I would argue a single dedicated load circuit for the Enphase Envoy, in a 
dedicated inverter combiner panel, is code legal. Why? Because 705.12 states 
the distribution equipment must be capable of supplying "multiple branch 
circuits" for the 120% rule to apply. A single  dedicated circuit for the Envoy 
appears to comply. Use a load center with a lockable cover if there are extra 
slots and you have done due diligence. 

Kirk Herander
VSE

On Jun 27, 2012, at 11:51 AM, Jason Szumlanski <ja...@fafcosolar.com> wrote:

> If you install a combiner panel that can supply additional branch circuits, 
> it becomes part of the building distribution system. Note that Enphase 
> recommends you install a branch circuit to supply power to the Envoy device 
> right from the combiner panel. If that is the case, the panel is certainly 
> part of the building distribution system and is obviously capable of 
> supplying branch circuits, in which case the 120% rule would apply. I don't 
> like it and I don't necessarily agree with it, but based on my strict 
> interpretation of the code I can see why an AHJ would require application of 
> this section in this case.
> 
> Jason Szumlanski
> Fafco Solar
> 
> 
> 
> 
> On Wed, Jun 27, 2012 at 10:59 AM, Chris Mason <cometenergysyst...@gmail.com> 
> wrote:
> I don't think this is expressed in the code, but in my opinion, the 120% 
> applies to the building distribution equipment, not to parts of the solar 
> system. In the case where a panel is being used to combine multiple inverter 
> outputs, the panel is part of the solar system only. The 120% rule was an 
> accommodation to allow solar to feed a building distribution panel and is not 
> applicable to solar system components. It would be good if the code could 
> indicate this more clearly.
> 
> 
> On Wed, Jun 27, 2012 at 8:29 AM, Jason Szumlanski <ja...@fafcosolar.com> 
> wrote:
> Kirk,
> 
> That's basically what I said. Unfortunately, your opinion holds no weight 
> with my local AHJ's. I've argued the point till blue in the face. Although, I 
> have never had the instance where all available slots were filled in the 
> combiner panel - I might be able to argue that case successfully.
> 
> Jason Szumlanski
> Fafco Solar
> 
> 
> 
> 
> On Tue, Jun 26, 2012 at 4:53 PM, Kirk Herander <k...@vtsolar.com> wrote:
> Jason,
> 
>  
> 
> In your email below you state:
> 
>  
> 
> “You DO need to observe the 120% rule for the combining subpanel, regardless 
> of whether there are loads present, at least in jurisdictions where I have 
> worked. I've heard that some inspectors will allow you to ignore it if it is 
> labeled as a PV combiner with "add no loads" notation.”
> 
>  
> 
> NEC 705.12 (D) states that the distribution equipment (in this case the 
> combiner panel, fed by multiple inverters and a utility source) must be 
> “capable of supplying multiple branch circuits or feeders or both” for (D)(1) 
> through (7) to apply. If you fully populated a combiner panel with inverter 
> breakers, leaving no slots for load breakers, it is not capable of supplying 
> branch circuits or feeders, and IMO the 120% rule does not apply to the 
> combiner buss or the conductors back to its point of utility interconnect. I 
> have argued this point as well as label combiners “load circuits prohibited” 
> (with or without available slots) and received AHJ approval.
> 
>  
> 
> You could also just lock shut a combiner that had spare slots as a deterrent 
> to adding load breakers.
> 
>  
> 
>  
> 
> Kirk Herander
> 
> VT Solar, LLC
> 
> dba Vermont Solar Engineering
> 
> NABCEPTM Certified installer Charter Member
> 
> NYSERDA-eligible Installer
> 
> VT RE Incentive Program Partner
> 
> 802.863.1202
> 
>  
> 
> From: re-wrenches-boun...@lists.re-wrenches.org 
> [mailto:re-wrenches-boun...@lists.re-wrenches.org] On Behalf Of Jason 
> Szumlanski
> Sent: Tuesday, June 26, 2012 8:28 AM
> To: RE-wrenches
> Subject: Re: [RE-wrenches] Enphase grid tie question
> 
>  
> 
> I'll email you off-list a 1-line diagram from a system with 164 
> microinverters broken down into 8 strings in a 208V system. This particular 
> system used two subpanels to accumulate PV, but that was only because we had 
> to backfeed two existing subpanels due to the size of existing 480/208V 
> transformers. You will have to look at the utility service and all existing 
> equipment.
> 
>  
> 
> Regarding the breakers in the subpanel, you will only need a maximum of a 20A 
> breaker for each string. The max inverters per string is 25 and the 
> calculation for OCPD is:
> 
>  
> 
> 215W / 208V x 25 inverters / 1.732 x 1.25 = 18.65A
> 
>  
> 
> “You DO need to observe the 120% rule for the combining subpanel, regardless 
> of whether there are loads present, at least in jurisdictions where I have 
> worked. I've heard that some inspectors will allow you to ignore it if it is 
> labeled as a PV combiner with "add no loads" notation.”
> 
>  
> 
> Use a MLO panel with a fusible disconnect between the subpanel and the 
> interconnection point. If you use a 225A panel, you can feed it with 270A. 
> With eight 20A backfed PV circuits, you would need to protect the line side 
> of the panel with a 100A fusible disconnect. That probably isn't going to 
> work. You may be best off from a cost perspective using two 225A subpanels 
> and two 60A fusible disconnects. Anything larger than a 60A 3P disconnect and 
> the price skyrockets. It all depends on your circuit calculations and the 
> existing equipment. Of course, you would need two spaces for your 
> interconnection point.
> 
>  
> 
> Jason Szumlanski
> 
> Fafco Solar
> 
>  
> 
> 
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> -- 
> Chris Mason
> President, Comet Systems Ltd
> www.cometenergysystems.com
> Cell: 264.235.5670
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