I've been going through the new Code book (which is in effect now in 
Massachusetts) and found myself somewhat puzzled by the intent of the new 
"rapid shutdown" requirement in 690.12. Does anyone have insight into how this 
is supposed to be interpreted and implemented? I've put together a list of my 
own questions, given below (the numbers reference the new 690.12 text). Thanks!

690.12 Rapid Shutdown
1.  Where should the rapid shutdown switch be located? (1) only says that the 
shutdown function should be installed if the circuit is longer than 10’ or goes 
more than 5’ into a building. If this condition is fulfilled, it says nothing 
about where the switch should be located. (2) says that controlled conductors 
should be limited to 30V, 240W, which will only be the case downline from the 
switch, so this may mean that  it should be located close to the source, i.e. 
on the roof. But this is just an inference, and one that doesn’t have clear 
boundaries; every source conductor for a series connected PV circuit (that is 
not Solar Edge, Enphase , etc.) will have a higher voltage and wattage 
potential when the sun is shining somewhere along its length, even if the 
disconnect is located very close to the array. Or does this requirement mean 
that all systems will need to have some kind of “smart” junction box, module 
DC-DC converter or module level
 AC inverter? Furthermore, individual modules often have higher voltages & 
wattages these days and there is no way to impose limits on their electrical 
characteristics in any field wired configurations. A listed AC module that sees 
the module leads as internal would be the only scenario that would be exempt.

2. (5) asks that equipment performing the shutdown should be listed and 
identified. Does that mean listed and identified for the purpose of this 
specific requirement? Or just listed and identified to limit voltage and 
wattage in 10 seconds? Does a specific UL standard exist for the function they 
have in mind? Does any equipment exist that has such listing and identification 
yet?

3. Is the rapid shutdown intended to be automatic or manual? If automatic, what 
are the parameters that would trigger the shutdown? If manual, are there any 
accessibility requirements?

4. Rapid shutdown seems more like a disconnect requirement than a circuit 
requirement. Why limit circuits to 30V, 240W, instead of just requiring a 
shutdown? Why 10 seconds, when all the disconnecting functions (i.e. manual 
disconnects, and internal AFCI, GFCI & UL 1740 disconnects) happen in less than 
a second? (It hardly seems like a “rapid” shutdown). Why write this article 
into section II rather than section III?
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