In submitting my comments, I only could access 2017, and that's where I made my comments.  Does anyone have more information, or is it too late?

On 8/29/2018 10:05 PM, Ray wrote:

The link to review the first draft of the 2020 code is not working.  Do you have just the changes for 690?  I'd really like to submit some comments.

Thanks,

Ray Walters
Remote Solar
303 505-8760
On 8/28/18 7:59 AM, Rebekah Hren wrote:
Hi all,
What you need to do now - to get your voices heard about rapid shutdown requirements-  is to make public comments on the first draft of the 2020 NEC. *_Comments are due AUGUST 30 at midnight!!! _*

Here is the link to a press release <https://www.necanet.org/about-us/news/news-release-archive/news/2018/07/02/nfpa-releases-2020-nec-first-draft-for-public-review> with links to read the draft and input your comments:
https://www.necanet.org/about-us/news/news-release-archive/news/2018/07/02/nfpa-releases-2020-nec-first-draft-for-public-review

The process for changing the NEC is standardized by the NFPA and while it may not be perfect, it's what we've got!

Best,
Rebekah Hren

On Tue, Aug 28, 2018 at 6:50 AM cwarfel <cwar...@entech-engineering.com <mailto:cwar...@entech-engineering.com>> wrote:

    I like your solutions to this. Just sticking to rapid shutdown
    and not the fire code, I think a lot of the problems with 690.12
    could be reduced if the maximum string voltage was 150 or even
    250.  It reduces the ampacity on a roof for a given power and I
    feel that is more of a danger than array voltage that the
    Firefighters are highly likely to avoid.

    I still cannot get Outback Power to provide a corrected
    installation manual or a start up procedure on the RSI/ICS
    equipment. Two plus months and all I get are repeated vague or
    incorrect information. One expert at OB said that they really
    didn't deal much with Rapid Shutdown............

    I cannot install any more Outback on roofs at this time.

    I'll see if it is ok to provide a link to an online petition to
    change 690.12.


    Chris



    On 8/27/2018 2:13 PM, Ray wrote:

    HI Chris;

    As with all things bureaucratic,  good intentions can go awry
    when actually implemented.  Years ago, I was one of the wrenches
    pushing for some form of disconnect closer to the power source,
    or the PV array.  I had no idea it would come back to bite us
    small off grid folks so hard, though.  I'm not quite for
    scrapping all of 690.12, but I do think it needs some serious
    work. /In or on the building/ needs to be defined more clearly
    as 'on the roof'. Ground mounts need a clearer exemption. The PV
    disconnect needs to be clearly defined and also clearly stated
    that the Rapid disconnect system stops there.  The time limit
    needs to be bumped up to 90 seconds: no one is going to throw
    the switch and be hacking on the roof that fast.  The array
    voltage should be 150 vdc, so that lower voltage off grid
    systems could be exempt, and I really think 690.12 should only
    apply to larger arrays (over 10kW) that have long exposed runs
    of conduit (over 10 yards) or that cover more than a certain
    percentage of the total roof area.  If an array covers one face
    of the garage it should be exempt, and if it covers half the
    total roof, then it should have Rapid disconnect, for instance. 
    We need to be sensible, do the fire fighters have a good spot to
    cut and vent the roof without electrical hazards or not?

    Its interesting how article 690 has morphed from being almost
    entirely oriented towards off grid in 99 and 02, to now off grid
    is barely even considered.  Just look at the lack of thought
    when they wrote the definitions for /DC to DC Converters/.  The
    solar industry has been ready and willing to be thrown under the
    bus at every turn.  I think its about time we started advocating
    for our own self interests like all the other parties involved. 
    This also means that us off grid folks need to be properly
    represented, and off grid considered with all code changes.  I
    think DC coupled PV should have its own section and be separated
    from AC coupled PV.  The systems are so different that it
    doesn't make sense to throw them into the same section.  The
    emergence of article 706 is a step in the right direction.

    Ray Walters
    Remote Solar
    303 505-8760
    On 8/23/18 5:31 PM, cwar...@entech-engineering.com
    <mailto:cwar...@entech-engineering.com> wrote:

    I think Rapid Shutdown should be scrapped professionally and
    personally.  It was ill conceived and ill written.  Anyone
    willing to join me in a petition to CMP 44 and the like,
    contact me off list.

    To your question directly, you have a ground mounted system and
    you are not subject to 690.12 unless your conductors are "in or
    on building" which i cannot seem to find what that actually
    means. Exempted are buildings that are isolated only for the PV
    system This is a big win for installers as almost everyone
    installs systems like this.......   Right.    They used to have
    a dimension to this, but I guess that gave installers too much
    information. This is a stupid Code addition for roof mounted pv
    systems, disguised as protecting Firefighters, but not doing so
    in reality. The NEC looks politically compromised by
    consultants and manufacturers who too advantage of this fear
    mongering. No other country with a pv industry has historically
    done this. Why are installers not up in arms about this?

    This is the NEC reference.

    690.12 Rapid Shutdown of PV Systems on Buildings. PV system
    circuits installed on or in buildings shall include a rapid
    shutdown function to reduce shock hazard for emergency
    responders in accordance with 690.12(A) through (D).

    If your system is ground mounted, you are outside the
    "altruistic" intent of 690.12 of protecting Firefighters. Put a
    initiation device disconnect switch at the array.  Any
    supporters of RS should chime in with the support of 690.12 and
    add clarity and guidance to those of us who actually install
    systems and have to deal with this baloney.  690.12 has caused
    more problems for multimode systems than any tariffs, which are
    bad enough. I don' think the industry needs any more "safe
    design and installation" assistance from the CMPs involved with
    this issue.

    Chris Warfel






    On 2018-08-23 00:31, Ray wrote:

    Greetings fellow wrenches;

    I know we have beat this many times but I once again have not
    been able to resolve the contradictory information in 690 in
    regards to implementing 690.12.  As Rebekah Hren pointed out
    before, the diagrams shown in Figure 690.1(b) show that the
    /PV System DC Circuit/ stops at the /PV Disconnect/.  Note 2
    says specifically the '/PV Disconnect separates the PV system
    from all other systems/'. But then in the definitions in 690.2
    on the next page, the new definition of a /P//V System DC
    Circuit/ says that it includes DC to DC converter output
    circuits.  (which are Solar Edge module level controls, but
    could be interpreted as a MPPT battery charge Controller?)

    Then 690.12 which only applies to '/PV System circuits in or
    on buildings/', says we have to control conductors more than 3
    ft after penetrating the building.

    So in my case, I'm looking at a ground mount, and installing
    an external lockable disconnect on the wall before it goes
    into the building. This will officially be the PV Disconnect. 
    In my interpretation, I should not need to do any Rapid
    Shutdown, because I've essentially prevented the /PV system/
    from ever entering the building at all ( based on the 5th
    diagram and Note 2)  However, I could see an AHJ claiming I
    had to do RS all the way to the output side of the charge
    controller.

    If this were true, could I simply apply RS equipment from the
    PV disconnect to the output of the charge controller, or am I
    back to module level shutdown for my ground mounted array, or
    could I build a tiny building that just housed the PV
    Disconnect and take the exemption for '/buildings with the
    sole purpose of housing PV system equipment/'?

    Essentially the definitions in 690.2 are too broad, and are at
    odds with the Figure and Notes of 690.1.  They really didn't
    fix this in the 2017 code for us lowly off gridders. Charge
    controllers are covered by article 706.23___/Charge Control/_,
    and NOT by 690.12 at all. IMHO, the charge controller needs to
    be clearly defined and differentiated from DC to DC converters
    like Solar Edge's module level DC equipment.

    I just want to go back to doing solar designs and
    installations, and quit acting like an attorney parsing every
    word of this confusing code language.

-- Ray Walters
    Remote Solar
    303 505-8760

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