbars could not be overloaded in terms of ampacity, the panelboard as an entity can be overloaded in terms of power delivered with any multiple sources of supply totaling above 100% of the rating for which it was tested. In the above example, the 200A bus assembly delivers 400A times voltage times applicable power factor in the form of power. My understanding, and this goes back to that cell phone conversation with the former CMP 9 NEMA rep I elaborated on at length in one of our previous conversations, is that this power density provides an overall heating effect that the panelboard manufacturers have not designed for.

The 120% rule should be understood, therefore, as an allowable fudge factor that can be applied due to concerns about practicalities and the knowledge that there doesn’t seem to be any loss experience to challenge it. I am looking at language that allows the 120% rule to be extended to a center-fed panelboard even though the 100% protection rule has an academic potential of being violated in some minor way unlikely to be experienced in the real world.



Public Comment No. 1162-NFPA 70-2015 [Section No. 705.12(D)(2)]

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(5) Fastening.

Listed plug-in-type circuit breakers backfed from interactive inverters or other electric power sources that are listed andidentified as interactive shall be permitted to omit the additional fastener normally required by 408.36(D) for such applications.


This section is now a little problematic. The allowance for not requiring fastening is based on the requirement that utility interactive inverters shut down on loss of utility power. Is saying "listed and identified as interactive" enough to ensure that the electric power source will shut down on loss of utility power? I'm not sure the term "interactive" will force that compliance.

Since the term "inverter" has been removed elsewhere in 705.12(D) is should also be removed from 705.12(D)(5) and electric power source will encompass it.

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1685 of 2079 10/1/2015 11:02 AM


705.22 Disconnect Device.

The disconnecting means for ungrounded conductors shall consist of a manually or power operable switch(es) or circuitbreaker(s) with the following features:

(1) Located where readily accessible

(2) Externally operable without exposing the operator to contact with live parts and, if power operable, of a type that could beopened by hand in the event of a power-supply failure

(3) Plainly indicating whether in the open (off) or closed (on) position

(4) Having ratings not less than the load to be carried and the fault current to be interrupted. For disconnect equipmentenergized from both sides, a marking shall be provided to indicate that all contacts of the disconnect equipment might beenergized.

Informational Note to (4): : In parallel generation systems, some equipment, including knife blade switches andfuses, is likely to be energized from both directions. See 240.40.

(5) Simultaneous disconnect of all ungrounded conductors of the circuit

(6) Capable of being locked in the open (off) position


The Correlating Committee directs the panel to reconsider the wording of the section and adjust as necessary for proper grammar and clarity

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1686 of 2079 10/1/2015 11:02 AM


705.23 Interactive System Disconnecting Means.

Means shall be provided in a readily accessible location to disconnect the interactive system from all wiring systems includingpower systems, energy storage systems, and utilization equipment and its associated premises wiring.


The purpose to add the phrase "readily accessible location" to the first revision is for clarity in the requirement to indicate that those requisite to operate the disconnecting means can access it quickly for operation without climbing over, or removing obstacles or resort to portable ladders, etc.

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1687 of 2079 10/1/2015 11:02 AM


705.31 Location of Overcurrent Protection.

Overcurrent protection for electric power production source conductors, connected to the supply side of the servicedisconnecting means in accordance with 705.12(A) , shall be located within 3 m (10 ft) of the point where the electric powerproduction source conductors are connected to the service.

Informational Note: This overcurrent protection protects against short-circuit current supplied from the primary source(s)of electricity.

Exception: Where the overcurrent protection for the power production source is located more than 3 m (10 ft) from the pointof connection for the electric power production source to the service, cable limiters or current-limited circuit breakers for eachungrounded conductor shall be installed at the point where the electric power production conductors are connected to theservice.


I agree with the PI. Service entrance conductors are by definition not protected by NEC for over current. Art 705.31 was added to the 2014 NEC according to the substantiation, "These unprotected conductors from the service entrance equipment to the remote disconnect with overcurrent protection are a safety hazard since they do not have adequate short-circuit current protection." But the same can be said of any service entrance conductors allowed in Art 230. Why hold these particular service entrance conductors to a higher standard than all other service entrance conductors?

In the resolution to this PI the CMP wrote, "Electric power production source conductors differ from service conductors by the definition in Article 100. "

I point out that "Electric power production source conductors" are not defined in Art 100. They are no different than service entrance conductors from the utility. So far no one has indicated a specific hazard from service entrance conductors in Art 750 that are different than those in Art 230. If these service extract conductors require overcorrect protection then we need to apply the same logic to service entrance conductors from the utility and require they be protected also.

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1688 of 2079 10/1/2015 11:02 AM


705.65 Overcurrent Protection.


Inverter input circuits, inverter output circuits, and storage battery circuit conductors and equipment shall be protected inaccordance with the requirements of Article 240. Circuits connected to more than one electrical source shall have overcurrentdevices located so as to provide overcurrent protection from all sources.

Exception: An overcurrent device shall not be required for circuit conductors sized in accordance with 705.60(B) and locatedwhere one of the following applies:


(2) The short-circuit currents from all sources do not exceed the ampacity of the conductors.

Informational Note: Possible backfeed of current from any source of supply, including a supply through an inverter intothe inverter output circuit and inverter source circuits, is a consideration in determining whether adequate overcurrentprotection from all sources is provided for conductors and modules.

(B) Power Transformers.

Overcurrent protection for a transformer with a source(s) on each side shall be provided in accordance with 450.3 byconsidering first one side of the transformer, then the other side of the transformer, as the primary.

Exception: A power transformer with a current rating on the side connected toward the interactive inverter output that is notless than the rated continuous output current of the inverter shall be permitted without overcurrent protection from thatsource.


The correlating Committee directs further consideration be given to the comments expressed in voting on FR 3663.

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1689 of 2079 10/1/2015 11:02 AM



Stand-alone power sources shall be provided with a lockable disconnecting means according to 705.21 and overcurrentprotection in accordance with 240.21.


This requirement as originally proposed gives no guidance to where such disconnect(s) should be located or what it should be capable of performing that isn't already better said by 705.21 and by reference 705.22. This includes the ability to being locked in the open (off) position.

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705.170 Island Interconnection Devices (IID).

(1) An IID shall be required for any connection between an intentionally islanded or stand-alone system and a primary powersource.

(2) Interconnection devices shall be listed, or field labeled, as suitable for the intended interconnection application.

(3) Interconnection devices shall have sufficient number of overcurrent devices located so as to provide overcurrentprotection from all sources.


The interconnection function is already addressed in existing requirements and standards, and should not be duplicated in this manner. UL standards for interactive product address the specific considerations that must be addressed for this application and listed Interactive inverters which manage the interconnection to the area EPS are available from numerous manufacturers, yet these devices are not marked as being "Island Interconnection Devices" and so would not appear to comply with this requirement. In addition, there is no functional requirement for an intentionally islanded system to perform a seamless transfer, other than customer convenience; a listed manual double throw safety switch would provide the same level of safety, albeit at a lower level of convenience, but is not marked as an Island Interconnection Device. Overcurrent protection, disconnecting means, synchronizing means and the protection from multiple sources are addressed elsewhere in this article, so there is no benefit from adding this new requirement, only added complexity and potential confusion to AHJs and installers.




Public Comment No. 1457-NFPA 70-2015 [Definition: Island Interconnection Device (IID).]

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705.170 Island Interconnection Devices (IID).

(1) An IID shall be required for any connection between an intentionally islanded or stand-alone system and a primary powersource.

?Exception: where an interactive inverter, ESS or other device listed for interactive operation incorporates the interconnectionfunction.

(1) Interconnection devices shall be listed, or field labeled, as suitable for the intended interconnection application.

(2) Overcurrent protection for Interconnection devices shall have sufficient number of overcurrent devices located so as toprovide overcurrent protection from all sources. be in accordance with 705.30.


The proposed 705.170 Island Interconnection Device (IID) does not add value and should be rejected, per comment 1208. However, if the CMP disagrees and sees merit in the concept, this section should be revised to allow available listed interactive product which manage the utility interconnection as part of their listed function to be used. Overcurrent protection requirements for multiple sources is already addressed in 705.30 in a more comprehensive manner, this section should simply reference that.

NOTE: Terraview inadvertently renumbered the requirements, this was not an intentional change.




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1692 of 2079 10/1/2015 11:02 AM


705.170 Island Microgrid Interconnection Devices (IID MID ).

(1) An IID A Microgrid Interconnection Device shall be required for any connection between an intentionally islanded orstand-alone system and a primary power source.

(2) Interconnection devices MIDs shall be listed, or field labeled, as suitable for the intended interconnection application.

(3) Interconnection devices MIDs shall have sufficient number of overcurrent devices located so as to provide overcurrentprotection from all sources.


IEEE is changing the name and definition of this device to better reflect its function. See for example, IEEE2030.7 (draft).. Island Interconnect Device often requires explanation, while Microgrid Interconnect Device is self explanatory.

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Affilliation: NEC DC Task Force / Microgrid WG.

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1693 of 2079 10/1/2015 11:02 AM


705.175 Stand-Alone Wiring Systems.

This section relates to stand-alone systems operating in stand-alone mode.

Premises wiring systems shall be adequate to meet the requirements of this Code for similar installations supplied by a feederor service. The wiring on the supply side of the building or structure disconnecting means shall comply with the requirements ofthis Code, except as modified by 705.175(A) through (F).

(A) Supply Output.

Power supply to premises wiring systems shall be permitted to have less capacity than the calculated load. The capacity of thestand-alone supply shall be equal to or greater than the load posed by the largest single utilization equipment connected to thesystem. Calculated general lighting loads shall not be considered as a single load.


The circuit conductors between a stand-alone source and a building or structure disconnecting means shall be sized based onthe sum of the output ratings of the stand-alone sources.


Stand-alone systems shall be permitted to supply 120 volts to single-phase, 3-wire, 120/240-volt service equipment ordistribution panels where there are no 240-volt outlets and where there are no multiwire branch circuits. In all installations, thesum of the ratings of the power sources shall be less than the rating of the neutral bus in the service equipment. This equipmentshall be marked with the following words or equivalent:

WARNING:






Plug-in type back-fed circuit breakers connected to an interconnected supply shall be secured in accordance with 408.36(D).Circuit breakers marked “line” and “load” shall not be back-fed.

(F) Voltage and Frequency Control.

The stand-alone supply shall be controlled so that voltage and frequency remain within suitable limits for the connected loads.


This commentor agrees with moving these requirements out of 690 and into 705, where they will apply to all interconnected systems. However, the title should be revised to more clearly indicate the issues being addressed.

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1694 of 2079 10/1/2015 11:02 AM


705.175 Wiring Stand-Alone Systems. [also move whole section to new Article 710]

This section relates to stand-alone systems operating in stand-alone mode.

Premises wiring systems shall be adequate to meet the requirements of this Code for similar installations supplied by a feederor service. The wiring on the supply side of the building or structure disconnecting means shall comply with the requirements ofthis Code, except as modified by 705.175(A) through (F).

(A) Supply Output.






WARNING:






Plug-in type back-fed circuit breakers connected to an interconnected supply shall be secured in accordance with 408.36(D).Circuit breakers marked “line” and “load” shall not be back-fed.




The title of this section should be "Stand-alone systems".Stand-alone systems do not belong in 705, as acknowledged by the TCC report.A working group should be formed to draft a new Article 710 Stand-Alone Systems based on this section from FR 705.175Some content for this can be extracted from the original proposal for 710 Microgrids (PI 4026).To be clear, all interconnection aspects of intentional island / microgrid behavior will remain in 705.The stand-alone (forming 710) language is essentially the same as what has been removed from 690, 690 and 694.There is general consensus that utilization aspects of renewable and off-grid power systems should not be in energy source articles such as 690.We recommend that Article 710 be kept in CMP4 as it is a natural companion to 705, and the members of CMP4 are alreadyfamiliar with its content as it came from 690, 694 etc.

Utility industry members of our WG have said:We see [stand-alone systems] as several photovoltaic panels with batteries operating signs, lights, point-of-sale parking, and instrumentation. In addition, there are people with installations who wish to be “off-grid” as an individual choice. The utility industry supports the concept for those types of connections. However, our position is that if a “stand-alone” system does wish to interconnect with the AC system, then the requirements of Article 705 would apply. We also support the concept of an interconnected system that complies with Article 705 to re-configure to a stand-alone system for any operational purpose.

There is some disagreement over the use of the term "microgrid", vs "intentional island".

We plan to build consensus on this and other issues among our members in a working group prior to the November meeting.

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1695 of 2079 10/1/2015 11:02 AM




Affilliation: NEC DC TG/ Microgrid WG

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1696 of 2079 10/1/2015 11:02 AM


705.175 Stand-alone Wiring Systems.

This section relates to stand-alone Premises wiring systems operating in stand-alone mode .Premises wiring systems shall beadequate to meet the requirements of this Code for similar installations supplied by a feeder or service. The wiring on thesupply side of the building or structure disconnecting means shall comply with the requirements of this Code, except asmodified by 705.175(A) through (F).

(A) Supply Output.






WARNING:






Plug-in type back-fed circuit breakers connected to an interconnected supply shall be secured in accordance with 408.36(D) .Circuit breakers marked “line” and “load” shall not be back-fed.




Revisions as suggested by Mr. Roger McDaniel in comment on affirmative vote.

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1697 of 2079 10/1/2015 11:02 AM


This section relates to stand-alone systems or multi-mode systems operating in stand-alone mode.

Premises wiring systems shall be adequate to meet the requirements of this Code for similar installations supplied by a feeder orservice. The wiring on the supply side of the building or structure disconnecting means shall comply with the requirements of thisCode, except as modified by 705.175(A) through (F).


This commentor agrees with moving these requirements out of 690 and into 705, where they will apply to all interconnected systems. However, the requirements should apply not only stand-alone systems but also to multi-mode systems operating in stand-alone mode.

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1698 of 2079 10/1/2015 11:02 AM

national fire protection association · public comment no. 995 section no. 690.7(a) bill brooks...

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