Here is the email that I sent to Matt Paiss in response to his contact with me.

Matt,

Thanks for your email. I was in the midst of answering it yesterday when my reply disappeared into cyberspace. Maybe it found its way to your mailbox.

We agree strongly that PV should be made as safe as possible, and that firefighters need to be educated about these systems. The issue I raise is that the new rule came through with no lead time, no NRTL listed equipment available to satisfy the requirement, and no prescribed way to implement it. Through the work of many, maybe including you, the ruling fortunately was not far more damaging.

There is no emergency requiring immediate implementation of a methodology that will create so many problems for the PV industry. The dangers of rooftop PV do not show up on the radar compared to even the use of extension cords; much less traffic deaths and fatalities related to mis-prescribed medicines; and diseases suffered by the general public, caused by the extractive industries.

This new code requirement presents a major new issue for the industry to deal with. It is yet another block in the way of solar cost effectiveness, and with it the success ratio of the industry. This requirement has come with no set solution, and will continue to cause considerable financial loss and stress until all the details are eventually worked out.

It is the fact that the PV industry has been wounded in this way that makes it seem like an ALEC-supported operation. This assault works well for the group's agenda. ALEC is not a matter of secret agendas; it is very visible, with an extremely well-orchestrated assault on the PV industry. <http://ecowatch.com/2014/01/22/largest-power-company-alec-solar/>http://ecowatch.com/2014/01/22/largest-power-company-alec-solar/ You may well be right that no committee members were lobbied. You were there and I was not. Nevertheless, I would really like to know who proposed the module level rapid disconnect requirement. Some may be alarmed about PV rooftop systems for good reason, and / or they may have been influenced to consider this relatively safe technology to be a threat.

Would it be possible for you to put me in contact with the people who presented this idea, and those who argued passionately for it? If they want to contact me, please forward my contact information to them.

Best regards,

Drake





At 02:11 PM 1/24/2014, you wrote:
Wrenches,

Matt Paiss is wanted to chime in here. He's a member of the Code-Making Panel No. 4 Firefighter Safety Task Group, as well as SEIA's PV Industry Forum.

Since he can't post to the list, I am sharing his comments with the group:


Drake,

After reading your initial comments, I think you have nailed both the intent of this code section as well as the benefits. But in reading your second posting, I felt it important to write you. As one of the representatives from the Fire Service that drafted 690.12, I can tell you that while there is always room for improvement in language, the goal is to have PV that can not start a fire. As I am not a "wrench" I can not post to the list (feel free to share any of my comments here if you wish), but I would like to chime in on this conversation.

Your assertion that ALECs are targeting the PV industry is not taking place in this process. There are many hard-working individuals from the PV industry, electrical inspectors, and the fire service working together to keep PV safe and secure for many years to come. I for one have both PV and thermal on my home.

While you are correct that no fire fighter fatalities have resulted from a PV system shock, the goal is to prevent the first. One problem is that the PV industry has not adequately addressed the arc and ground fault problems in the US. Simply put, many rooftop systems are not NEC compliant; they can not detect and interrupt all faults. This has unfortunately resulted in far too many fires. The many additions & changes to sec 690 in the 2014 cycle will go far in achieving a much safer system.

The fire service is becoming increasingly aware, educated, and involved in the code process for PV safety. It should be clear that the goal for all parties is a safe electrical product. There is no secret agenda to pull the rug out from under solar. To those that are concerned with the imbedded cost increases, please take a longer view than your current FY. The systems that fire fighters respond to may be many years old, but in reality most of the fires have occurred on new systems. We will respond to older systems over time, and some buildings will be lost due to concern over the inability to isolate power down to a safe level. As I teach firefighters about electrical safety, many express both an interest in PV as well as concern that it should be possible to shut a system down in the event of an emergency either manually, or as a result of a fault.

Thank you,
Matt

CA Matthew Paiss, E19B
Bureau of Field Operations
San Jose Fire Department
1661 Senter Rd
San Jose, CA 95113
(831) 566-3057 c

BTW: the stakeholders who developed the consensus language in 690.12 are listed in the NEC 2014 Report on Comments:

This comment is the result of a consensus process established among three groups of stakeholders: 1) CMP4 Firefighter SafetyTask Group; 2) SEIA Codes and Standards Working Group; and 3) PV Industry Forum. Participants in these groups included the following individuals:

CMP4 Firefighter Safety Task Group
1. Ward Bower, CMP4 representing SEIA
2. Bill Brooks, CMP4 representing SEIA and Chair of Task Group
3. Bob Davidson, Davidson Code Concepts
4. Mark Earley, Secretary, NFPA
5. Bob James, UL
6. Matt Paiss, City of San Jose Fire Department
7. Jim Rogers, CMP4 representing IAEI
8. Todd Stafford, CMP4 representing IBEW
9. Ronnie Toomer, Chair of CMP4
10. Peter Willse, Global Asset Protection Services

SEIA Codes and Standards Working Group
1. Mark Albers, SunPower
2. Mark Baldassari, Enphase Energy
3. Ward Bower, SEIA
4. Bill Brooks, Brooks Engineering/SEIA
5. Joe Cain, Chair of SEIA Codes and Standards Working Group
6. Keith Davidson, SunTech
7. Darrel Higgs, Dow Solar
8. Lee Kraemer, First Solar
9. Carl Lenox, SunPower
10. Charles Luebke, Eaton
11. Martin Mesmer, E.ON
12. Steve Pisklak, Dow Solar13. Robert Rynar, First Solar
14. Michael Schenck, First Solar
15. John Smirnow, SEIA
16. Kris VanDerzee, First Solar
17. Leo Wu, SolarCity
18. Tilak Gopalarathnam, REFUsol Incorporated

PV Industry Forum
1. Mark Albers, SunPower
2. Greg Ball, DNV
3. Bill Brooks, Brooks Engineering, lead for 690.12
4. Mark Baldassari, Enphase Energy
5. Ward Bower, SEIA
6. Michael Coddington, NREL
7. Marv Dargatz, SolarEdge
8. Chris Flueckiger. UL
9. Joerg Grosshennig, SMA
10. Darrel Higgs, Dow Solar
11. Dan Lepinski, Exeltech
12. Carl Lenox, SunPower
13. Charles Luebke, Eaton
14. Matt Paiss, City of San Jose Fire Department
15. Steve Pisklak, Dow Solar
16. Jim Rogers, Town of Oak Bluffs
17. Jon Sharp, Ampt
18. Bhima Sheridan, SolarCity
19. John Smirnow, SEIA
20. Holly Thomas, U.S. Dept. of Energy
21. Phil Undercuffler, Outback Power
22. John Wiles, NMSU, Secretary of PV Industry Forum
23. Leo Wu, SolarCity
24. Tim Zgonena, UL


On Jan 24, 2014, at 1:00 PM, <mailto:re-wrenches-requ...@lists.re-wrenches.org>re-wrenches-requ...@lists.re-wrenches.org wrote:

From: Drake <<mailto:drake.chamber...@redwoodalliance.org>drake.chamber...@redwoodalliance.org>
Subject: Re: [RE-wrenches] NEC 2014 690.12 Rapid Shutdown
Date: January 22, 2014 2:16:18 PM CST
To: RE-wrenches <<mailto:re-wrenches@lists.re-wrenches.org>re-wrenches@lists.re-wrenches.org> Reply-To: RE-wrenches <<mailto:re-wrenches@lists.re-wrenches.org>re-wrenches@lists.re-wrenches.org>



David,

My sincere thanks to all of you who worked to keep the module level disconnect requirement out of the 2014 code cycle. That ruling would have amounted to a knockout punch for string and central inverters on buildings.

What was the driving force behind this push for immediate module level disconnection? There has clearly not been a rash of firefighter deaths due to PV systems. Although PV needs to continue evolving safety standards that take into account the concerns of firefighters, there is no crisis that would justify thwarting one of the few growing sectors of our economy.

The PV track record has been amazingly good. So far, I've found no accounts of solar related firefighter deaths or injuries. The NFPA statistics show that the highest cause of firefighter death is heart attack. <http://www.nfpa.org/newsandpublications/nfpa-journal/2013/july-august-2013/features/firefighter-fatalities-in-the-united-states-2012>http://www.nfpa.org/newsandpublications/nfpa-journal/2013/july-august-2013/features/firefighter-fatalities-in-the-united-states-2012

This push for crippling regulation bears the earmark of ALEC's extensive and effective war on solar. As you can read in the following links, the massively funded, Koch brothers-linked ALEC is lobbying heavily, on every level, to derail solar. All who are associated with the solar industry need to be aware of this powerful lobbying campaign.

<http://www.theguardian.com/world/2013/dec/04/alec-freerider-homeowners-assault-clean-energy>http://www.theguardian.com/world/2013/dec/04/alec-freerider-homeowners-assault-clean-energy

http://www.salon.com/2013/12/05/alec_freeriders_with_solar_panels_must_pay_for_robbing_the_system/

<http://beforeitsnews.com/environment/2014/01/alec-gain-an-inside-track-on-colorado-solar-2490132.html>http://beforeitsnews.com/environment/2014/01/alec-gain-an-inside-track-on-colorado-solar-2490132.html

Is there any way that the solar community can be alerted when threats to our industry are being put before the NEC? Although few contractors have the time or money to walk away from their businesses and attend code writing committees, a substantial number might have the time to make phone calls and send letters or emails to code writers.

The solar industry needs a strong lobby of its own.

Drake



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